HomeMy WebLinkAbout1.00 General Application Materials_Part05UELS, LLCCorporate Office * 85 South 200 EastVernal, UT 84078 * (435) 789-1017
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CHEVRON U.S.A. INC.
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CHEVRON U.S.A. INC.
06-06-23
SKR #698-10-BV PAD ALTERNATIVE 5TRACTS 39B & 40, SECTION 9, T6S, R98W, 6th P.M.GARFIELD COUNTY, COLORADO
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CHEVRON U.S.A. INC.
06-06-23
SKR #698-10-BV PAD ALTERNATIVE 5TRACTS 39B & 40, SECTION 9, T6S, R98W, 6th P.M.GARFIELD COUNTY, COLORADO
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T.L.L.06-06-23UELS, LLCCorporate Office * 85 South 200 EastVernal, UT 84078 * (435) 789-1017
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UELS, LLCCorporate Office * 85 South 200 EastVernal, UT 84078 * (435) 789-1017
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T.L.L.06-06-23UELS, LLCCorporate Office * 85 South 200 EastVernal, UT 84078 * (435) 789-1017
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SKR #698-10-BV PAD ALTERNATIVE 7TRACTS 45, 57 & 122, SECTION 31, T5S, R97W, 6th P.M.GARFIELD COUNTY, COLORADO
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UELS, LLCCorporate Office * 85 South 200 EastVernal, UT 84078 * (435) 789-1017
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·This map is a compilation of publicly available data. The accuracy and completeness of saiddata has not been verified by UELS. Existing conditions may differ from what is shown.CHEVRON U.S.A. INC.
T.L.L.06-06-23
SKR #698-10-BV PAD ALTERNATIVE 7TRACTS 45, 57 & 122, SECTION 31, T5S, R97W, 6th P.M.GARFIELD COUNTY, COLORADO
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UELS, LLCCorporate Office * 85 South 200 EastVernal, UT 84078 * (435) 789-1017
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·This map is a compilation of publicly available data. The accuracy and completeness of saiddata has not been verified by UELS. Existing conditions may differ from what is shown.CHEVRON U.S.A. INC.
T.L.L.06-06-23
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APPENDIX H
ASSESSMENT OF
IMPACTS
SKR 698‐10‐BV Pad
Township 6 South, Range 98 West, 6th PM
Sections 10 & 15: Tract 72
Garfield County, Colorado
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CUMULATIVE IMPACTS PLAN
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OGDP SKR 698-10-BV 1 Cumulative Impacts
CUMULATIVE IMPACTS PLAN
Date: November 29, 2023
Location: OGDP SKR 698-10-BV
Development Area Legal Description (Garfield County, CO):
Township 6 South, Range 98 West, 6th P.M.
Section 3: Part of Lot 5 and Tracts 38, 48B, 49, 58, and 107
Section 10: Part of Lots 1, 3, 4, and Tracts 72, 45, 46, 48B, 49, 50
Section 15: Part of Tract 72
Township 5 South, Range 97 West, 6th P.M.
Section 31: Part of Lots 9, 10, 11, and Tract 58
This Cumulative Impacts Plan has been prepared in accordance with the Colorado Energy and
Carbon Management Commission (ECMC or Commission) Rule 304.c.(19) and follows the
resources analyzed for potential cumulative impacts pursuant to Rule 303.a.(5).
The Plan provides an overview of the OGDP SKR 698-10-BV Project, specifically the proposed
drilling, completion and production of two wells on the existing SKR 698-10-BV Pad and the
methodology used for determining cumulative impacts. Finally, the Plan also includes the
following sections, as prescribed in Rule 304.c.(19):
Resources Impacted (Section 3.0) – A description of all resources to which cumulative
adverse impacts are expected to be increased;
Minimization Measures (Section 4.0) – A description of specific measures taken to avoid or
minimize the extent to which cumulative adverse impacts are increased;
Mitigation Measures (Section 5.0) – A description of all measures taken to mitigate or offset
cumulative adverse impacts to any of the resources; and
Additional Information (Sections 1.0 and 2.0) – Information determined to be reasonable
and necessary to the evaluation of cumulative impacts by the Operator, the Director, CDPHE,
CPW, or the Relevant Local Government.
1.0 Project Overview
This document provides site-specific information for OGDP SKR 698-10-BV. The information in this
document relates specifically to the time during the construction, drilling, completion, and
production of the two proposed horizontal wells in this OGDP. The proposed location is an existing
well pad in rangeland adjacent to Garfield County Road 211 (CR 211) approximately 4.1 miles
north of CR 204.
A pre-application conference with Garfield County was held on October 12, 2023, and was
attended by representatives from Garfield County, ECMC, CPW, CDPHE, and Chevron. Based on
input from CDPHE staff during the pre-application conference, a pre-application consultation with
CDPHE staff was not held for this project. CDPHE will determine whether formal consultation will
be required when the OGDP has been deemed complete by ECMC.
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OGDP SKR 698-10-BV 2 Cumulative Impacts
The two proposed wells on this location will produce to initial production equipment located on the
well pad. The equipment at the well pad will include separators, pigging stations, a gas meter, pipe
skid, an instrument air skid, a skid drain vault, a chemical injection skid, a communication tower,
solar skids, a maintenance tank, heat trace equipment, a transformer or electric generators,
switchracks, and a battery box. Liquids (condensate/oil and water) and natural gas produced from
these wells will be transported via underground pipelines to Chevron’s existing Central Production
Facility (CPF) for additional processing. Condensate/oil and natural gas will be transferred to
midstream assets at the CPF and produced water will be transported to an existing, permitted
disposal well via an underground pipeline.
1.1 Surface Disturbance
Construction associated with the OGDP SKR 698-10-BV Pad will be minimal and associated
with an additional access road, flowlines, and drainage basins. This construction would result
in an estimated initial disturbance of 16.4 acres (including existing and new disturbance) and
long-term disturbance of 2.4 acres. Initial and long-term disturbance by project feature is
summarized in Table 1. Site reclamation would be initiated for portions of the well pad not
required for the continued operation of the well within six months of completion, weather
permitting.
Table 1
Estimated Surface Disturbance
Project Feature Initial (acres) Long-Term (acres)1
Well Pad 6.9 2.3
Existing Disturbance 6.2
New Disturbance 0.7
New Access Road Corridors 0.1 0.1
Flowline Corridors 9.5 0
OGDP Total 16.4 2.4
1 Residual disturbance calculations are based on the assumption that interim reclamation would be successful.
As documented in the Alternative Location Analysis (ALA) submitted with this OGDP, Chevron
analyzed alternative locations for the proposed well pad, however, none of these alternative
locations resulted in reduced impact. It is difficult, if not impossible, to find alternative locations
that are outside of HPH or a DI community, and all alternative locations would result in new and
increased surface disturbance. The use of the existing well pad minimizes surface disturbance
to the maximum extent possible, and interim reclamation of this well pad will result in the
disturbance being reduced by approximately 3.8 acres from what has been in use for the
storage yard. Although the existing SKR 698-10-BV Pad can safely accommodate the
proposed drilling and completions operations, it is smaller than what Chevron would consider
as an ideal size for these operations; therefore, the use of the existing pad res ults in
approximately 1.5 acres less of disturbance than would occur if a new pad was constructed.
Additionally, most alternative locations would require significantly more disturbance for
construction of access roads and flowlines.
2.0 Cumulative Impact Methodology
Cumulative impacts on the environment may result when the environmental effects associated
with a proposed project are added to other past, current, and reasonably foreseeable future
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actions. Cumulative impacts can result from individually minor but collectively significant actions
taking place over a period of time. The proposed OGDP SKR 698-10-BV is within an area of
existing oil and gas development, and is surrounded by agricultural operations in Garfield
County, Colorado. Most of the past, present, and reasonably foreseeable development in the
vicinity of the OGDP SKR 698-10-BV is associated with current or planned oil and gas
exploration, midstream infrastructure, and agricultural development. This area is very sparsely
populated and the nearest RBU to the SKR 69 -10-BV Pad is over one mile to the south. The
only occupied buildings near the well pad are associated with Chevron’s field office
approximately 830 feet to the northwest. Information for this cumulative impact assessment
was obtained from county, state, and federal websites, and other public domain sources.
Specifically, the existing SKR 698 -10-BV Pad has approximately 7 oil and gas locations
considered “active” within a 1-mile radius to the ECMC location files online.
To provide information relevant to ECMC decision making, a practical delineation of the spatial
and temporal scales is needed for an informative cumulative impacts’ analysis. The geographic
extent of each specific Cumulative Impact Analysis Area (CIAA) varies by resource and is larger
for resources that are mobile or migrate, as compared to those that are stationary. For some
resources, the CIAA is smaller due to the geographically confined nature of cumulative impacts
(e.g., vegetation), while for others the CIAA is much larger (e.g., air quality). Table 2 provides
the geographic extent for cumulative impact analysis that was applied for the OGDP SKR 698-
10-BV location. For most resources, the temporal boundary is assumed to be the 30-year life of
production. For wildlife and vegetation, the temporal boundary is extended an additional 5 years
to account for the time required to reach 75-100 percent reclamation.
Table 2
Geographic Scope for Cumulative Impact Analysis
Environmental Resource Cumulative Impact Assessment Area (CIAA)
Air Quality 1-mile radius
Public Health 1-mile radius
Water Resources ½-mile radius
Terrestrial and Aquatic Wildlife
Resources and Ecosystems
1-mile radius (specifically High Priority Habitats [HPH] within 1-mile)
Soil Resources Limits of disturbance for the location (including access roads and
pipeline rights-of-ways [ROWs])
Vegetation 1-mile radius
Public Welfare –
Noise, Odor, Light
1-mile radius
3.0 Resources Impacted
The following section describes the resources for which cumulative impacts are anticipated,
based on the information included on the Form 2B and the site-specific plans associated with
Form 2A.
3.1 Air Resources and Public Health1
Air quality in an area is generally influenced by the quantities of pollutants that are released
within and upwind of the area, and it can be highly dependent upon the pollutants’ chemical and
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physical properties. Air quality regulations and source-specific permits limit the allowable
quantities of pollutants that may be emitted. The topography, weather, and land use in an area
will also affect how pollutants are transported and dispersed and the resulting ambient
concentrations.
The location of the OGDP SKR 698-10-BV and broader CIAA currently contains various emission
sources including agricultural fields, vehicle traffic, and oil and gas production and infrastructure.
Most notably, there are no Residential Building Units (RBUs) within over 1 mile from the Working
Pad Surface (WPS) of the SKR 698-10-BV Pad. The addition of the infrastructure needed to
construct, drill, and operate the OGDP SKR 698-10-BV location would have a cumulative impact
on air quality within the 1- mile CIAA. However, the proposed wells’ contribution to cumulative
effects would be minor, as demonstrated by the Emissions Inventory results reflected in Form 2B,
and modeling assessment results from the October 17, 2019 Final Report: Human Health Risk
Assessment for Oil & Gas Operations in Colorado published by CDPHE.
The Air Resources impacts would be minimized and mitigated by the measures included in
Sections 4 and 5 of this Cumulative Impacts Plan. Emissions would be permitted and regulated
by the Colorado Department of Public Health and Environment, Air Pollution Control Division,
and would be subject to appropriate controls to reduce emissions to minimal levels. However, in
the context of cumulative impact assessment, any contribution to emissions, no matter how
small, adds to the cumulative effects from past, present, and reasonably foreseeable future
projects.
3.2 Water Resources
There are no public water system intakes located within a mile of the proposed OGDP SKR
698-10-BV location. Construction of oil and gas facilities and associated infrastructure and
industrial development would likely have the greatest potential impact on water resources
within the ½-mile radius CIAA due to the potential for increased erosion and sedimentation
rates. Soils compacted on existing roads, new access roads, and well pads contribute to
slightly greater runoff than undisturbed sites. Increased erosion and subsequent increased
sedimentation of intermittent streams and ephemeral drainages within the CIAA is possible,
especially during construction and other surface disturbing activities. These effects could
have negative impacts on aquatic habitat within affected drainages.
To assess the potential of impacts to water resources, Chevron utilizes several different
sources of information and field surveys to verify the location and nature of hydrologic
features. The Hydrology Map included in the Form 2A submittal for this pad reflects the
compilation of information available from a variety of public sources and limited information
from land surveyors employed by Chevron. Chevron also utilizes the services of a third-
party environmental consultant to conduct aquatic resources inventories and the results of
these inventories are documented in the Aquatic Resources Inventory Report (ARIR)
attached to the Wildlife Mitigation Plan included in the Form 2A submittal. This ARIR
documents the results of additional desktop reviews and field surveys by qualified biologists
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to verify the results of the desktop reviews and to identify any resources that may not have
been identified by the desktop reviews. These field surveys are conducted to identify and
formally delineate any wetlands or other aquatic features within 500 feet of the proposed
location. It is not uncommon for the ARIR to provide information that appears to conflict with
the initial Hydrology Maps, however, the results of the ARIR are far more definitive and
Chevron updates the Hydrology Maps to include the information from the ARIR.
For the OGDP SKR 698-10 -BV Pad , the nearest aquatic feature to the WPS of the pad is the
intermittent stream referred to as Deer Park Gulch located approximately 148 feet to the
southeast. This intermittent stream is identified as Aquatic Sportfish Management Waters
HPH, however, upon reviewing the ARIR CPW determined that this drainage does not
contain sufficient year-round flows to support sportfish populations. Therefore, CPW granted
waivers from Rule 1202.c.(1).S. and Rule 1202.a.(3) for this project. In addition, Chevron will
implement several BMPs at th is location to minimize and mitigate any potential impacts to
these and other aquatic features.
In addition, production activities at the OGDP SKR 698 -10 -BV location or other past, present,
or reasonably foreseeable production facilities or industrial development could increase the
potential for accidental spills of fuels, lubricants, and other petroleum products, which could
contaminate surface water within the ½-mile CIAA. All production from the well pad will be
transported via buried flowlines to the existing CPF where additional production equipment will
be located. There will be no routine storage of condensate or produced water on the pad,
however, there will be a maintenance tank on the pad that will only be used when the wells and
equipment on the well pad may need to be blown down. Spills of fuels or produced fluids from
well pads and pipelines also have the potential to contaminate shallow alluvial groundwater.
However, oil and gas development regulatory requirements to prevent spills from reaching
surface and groundwater make these impacts unlikely, and therefore, represent a negligible
potential cumulative impact within the CIAA.
Total water volume needed for the Project would be approximately 1,444,000 barrels (bbls).
Water for the Project would come from existing, permitted sources (both surface and
groundwater) outside of the OGDP SKR 698-10-BV area; no new water wells or water storage
areas are proposed – refer to the Water Plan submitted with the Form 2A for details of the water
sources. The use of more than 1.4 million bbls of water for the construction, drilling and
completion of wells on the OGDP SKR 698-10-BV location would cumulatively contribute to
water use from other oil and gas development and agricultural activity within the CIAA. At the
time of this application, the Piceance area lacks the infrastructure to source produced water for
recycling. As development continues, the potential for recycled water in this region will also
improve. In the interim, Chevron will continue to use water as efficiently as possible when
drilling and completing these wells, to ensure that water usage is minimized.
Chevron’s use of oil-based muds during drilling also reduces freshwater use at the Location.
Minimization and mitigation measures intended to protect water resources within the CIAA are
described in Section 4 and 5; Chevron’s commitment to implementation of these measures will
further limit impacts to water resources within the CIAA.
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3.3 Terrestrial and Aquatic Wildlife Resources and Ecosystems
Cumulative impacts on terrestrial wildlife populations and habitats primarily result from surface-
disturbing activities. Cumulative impacts to aquatic species primarily occur from water depletion
and impacts to the quality of surface and groundwater, such as those discussed in Section 3.2.
Wildlife Populations
Surface Disturbance Impacts
Development of the OGDP SKR 698-10 -BV location would temporarily incrementally increase
the acres of cumulative surface disturbance from past, present, and reasonably foreseeable
development within the 1-mile CIAA. Cumulative impacts to wildlife species can include habitat
fragmentation, habitat loss, loss of foraging opportunities, and animal displacement; impacts
that can last until successful final reclamation is completed. As summarized below and
discussed in detail in the Wildlife Mitigation Plan submitted with the Form 2A, Chevron is
implementing several measures to mitigate impact to wildlife. Chevron’s production design also
provides for all fluids to be piped from the location to the CPF, which dramatically reduces the
traffic traditionally associated with transporting these fluids.
The proposed well pad and the associated access roads and flowline corridors are located
within HPH, and Chevron will implement numerous wildlife-related BMPs for all development.
The use of the existing well pad, which will require very little additional disturbance to
accommodate the proposed wells, limits additional disturbance in HPH. Once this well pad
undergoes interim reclamation, the resulting long-term disturbance will be less than exists for
the storage yard currently. As noted above, CPW has granted Chevron a waiver from Rule
1202.c.(1).S. due to the fact that Deer Park Gulch cannot support sportfish populations.
Additionally, Chevron is committed to performing all construction, drilling and completion
operations outside of the timing limitations for Elk HPH.
As noted above, the proposed well pad will be connected to the existing CPF via buried
flowlines carrying oil, gas, and water to the production facility. As a result, there will be no truck
traffic required to transport liquids from the well pad when the wells are in production which will
dramatically decrease the potential impact to wildlife populations.
Noise and Light Impacts
Noise and light from anthropogenic activities both have the potential to adversely impact
terrestrial and aquatic wildlife. Artificial light can have several effects on wildlife. Nocturnal
animals rely on darkness for hunting, foraging, and scavenging. Predatory animals rely on
darkness for hunting, while prey animals rely on the cover of darkness for protection from
predators. Artificial light can also impact migratory birds including causing them to migrate too
early or too late and miss ideal climate conditions for nesting, foraging, and other behaviors.
Birds can also be attracted to sources of artificial light, which can lead to collisions and bird
mortality. Artificial lights can also impact aquatic species. For example, glare from artificial lights
can impact wetland or riparian habitats and interfere with activities such as nighttime croaking of
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frogs and toads, which can impact breeding and reproductive success and lead to reduced
populations.
Noise from human activity can also have an adverse impact on wildlife. Wildlife species use
sound for a variety of reasons, including to navigate, find food, attract mates, and avoid
predators. Anthropogenic noise, especially loud or high frequency noise intrusions, can be
perceived by wildlife as a threat, causing them to flee an area. Noise can distract foragers such
as big game species, reducing their efficiency of finding and handling food. Noise may increase
physiological stress levels, which can impact behaviors and result in decreased physical health
of animals and decreased reproduction. Noise can have indirect effects on wildlife, such as
scaring away prey from an area predators rely on, or conversely, driving predators into prey
habitat. Human introduced noise can also impede acoustic communication between wildlife or
mask the sounds of an approaching predator or potential prey. Noise can also hinder animal
communication by reducing the distance at which a signal can be detected, limiting the ability of
the signal to reach its intended receiver, and decreasing the amount of information that can be
extracted from a signal. For example, anthropogenic noise can reduce the ability of birds, small
mammals, and insects to collect information on their surroundings, increase their predation risk
(by masking the sounds of predators), and interfere with signals that are crucial for their
breeding success and parental care.
The pre-production potential for light and noise related impacts on wildlife will be decreased at
the OGDP SKR 698-10-BV location because Chevron intends to down-shield lighting during
drilling and completion. Chevron is also committed to performing all construction, drilling and
completion operations outside of the timing limitations for Elk HPH. Additionally, limited
permanent lighting will be located on the well pad and will be switched so only on when in use,
so long-term light and noise related impacts would be limited to headlights and vehicle engine
noise from operational vehicles on location and enroute to and from the location during
production. The majority of production-related traffic at the well pad will be during daylight
hours. As indicated above, the use of pipelines to transport all fluids from the well pad will
result in a dramatic reduction of traffic associated with production activities.
In addition, given the existing oil and gas, industrial, and agricultural activity in and around the
CIAA, local wildlife has likely become habituated, to some extent, to human presence, vehicle
traffic, and operational activities (including associated noise and light from vehicle traffic)
associated with these current land uses. Finally, the minimization and mitigation measures
outlined in Sections 4 and 5 of this Plan would further diminish cumulative impacts on terrestrial
and aquatic wildlife within the CIAA.
3.4 Soil Resources
The CIAA for soils is a ½-mile radius around the Location. Construction of the OGDP SKR 698-
10-BV location would result in new disturbance of approximately 10 acres of soils. The soils
present at the proposed location are detailed in the Dust Mitigation Plan submitted with the
Form 2A.
Cumulative impacts on soil resources can occur from any surface-disturbing activity that
removes native vegetation and topsoil. These impacts can result in soil compaction, increased
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OGDP SKR 698-10-BV 8 Cumulative Impacts
erosion, and sediment yield, all of which reduce soil productivity, stability, and viability. Of these
impacts, compaction may be the most deleterious. Compaction affects the movement of water
and air across the soil surface boundary. Infiltration, the movement of water into the soils, is
critical for plant and soil health. If water cannot move into the soil quickly, it will pond and run off,
leaving vegetation dry and dying, increasing erosion, and increasing flood frequency and
magnitude. Compaction can also cause a shift from aerobic to more anaerobic organisms and
may increase losses of nitrogen to the atmosphere (denitrification). Surface disturbance can
also impact soil biological functions and viability because the disturbance can 1) enhance or
degrade the microbial habitat, 2) add to or remove food resources, and/or 3) directly add or kill
soil organisms.
Most soil organisms – especially larger ones that contribute to soil health and viability – live in
the top few inches of soil. Surface disturbance, compaction, and erosion disrupts and removes
that habitat for soil organisms. As such, one of the most effective ways to reduce impacts to soil
viability from surface disturbance is to protect and preserve topsoil. During the minimal
additional construction at the location, topsoil will be segregated, stored and seeded to
maximize the topsoil’s viability for future reclamation activities.
Implementation of this and other minimization and/or mitigation measures listed in Sections 4
and 5 of this Plan, would help to lessen the potential for impacts to soils at the OGDP SKR
698-10-BV location, and therefore, reduce its cumulative contribution to soil disturbance and
loss of soil viability.
3.5 Vegetation
The CIAA for vegetation is defined as a 1-mile buffer around the proposed OGDP SKR 698-10 -
BV location. Past, present, and other reasonably foreseeable activities within the CIAA that
have or will continue to affect vegetation communities include oil and gas development/other
industrial activities, livestock grazing, and agriculture. Construction of the OGDP SKR 698-10-
BV location, when combined with all past, present, and reasonably foreseeable activities in the
CIAA, would have minimal to moderate impacts on vegetation across the CIAA. Yet in the
context of cumulative impacts, each acre of vegetation disturbance would incrementally add to
other existing and future surface disturbances in the CIAA by increasing erosion, incrementally
adding to the overall native vegetation loss, and potentially increasing invasion or expansion of
invasive and noxious weeds. Cumulative impacts for general vegetation would be mitigated in
accordance with ECMC requirements. Interim reclamation would reduce the location and
associated access road and flowline disturbance to approximately 2.4 acres. Minimization and
mitigation measures (listed in Section 4 and 5 of this Plan) used to implement noxious weed
management, erosion control, and apply dust abatement, would reduce impacts to native
vegetation communities by reducing the potential for competition with invasive and noxious
weed species, minimizing soil erosion and sedimentation, and reducing fugitive dust on plant
surfaces.
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OGDP SKR 698-10-BV 9 Cumulative Impacts
3.6 Public Welfare – Noise, Odor, and Light
The OGDP SKR 698-10-BV location is wholly located within rangeland and is zoned as
Resource Lands by Garfield County. The nearest RBU to the WPS is over 1 mile to the south.
The CIAA for Public Welfare is a 1-mile radius around the Location. There are no recreation
areas within a 1-mile radius, and the OGDP SKR 698-10-BV location is located in an area that
has active oil and gas development meaning that visual impacts from oil and gas are already
present in the CIAA. The scenic value of the location will not be impacted by the construction
and operation of the OGDP SKR 698-10-BV location.
Noise
Noise during production operations at the well pad will be very limited. Visits to the pad by
lease operators will be normally occur only during daylight hours. All produced gas and fluids
will be piped from the well pad to the existing CPF which eliminates the trucking of fluids from
the well pad and the noise impacts associated with this trucking.
Odor
Odor from existing and proposed oil and gas operations, including the OGDP SKR 698-10-BV
location, within the CIAA should not have any cumulative impact on residents because the
nearest RBU is over 1 mile to the south. Chevron will utilize Group III drilling fluids to reduce
odors from drilling operations. Cuttings will not be stockpiled, but rather they will be removed
from the location on a regular and timely basis to reduce potential odor impacts. Other
exploration and production activity wastes stored onsite would be stored in compatible
containers or engineered containment devices. Wastes would be transported offsite via truck by
a licensed transporter, and transportation frequencies would vary based on waste volumes.
These measures would help to contain odors from being noticed within the CIAA. Additionally,
the minimization and mitigation measures listed in Sections 4 and 5 would further limit the
impacts of odor within the CIAA.
Light
Chevron’s development of the OGDP SKR 698-10-BV location would require work activities to
be performed 24 hours per day during drilling, completion, drill-out, and flowback stages; all of
which require the use of temporary lighting. Lighting needed for these activities would conform
to nationally recognized industry and federally mandated safety standards. However, during
nighttime work activities, lighting required for safe operations may be observed from locations
beyond the boundaries of the well pad site. As such, nighttime drilling and completion activities
would result in a short- term contribution to cumulative light pollution within the CIAA. However,
light pollution BMPs (see Section 4.7) would be used to minimize light impacts during all
phases of the OGDP SKR 698-10-BV location’s proposed operations, including precautions to
ensure that site lighting does not directly shine outside of the site boundaries, which would
decrease potential light impacts on nearby receptors. Cumulative light impacts within the CIAA
during these phases would be short-term and temporary.
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OGDP SKR 698-10-BV 10 Cumulative Impacts
During production, operations would typically only occur during daylight hours. Permanent
lighting on the well pad during production operations will be limited and switched so it is only on
when needed . All permanent lighting will be shielded to reduce the amount of light leaving the
location. Therefore, there would be little or no long-term contribution to cumulative light pollution
within the CIAA from the OGDP SKR 698-10-BV location.
4.0 Minimization Measures
ECMC defines “minimizing adverse impacts” as provided by § 34-60 -106(2.5), C.R.S., as
“providing necessary and reasonable protections to reduce the extent, severity, significance, or
duration of unavoidable direct, indirect and cumulative adverse impacts to public health, safety,
welfare, the environment, or wildlife resources from oil and gas operations. Minimization
measures reduce impacts to the smallest amount possible and can include operational and
engineering controls. Chevron has committed to the fo llowing minimization measures for
resources based on the cumulative impact analysis provided in this Plan. These minimization
measures are included within the operational plans submitted as attachments to Chevron’s
Form 2A’s for the proposed OGDP SKR 698-10-BV location.
4.1 Air Quality
• Chevron will employ practices for continuous control of fugitive dust caused by
operations. These practices shall include but are not limited to:
o Speed restrictions on lease roads and location of 10 MPH during dryer
conditions (if dust is visible) and 20 when dust is not visible.
o Regular lease road maintenance to consist of, grading and recompacting the
road surface with the optimum amount of water applied when the road surface
becomes deteriorated or monthly when heavy traffic is present.
o Restriction of construction activity during high-wind days. On windy days or days
when dust becomes fugitive (leaves or threatens to leave the site) construction or
activities will be halted until either fresh water can suppress dust or dust is no
longer visible.
o All public roads to be utilized for this project that are not paved will be treated in
coordination with Garfield County to alleviate dust concerns.
o Chevron uses a gravity fed box proppant delivery system that meets OSHA
standards, rather than the historic pneumatic trailer proppant transfer system that
blows sand out of the trailer into frac sand silos on the location; a method that
required supplemental dust control to meet OSHA requirements. With a gravity
fed proppant delivery system, the delivery container is also a well pad storage
container, eliminating the need for frac sand silos on location. Storing frac sand
in containers reduces sand dust during fracing operations by dropping sand
directly from the container into the blender sand hopper. As a result of the gravity
fed box proppant delivery system, Chevron does not anticipate any silica dust to
migrate off the proposed well pad during completion operations.
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OGDP SKR 698-10-BV 11 Cumulative Impacts
o Chevron uses automation on all new wells and production facilities to minimize
truck traffic and to reduce the number of visits to location. Chevron monitors
locations 24 hours a day in the Operations Control Center (OCC) and that has cut
down on the need for physical location checks greatly. Chevron will also have
camera coverage of the site that can be viewed remotely.
• Chevron will not flare produced gas during normal operations.
• Chevron will use supervisory control and data acquisition (SCADA) systems to monitor
well operations, which will reduce emissions from vehicle traffic due to the reduced
number of vehicle trips to the site.
• Chevron has 24/7 monitoring through the OCC that allows for continuous monitoring of
operating conditions when personnel are not on-site to identify and correct any improper
operations as soon as possible.
• Chevron will transport all fluids from the well pad to the CPF via buried pipelines which
will eliminate the truck traffic associated with transporting these fluids.
• Chevron completes regular audio/visual/olfactory observations at every active location
which provides early detection of equipment malfunctions thereby minimizing
emissions from leaks.
• Chevron will use instrument air pneumatic control valves at the well heads.
• Chevron will implement a Leak Detection and Repair program (LDAR).
• As Chevron is committed to closed-loop drilling, there will be no emission-producing
reserve pits.
• Chevron’s green completions practices includes transporting all flowback fluids via buried
pipelines to the CPF where they will be processed.
4.2 Public Health
• Based on the airborne HAP concentrations estimated using HAP emission rates
described in Section 3.1, no HAP is expected to exceed the target cancer risk or
noncancer hazard index for chronic duration exposures within the location during pre-
production or production. These results support the conclusion that HAP emissions are
not expected to contribute to acute or chronic risks to human health within or beyond
the location. Therefore, no additional minimization measures are required.
4.3 Water Resources
• Chevron will implement a site-specific Stormwater Management Plan (SWMP) (included
with Form 2A) to protect Waters of the State that could receive stormwater runoff from
the Location.
• Chevron will manage potential pollutants located onsite by sealing, wrapping, covering,
or having containment/protection while not actively being used in order to
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OGDP SKR 698-10-BV 12 Cumulative Impacts
eliminate/minimize contact with stormwater runoff, and prevent discharges of chemicals
or other materials from the site.
• Chevron will practice proper storage, safe -handling, good housekeeping and spill
prevention practices and procedures to prevent pollutants or contaminants from leaving
the site.
• Upon surface owner authorization and per ECMC Rules 615 and 318A.e(4), Chevron
will collect baseline water quality samples from an appropriate set of water wells within
the vicinity of the oil and gas location. Baseline samples will be collected prior to
drilling (setting of conductor casing) operations for the initial site well.
• Chevron will use SCADA to allow for rapid well shutdown in the event of a potential
release.
4.4 Terrestrial and Aquatic Wildlife Resources and Ecosystems
• Chevron is committed to performing all construction, drilling and completion
operations outside of the timing limitations for Elk HPH.
• Chevron will inform and educate employees and contractors on wildlife
conservation practices, which includes no harassment or feeding of wildlife.
• Chevron will consolidate and centralize collection and distribution facilities to
minimize impact to wildlife.
• Chevron will pipe all produced oil, water and gas from this well pad to the CPF,
thereby significantly reducing traffic impacts.
• Chevron will implement fugitive dust control measures.
• Chevron will post speed limits and caution signs to the extent allowed by Garfield
County.
• Chevron will use remote monitoring of well production.
• Chevron will reduce traffic associated with transporting drilling and completions water
and produced liquids with pipelines, large tanks, or other measures.
• Chevron will install automated emergency response systems (e.g., high tank
alarms, emergency shutdown systems).
4.5 Soil Resources
• Chevron will implement a site-specific Topsoil Management Plan and Stormwater
Management Plan (Form 2A). Key control measures from those documents are included
here:
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OGDP SKR 698-10-BV 13 Cumulative Impacts
o During the minimal construction required for this Location, topsoil will be stripped
and segregated into stockpiles that are reseeded to maximize the viability of the
topsoil for future reclamation activities.
o BMPs such as straw mulch, sediment basins, swales and perimeter ditches will
be used to prevent excess erosion of soils from disturbed areas. These
structures will be installed during construction and left in place and maintained
for the life of the project or until the disturbed slopes have been revegetated
and stabilized.
o The site will be inspected bi-weekly by a third-party contractor for BMP integrity
and current installation. Any deficiencies noted will be brought to the attention of
the operator and addressed in a timely manner.
o Chevron will limit construction activities during wet periods to avoid
excess disturbance of areas surrounding operations.
• Chevron will regrade cut and fill areas awaiting reclamation to match pre-existing
contours to the nearest extent possible to provide long term erosion control and site
stability.
4.6 Vegetation
• Chevron will confirm that erosion and sedimentation controls are implemented as
necessary before and after seeding operations, as detailed in the Site SWMP.
• Chevron will monitor and maintain the vegetation on disturbed surfaces to promote
native vegetation and to suppress invasive and noxious weeds.
4.7 Public Welfare – Noise, Odor, and Light
Public Welfare – General
• To minimize the possibility of fires during the construction phase, equipment, including
welding trucks, will be equipped with fire extinguishers and spark arresters.
• Where alignment of pipelines will cross or parallel roads, Chevron will provide warning
signs to inform the public of the presence of the line.
• Vehicle users associated with the oil field will be instructed to travel at low speed and
remain on existing roads and well pads at all times.
• Chevron will transport all fluids from the well pad to the CPF via buried pipelines which
will eliminate the truck traffic associated with transporting these fluids.
• Chevron will not truck any water to location for completions. Rather, temporary
surface pipelines will be utilized.
• Chevron will use SCADA to reduce the frequency of vehicle trips to the location to
monitor well operations.
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OGDP SKR 698-10-BV 14 Cumulative Impacts
Noise
• Chevron will utilize a quiet frac fleet for completions operations.
Odor
• Chevron will ensure that oil and gas operations will be in compliance with the
Department of Public Health and Environment, Air Quality Control Commission,
Regulation No. 2 Odor Emission, 5 C.C.R. 1001-4, Regulation No. 3 (5 C.C.R. 1001-5),
and Regulation No. 7 Section XVII.B.1 (a-c) and Section XII.
• Chevron will utilize a freshwater mud system for surface hole.
• Chevron will use Group III drilling fluids for this location .
• Chevron will store oil-based drilling fluid not being used in the active mud system in
closed, upright tanks.
• To keep odor from oil base cuttings as low as possible, Chevron continuously hauls
cuttings to an approved disposal facility throughout the drilling process. Chevron will
not stockpile cuttings or store any large amount of cuttings on location. Trucks run
continuously during daylight hours to keep the volume of cuttings on location at a
minimum.
• Chevron will wipe the OD and ID of the drill pipe to remove any residual mud upon
tripping out of the hole.
• Chevron will utilize a catch can system mounted around the BOP to catch any mud that
falls through the rotary table, thereby preventing any spillage and reducing the source of
odor.
• Chevron will perform emission testing, as applicable, on natural gas-powered engines to
ensure emission control devices are operating properly. Additionally, catalyst
monitoring and maintenance activities recommended by the manufacturer or mandated
by state and federal regulations will be performed to ensure that control devices are
functioning as intended.
Light
Chevron will utilize BMPs to minimize light pollution which may include the following:
• Use of LED fixtures, as feasible, to reduce skyglow.
• Position lights in a downward direction where vertical light is not required.
• Angle light away from off-site buildings.
• Reduce lighting within well pad to the minimal level for safe pre-production activity.
• Use of light sensors that automatically switch light sensors on and off on light masts.
• Direct lights to drilling and completion tasks only.
• Minimize permanent lighting on the well pad.
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OGDP SKR 698-10-BV 15 Cumulative Impacts
5.0 Mitigation Measures
ECMC defines “mitigating adverse impacts” as “measures that compensate for unavoidable
direct, indirect, and cumulative adverse impacts and loss of such resources from oil and gas
operations.” Mitigation measures are used to offset the intensity or severity of impacts and can
include compensatory actions and administrative controls. Chevron has committed to the
following mitigation measures for resources based on the cumulative impact analysis provided
in this Plan.
5.1 Air Quality
• Minimization measures listed for air quality in Section 4 will address the potential
impacts to air resources within the CIAA. Therefore, no additional mitigation measures
for air quality are included.
5.2 Public Health
• HAP emissions are not expected to contribute to acute or chronic risks to human health
within or beyond the well pad Location. Therefore, no additional mitigation measures are
required.
5.3 Water Resources
• Minimization measures included in the site-specific SWMP for the OGDP SKR 698-
10-BV location and other measures included in Section 4 will address the potential
impacts to water resources within the CIAA. Therefore, no additional mitigation
measures are required.
5.4 Terrestrial and Aquatic Wildlife Resources and Ecosystems
• During final reclamation, Chevron will re-contour and re-vegetate all roads and the
pad to a stable condition to restore natural habitats for wildlife species, as is
compatible with ongoing agricultural operations.
5.5 Soil Resources
• Minimization measures listed for soil resources in Section 4 will address the
potential impacts to these resources in the CIAA. Therefore, no additional mitigation
measures for soil resources are included.
5.6 Vegetation
• Chevron will reseed disturbed areas in the first favorable season following rig
demobilization with species consistent with the plant community in the vicinity of the
Location.
• Chevron will monitor the site to identify areas of poor growth or areas that fail to
germinate; these areas will be reseeded as needed.
• Chevron will monitor the site for the presence of noxious weeds. If encountered,
Chevron will employ a third-party consultant knowledgeable in identifying such
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OGDP SKR 698-10-BV 16 Cumulative Impacts
species and implement weed control measures consistent and in compliance with
the Colorado Noxious Weed Act. If necessary, Chevron will implement a weed
control plan.
5.7 Public Welfare – Noise, Odor, and Light
Noise
• Chevron will respond to any noise complaints with appropriate measures to mitigate the noise.
Odor
• Minimization measures listed for odor in Section 4 will address the potential impacts
from odors in the CIAA. Therefore, no additional mitigation measures for odors are
included.
Light
• Minimization measures listed for lighting in Section 4 will address the potential impacts
from lighting to the CIAA. Therefore, no additional mitigation measures for lighting are
included.
152
LESSER IMPACT AREA
EXEMPTION REQUEST
(NOISE AND LIGHT)
153
Doug Dennison
Senior Permitting Coordinator
Chevron
Rockies Business Unit
2115 117th Avenue, Greeley, Colorado 80634
Tel 970 304 5057 Mob 970 270 2853
dougdennison@chevron.com
December 7, 2023
Ms. Julie Murphy, Director
Colorado Energy and Carbon Management Commission
1120 Lincoln Street, Suite 801
Denver, Colorado 80203
RE: ECMC Rule 304.d.(2) Lesser Impact Area Exemption
OGDP SKR 698-10-BV - Oil and Gas Development Plan Application
SKR 698-10-BV Pad
SWSW Section 10 and NWNW Section 15, T6S, R98W, 6th PM
Form 2A Document No. 403534889
Garfield County, Colorado
Dear Director Murphy,
Chevron USA, Inc. has filed a Form 2A with the Colorado Energy and Carbon Management
Commission (ECMC) for the above referenced location. ECMC Rule 304.d. stipulates that the
Director may exempt an Operator from submitting any of the information required by Rule 304.b.
or any plan required by Rule 304.c. Chevron respectfully requests an exemption from the Director
based on evidence showing the information or plan is unnecessary because the impacted resource
or resource concern is not present in the area; or impacts to the resource will be so minimal as to
pose no concern. Please see the attached Table for details.
Pursuant to ECMC Rule 304.d.(2), Operators may request an exemption from the Director in writing,
without proceeding through the ordinary Rule 502 variance process. A request for an exemption
will be provided with the Form 2A at the time the Form is submitted. This letter serves as the
required exemption request.
If you should have any questions or require additional information, please do not hesitate to
contact me at your earliest convenience at (970)304-5057, or dougdennison@chevron.com.
Regards,
Doug Dennison
Senior Permitting Coordinator
154
Chevron USA, Inc.
OGDP SKR 698-10-BV Lesser Impact Area Exemption Request
Exemption Requested
From Resource Concern Exemption
Circumstance Description
Rule 304.c.(2) & 423.a.
Noise Mitigation Plan
Noise impacts to People and
Wildlife
Impact to Resource is
minimal.
This location is in a sparsely populated and mostly
undeveloped area. A review of available map data and
plats indicates the closest residential building unit is over
one mile from the proposed working pad surface of the
SKR 698-10-BV Pad. The nearest building units to the
pad are all associated with Chevron’s Hiner Gate field
office. Chevron is also committing to all oil and gas
operations being performed outside of the timing
limitations for elk HPH. Based on all the above facts,
noise is not expected to pose a concern to people or
wildlife.
155
Chevron USA, Inc.
OGDP SKR 698-10-BV Lesser Impact Area Exemption Request
Rule 304.c.(3) & 424.a.
Light Mitigation Plan
Light impacts to People and
Wildlife
Impact to Resource is
minimal.
This location is in a sparsely populated and mostly
undeveloped area. A review of available map data and
plats indicates the closest residential building unit is over
one mile from the proposed working pad surface of the
SKR 698-10-BV Pad. The nearest building units to the
pad are all associated with Chevron’s Hiner Gate field
office. Chevron is also committing to all oil and gas
operations being performed outside of the timing
limitations for elk HPH. Based on all the above facts,
light is not expected to pose a concern to people or
wildlife.
156
Chevron Rockies Business Unit
Chevron Energy, Inc.
2001 16th Street, Suite 900
Denver, Colorado, 80202
ECMC Wildlife Mitigation Plan-
Skinner Ridge OGDP SKR 698-10-BV Drill Pad
Per the Colorado Energy and Carbon Management Commission (ECMC) 300 Series and 1200
Series Rules for the protection of wildlife and habitat, Chevron is presenting this Wildlife Mitigation
Plan for the proposed Skinner Ridge OGDP SKR 698-10-BV drill pad. The OGDP SKR 698-10-
BV drill pad includes a single existing pad with the potential to drill up to two wells with a collocated
gas production facility, and lies within T6S, R98W, Section 15 (NW/NW) and Section 10 (SW/SW)
(Figure 1). The evaluations herein are submitted in support of the ECMC 2A permitting process,
and specifically the SKR 698-10-BV drill pad, and pursuant to Rule 304.c.(17) Wildlife Mitigation
Plan (WMP), and Rule 1201.b for an Oil and Gas location inside High Priority Habitat (HPH). It
should be noted that figures supporting this WMP are schematic representations used for
approximate presentation of environmentally sensitive habitat in the project area, and that full
design drawings should be referenced for detailed location placement and analysis.
Environmental Summary
Chevron’s SKR 698-10-BV project will utilize an existing drill pad that was permitted for Oil and
Gas development under O&G Location ID Number 336056 but was never used for oil and gas
purposes. The pad has been dedicated for equipment/materials staging and storage, as permitted
through Garfield County. The proposed development pad will include a collocated gas processing
facility on pad. The entire well pad lies within 500’ of the Ordinary High Water Mark (OHWM) of
Deer Park Gulch (aka Tom Creek) designated as 1202.c.(1).S Sportfish Management Waters HPH,
and approximately ½ of the pad lies within 300’ of the OHWM. The proposed development pad
also lies entirely within 1202.d.(2) Elk Winter Concentration Area HPH and Elk Severe Winter
Range HPH, with a protective timing stipulation between December 1st and April 15th.
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November 29, 2023 Page 2 of 15
2001 16th Street, Suite 900 Denver, Colorado 80202
FIGURE 1- SKR 698-10-BV Well Pad
As stated, the Deer Park Gulch drainage is identified as a Sportfish Management-protected HPH,
and Chevron pre-consulted with CPW pursuant to the potential need for a request to the
Commission for approval of a Rule 502 Variance as it relates to Rule 1202.c(1).S. (i.e., Sportfish
management waters not identified by CPW as “Gold Medal” (within 500 feet of OHWM)).
CPW Northwest Energy liaison Taylor Elm reviewed the SKR 698-10-BV location and determined
that although the location does fall within Rule 1202.c.(1).S. HPH, the applicability of waiver
provisions of Rule 309.e.(5).D.ii.bb would be appropriate to Deer Park Gulch. The Rule provision
allows for CPW to grant a waiver for an intermittent drainage anywhere within the 500-foot Aquatic
HPH buffer area, instead of within 300 to 500 feet of the OHWM, as would be the case if Deer Park
Gulch were a perennial waterway. The waiver request was reviewed and approved by CPW on
11/16/23 and Chevron committed to the Best Management Practices (BMPs) documented in the
waiver request and reiterated below under the Field Hydrology Review section.
All upgrades, with the exception of a slight expansion to the pad, will remain within the approved
disturbed area (DA) and avoid any direct impact to water way features; a flowline to the existing
gas processing plant is in-place along CR211 (Clear Creek Road) just southwest of the SKR 698-
10-BV DA and the gas tie-in (approximately 90 feet in length) will not impact any sensitive water
way or wetland features classified as 1202.c.(1) Q,R or S HPH. The liquid line tie-in will be installed
within the existing Clear Creek Road pipeline ROW up to the SKR 698-09-AV pad approximately
4981 feet to the north (Figure 2).
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November 29, 2023 Page 3 of 15
2001 16th Street, Suite 900 Denver, Colorado 80202
FIGURE 2- Liquids (Red) and Gas (Yellow) Flowline Tie-in; SKR 698-10-BV Well Pad to the
SKR 698-09-AV Well Pad
The extent of the proposed activities also includes freshwater sourcing from the Colorado River.
Source water for drilling and completion activities will be pumped from the Kobe Water Facility and
along a federal Right-of-Way (ROW) evaluated and approved by the Bureau of Land Management
(BLM) in 2023 for earlier well completion activities in Skinner Ridge and initiated in August 2023.
The temporary ROW authorization (COC-80860) is good for a three-year term and will be utilized
for Chevron’s well drilling under this project as well. The temporary source water flowline will include
approximately 12 miles of surface flat-lay flowline and pump stations along existing water diversion
and access road disturbances, up to the Skinner Ridge 66S98W/22NENW water staging pad
(Location ID# 324358, aka SKR 22-1) and then to the SKR 698-10-BV well pad by means of a
surface-lay line and two booster pumps (Figure 3). The SKR 22-1 will utilize a Modular Large
Volume Tank (MLVT) on the pad working surface for fresh water staging in support of well
completion activities. The SKR 22-1 pad and proposed surface-lay freshwater line to the SKR 698-
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November 29, 2023 Page 4 of 15
2001 16th Street, Suite 900 Denver, Colorado 80202
10-BV pad are located within the Clear Creek Sportfish Management Waters HPH 500-foot offset.
Water sourcing activities were included in the CPW waiver request document for the project.
FIGURE 3- Fresh Water Sourcing from the SKR 22-1 Pad to the SKR 698-10-BV Well Pad
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Field Hydrologic Review
Hydrologic field review (Aquatic Resource Inventory) of the SKR 698-10-BV project was performed
by a SWCA Environmental Services Professional Wetland Scientist (PWS) the week of July 21st,
2023. Survey activities were performed based on existing hydrologic features identified in the field
including National Wetland Inventory (NWI)-mapped wetlands, National Hydrography Dataset
(NHD) delineations, and the features presented on the SKR 698-10-BV Well Pad Hydrology Map
submitted with the 2A application packet to ECMC. As depicted on Figure 4, SWCA confirmed
that Deer Park Gulch (aka Tom Creek and dry at the time of inspection) which can seasonally hold
water and has a defined OHWM is identified as Sportfish Management Waters HPH, and is located
±150 feet southeast of the pad’s permitted DA. Also, an agricultural ditch (holding water at the time
of inspection) was identified ±343 feet southwest of the pad’s DA. No other associated wetlands,
water features or hydrophytic plant or soil indicators were identified within 500 feet of the pad’s DA.
FIGURE 4- SKR 698-10-BV Well Pad proximity to Deer Park Gulch (aka Tom Creek)
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November 29, 2023 Page 6 of 15
2001 16th Street, Suite 900 Denver, Colorado 80202
The recent hydrology field investigation suggests that per Rule 1202.a.(3), long-term well and
facility operations will place the maintenance tank in the northeast portion of the pad within 500 feet
of Deer Park Gulch to the southeast and the agricultural ditch to the southwest. Chevron requested
CPW Waiver approval to Rule 1202.a.(3) for this location in protection of these potential aquatic
resources and received CPW approval on 11/16/23 (attached to this submittal). Chevron
committed to institute the following BMPs to be protective of Deer Park Gulch and the agricultural
ditch:
o Stormwater management design protections during drilling and completion operations that
include a perimeter collection channel around the entire pad circumference while routing
stormwater flow to two dedicated detention ponds on the south and west sides of the pad.
o Interim reclamation for long-term well production and facility operation will reduce the
original location disturbed area (DA) from 6.16 acres to 2.35 acres, re-establishing
approximately 3.81 acres of habitat to the area.
o Post interim reclamation will maintain diversion channels on the south and west side of the
reclaimed pad area to route surface flows to the permanent sediment pond(s).
o Per post-interim reclamation, the facility pad area will include a permanent raised berm
between the facility maintenance tank and Deer Park Gulch.
o The facility maintenance tank (example picture below) will be constructed within an
impervious, geosynthetic-lined under base, anchored into a metal-sided secondary
containment system capable of containing up to 50% of the tanks capacity and any spill or
leak from the storage vessel;
o Permanent, post-interim reclamation stormwater controls will route flow from the facility
area to perimeter collection channels and to stormwater sediment ponds located between
the pad and downgradient aquatic features;
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