HomeMy WebLinkAbout4.0 CorrespondenceENCANA.
EnCana Oil & Gas (USA) Inc.
January 28, 2009
Fred Jarman
Garfield County Building and Planning Department, Director
108 8th Street, Suite 401
Glenwood Springs, CO 81601
EnCana Oil & Gas (USA) Inc.
370 17°h Street, Suite 1700
Denver, CO 80202
720.876.3989 direct
720.876.4989 fax
Re: Special Use Permit for Material Handling, Processing, and Storage of Natural Gas for the
EnCana Oil & Gas (USA) Inc. (EnCana) 24 -inch diameter Hunter Mesa Pipeline.
Dear Mr. Jarman:
The Board of County Commissioners (BOCC) approved EnCana's 24 -inch diameter Hunter Mesa
Pipeline Special Use Permit Application (Resolution 2004-16) subject to compliance with certain
conditions. The purpose of this letter is to confirm compliance with, and agreement to, the county's
conditions so that the Special Use Permit for the pipeline may be issued to EnCana. For your reference,
the BOCC conditions appear in italicized type and the EnCana response appears in normal font.
1. All representations of the Applicant, either within the application or stated at the hearing before
the Board of County Commissioners, shall be considered conditions of approval, unless
specifically altered by the Board.
EnCana agrees to this condition.
2. Prior to the issuance of the actual Special Use Permit, the Applicant shall provide written
comments from the Grand Valley Fire Protection District that all recommendations outlined in the
Fire District's letter dated September 30, 2003, have been addressed accordingly.
According to EnCana personnel, recommendations dictated by this letter were reportedly followed
during the construction phase of this project. However, written documentation to this effect is
unavailable. The intent of the fire district's recommendations was to minimize the potential for a fire
during pipeline construction. The pipeline has been completed and no fires ensued during
construction. Therefore, the objective of this condition has been met.
3. Prior to the issuance of the actual Special Use Permit, the Applicant shall provide written
documentation with respect the legal use of the water to be used controlling airborne dust along
construction rights-of-way, unpaved haul roads, and other graded traffic routes, and for watering
the topsoil and spoil storage piles in order to minimize the effects of wind erosion and fugitive
dust, as well as for fire protection.
A copy of a document from the West Divide Water Conservancy District, which entitles EnCana to
water rights from the Last Chance Ditch, is contained in Attachment 1.
4. The Applicant shall obtain a road cut permit from the Garfield County Road and Bridge
Department, prior to the issuance of the actual Special Use Permit.
EnCana obtained the required road crossing permits from Garfield County Road & Bridge Department
for utility crossings to be made under County Roads 244 and 215 (Permit numbers 127 &128). No
open cuts were made as EnCana bored under the County right-of-ways for the installation of the 24 -
inch diameter pipeline. Therefore, a road cut permit was not needed.
5. Prior to the issuance of the actual Special Use Permit, the Applicant shall provide to the County
an approved Stormwater Discharge Permit.
A copy of the applicable area -wide Stormwater Management Plan (sans appendices) is contained in
Attachment 2.
I trust that these responses provide sufficient information regarding the BOCC conditions of approval
such that a Special Use Permit for this pipeline can be issued. If you have any questions or need
additional information, please don't hesitate to contact me at (720) 876-3989.
erely,
e da R. Linster
gulatory & Land
Attachments
visor
WEST DIVIDE WATER CONSERVANCY DISTRICT
109 WEST FOURTH STREET P. 0. BOX 1 478
RIFLE. COLORADO 81650-1478
TELEPHONE AND FAX: (970) 625-5461
wowed@rif!e.ntt
March 3, 2003
Tim Baer
EnCana 011 & Gas (USA) Inc.
Y950 Seventeenth Street, Suite 2600
Denver, CO 80202
Dear Mr. Baer-
Encios`ed is your approved assignment of ownership, a copy of the original contract siOlO,628BP(b),
and the amended contract from 28 acre feet to 200 acre feet. Please read the contract carefully if you
have not aheady done so, but please especially note paragraph 2 concerning availability of water.
West Divide obtains its storage water from a number of sources including Ruedi Reservoir and Green
Mountain Reservoir which are Bureau of Reclamation projects. Federal policy relating to endangered
species, among other environmental concerns, provides that supplies from these reservoirs may be
interruptible. Moreover, the forces of nature are always such that no source of water can be
guaranteed fromycar to year. West Divide continues to make good -faith efforts to obtain alternative
long -terns supplies in an effort to make reliable grid predictable the water supply anticipated by your
contract with us.
As part of the approval of amending the contract from 28 acre feet to 20O acre feet, West Divide and
the Colorado Division of Water Resources requests that a meter be installed on the pipeline from the
Loesch and Crane Ditch and a map detailing the pipelines and diversion points be provided. The
form given you by the Division of Water Resources is not adcgoatc for all your diversions . We
Samuel B. Potter, President Kelly Couoy, Vice President Robert J. Zanelta, Secretary
Laverne Starbuck, Treasurer Bruce E. Warrlpler, Director
TRANS:Y1ITTAL
LETTER
DATA May 30, 2003
TO:
WEST DIVIDE WATER CONSERVANCY DISTRICT
109 West Fourth Street, P. 0_ Box 1478
RIM, Colorado 81650-.478
Telephone and Fax: 9701625-5461
vidwcdaiearrhlink.net
Tim Baer
E Cana Oil & Gas (USA) Inc.
950 Seventeenth Street, Suite 2600
Denver, CO 80202
RS: Amended Contract #010628BP(b)
1 A-VISMIlailIGYO:
Original executed amended contract for 500 acre feet.
MESS AR. SRN7 TO YOU:
For your files.
REMARY.S.
Sincerely yours,
WEST DIVIDE WATER CONSERVANCY DISTRICT
3a�cMaddock
cc; Division No. 5 Water Resources wlcnclosure
Ferry D. Sudor, Hydrologist wlcnclosusc
WEST DJVIOE WATER CONSERVANCY DISTRICT
109 WEST FOURTH STREET P. 0. BOX 1473
RIFLE, COLORADO 89850-147$
TELEPHONE AND FAX: (970) 625-5451
wdwcd@rillle.net
December 5, 2002
Tirn Baer
EnCana Oil and Gas (USA) Inc.
950 1 7th St., Suite 2600
Denver, CO 80202
Re: Water Contract #010628BP(a)
Dear Mr. Baer
Per our recent conversation, I am enclosing duplicate Applications for Assignment of Ownership and
duplicate Applications to Amend Water Lease. Each form needs to be completed and returned to ate
in duplicate_ There is a $110 fee for each the assignment and the amendment. If they are processed
together, one of the fees wt11 be waived, hence the total due wx11 be S110.
I have billed EnCana for the 28 contracted acre feet for 2003. Please submit payment for the
addhiona.1 water at $450 per acre foot.
If you have any questions, please do not hesitate to contact me.
Sincerely yours,
Janet Maddock
Enclosures
5
/10)3
Samuel 8. Potter, President Kelly Couey, Vice President William M. Zilns, Secretary
LuVerne Starbuck, Treasurer & Alternate Secretary Robert ,l. Znella, Di rector
Attachment 2
Stormwater Management Plan
Volume 1
Master Stormwater Management Plan
Mamm Creek Unit
COR -034840
EnCana Oil & Gas (USA) Inc.
Updated February 2008
Volume 1
Master Stormwater Management Plan
Mamm Creek Unit
COR -034840
Prepared By Lindsey Kruckenberg, Environmental Field Coordinator
Reviewed By Ryan Meath, Environmental Field Coordinator
EnCana Oit & Gas (USA) Inc.
Updated February 2008
Contents
1.0 Introduction 1-1
1.1 Site Specific Records 1-1
1.2 SWMP Administrator 1-2
2.0 Narrative Description of Master SWMP Permit Coverage Area 2-1
2.1 Sequence of Major Activities 2-1
2,1.1 Well Pads and Roads .... 2-1
2.1.2 Pipelines 2-2
2.1.3 Compressor Stations, Treatment Facilities, or Other Facilities 2-4
2.2 Area Estimates 2-6
2.3 Description of Existing Topography and Soils 2-6
2.4 Description of Existing Vegetation 2-6
2.5 Identification of Potential Pollution Sources 2-7
2.6 Allowable Sources of Non-Stormwater Discharge 2-8
2.7 Receiving Water 2-8
2.8 Master SWMP Permit Area Map and Individual Stormwater Site Plans 2-9
3.0 Best Management Practices (BMPs) 3-1
3.1 Erosion, Drainage, and Sediment Control BMPs 3-1
3.2 Non-Stormwater Control BMPs 3-1
3.2.1 Materials Delivery and Storage 3-2
3.2.2 Material Handling and Spill Prevention 3-2
3.2.3 Vehicle Cleaning, Fucfing, Maintenance, and Tracking Controls 3-2
3.2.4 Waste Management and Disposal 3-3
3.2.5 Dewatering 3-3
3.3 Stomiwater Manual of BMPs 3-4
3.4 Phased BMP Implementation 3-5
4.0 Interim Reclamation and Final Stabilization 4-1
5.0 Inspection and Maintenance 5-1
5.1 Inspection Schedule 5-1
5.1.1 Minimum Inspection Schedule for active sites 5-1
5.1.2 Post -Storm Event Inspections at Temporarily Idle Sites 5-1
5.1.3 Completed Sites 5-1
5.1.4 Winter Conditions Inspections Exclusion 5-2
5.2 Performing Inspections 5-2
Haeata'COA's Hunter Mesa 24wn Pipetrne,Atlacbmenl
31,Mamm Greek SWMP 100% 021208 decal
Updated February 20n6
5.3 Maintenance 5-2
5.4 Documenting Inspections and Maintenance 5-3
6.0 Plan Revisions and Retention 6-1
7.0 Inactivation Notice 7-1
8.0 Signature 8-1
9.0 References 9-1
List of Appendices
Appendix A General Permit Application
Appendix B Revegetation Manual
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
Appendix H
Existing Soil and Vegetation Data
Master SWMP Permit Area Map
Stormwater Manual of Best Management Practices (BMPs)
Final Stabilization Certification
Inspection and Maintenance Report Form
Inactivation Form
t1'VatatCOA'aWunter Mesa lain Plpeu0e1A0at:trment
30k1ama1 Creek SWMP 100% 021209dew.
tl Upddted February 20011
1.0 Introduction
This Master Stormwater Management Plan (Master SWMP) satisfies the Colorado Department of Public
Health and Environment (CDPHE) Water Quality Control Division (WQCD) General Permit No. COR -030000
issued on May 31, 2007 for Stormwater Discharges Associated with Construction Activities (the Stormwater
Construction Permit). EnCana Oil & Gas (USA) Inc. (EnCana) has submitted a General Permit Application to
WQCD, a copy of which is provided as Appendix A.
This Master SWMP has been prepared in compliance with CDPHE WQCD, the Federal Clean Water Act
(CWA), and the National Pollutant Discharge Elimination Permit (NPDES) regulations found in 40 CFR,
Part 122.26 for stormwater discharges.
The objectives of this Master SWMP are to;
1. Identify all potential sources of pollution which may reasonably be expected to affect the quality of
stormwater discharges associated with construction activity within this Master SWMP permit area at
each project site;
2. Describe the practices to be used to reduce the pollutants in stormwater discharges associated with
construction activity within this Master SWMP permit area at each project site (also known as Best
Management Practices (BMPs)); and ensure the practices are selected and described in accordance
with good engineering practices, including the installation, implementation and maintenance
requirements;
3. Be properly prepared and updated to ensure compliance with the terms and conditions of the
Stormwater Construction Permit;
4. Work hand in hand with the Site Specific Records, as described in the following section; and
5. Serve as an education tool and comprehensive reference/guide to stormwater management for
inspectors. surveyors, engineers, and EnCana employees and contractors.
EnCana construction activities fall under one of two types. Exploration and Production (E&P) sites involve the
construction of well pads, roads, and other facilities. Midstream Services (also referred to as Gas Gathering)
sites involve the construction of pipelines and compressor, treatment, and other facilities. This Master SWMP
is intended to address stormwater management for any and all of these sites within this Master SWMP's
Permit Coverage Area.
1.1 Site Specific Records
While Volume 1 of the Master SWMP contains all of the general permit area information, Volume 2 of the
Master SWMP contains all of the Site Specific Records including all Individual Stormwater Site Plans (Site
Plans), as discussed in Section 2.8, and all Inspection and Maintenance Reports (discussed in Section 5,4).
These Site Specific Records contain information specific to each site (each well pad, compressor station.
section of road/pipeline, etc.), including information on areas of disturbance, ecosystems and vegetation, soil
types, percent pre -disturbance vegetation, etc. Any changes to the design of individual sites or the BMPs
used at those sites will be noted on the Site Plans as those changes occur, and kept with the Site Specific
Records.
The Site Specific Records (Volume 2 of the Master SWMP) are bound separately from the body of this Master
SWMP; however, both are readily available during any inspection. Both the body of this SWMP (Volume 1)
and the Site Specific Records (Volume 2) comprise the entire SWMP, and go hand in hand in keeping EnCana
in compliance with stormwater regulations. The Site Specific Records will be kept at the EnCana field office in
H1 Daea5C.0A's'W unler Meso 241n PlpelineMllachmenl
3W,amm Creek SWMP 1Q2% 02121:19 Eocm
1-1
Updated February :009
Parachute during active construction and site inspections to ensure accurate implementation, inspections, and
maintenance of BMPs, as well as timely revisions to the Site Specific Records.
1.2 SWMP Administrator
The SWMP Administrator is responsible for the process of developing, implementing, maintaining, and revising
this SWMP as well as serving as the comprehensive point of contact for all aspects of the facility's SWMP.
SWMP Administrators:
• E&P Sites:
Terry Gosney, Regional Environmental Coordinator
2717 County Road 215, Suite 100, Parachute, CO 81635
(970) 285-2600
• Midstream Services: Brad Ankrum, Piceance Midstream Operations Manager
2717 County Road 215, Suite 100, Parachute, CO 81635
(970) 285-2600
NlOalalCOA'sWunler Mesa 24tn PtpeIIneWllsonmeel
7lMamm Creek SWMP 1 DO% D21206.docm
1-2
Updated February 2008
2.0 Narrative Description of Master SWMP Permit Coverage Area
Name of Permit Coverage Area: Mamm Creek Unit
Permit Number: COR -034840
Location of the Permit Coverage Area:
• County: Garfield and Mesa County,
• City: Located in Colorado approximately 1 mile south of Rifle and south of the Colorado River within
the southern portion of the Piceance Basin.
• Townshlp(Secfion/Range: Township 6S, 7S, & 8S, Range 92W, 93W, & 94W, portions or all of 113
sections, Sixth Principal Meridian.
Activities at the Permit Coverage Area will likely involve the construction of:
• Well pads
• Access roads
• Pipelines
• Compressor stations
• Water Treatment Facility
• Fresh Water Storage Pond
• Evaporation Facility
The above construction activities are only typical and may vary once construction begins. Up-to-date
information on the construction of well pads, roads, pipelines, etc. will be kept with the Site Specific Records
(Volume 2 of the Master SWMP).
2.1 Sequence of Major Activities
Site specific, scheduling, surface use agreements, and/or other constraints can and/or may dictate changes in
construction sequences. Significant sequence changes are addressed in the Site Specific Records (Volume 2
of the Master SWMP). Specific details on the construction and maintenance of BMPs mentioned below are
provided in the Stormwater Manual of Best Management Practices (BMP Manual) as discussed in Section 3.3.
2.1.1 Well Pads and Roads
Construction activities for well pads and roads are generally completed in the following sequence:
Preconstruction:
1 Surveys. Topographic, vegetation, wildlife and archeology, as dictated.
2. Temporary BMP's. Where physical access is available, installation of terminal perimeter and
temporary sediment controls. such as wattles, silt fence and/or other as necessary. Actual BMPs
used for each site are shown on the Site Plans (discussed in Section 2.8) and kept with the Site
Specific Records (Volume 2 of the Master SWMP).
Construction:
H IQa1atCOA'sViunter Mesu 24ln Pveline An cnmenl
3Wamm C1ec%. SWMP 100% 021208.doun
2-1
updaled February 2009
3. Vegetation Clearing. Vegetation will be cleared/grubbed and placed along the perimeter at the
terminal discharge edges/points in a windrow and/or dam beyond the edge of excavation and at any
run -on -protection discharge points, and/or chipped or other depending on landowner requirements
4. Diversions and Retention Reservoirs. After vegetation clearing and prior to topsoil stockpiling,
diversions are to be placed for run -on -protection (ROP) to prevent the greater landscape from
discharging onto the planned disturbance. Temporary sediment control BMPs shall be placed at the
discharge points of the ROP until permanent erosion controls can be installed along the entire
length of the ROP. Diversions are to be installed along the terminal discharge edge inside of the
vegetation windrows to convey site water/sediment to terminal discharge points where rough
retention reservoirs are to be installed. The retention reservoir outlets are to receive temporary
sediment control BMPs until permanent retention reservoirs and erosion, drainage, and sediment
BMPs can be installed.
5. Topsoil Stripping/Conservation. All ACCESSIBLE TOPSOIL {s to be removed from areas that are
to be excavated, covered in subsoils, or turned into stabilized unpaved surfaces. If initial topsoil
stockpile areas are insufficient to accommodate the quantities of topsoil being generated, the excess
is to be placed at either end of the subsoil stockpile and segregated as much as possible. After major
earthwork, grading, and erosion/drainage/sediment controls are complete, any areas that can be
identified for immediate interim reclamation shall receive topsoil.
6. General Rough Grading. The site location will be graded to provide suitable surfaces for vehicle
traffic and/or building sites, and may be graded to establish surface drainage patterns, such as berms
or roadside ditches as necessary.
7. Facility Specific Grading. Individual facilities may require additional excavation to allow for
construction of foundations Excess soil will typically be used in general site grading.
5. Foundation Construction. To support facilities (such as tanks, processing equipment, etc),
foundations will be constructed. Foundations may consist of select backfill, concrete spread footings,
or piles. Finished support elevations are to be installed twelve to eighteen inches (12-18") above
finished grade or the lowest point of the facility.
9. Facility Construction. Tanks, processing equipment, etc. will be constructed.
Interim Reclamation:
10. Gravel Surfacing. Areas used for access, parking, or materials staging will typically be gravel
surfaced.
1 1 _ Reclamation of Unused Areas. Areas not needed for facilities, roads, parking, or materials staging
will gener"ally be reclaimed. Salvaged topsoil will be spread and the vegetative seed mix will be
applied.
12, Application of Erosion Stabilization. Depending on terrain (e.g. steep slopes and drainage
crossings) additional measures may be applied to increase stability of the reclaimed area.
Final Reclamation:
13. Reclamation of Post -Operation Areas. When operation of well pad or road is no longer necessary,
the area will be decommissioned and all newly disturbed areas will be reclaimed. Any remaining
topsoil will be spread and the vegetative seed mix will be applied. This may occur after termination of
this permit and under the coverage of a new construction permit.
2.1.2 Pipelines
Construction activities for pipelines are generally completed in the following sequence:
Pre construction:
1. Surveys. Topographic, vegetation, wildlife and archeology, as dictated.
Cata4CCN.'s W unser Mesa 2e1n Pekellne448achment
5Mamm Creek SWAN. 100% 021208,doan
2-2
Updated February 2008
2. Mark Right -Of -Way. The construction right-of-way (ROW) will be marked prior to construction with
laths andforflagging. Laths/flagging will be maintained throughout construction and will not be
removed until after reclamation activities have been completed.
3. Temporary BMPs. EnCana's stormwater inspectors will determine locations to install preconstruction
temporary erosion control devices, per site specific BMP installation plans and as necessary.
EnCana's contractor will maintain the erosion control structures as directed by the stormwater
inspectors throughout all phases of construction, or until permanent erosion control measures are
installed. Actual BMPs used for each site are shown on the Site Plans, which are kept with the Site
Specific Records (Volume 2 of the Master SWMP).
Construction:
4. Vegetation Clearing. If necessary, vegetation will be cleared and placed in a windrow at the edge of
the work area to be used later in reclamation activities, removed from the construction site, or
burned/chipped depending on landowner requirements. Details for windrows are provided within the
Stockpiling BMP of the BMP Manual (discussed in Section 3.3).
5. Topsoil Stripping. All ACCESSIBLE TOPSOIL (from the entire width of the right-of-way) will be
removed and temporarily stockpiled along the up -hill side of the right-of-way (if terrain grades will
allow) for later use in reclamation activities.
6. General Grading. For pipeline segments that occur in relatively rough terrain, general grading will be
conducted to create a safe and workable ground surface. This is generally done to form a relatively
level work surface on steep cross slopes and to reduce slopes in undulating terrain (arroyo and wash
crossings). The site location will be graded to provide suitable surfaces for vehicle traffic and/or
building sites, and may be graded to establish surface drainage patterns, such as berms or roadside
ditches as necessary,
7. Trench Excavation. The trench needed for pipeline installation is alrnost always off -set in the ROW.
The surveyors may indicate the location of the trench on their pipeline lateral. Generally, the trench will
be located in the first third of the ROW. The remaining two thirds of the ROW will be used for working
space. The trench depth and width will vary with the number of pipes to be instated and the pipe
diameter. Generally, a 4 -foot deep trench will be excavated by track -mounted excavators. The ditch
will be excavated and sloped in accordance with OSHA specifications. The cover from top of pipe to
ground level will be a minimum of 36 inches. Where rock is encountered, tractor -mounted mechanical
rippers or rock trenching equipment may be used to facilitate excavation. The trench will be excavated
and subsoil material stockpiled within the confines of the approved right-of-way limits. Trench spoil will
be stored in a separate location from the previously segregated topsoil.
8. Pipe Installation. Pipe installation will include stringing, bending for horizontal or vertical angles in
the alignment, welding the pipe segments together, coating the joint areas to prevent corrosion, and
then lowering -in and padding.
9. Stringing. Pipe will be hauled by truck to the pipeline ROW. Each joint of pipe will be unloaded and
placed parallel to the ditch.
10. Bending. After the joints of pipe are strung along the ditch, individual joints of pipe may need to be
bent to accommodate horizontal and vertical changes in direction. Field bends will be made utilizing a
hydraulically operated bending machine. Where the deflection of a bend exceeds the allowable limits
for a field -bent pipe, factory (induction) bends will be installed.
11. Welding. After the pipe joints are bent, the pipe is lined up end-to-end and clamped into position. The
pipe is then welded in conformance with 49 CFR Part 192, Subpart E. 'Welding of Steel Pipelines"
and API 1104, "Standard for Welding Pipelines and Related Facilities".
12, Welding Inspection. Welds will be visually inspected by a qualified inspector. Any defects will be
repaired or cut out as required under the specified regulations and standards.
13 Coating. To prevent corrosion, the pipe will be externally coated with fusion bonded epoxy coating
prior to delivery. After welding, field joints will be coated with fusion bond epoxy coating, tape and
tt,VOata1COA's11-Iunler Mesn 24in Pipelineadachment
35Mamr' Creek SWMP 546% 021208.nacln
2-3
Updated February -2008
primer, or shrink sleeves. Before the pipe is lowered into the ditch, the pipeline coating will be visually
inspected and tested with an electronic detector, and any faults or scratches will be repaired.
14. Lowering -En and Padding. Once the pipe coating operation has been completed, a section of the
pipe will be lowered into the ditch. Side -boom tractors may be used to simultaneously lift the pipe,
position it over the ditch, and lower it in place. Inspection will be conducted to verify: that minimum
cover is provided; the trench bottom is free of rocks, debris, etc.; external pipe coating is not damaged;
and the pipe is properly fitted and installed into the ditch. Specialized padding machines will be used
to sift soil fines from the excavated subsoil to provide rock -free pipeline padding and bedding. In rocky
areas, padding material or a rock shield will be used to protect the pipe. Topsoil will not be used to pad
the pipe. At the completion of lowering -in and padding activities the contractor may install trench
breakers around the pipelines to minimize subsurface water flow. Details for trench breakers are
provided within the BMP Manual (discussed in Section 3.3).
15. Backfilling. Backfilling will begin after a section of the pipe has been successfully placed in the ditch
and final inspection has been completed. Backfilling will be conducted using a bulldozer, rotary auger
backfill, padding machine or other suitable equipment. Backfilling the trench will use the subsoil
previously excavated from the trench. Backfill will be graded and compacted, where necessary for
ground stability, by being tamped or walked in with a wheeled or track vehicle. Compaction wit be
performed to the extent that there are no voids in the trench. Any excavated materials or materials
unfit for backfill will be utilized or properly disposed of in conformance with applicable laws or
regulations.
16. General Grading. If general grading was conducted to facilitate pipeline construction, these materials
will be replaced and graded to recreate the preconstruction topography.
Final Reclamation:
17. Cleanup. Cleanup activities will be initiated as soon as practicable after backfilling activities have
been completed. All construction -related debris will be removed and disposed of at an approved
disposal facility.
18. Subsoil and Topsoil Placement. Subsoil will be evenly re-contoured across the right-of-way to
pre -construction conditions. After the subsoil has been re -spread the contractor will spread the
previously segregated topsoil back across the right-of-way. The topsoil will be evenly spread to
original contours.
19. Vegetation. After any remaining topsoil is spread, the vegetative seed mix will be applied. The area
will be revegetated according to private landowner Surface Use Agreements and/or according to the
BLM/Forest Service reclamation requirements. Details for revegetation are provided within the BMP
Manual (discussed in Section 3.3) and the Revegetation Manual (provided as Appendix B).
20. Application of Erosion Stabilization. Depending on terrain (e.g. steep slopes and drainage
crossings) additional measures may be applied to increase stability of the reclaimed area. Possible
erosion stabilization methods are provided within the BMP Manual (discussed in Section 3.3). Actual
locations and measures used are shown on the Site Plans, which are kept with the Site Specific
Records (Volume 2 of the Master SWMP).
2.1.3 Compressor Stations, Treatment Facilities, or Other Facilities.
Construction activities for compressor stations, treatment facilities, and other facilities are generally completed
in the following sequence:
Preconstruction_
1. Surveys. Topographic, vegetation, wildlife and archeology, as dictated.
2 Temporary BMP's. Where physical access is available, installation of terminal perimeter and
temporary sediment controls, such as wattles, silt fence and/or other as necessary. Actual BMPs
H:\DatatCOA'sWunter Mesa 24in Pipellnel tlachmenl
T.Mamm Creek SWMP 100e 021208.docm
2-4
Updated Feare ary 2005
used for each site are shown on the Site Plans, which are kept with the Site Specific Records
(Volume 2 of the Master SWMP).
Construction:
3 Vegetation Clearing. Vegetation will be cleared/grubbed and placed along the perimeter at the
terminal discharge edges/points in a windrow and/or dam beyond the edge of excavation and at any
run -on -protection discharge points, and/or chipped or other depending on landowner requirements.
4. Diversions and Retention Reservoirs. After vegetation clearing and prior to topsoil stockpiling,
diversion are to be placed for ROP to prevent the greater Vandscape from discharging onto the
planned disturbance. Temporary sediment control BMP's shall be placed at the discharge points of
the ROP until permanent erosion controls can be installed along the entire length of the ROP.
Diversions are to be installed along the terminal discharge edge inside of the vegetation windrows
to convey site water/sediment to terminal discharge points where rough retention reservoirs are to
be instated. The retention reservoir outlets are to receive temporary sediment control BMP's until
permanent retention reservoirs and erosion, drainage, and sediment BMP's can be installed.
5. Topsoil Stripping/Conservation. All ACCESSIBLE TOPSOIL is to be removed from areas that are
to be excavated, covered in subsoils, or turned into stabilized unpaved surfaces, If initial topsoil
stockpile areas are insufficient to accommodate the quantities of topsoil being generated, the excess
is to be placed at either end of the subsoil stockpile and segregated as much as possible. After major
earthwork, grading. and erosion/drainage/sediment controls are complete, any areas that can be
identified for immediate interim reclamation shall receive topsoil.
6. General Rough Grading. The site location will be graded to provide suitable surfaces for building
sites and vehicle traffic, and may be graded to establish surface drainage patterns, such as berms or
roadside ditches as necessary.
7. Excavation. Soil will be excavated to allow for the construction of foundations. Trenches will be
excavated for all underground piping and conduit. Excess soil will typically be used in general site
grading.
8. Foundation Construction. Foundations will be constructed to support facility buildings. Foundations
may consist of select backfill, concrete spread footings, piles, etc. Finished support elevations are to
be installed twelve to eighteen inches (12-18") above finished grade or the lowest point of the facility.
9. Facility Construction. Buildings, tanks, processing equipment, etc. will be constructed. Utilities will
be installed.
Interim Reclamation:
10. Landscaping. If necessary, certain areas will be spread with topsoil and landscaped.
11, Gravel Surfacing. Areas used for access, parking, or materials staging will typically be gravel
surfaced.
12, Reclamation of Unused Areas. Areas not needed for facilities, roads, parking, or materials staging
will generally be reclaimed. Salvaged topsoil will be spread and the vegetative seed mix will be
applied.
13, Application of Erosion Stabilization. Depending on terrain (e.g. steep slopes and drainage
crossings) additional measures may be applied to increase stability of the reclaimed area. Possible
erosion stabilization methods are provided within the BMP Manual (discussed in Section 3.3). Actual
locations and measures used are shown on the Site Plans,, which are kept with the Site Specific
Records (Volume 2 of the Master SWMP),
Final Reclamation:
14, Reclamation of Closed Facilities. When facilities are no longer necessary, the buildings may be
demolished, according to approved procedures, All construction materials will be removed and the
newly disturbed areas will be reclaimed, Any remaining topsoil will be spread and the vegetative seed
H DSMICOM V*Inter Mesa 24in PipelineiAttadtrn nt
30Namm Cteek SAW 100% 021200.00ga
2-5
Updated February 2000.
mix will be applied. This may occur after termination of this permit and under the coverage of a new
construction permit.
2.2 Area Estimates
The Permit Coverage Area encompasses portions or all of 113 sections of surface land (approximately
72,273 acres) in Township 6, 7, and 8 South, Range 92, 93, and 94 West. Development of the natural gas
resource and related facilities within the area is estimated to result in a total disturbance area of 999+ acres.
Because the area will vary over time, these are only approximate estimates. This information is used to help
determine the extent of control measures (BMPs) needed.
2.3 Description of Existing Topography and Soils
The Permit Coverage Area consists of relatively flat mesas and ridge crests, alluvial terraces, steep slopes,
mountainsides, intermittent drainage swells, and valley bottoms. The Mamm Creek Unit is located south of the
Colorado River, within the southern portion of the Piceance Basin. The Piceance Basin is a broad, asymmetric,
southeast -northwest trending structural basin that contains sedimentary rocks up to 20,000 feet thick and lies
between the White River uplift to the northeast, the Gunnison uplift to the south, and the Uncompahgre swell to
the west (George 1927; Weiner and Haun 1960).
Elevations within the Permit Coverage Area range from approximately 5,000 feet above mean sea level (amsl)
along the Colorado River to 8,900 feet on Grass Mesa near the western edge of the unit area, Annual
precipitation within the Permit Coverage Area ranges from 10 to 40 inches. Soils surrounding the Permit
Coverage Area are distributed according to the major soil forming factors including climate (effective moisture
and temperature), parent material, topographic position, and slope. The soils table within Appendix C provides
a summary of the soil types found within the Permit Coverage Area (including permeability, available water
capacity, surface runoff, erosion hazard, and others). Most of these soil types are considered to possess
moderate to very severe potential for water erosion.
2.4 Description of Existing Vegetation
The existing percent vegetative ground cover for each well pad, section of roadway/pipeline, etc. within the
Permit Coverage Area is estimated on each inspection and maintenance report form (discussed in
Section 5.4), which are kept with the Site Specific Records (Volume 2 of the Master SWMP). The primary
vegetation types in the Marnm Creek Unit are sagebrush shrublands (Artemisia tridentate), pinyon -juniper
woodlands (Pinus edulis-Juniperus osteosperma), and Gambel oak shrublands (Quercus gambelii). A small
amount of aspen js present at the southern and eastern edge of the Project Area. The riparian vegetation
includes narrowleaf cottonwood (Populus angustifolia), mountain maple (Acer glabrum), river birch (Betula
occidentalis), alder (Alnus inoana spp. tenuifolia), dogwood (Comas sereciea), and Woods' rose (Rosa
woodsii). Snowberry occurs in the shrublayer, and orange sneezeweed (Dugaldia hoopesii), tailcup lupine
(Lupinus caudatus), field horsetail (Equisetum arvense), American vetch (Vicia americana), orchardgrass
(Dactylis gloverata), northern bedstraw, geranium (Geranium caespitosum), and yarrow (Achillea lanulosa)
occur in the understory. Further to the southwest, numerous blue spruce (Picea pungens) occur along the
creek (BLM 2005).
Vegetation within the Grass Mesa area primarily consists of hillsides dominated by pinyon -juniper
woodlands (Juniperus osteosperma and Pinus edulis) and the mesa top dominated by mixed mountain
shrubs, mostly big sagebrush (Artemisia tridentate), Gambel oak (Quercus gambelii), and serviceberry
(Amelanchier alnifolia). Several of the proposed locations fall within areas dominated by sagebrush -steppe.
Herbaceous and succulent species commonly found in the project area include arrow -leaf balsamroot
(Balsarnorhiza sagittata), prickly pear cactus (Opuntia polyacantha), prairie lupine (Lupinus wyethii), orange
glcbemallow (Sphaeralcea munroana), and several species of penstemon (Penstemon spp.) and paintbrush
(Castilleja spp.) (BLM 2004).
m valalCOA'eW anter Mesy 24in Pipe?ine1Attaceseen1
3Wiamm Cteek SWMP ibbrVy 021 08.dabn
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Lipdelea February 2068
The entire Mamm Creek Unit has, to some extent, been affected by cheatgrass (downy brome) (Brvmus
tectorum) (see Invasive, Non -Native Species). It is often associated with sagebrush communities and
disturbed areas, especially two -track roads. In the pinyon/juniper woodlands, this species may be found as the
understory.
Stressed by the recent drought, many pinyon pine trees in the Colorado Plateau have succumbed to an
engraver beetle (Ips confusus) infestation. However, in the Mamm Creek Unit, the scattered pinyon pine trees
have shown few signs of infestation.
2.5 Identification of Potential Pollution Sources
Potential sources of pollution are associated with all phases of the project from the start of construction though
interim reclamation and up until final stabilization has occurred. Final stabilization occurs when construction
activities have been completed and all disturbed areas have been either built on, paved, or a uniform
vegetative cover has been established with a density of at least 70 percent of pre -disturbance levels, or
equivalent permanent, physical erosion reduction methods have been employed.
The most common source of pollution during construction is sediment resulting from the erosion of recently
cleared and/or graded areas, such as cut/fill slopes and soil stockpiles. However, there may be many potential
pollution sources at any given site. The following types of conditions that might affect the potential for a
pollutant source to contribute pollutants to stormwater (CDPHE, 2007B) shall be evaluated:
• The frequency of the activity (Le., does it occur every day or just once a month? can it be scheduled to
occur only during dry weather?);
• Characteristics of the area where the activity takes place (i.e., surface type (pavement, gravel,
vegetation, etc.), physical characteristics [site gradients, slope lengths, etc.]);
• Ability of primary and secondary containment (fuel tanks, drum storage, etc.) at product storage and
loading/unloading facilities to prevent and contain spills and Teaks;
• Proximity of product storage and loading/unloading facilities to waterways or drainage facilities;
• Concentration and toxicity of materials which may to be found in the site's stormwater runoff; and
• Contamination of storage facilities/containment with stored materials (Le., used oil drums or tanks
coated with spilled oil).
The following items are potential sources of pollutants at the Mamm Creek Unit. Each of the potential sources
of pollutants will be controlled using one or more of the following types of BMPs: Erosion Controls, Drainage
Controls, Sediment Controls or Non-Stormwater Controls. Descriptions and details for each of these types of
BMPs are provided in the BMP Manual (discussed in Section 3.3). Actual BMPs used at each site are shown
on the Site Plans (discussed in Section 5.4).
Construction:
• All Disturbed and Stored Soils: Erosion Controls, Drainage Controls, Sediment Controls.
• Vehicle Tracking of Sediments: Sediment Controls, Non-Stormwater Controls.
• Management of Contaminated Sails: Non-Stormwater Controls.
• Loading and Unloading Operations: Non-Stormwater Controls.
• Outdoor Storage Activities (Building Materials, Fertilizers, Chemicals, etc.): Non-Stormwater Controls.
• Vehicle and Equipment Maintenance and Fueling: Non-Stormwater Controls.
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Updated February 2008
• Significant Dust or Particulate Generating Processes: Non-Stormwater Controls.
• Routine Maintenance Activities Involving Fertilizers, Pesticides, Detergents, Fuels, Solvents, Oils, etc.:
Non-Stormwater Controls.
• On -Site Waste Management Practices (Waste Piles, Liquid Wastes, Dumpsters, etc.):
Non-Stormwater Controls.
• Concrete Truck/Equipment Washing, Including the Concrete Truck Chute and Associated Fixtures
and Equipment: Non-Stormwater Controls.
• Dedicated Asphalt and Concrete Batch Plants: There will be no asphalt or concrete batch plants
located within the Permit Coverage Area of this SWMP.
• Non -Industrial Waste Sources Such as Worker Trash and Portable Toilets: Non-Stormwater Controls.
Interim/Final Reclamation:
• At Disturbed and Stored Soils: Erosion Controls, Drainage Controls, Sediment Controls.
• Vehicle Tracking of Sediments: Sediment Controls, Non-Stormwater Controls.
• Vehicle and Equipment Maintenance and Fueling: Non-Stomnwater Controls.
• Significant Dust or Particulate Generating Processes: Non-Stormwater Controls.
• Non -Industrial Waste Sources such as Worker Trash and Portable Toilets: Non-Stormwater Controls.
2.6 Allowable Sources of Non-Stormwater Discharge
Allowable sources of nen-stormwater discharge within the Permit Coverage Area include the following:
• Uncontaminated Springs. Although there are several springs within the Permit Coverage Areas,
none of these springs are currently located in areas where soil disturbance will occur. If this changes
in the future, the controls used at any such location will be noted with the Site Specific Records.
• Landscape Irrigation Return Flow. There are several locations where pipelines cross through
irrigated fields. These locations will be treated similarly to any water crossing with the use of an
appropriate control which will be noted in the Site Specific Records.
• Construction Dewatering. Construction dewatering is described and discussed in Section 3.2.5.
• Concrete Washout. Concrete washout is described and discussed in Section 3.2.4.
• Emergency Fire Fighting Water. Water used to put out any type of fire is considered an allowable
source of non-stormwater discharge.
No other non-stormwater discharges are allowed under the Stormwater Construction Permit. Other types of
non-stormwater discharges must be addressed in a separate permit issued for that discharge.
2.7 Receiving Water
Runoff from disturbed areas during construction will be controlled and/or routed through the use of one or
more BMPs, as described later in this plan, prior to being discharged to receiving waters. However, it may be
expected that runoff from certain areas will infiltrate into the earth and is not expected to contribute to receiving
waters.
All streams in the Mamm Creek Unit are tributary to the Colorado River. The project area is located in the
Mamm Creek watershed, and drained by Gant Gulch, Middle Mamm Creek, and an unnamed tributary to
Middle Mamm Creek. Gant Gulch is tributary to West Mamm Creek, These drainages flow to the northeast
into the mainstream portion of Mamm Creek. Mamm Creek is a perennial tributary to the Colorado River.
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Updated PeS+uary 2005
Floodplain habitat occurs along Middle Mamm Creek and East Mamm Creek, which are perennial streams
within the Gant Gulch Area. Dry Hollow Creek is also within the Project Area. Riparian habitat is found along
the banks of these streams. The riparian vegetation along Middle Mamm creek extends up to 100 feet on
either side of the creek. The riparian habitats associated with Middle Mamm, East Mamm and Dry Hollow
Creeks, have been determined to be "non-functional" or "functioning at risk" (M. Kinser, BLM, personal
communication, September 2005) (BLM 2005).
The Grass Mesa area is located within the watersheds of Dry Creek and Ramsey Gulch. Both of these
creeks are tributaries to the Colorado River. Stream flows in the drainages within the Grass Mesa area are
generally ephemeral and dependent on seasonal storm and snowmelt runoff, Floodplain habitats occur
along the intermittent drainages within Dry Creek and Ramsey Gulch but no floodplain habitat would be
impacted by the proposed action. Intermittent drainages occur along Dry Creek and Ramsey Gulch.
However, no wetland habitats or riparian vegetation have been documented along these drainages (BLM
2004)
2.8 Master SWMP Permit Area Map and Individual Stormwater Site Plans
An overall Master SWMP Permit Area Map is provided as Appendix D. This map is likely to change constantly
and will be updated at least annually. The Master SWMP Permit Area Map includes:
▪ Contours and elevations (topography) with existing drainage patterns;
• Locations and names of major surface waters such as streams, wetlands, irrigation ditches, canals,
etc.;
• Master SWMP permit area boundaries;
• Construction area locations including roads, pipelines, well pads, compressor station facilities,
treatment facilities, water parks, and all other facilities.
Individual Stormwater Site Plans (Site Plans) of each site (well pad, access road, section of pipeline, etc.) are
provided with the Site Specific Records (Volume 2 of the Master SWMP) Separate Site Plans will be
developed for each phase of construction: preconstruction, construction, interim reclamation (if applicable),
final stabilization (if applicable) and final reclamation (if applicable). These Site Plans include:
• Construction site boundaries (this is the area expected to be disturbed by clearing, excavating,
grading, or other construction activities);
• Contours and elevations (topography) with existing and proposed drainage patterns;
• Limits of well pads and locations of reserve pits and well heads (if applicable);
• All areas of ground surface disturbance, including areas of cut and fill;
• Locations of all potential pollutant sources listed in Section 2.5 (including areas used for vehicle
fueling, the storage of materials, equipment, soil, or waste, etc...);
• Locations of all minor surface waters and all anticipated allowable sources of non-stormwater
discharge (including springs, dewatering, concrete washout, etc...);
• Locations of all existing and planned BMPs (including erosion, drainage, and sediment controls);
• Locations, names. distances to streams, wetlands, irrigation ditches, canals, other surface waters, etc;
• The size, type and location of any outfall(s). If the stormwater discharge is to a municipal separate
stormwater system, name that system, the location of the storm sewer discharge. and the ultimate
receiving water(s).
Figures showing typical BMP locations along roadways and pipelines are provided as part of the BMP Manual
(discussed in Section 3.3).
H.1OatatCOA's1Hunler Mesei 24,n ?Ipeline%MtacJ neat 2-9 Updated February 2009
3 Mamm Creek SWMP 100% 021200.docm
3.0 Best Management Practices (BMPs)
A key component of this Master SWMP is employing BMPs to improve stormwater quality. Local factors will
be evaluated to determine what BMPs are suitable and practical at different locations. BMPs will be employed
in different combinations during construction activities and phases as conditions warrant. Due to the fact that
this Master SWMP is likely to cover more than one ecosystem (as described in Section 2.4), the selection of
BMPs (including type, quantity, sequence/combination, etc.) will vary at each site within the Master SWMP
Permit Area. Specific BMPs to be employed at each well pad, road, pipeline, or other facility are identified on
the Site Plans, which are kept with the Site Specific Records (Volume 2 of the Master SWMP).
3.1 Erosion, Drainage, and Sediment Control BMPs
The primary method for controlling erosion, drainage, and sediment transport consists of minimizing initial
disturbance of the soil and ground cover. However, many other methods can also be used. All stormwater-
related BMPs will fall under at least one of the following three types of controls:
• Erosion Control. Any source control practice that protects the soil surface andfor strengthens the
subsurface in order to prevent soil particles from being detached by rain or wind, thus controlling
raindrop, sheet, and/or rill erosion.
• Runoff Control. Any practice that reduces or eliminates gully, channel, and stream erosion by
minimizing, diverting, or conveying runoff,
• Sediment Control. Any practice that traps the soil particles after they have been detached and
moved by wind or water. Sediment control measures are usually passive systems that rely on
filtering or settling the particles out of the water or wind that is transporting them prior to leaving
the site boundary.
BMPs may also be classified as either structural or non-structural controls:
• Structural Control. Handles sediment -laden stormwater prior to it leaving each site, Structural
BMPs are used to delay, capture, store, treat, or infiltrate stormwater runoff. Some examples of
structural BMPs include sediment traps, diversions, and silt fences. Most Runoff Controls and
Sediment Controls can also be classified as Structural Controls.
• Non-structural Control. Reduces the generation and accumulation of pollutants, including sediment,
from a construction site by stabilizing disturbed areas and preventing the occurrence of erosion.
Some examples of non-structural BMPs include revegetation, mulching, and surface roughening.
These types of stabilization techniques are not only the most effective method for reducing soil loss,
but they are also normally the most cost effective due to low initial cost and reduced maintenance
requirements. Most, but not all, Erosion Controls can also be classified as Non-structural Controls.
The Site Plans, as mentioned previously and kept with the Site Specific Records (Volume 2 of the Master
SWMP), show the proposed locations of all erosion, drainage, and sediment control BMPs (both structural and
non-structural). Detailed descriptions, design criteria, construction specifications, and maintenance
information for all BMPs are provided in the BMP Manual (discussed in Section 3.3).
3.2 Non-stormwater Control BMPs
Non-stormwater controls include general site and materials management measures that indirectly aid in the
minimization of water pollution. Types of pollution sources include, but are not limited to, litter, oil and grease,
hazardous material spills, and sediment..
H', lCata1CCA's1Huater Mesa 241n PlpeWn0A0acernenl
3lMamm Creek SWMP 103% 021208.docm
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Updated February 2008
3.2.1 Materials Delivery and Storage
The good housekeeping practices listed below will be followed on site during construction and operation:
• An effort will be made to store only enough product required for task completion.
• All materials stored on site will be stored in a neat and orderly manner in appropriate containers and,
where possible, under a roof or other enclosure, and/orwithin secondary containment areas to avoid
contact with stormwater.
• Products will be kept in their original containers with the original manufacturers label.
• Substances will not be mixed with one another unless recommended by the manufacturer.
• Whenever possible, all of the product will be used before disposing of the container.
• Manufacturer's recommendations for proper use and disposal will be followed.
Additional information an material delivery and storage is available in the BMP Manual (discussed in
Section 3.3).
3.2.2 Material Handling and Spill Prevention
In addition to the material storage practices (listed in the previous section) that will be used to reduce the risk
of spills or other accidental exposure of materials and substance, the BMP Manual (discussed in Section 3.3)
will provide more detailed information on spill prevention and control. Furthermore, the Spill Prevention,
Control and Countermeasure (SPCC) Plan will be followed for the control of hydrocarbons. In general, spill
prevention and response procedures wit! include notification (CDPHE 24-hour spill reporting line — 877-518-
5608), clean-up with the use of spill kits and absorbents, and ensuring that materials and wash water can not
discharge from the site, and never into a storm drain system or stream.
3.2.3 Vehicle Cleaning, Fueling, Maintenance, and Tracking Controls
As required by EnCana Oil & Gas (USA), Inc, master service agreement(s) and drilling contract(s), contracting
companies and/or vendors are required to service all vehicles and equipment prior to entering EnCana
facilities. However, in the event maintenance procedures are required at EnCana facilities, all fluids
transferred must utilize secondary containment and drip pans to minimize a release of materials and properly
dispose or recycle spent materials in compliance with local, state, and federal guidelines
While on site, equipment will be parked, serviced, and fueled within designated areas. Equipment fueling on
pipeline rights-of-way will be mobile during active construction. Periodic inspections of equipment and control
procedures will be implemented. Selected equipment may be fueled in place using fuel trucks. When
necessary, equipment and machinery will be decontaminated at an on-site decontamination area prior to
removal from the construction area. Areas will be provided with adequate waste disposal receptacles for liquid
as well as solid waste.
Vehicle tracking of sediments is not expected to be a problem due to construction scheduling, Construction
vehicles will remain on site throughout earth -moving activities. All other vehicles remain in stabilized areas
and do not enter the construction area until that area is stabilized. However, applicable BMPs (such as
scheduling (to minimize site access), stabilized construction entrances, vehicle cleaning, etc.) will be utilized if
sediment tracking does become a problem.
In addition to the typical practices listed above, the BMP Manual (discussed in Section 3.3) provides more
detailed information on vehicle cleaning, fueling, maintenance, and tracking controls,
el Oats1COA'sWanter Mesa lain PipelineW0achment
31Mamm Greek SWMP 100% 021200.tlocm
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Updated February 2000
3.2.4 Waste Management and Disposal
As required by EnCana Oil & Gas (USA). Inc. master service agreement(s) and drilling contract(s), contracting
companies and/or vendors are required to manage all waste generated by their activities at EnCana facilities in
compliance with local, state, and federal guidelines. EnCana Oil & Gas (USA) utilizes a periodic inspection
program to ensure waste management requirements are fulfilled and inspections are documented.
A few of the waste management procedures that will be followed include the following:
• Proper bins will be provided for trash collection and disposal in compliance with local, state, and
federal guidelines.
• Contaminated soils will be placed into a lined and bermed area. Samples of the impacted soil will be
collected and a complete characterization analysis will be performed. When applicable, the impacted
soil will be sent to a licensed disposal facility.
• The contractor will provide portable toilets. Sanitary waste will be regularly collected by a licensed
sanitary waste management contractor and disposed of in an approved manner.
• In the event That sediment is inadvertently transported off the construction site, it wit be collected and
returned to the site and placed on the sof stockpile or spread over the construction pad area and
compacted.
On well pads and access roads concrete washout is used as an interior conductor pipe ballast. Concrete
washout water can NOT be discharged to surface waters or to storm sewer systems without separate permit
coverage However, discharge to the ground of concrete washout water from washing of tools and concrete
mixer chutes may be authorized by this permit, provided that (CDPHE, 2007a):
1. The source is identified in the SWMP;
2. BMPs are included in the SWMP to prevent pollution of groundwater, and
3. These discharges do not leave the site as surface runoff or to surface waters.
Locations where concrete washout activities take place are shown on the Site Plans.
Additional waste management procedures, including solid waste, hazardous waste, contaminated soil,
concrete washout, and septic and sanitary waste, are included in the BMP Manual (discussed in Section 3.3).
3.2.5 Dewatering
Dewatering refers to the mechanical removal of water from an excavation or other structure. Both
groundwater and stormwater may require dewatering during construction. Dewatering of pipelines at the
completion of hydrostatic testing will be required for most pipeline installations.
3.2.5.1 Groundwater Dewatering
Groundwater is very rarely encountered during the construction activities associated with either E&P sites or
Midstream Services sites. If groundwater is encountered, it is typically during construction of a pipeline across
a stream crossing. These pipelines are either bored under the stream or a flume is utilized.
Non-stormwater construction dewatering of groundwater can NOT be discharged to surface waters or to storm
sewer systems without separate permit coverage. However, discharges to the ground of water from
construction dewatering activities may be authorized by this permit, provided that (CDPHE, 2007a):
Fk. IDatalCCQA'sVIunler Mesa 24in PrpaIIne+AI1acnrneru
3WMamm Creek SWMP 100% 021208.decm
3-3
Updal@II February 2008
1. The source is groundwater andlor groundwater combined with stormwater that does not contain
pollutants in concentrations exceeding the State groundwater standards in Regulations 5 CCR
1002-41 and 42;
2. The source is identified in the SWMP;
3. BMPs are included in the SWMP; and
4. These discharges do not leave the site as surface runoff or to surface waters.
Dewatered groundwater shall be pumped or diverted to a sediment control BMP prior to discharge to the
ground. Locations of groundwater dewatering, as well as any BMPs utilized, will be noted on the Site Plans as
soon as such dewatering occurs. Additional information on groundwater dewatering is provided in the BMP
Manual, discussed in Section 3.3.
3.2.5.2 Stormwater Dewatering
The discharge of pumped storrnwater (not including groundwater or other non-stormwater sources) from
excavations, ponds, depressions, etc., to surface water, or to a municipal separate storm -sewer system is
allowed by the Stormwater Construction Permit, as long as the dewatering activity and associated BMPs are
identified in the SWMP (including location of the activity), and BMPs are implemented in accordance with the
BMP Manual, discussed in Section 3.3 (CDPHE, 2007c).
Stormwater that collects in open depressions or trenches during construction activities will be dewatered into
an existing sediment control, such as a detention pond, a sediment trap, or simply into a well -vegetated area to
percolate into the ground and catch suspended sediment. The quality, source, and location of dewatering, as
well as any BMPs utilized, will be noted on the Site Plans as soon as such dewatering occurs. Additional
information on stormwater dewatering is provided in the BMP Manual, discussed in Section 3.3.
3.2.5.3 Pipeline Dewatering
New Department of Transportation (DOT) pipelines are hydrostatically tested with water upon completion of
construction. Once the hydrostatic testing has been completed, dewatering of the pipeline must occur. This
will involve the insertion of a displacer, commonly referred to as a pig, in the pipeline. The discharge rate will
be regulated, and energy dissipation devices, andlor sediment controls will be used, as necessary, to prevent
erosion, streambed scour, suspension of sediments, or excessive streamflow. Locations on pipeline
dewatering, as well as any BMPs utilized, will be noted on the Site Plans as soon as such dewatering occurs.
Additional information on stormwater dewatering is provided in the BMP Manual, discussed in Section 3.3.
3.3 Stormwater Manual of BMPs
A Storrpwater Manual of Best Management Practices (BMP Manual) is provided as Appendix E. The BMP
Manual has been prepared to provide EnCana personnel, contractors, and subcontractors with information on
the proper selection, design, installation, and maintenance of BMPs to manage oil and gas related stormwater
and to meet federal and state SWMP implementation requirements. The main objectives of the BMP manual
are to:
• Serve as an easy-to-use guide for selecting, designing, installing, and maintaining BMPs.
• Function as a reference for construction plans and specifications.
• ultimately lead to the avoidance of any net increase in off-site erosion and sedimentation of waters of
the U.S.
The BMPs within this BMP Manual are organized into four main types of controls for easy reference: Erosion
Controls, Runoff Controls, Sediment Controls, and Non-stormwater Controls. Each of these types of controls
has been discussed earlier in this section of the SWMP.
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Updates February 200a
3.4 Phased BMP Implementation
Various BMPs will be implemented and maintained during different phases of the project. A description of
each phase is as follows:
• Preconstruction. The preconstruction phase involves the installation of BMPs (temporary and/or
permanent) around each site perimeter and at discharge points (such as vegetation buffers (no
installation required for this BMP), slash, wattles, diversions, sediment basins and reservoirs, etc...).
• Construction. The construction phase involves the stripping and stockpiling of topsoil, the excavation
and backfill for access roads, pipelines, and well pads, and the installation of additional BMPs
(preferably permanent BMPs) to control erosion and sedimentation (such as tracking topsoil piles and
the installation of roadside channels, culverts, diversions, etc...).
• Interim Reclamation. The interim reclamation phase primarily involves seeding of all disturbed areas
not needed during operation of the well pads. However, this phase also involves the installation of any
additional permanent BMPs that may be needed, as well as the continued maintenance and
inspections of all BMPs until final stabilization occurs. Final stabilization occurs once all surfaces are
built on, paved or graveled, and/or a uniform stabilized vegetative cover with a density of 70 percent of
pre -disturbance levels has been established or when an equivalent permanent, physical erosion
reduction method has been employed. A further explanation of final stabilization is provided as
section 4 of this plan.
▪ Final Reclamation. For pipelines, this phase involves seeding of all disturbed areas, and the
installation of any additional permanent BMPs that may be needed, as well as the continued
maintenance and inspections of all BMPs until final stabilization occurs. For other areas (roads, well
pads, facilities, etc...), this phase (which may occur after termination of this permit and under the
coverage of a new construction permit) occurs when operation of the area is no longer necessary. In
these cases, this phase will include the installation of any additional BMPs required during facility
decommissioning as well as the spreading of any remaining topsoil, the application of seed, and the
inspection/maintenance of all BMPs until final stabilization occurs.
Temporary controls, such as silt fencing, may be used to control sediment and erosion during preconstruction
and construction activities. Permanent controls, such as diversions and sediment traps, may also be used
during the initial phases of the project. However only permanent controls will be used during interim
reclamation and final stabilization. Temporary controls may be converted into permanent controls (such as
revegetating a diversion) if needed. The primary control used during interim and final stabilization will be
revegetation. Seeding will occur as soon as possible after disturbance of an area is complete. If the seeding
is not successful, the area will either be reseeded or other controls will be put in place until reseeding can
occur.
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4.0 Interim Reclamation and Final Stabilization
As soon as practicable after construction activities have been completed in a disturbed area, interim (for well
pads, or other facilities) or final (for roads and pipelines) reclamation will be started to prevent further erosion
of soil from that area. This typically occurs immediately upon completion of earthwork activities. All disturbed
areas (except for the surface of dirt roads, those portions covered by pavement or a structure, and those areas
used during operation of a well) will be stabilized with permanent controls. The most common measure used
to achieve final stabilization is revegetation. Mulching, erosion control blankets, surfacing with gravel or slash,
and/or other methods may also be used. Structural controls (such as diversions, berms, and sediment traps)
may be revegetated and used as permanent measures to control pollutants in stermwater discharges that will
occur after construction operations have been completed. Appendix E includes detailed information an each
of the previously discussed BMPs. In addition, a revegetation manual is provided as Appendix B, which
provides guidance as to possible methods and materials needed to accomplish revegetation on differing site
conditions. The specific BMPs used at each site are shown on the Site Plans which are kept with the Site
Specific Records (Volume 2 of the Master SWMP).
Final stabilization means that all ground surface disturbing activities at the site have been completed, and all
disturbed areas have been either built on, paved, or a uniform vegetative cover has been established with an
individual plant density of at least 70 percent of pre -disturbance levels, or equivalent permanent, physical
erosion reduction methods have been employed. For purposes of this permit, establishment of a vegetative
cover capable of providing erosion control equivalent to pre-existing conditions at the site will be considered
final stabilization. Areas developed as stabilized unpaved surfaces as needed for operation of the facility after
interim reclamation, wilt also qualify as "finally stabilized." This includes dirt road surfaces and the portions of
the well pad surfaces that cannot be revegetated due to operational necessity, but does not include slopes,
ditches, and other areas where revegetation is necessary. Stabilized unpaved surfaces will be prepared in
such a way as to prevent ongoing erosion issues.
Coverage under the Stormwater Construction Permit may be inactivated for any individual site or a
portion/section of that site (i.e. the access road to a well pad) when the area has attained final stabilization and
all temporary erosion and sediment control measures associated with that area have been removed. An area
will be considered finally stabilized when construction and interim reclamation is complete and when the above
final stabilization criteria have been met, even though the site may be disturbed again in the future for final
reclamation. However, future land disturbances that follow final stabilization and result in disturbance of one
acre or greater (such as final reclamation) will require new permit coverage at that time.
Upon final stabilization of any site or portion/section of a site, a signed certification sheet (provided in
Appendix F) will be placed into the Site Specific Records binder to replace the Site Plans and the inspection
and maintenance records fret that area. However, the Site Plans and inspection reports shall be retained in a
separate location fora period of three years following final stabilization of the Permit Coverage Area. These
documents will be made available to WQCl7 or EPA upon request and at the time of inspection.
H'lDala1COA's1Hunter Meru 24in FIpelmeAtlaCnmenl
35Marnrn Creek SWMP 19694 021200.0etar
4-1
Updated February 2008
5.0 Inspection and Maintenance
Inspections and maintenance is an extremely important part of the Stormwater Construction Permit.
The Construction Manager will ensure that all stormwater management controls are constructed or applied in
accordance with governing specifications or good engineering practices. Experienced teams will be used for
construction, A first inspection will occur upon installation of the controls. In addition, all workers on the site
will be trained as to the location and use of the controls, especially those controls that will be disturbed as
construction proceeds across the site. The goal is to minimize the potential for inadvertent removal or
disturbance of BMPs and to prevent the off site transport of sediment and other pollutants.
5.1 Inspection Schedule
Inspections are required as soon as the first soil disturbance occurs at the site. Once final stabilization of the
site has occurred and the EnCana inspector has filled out the final stabilization certification sheet (see
Section 4), inspections are no longer necessary. Specific information regarding inspection schedules are
provided in the following sections.
5.1.1 Minimum Inspection Schedule for active sites
The minimum inspection schedule applies to those sites under active construction, which includes the period
from when the ground is initially disturbed to when construction activity is completed, and also includes the
preparation of areas that will be revegetated for interim reclamation. During the Active Site period, a thorough
inspection of the site stormwater management system (which includes all utilized BMPs) must be conducted at
least every 14 calendar days. Also, post -storm event inspections must be conducted within 24 hours after the
end of any precipitation or snowmelt event that causes surface erosion,
There are three exceptions to the minimum inspection schedule which are described in detail within the next
three sections: post -storm event inspections at temporarily idle sites (inspections required within 72 hours after
a storm), inspections at completed sites (inspections required monthly), and inspections during certain winter
conditions (inspections may not be required). Any use of an exception is temporary, and does not eliminate
the requirement to perform routine maintenance due to the effects of a storm event or other conditions that
may impact BMP performance, including maintaining vehicle tracking controls and removing sediment from
impervious areas.. Inspections, as described above, arc required at all other times.
5.1.2 Post -Storm Event Inspections at Temporarily Idle Sites
Temporarily idle sites are those where there are no construction activities occurring following a storm event.
At such sites, post -storm event inspections must be conducted prior to restarting construction activities at the
site, but no later than 72 hours following the storm event, and the delay noted in the inspection report. Routine
inspections still must be conducted at least every 14 calendar days.
5.1.3 Completed Sites
Once construction is completed and the site has been prepared for interim or final stabilization (including
completion of appropriate soil preparation, amendments and stabilization practices), the site (or portion of the
site) is considered a Completed Site (for purposes of the stormwater permit). Note: only construction activities
that result in a disturbance of the ground surface must be completed. Construction activities that can be
conducted without disturbance of the ground surface, such as certain well completion activities, would not
prohibit a site frorp otherwise qualifying as a Completed Site. (Completed Sites still require permit coverage
until the final stabilization criteria have been met)
Completed Sites qualify for a reduced inspection schedule, as the potential for pollution is reduced if the site
has been adequately prepared and/or seeded. However, because slopes and other disturbed areas may not
H.16ata9GOA's1Hvoter Mesa 24in Pipeline'vtttachnteM 5-1 . pdatad February 2408
39Mamm Creek SWMP 100% 421208,dactn
be fully vegetated, erosion in these areas still occurs which requires maintenance activities such as regrading
and seeding of problem areas. As such, inspections must continue in order to address these situations.
During the Completed Site period, a thorough inspection of the site stormwater management system (which
included all utilized BMPs) is required at least once every month. The SWMP must be amended to indicate
those areas that will be inspected at this reduced frequency.
5.1.4 Winter Conditions inspections Exclusion
Inspections are not required at sites where construction activities are temporarily halted, snow cover exists
over the entire site for an extended period, and melting conditions posing a risk of soil erosion do not exist.
Tills temporary exclusion is applicable only during the period where melting conditions do not exist, and
applies to the routine 14 -day and monthly inspections, as well as the post -storm -event inspections. It is typical
that when snow cover exists, even at a Completed Site, significant potential for erosion and BMP failure exists
when melting does finally occur, Therefore, the site should prepared prior to snow cover to ensure it is as
stabilized as possible, and be prepared to perform site maintenance when melt -off occurs, to alleviate any
potential problems. Inspection records (see Section 5.4) will document that winter conditions exist and that
inspections will be excluded.
5.2 Performing Inspections
Inspections will be conducted by qualified personnel on the following areas:
• All vegetated areas until 70% of pre -disturbance vegetation levels are reached.
• All BMP measures identified in this document.
• Construction site perimeter and discharge points,
• All disturbed areas.
• Areas used for storage of material/waste that are exposed to precipitation.
• Other areas determined to have a significant potential for stormwater pollution, such as demolition
areas or concrete washout locations, or locations where vehicles enter or exit the site,
These areas will be inspected to determine if there is evidence af, or the potential for, pollutants leaving the
construction site boundaries, entering the stormwater drainage system, or discharging to state waters. All
BMPs will be evaluated to determine if they still meet the design and operational criteria in the SWMP and if
they continue to adequately control pollutants at the site. Any BMPs not operating in accordance with
Appendix E of this SWMP will be addressed as soon as possible, immediately in most cases, to minimize the
discharge of pollutants, and the Site Specific Records will be updated.
5.3 Maintenance
Maintenance activities will ensure that all control measures are functioning at optimum levels and that all
procedures and techniques will be in proper working order during S runoff event or spill condition. Any
maintenance, repairs, or replacements deemed necessary after required inspections will be corrected as soon
as possible (if not immediately), to minimize the discharge of pollutants. Certain maintenance procedures may
take a short period of time to make sure that all the proper safety precautions are in place, such as a "one call"
for utilities, if the maintenance involves excavation of sediment located above a buried pipeline.
Maintenance will include, but is not limited to:
• Pickup or otherwise prevention of litter, construction debris, and construction chemicals from
becoming a pollutant source prior to anticipated storm events.
• Removal of sediment from silt fences, sediment traps, and other sediment contro Is.
H N}ata1COA'sWunter M¢sy tam PVpef eWttachment
\Hamm Creek SWMP 100./. 0212684ero
5-2
Uptlatutl February 2008
• Reseeding of any bare spots where vegetation has failed to establish.
• Repairs andlor adjustments to any erosion and sediment control that is deteriorating or found to be
performing inadequately.
Detailed maintenance requirements for each BMP are identified in Appendix E.
When maintenance s required, the following process will typically be followed:
1. Perform inspections according to the minimum inspection schedule discussed in Section 5.1.
2. Note the need for maintenance on the inspection and maintenance report form.
3. If necessary, collect the additional materials and/or resources needed to perform the maintenance
activity,
4. Perform maintenance and note the date performed an the inspection and maintenance report form
5. Re -inspect the area to ensure compliance,
5.4 Documenting Inspections and Maintenance
The permittee must document inspection results, maintenance activities, and maintain a record of the results
for a period of 3 years following expiration or inactivation of permit coverage. A typical inspection and
maintenance report form is provided in Appendix G. Although the site may have a phased construction
schedule, all construction areas may be inspected at the same time and on one form, Each well pad, road,
pipeline, or other facility which is inspected shall be clearly written on the inspection form. Inspection reports
will include the following:
• Date of inspection, name of inspector, and title of inspector
• The area inspected (Site ID), type of area (well pad, access road, pipeline, etc.), phase of construction
(preconstruction, construction, etc.), and type of inspection (active, completed, etc.)
• Site specific information including disturbed area, soil type(s), ecosystem/vegetation type(s), receiving
waters, etc.
• Vegetation observations including the percent pre -disturbance vegetation and whether or not
vegetation growth has reached 70% of pre -disturbance levels
• Specific inspection requirements (all BMPs and areas of potential pollutant sources)
• Observed conditions including:
— Location(s) of discharges of sediment or other pollutants from the site
- Location(s) of BMPs that need to be maintained
- Location(s) of BMPs that failed to operate as designed or proved inadequate for a particular
location
Location(s) where additional BMPs are needed that were not in place at the time of inspection
• Description and dale(s) of corrective action(s) taken, and measures taken to prevent future violations
• Changes necessary to the SWMP
A hand drawn Site Plan shall be included, if necessary, to show the location(s) of any observed condition (as
listed above).
H- CataICQA'sWunter Masa 24in PiaelineiAllactmenl
3iMamm Creek SWOP 100% 021208,do in
5-3
Updated February 2008
After adequate corrective action(s) has been taken and recorded, or where a report does not identify any
incidents requiring corrective action, the report will contain a signed statement indicating the site is in
compliance with the permit to the best of the signers knowledge and belief.
All completed inspection and maintenance report forms (a blank copy of which is included in Appendix G) are
kept with the Site Specific Records (Volume 2 of the Master SWMP).
H:DalalCOA's W unser Mesa 24m PipelirreNAttkehme l
311Mamm Creek SWMP 100% 021200.dacm
5-4
Updated February 2dde
6.0 Plan Revisions and Retention
When BMPs or site conditions change, the Master SWMP (Volume 1) and/or the Site Specific Records
(Volume 2) will be amended to accurately reflect the actual field conditions. Examples include, but are not
limited to, removal of BMPs, identification of new potential pollutant sources, addition of BMPs, modification of
BMP installation/implementation specifications or maintenance procedures, and changes in items included in
the Site Plans. Changes to the Master SWMP (Volume 1) shall be noted on the SWMP Revisions log at the
front of this plan. Changes to individual site conditions will be noted in the Site Specific Records (Volume 2) on
the applicable inspection and maintenance report form. All changes in Volume 1 and Volume 2 shall be made
prior to actual changes in the site conditions, except for responsive SWMP changes, which shall be made
immediately after changes are made in the field or as soon as practical, but in no case more than 72 hours
after the change(s) in BMP installation and/or implementation occur at the site that require development of
materials to modify the SWMP. At a minimum, the Master SWMP will be updated annually.
The Master SWMP and the Site Specific Records will be retained at the EnCana field office in Parachute
during active construction and site inspections to ensure accurate implementation and maintenance of BMPs,
and required revisions. These documents will be retained for a period of three years following final
stabilization of the Permit Coverage Area. These reports will be made available to WQCD or EPA upon
request and at the time of inspection.
HAIDalatCQA's 1anter Mesp 241n Plpeline\Attachmenl
3Vvlamm Creek SWMP 102% 021200,decm
6-1
Updated February 2000
7.0 Inactivation Notice
VVhen all disturbed areas associated with the Stormwater Construction Permit have reached "final stabilization"
(as described in Section 4), all temporary erosion and sediment control measures have been removed, and all
components of the SWMP are complete, the area no longer requires coverage under the permit terms. At that
time, EnCana will submit an Inactivation Notice that closes this permit to the WQCD upon final stabilization of
all areas covered by the permit. A blank copy of this form is included in Appendix H of this document.
Upon receipt of the Inactivation Notice, the WQCD will provide written confirmation that coverage under this
permit has been terminated. This historical documentation will be maintained at the EnCana field office in
Parachute for a period of at least three years following termination of permit coverage.
H'AData4CCcA's44umer Mese! 241n Pipe]int1Adachmenl
35Mamm Creek SWMP 100% 02120B,docin
7-1
L ptlaind February 2008
8.0 Signature
"1 certify under penalty of law that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gathered and
evaluated the information submitted. Based on my inquiry of the person or persons who manage the system,
or those persons directly responsible forgathering the information, the information submitted, to the best of my
knowledge and belief is true, accurate, and complete. t am aware that there are significant penalties for
submitting false information, including the possibility of fine and imprisonment or knowing violations,"
Printed name Title
Signature Date
Printed name Title
Signature Date
H DataSCQA's Wenler Mesa 24m P4pellneyaachmenl
3\Memel Creek SWMP 100% 02120d [lucre
8-1
Updated February 2000
9.0 References
CDPHE, 2007a. COPS General Permit, Authorization to Discharge under the Colorado Discharge Permit
System. Colorado Department of Public Health and Environment. Water Quality Control Division.
Issued May 31, 2007.
http:liwww,cdphe.state.co.uslwgtPermitsUnitistormwater/SWConstructionPermit.pdf
CDPHE, 2007b. General Permit Application and Stormwater Management Plan Preparation Guidance.
Colorado Department of Public Health and Environment. Water Quality Control Division. Revised
July, 2007. http:/ www.cdphe.state.co.us/wq/PermitsUnit/stormwater/SWConstructionApplication.pdf
CDPHE, 2007c. Rationale. Colorado Department of Public Health and Environment. Water Quality Control
Division. 2007.
http:l/www.cdphe.state.co.usiwq/PermitsUnitlstormwater/SWConstructionRatienale.pdf
CDPHE, 2007d. Stormwater Fact Sheet— Construction at Oil and Gas Facilities. Colorado Department of
Public Health and Environment. Water Quality Control Division. Revised July, 2007.
http:llwww.cd phe.state.co.uslwglPermitsUnit!stormwater/OGfactsheet.pdf
George, R.D. 1927. Geology and Natural Resources of Colorado. University of Colorado, Boulder, CO.
Mute!, C.F., and Emerick, J.C., 1992. From Grassland to Glacier - The Natural History of Colorado and the
Surrounding Region.
U.S. Department of Interior, Bureau of Land Management. 2004. Environmental Assessment of the Grass
Mesa Geographic Area Plan. EA# CO140-2004-081EA. Glenwood Springs Energy Office, Colorado.
Online version available at-
http://www.blm.govico/stienifoiesfo/OSFO MasterPlansofDeveiopment.print.htmi
U.S. Department of interior, Bureau of Land Management. 2005. Environmental Assessment of the Gant
Gulch Geographic Area Plan. EA# C0140-2005-134EA. Glenwood Springs Energy Office, Colorado,
Online version available at:
http:llwww.blm.govico/st/en/fo/gsfo/G5FO MasterPlansOfDevelopment.printhtml
USEPA, 1990. NPDES Stormwater Regulations, 40 CFR Parts 122.26. U.S. Environmental Protection
Agency.
VVeiner, R.J., J.D. Haun. 1960. Guide to the Geology of Colorado. Geological Society of America.
H;lpatalC(ek'slHunler Meso 24in P,pehpelP..tlachmenl
3lMamm Creek SWMP 100 02120e.doGn
9-1
Updated February 200e
General Permit Application
Revegetation Manual
Existing Soil and Vegetation Data
Appendix D
Master SWMP Permit Area Map
Updated February 2008
W
eL
Stormwater Manual of Best Management Practices (BMPs)
I Formatted: Space Before: 0 pt
Final Stabilization Certification
Updat d February 200H
Inspection and Maintenance Report Form
Inactivation Form
Upd l,led February 2008
encanam
natural gas
October 27, 2011
Fred Jarman
Director, Garfield County Building and Planning Department
109 8th Street, Suite 401
Glenwood Springs, CO 81601
Re: Rifle 24" Special Use Permit (reference Resolution 2003-59)
Dear Mr. Jarman:
Encana Oil & Gas (USA) Inc. (Encana) has transferred the above -referenced pipeline to Grand River
Gathering, LLC (Grand River). Encana requests that the Rifle 24" Special Use Permit (reference
Resolution 2003-59) and any future correspondence be transferred and directed to Grand River effective
October 27, 2011.
As existing permittee, I hereby agree to the transfer of the above -referenced permit and al I responsibilities
thereof.
eit/V6 21A
Brenda R. Linster
Regulatory Advisor
I hereby accept transfer of the above -referenced permit and have reviewed the terms and conditions of
this permit and accept full responsibility, coverage, and liability. Please direct any future correspondence
regarding this permit to Mike Rose, Director—Engineering and Operations, Grand River Gathering, LLC,
2100 McKinney Avenue, Suite 1250, Dallas, TX 75201 (0 214-242-1964. I request the transfer be
effective on October 27, 2011.
Steve Newby
President
Grand River Gathering, LLC
2100 McKinney Avenue, Suite 1250
Dallas, TX 75201
Encana Oil & Gas (USA) Inc.
Republic Plaza
370 —17 Street, Suite 1700
Denver, Colorado
United States 80202
t 720.876.3989
f 720.876.4989
e brenda.linster@encana.com