Loading...
HomeMy WebLinkAbout1.25 Article 7 Division 2 (General Resource Protection Standards Narrative)Administrative Review CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 TPR 176-25 Underground Injection Control Well General Resource Protection Standards Narrative TPR 176-25 UIC Well Article 7 - Division 2. General Resource Protection Standards General Resource Protection Standards Narrative Administrative Review 1 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 1. Introduction The following narrative addresses the requirements for the General Resource Protection Standards under Article 7, Division 2 of the Garfield County Land Use and Development Code (LUDC). 2. Section 7-201. AGRICULTURAL LANDS. A. No Adverse Affect to Agricultural Operations, Domestic Animal Controls, Fences, Roads, and Irrigation Ditches. B. Domestic Animal Controls. C. Fences. D. Roads. E. Ditches. The proposed TPR 176-25 UIC Well involves the conversion of an existing, drilled-but- uncompleted well into an injection well. The injection well will be located on an existing, established well pad constructed in 2008 that has other existing natural gas wells and on which the Applicant is developing new natural gas wells. The proposed injection well will not have any adverse affect on agricultural lands or agricultural operations. 3. Section 7-202. WILDLIFE HABITAT AREAS. The Applicant shall consult with the Colorado Parks and Wildlife or a qualified wildlife biologist in determining how best to avoid or mitigate impacts to wildlife habitat areas. The TPR 176-25 well and Well Pad 25A were previously constructed. A pre-application consultation for the location was conducted with Colorado Parks and Wildlife on 5/27/21 and Colorado Parks and Wildlife (CPW) granted a waiver for the continued use of a location between 300 and 500 feet of cutthroat trout high priority habitat (HPH). CPW stated that it incentivizes the use of already disturbed locations and BMPs, like berms, stormwater controls, and secondary containment when no adverse impacts are anticipated. CPX will comply with all applicable BMPs. The injection well and associated equipment will also be located outside the 500-foot buffer for cutthroat trout. The nearest mapped terrestrial HPH is Elk Production HPH 4,350 feet to the east. The well pad represents a continued land use that is separated from mapped elk habitat by a ridgeline, approximately 0.75 miles of spruce/fir forest and aspen woodlands, and a drop of approximately 400 feet from the ridge into the next drainage, the Mamm Creek drainage. The combination of topography, forest cover, and distance avoids impacts to mapped HPH The conversion of the existing well into an injection well not result in TPR 176-25 UIC Well Article 7 - Division 2. General Resource Protection Standards General Resource Protection Standards Narrative Administrative Review 2 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 additional surface disturbance nor fragment wildlife habitat. CPX will not impact natural drainage patterns by utilizing an existing location. 4. Section 7-203. PROTECTION OF WATERBODIES. 4.1. Section 7-203.A. Minimum Setback. 1. A setback of 35 feet measured horizontally from the Typical and Ordinary High Water Mark (TOHWM) on each side of a Waterbody is required. 2. In the case of entrenched or incised streams, where the vertical distance from the bank exceeds 25 feet, all activities, except for those referenced in section 7-203.A.3, will adhere to a setback of 2.5 times the distance between the TOHWMs or 35 feet, whichever is less. 3. A minimum setback of 100 feet measured horizontally from the TOHWM shall be required for any storage of hazardous materials and sand and salt for use on roads. The proposed site is located more than 35 feet from any waterbody. There are no streams, areas subject to flooding, high ground water areas, and lakes within the perimeter of the site. An unnamed drainage is approximately 316’ uphill to the south. An unnamed drainage is approximately 485’ cross gradient to the north. The drainage contains woody debris and no stream features. The well pad berm, cross-gradient topography, and distance prevent flow from the well pad from reaching the drainage. The Surface Hydrology Map and a narrative exhibit describing the hydrology surrounding Well Pad 25A is located in the Grading and Drainage Plan tab. 4.2. Section 7-203.B. Structures Permitted In Setback. Irrigation and water diversion facilities, flood control structures, culverts, bridges, pipelines, and other reasonable and necessary structures requiring some disturbance within the 35 foot setback may be permitted. No features will be installed within the 35-foot setback. 4.3. Section 7-203.C. Structures and Activity Prohibited in Setback. Unless otherwise permitted or approved, the following activities and development shall be prohibited in the 35 foot setback: 1. Removal of any existing native vegetation or conducting any activity which will cause any loss of riparian area unless it involves the approved removal of noxious weeds, nonnative species, or dead or diseased trees. TPR 176-25 UIC Well Article 7 - Division 2. General Resource Protection Standards General Resource Protection Standards Narrative Administrative Review 3 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 2. Disturbance of existing natural surface drainage characteristics, sedimentation patterns, flow patterns, or flood retention characteristics by any means, including without limitation grading and alteration of existing topography. Measures taken to restore existing topography to improve drainage, flow patterns, and flood control must be approved. No vegetation will be removed from the 35-foot setback or outside the area of disturbance for Well Pad 25A. No riparian areas will be impacted by the proposed UIC well. The site will not impact or disturb existing natural surface drainage characteristics, sedimentation patterns, flow patterns, or flood retention characteristics. Well Pad 25A and the TPR 176-25 well were previously constructed. 4.4. Section 7-203.D. Compliance with State and Federal Laws. Any development impacting a Waterbody shall comply with all applicable state and federal laws, including, but not limited to, CDPHE water quality control division regulations The proposed UIC well will not be located within a waterbody setback and will not impact any waterbody. CPX’s operations will comply with all applicable state and federal regulations. 5. Section 7-204. DRAINAGE AND EROSION. 5.1. Section 7-204.A. Erosion and Sedimentation. Excluding Grading activities for agricultural purposes, development disturbing 1 acre or more is subject to the CDPHE National Pollutant Discharge Elimination System Permit, unless otherwise exempted by CDPHE. No grading activities will be associated with the proposed use. Grading activities were completed prior to the submittal of the Land Use Change application. Well Pad 25A was constructed in 2008 and the TPR 176-25 well was drilled in 2013. CPX will adhere to the Tepee Park Ranch Stormwater Management Plan (SWMP) detailing stormwater BMPs, controls, and inspections. The approved Stormwater Permit (Certification Number: COR401163) issued by CDPHE is located in the Grading and Drainage Plan tab. TPR 176-25 UIC Well Article 7 - Division 2. General Resource Protection Standards General Resource Protection Standards Narrative Administrative Review 4 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 5.2. Section 7-204.B. Drainage The sites have been designed to adhere to the Drainage Standards stated in Section 7- 204 B of the Garfield County LUDC and COGCC stormwater requirements. Well Pad 25A has no uncontrolled stormwater on the well pad. The well pad has a 6-inch- diameter drain at the center of the well pad. The drain is piped outside of the berm to a trench. The trench drains to a catchment basin. Solids settle in the catchment basin for removal. The stormwater evaporates. The well pad fill slopes have 2-foot-high earthen berms, which are compacted to 95 percent soil/moisture density. The outside slopes of the berms have 80 percent vegetative cover. The berms are stable with high structural integrity. A drive-over berm will be installed at the entrance of the pad for additional stormwater control. An additional 4 to 6 inches of aggregate will be added to the pad surface to support drilling equipment. 5.3. Section 7-204.C. Stormwater Run-Off The proposed UIC well is not located within 100 feet of any water body. The development/conversion of the proposed well will not create 10,000 square feet of impervious surface area. The TPR 176-25 Well is located on CPX’s existing Well Pad 25A. Well Pad 25A has no uncontrolled stormwater on the well pad. 6. Section 7-205. ENVIRONMENTAL QUALITY. 6.1. Section 7-205.A. Air Quality. Any Land Use Change shall not cause air quality to be reduced below acceptable levels established by the Colorado Air Pollution Control Division. The proposed use will not cause air quality to be reduced below acceptable levels established by the Colorado Air Pollution Control Division. The UIC well and associated facilities will be properly permitted with the Air Pollution Control Division (APCD) and comply with all applicable APCD regulations. 6.2. Section 7-205.B. Water Quality. At a minimum, all hazardous materials shall be stored and used in compliance with applicable State and Federal hazardous materials regulations. Hazardous materials will not be stored on or transported to the proposed site. TPR 176-25 UIC Well Article 7 - Division 2. General Resource Protection Standards General Resource Protection Standards Narrative Administrative Review 5 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 7. Section 7-206. WILDFIRE HAZARDS. The following standards apply to areas subject to wildfire hazards as identified on the County Wildfire Susceptibility Index Map as indicated in the County’s Community Wildfire Protection Plan. 7.1. Section 7-206.A. Location Restrictions. Development associated with the land use change shall not be located in any area designated as a severe wildfire Hazard Area with Slopes greater than 30% or within a fire chimney as identified by the Colorado State Forest Service. The proposed injection well will be located on an existing, previously constructed well pad. The existing well pad is not located in a severe wildfire Hazard Area with Slopes greater than 30% or within a fire chimney. 7.2. Section 7-206.B. Development Does Not Increase Potential Hazard. The proposed Land Use Change shall be developed in a manner that does not increase the potential intensity or duration of a wildfire, or adversely affect wildfire behavior or fuel composition. The proposed facility will not increase the potential intensity or duration of a wildfire. The proposed. The facility will have an ESD (Emergency Shut Down) system, so in the event of an emergency, including wildfires, the facility can be shut down. CPX will maintain weed and vegetation control to prevent wildfire from entering the site. 7.3. Section 7-206.C. Roof Materials and Design. Roof materials shall be made of noncombustible materials or other materials as recommended by the local fire agency. There will be no structures associated with the UIC well that require roofing material. 8. Section 7-207. NATURAL AND GEOLOGIC HAZARDS. The Geologic Hazard Assessment, prepared by a Ken Walter, P.G. at Walter Environmental and Engineering Group, Inc. of Grand Junction, determined there are no known Geological Hazards within the Tepee Park Ranch Well Pad 25A Site. The Geologic Hazards Assessment and site photos are located in the Impact Analysis tab. TPR 176-25 UIC Well Article 7 - Division 2. General Resource Protection Standards General Resource Protection Standards Narrative Administrative Review 6 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 8.1. Section 7-207.A. Utilities. No public utilities or above ground utilities will be installed for the proposed UIC well. Any power required for the UIC well will be sourced from an onsite generator. 8.2. Section 7-207.B. Development in Avalanche Hazard Areas. The Geologic Hazard Assessment conclude that avalanches are not a geologic hazard to the Site. The Geologic Hazards Assessment is located in the Impact Analysis tab. 8.3. Section 7-207.C. Development in Landslide Hazard Areas. The Geologic Hazard Assessment conclude that landslides are not a geologic hazard to the Site. 8.4. Section 7-207.D. Development in Rockfall Hazard Areas. The Geologic Hazard Assessment conclude that rockslides are not a geologic hazard to the Site. 8.5. Section 7-207.E. Development in Alluvial Fan Hazard Area. The proposed injection well will be located on an existing, previously constructed and established well pad. The Geological Hazard Report concluded that there is no evidence of mudflow or debris fan hazard on or near the site. 8.6. Section 7-207.F. Slope Development. The Geologic Hazard Report concluded that slope hazard is not a concern for the subject site. 8.7. Section 7-207.G. Development on Corrosive or Expansive Soils and Rock. The Geologic Hazard Report concluded that corrosive or expansive soil conditions do not impact the subject site. 8.8. Section 7-207.H. Development in Mudflow Areas. The Geologic Hazard Assessment concluded that the Site is not located in or near a mapped debris flow. TPR 176-25 UIC Well Article 7 - Division 2. General Resource Protection Standards General Resource Protection Standards Narrative Administrative Review 7 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 8.9. Section 7-207.I. Development Over Faults. The Geologic Hazard Assessment conclude that the Site, which is located in central Garfield County, is not located above any known mapped faults. Additionally, a Seismicity Evaluation was conducted by Tom Feldkamp, P.G. and Principal at High Ground Interests LLC. The Seismicity Evaluation concluded there is an extremely low potential for induced seismicity during the proposed injection operations. The Seismicity Evaluation, prepared in accordance with COGCC Rule 803.g.6, is provided in the Impact Analysis tab. 9. Section 7-208. RECLAMATION. Well Pad 25A and the proposed UIC well will be subject to, and CPX will comply with, all applicable COGCC reclamation standards. 9.1. Section 7-208.A. 1. Installation of ISDS. Installation of a new or replacement ISDS. An ISDS will not be installed at Well Pad 25A. 9.2. Section 7-208.A. 2. Driveway Construction. Any driveway construction that requires a Garfield County Access Permit or a CDOT Access Permit. The site will be accessed using CPX’s existing, private access road owned and maintained by the Applicant. No road or driveway construction will be associated with the proposed UIC well conversion. 9.3. Section 7-208.A. 3. Preparation Area. All areas disturbed during development that do not comprise the longer-term functional areas of the site but are those areas used for the short-term preparation of the site. The existing Well Pad 25A is 5.5 acres with a Working Pad Surface of 2.6 acres. After interim reclamation, the Working Pad Surface will be reduced to approximately 1.8 acres. CPX is not proposing any additional surface disturbance beyond the existing footprint of the Oil and Gas Location. TPR 176-25 UIC Well Article 7 - Division 2. General Resource Protection Standards General Resource Protection Standards Narrative Administrative Review 8 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 9.4. Section 7-208.B. Reclamation of Disturbed Areas. Areas disturbed during development shall be restored as natural-appearing landforms that blend in with adjacent undisturbed topography. When the final landform is achieved, the surface shall be stabilized by vegetation or other means to reduce further soil erosion from wind or water, provide forage and cover, prevent fugitive dust as required by State Statute, and reduce visual impacts. After UIC well and natural gas well completion on the well pad, the well pad will be downsized to approximately 1.8 acres to support operations. Equipment that is not needed to support production, and stored materials, will be removed from the location in preparation for interim reclamation. To decompact soil layers, areas to be reclaimed will have any gravel or surface material removed. The material will be redistributed during interim reclamation and trucked off site during final reclamation. Areas to be reclaimed will be cross ripped to an estimated depth of 18 inches unless restrictive features are encountered at a shallower depth. Decompaction will be used to improve the soil structure and to promote soil aeration, water infiltration, and microbial activity, which will promote plant growth. 9.4.1. Section 7-208.B. 1. Contouring and Revegetation. Abrupt angular transitions and linear placement on visible Slopes shall be avoided. Areas disturbed by Grading shall be contoured so they can be revegetated, and shall be planted and have vegetation established. A uniform vegetative cover shall be established with an individual plant density of at least 70% of pre-disturbance levels within 4 growing seasons. Revegetation cover shall consist of a diversity of native and/or beneficial nonnative vegetation species capable of supporting the post-disturbance land use. State or County listed noxious weeds, as well as alien annual invasive species, do not count as part of the 70% cover. To the maximum extent feasible, disturbed areas shall be revegetated to a desired plant community with composition of weed-free species and plant cover typical to that site. Topsoil previously stockpiled on the location will be restored on the reclaimed area. The reclaimed area will be blended with the surrounding surface to restore natural grades and hydrology patterns. The area will be tilled or disked to prepare a seedbed following natural contours. Soil amendments may be introduced at this stage to promote moisture retention and soil stabilization. Seedbed preparation will be conducted immediately before seeding to ensure that the seedbed maximizes revegetation success. Seeding will be conducted using broadcast seed distributed by hand or hydroseeding to obtain complete coverage. Spring and fall typically are preferred seeding periods to coincide with increased precipitation and conditions favorable to seed germination. A site operator will be on location daily to monitor the wells, tanks, and other equipment. Vegetative success will be monitored as part of these routine site visits. Invasive weeds, TPR 176-25 UIC Well Article 7 - Division 2. General Resource Protection Standards General Resource Protection Standards Narrative Administrative Review 9 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 evidence of erosion, and areas requiring reseeding will be identified and addressed through weed treatment, adapting stormwater controls, and application of additional seed and soil amendment or fertilizer. Vegetative success will be considered at least 80 percent of pre-disturbance reference area cover. 9.4.2. Section 7-208.B. 2. Weed Management. A management plan with appropriate strategies shall be employed for all Garfield County listed noxious weeds, State of Colorado listed noxious weeds that are targeted for statewide eradication and any other invasive species. The proposed injection well will be located on an existing, previously constructed well pad. No new construction or surface disturbance will be associated with the well conversion. The CPX Weed Control Plan will be used to guide management of weed species. CPX performs noxious weed management in accordance with the Noxious Weed Management Plan (February 16, 2016) issued by Garfield County. Equipment used for the well conversion will be washed and treated to remove seeds, plants, and plant fragments from the equipment before the equipment is used for CPX operations. When seeding disturbed areas, CPX uses certified weed-free seed mixes recommended by the adjacent U.S. Forest Service. The seed mixes represent native species that are most likely to proliferate and be sustainable. 9.4.3. Section 7-208.B. 3. Application of Top Soil. Top soil shall be stockpiled and placed on disturbed areas and managed for later use in reclamation. Provisions for salvaging on-site topsoil, a timetable for eliminating topsoil and/or aggregate piles and a plan that provides for soil cover if any disturbances or stockpiles will sit exposed for a period of 90 days or more shall be reviewed and accepted by the Garfield County Vegetation Manager. The site was previously constructed in 2008. The current soil stockpile contains an estimated 8,450 cubic yards of soil salvaged during construction of the location. It is protected from wind and water erosion by a stable 2:1 slope and vegetation. The vegetation also protected microbial activity. When the well pad is reclaimed, the topsoil will be brought up from the fill slope and down from the cut slope onto the pad as the final layer for reclamation and reseeding. In each area, the topsoil was tracked and seeded by hand with broadcast seed using a Forest Service special blend seed mix that was in circulation at the time that the well pad was developed. TPR 176-25 UIC Well Article 7 - Division 2. General Resource Protection Standards General Resource Protection Standards Narrative Administrative Review 10 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 9.4.4. Section 7-208.B. 4. Retaining Walls. The standard, Reclamation: Reclamation of Disturbed Areas: Retaining Walls, Section 7-208.B.4 of the Garfield County LUDC, is not applicable to the proposed site; retaining walls are not located on the proposed site nor are proposed to be installed. 9.4.5. Section 7-208.B. 5. Slash Around Homes. The site was previously constructed in 2008. No additional surface disturbance is anticipated with the conversion of the existing well to an UIC well. Vegetation clearing will not occur as a result of the proposed UIC well. 9.4.6. Section 7-208.B. 6. Removal of Debris. The site was previously constructed in 2008. No additional surface disturbance is anticipated with the conversion of the existing well to an UIC well. Vegetation clearing will not occur as a result of the proposed UIC well. 9.4.7. Section 7-208.B. 7. Time Line Plan. Every area disturbed shall have a time line approved for the reclamation of the site. No new surface disturbance will be associated with the conversion of the proposed injection well. The expected lifespan of the subject UIC well is approximately 30 years. A well in the Piceance Basin may produce for up to 30 years; therefore, the proposed facility will operate as a support facility for the gas wells the same duration as the supported wells may produce. Interim reclamation will occur at the site after well development on TPR is complete, consistent with COGCC requirements. During initial grading activities, the site was developed to 5.5 acres. During interim reclamation, approximately 3.7 acres will be reclaimed, leaving an approximately 1.8-acre working pad surface after interim reclamation.