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HomeMy WebLinkAbout21 LUMA CommentsLUMA SITE VISIT COMMENTS O\OLSSON ASSOCIATES THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. O\OLSSON ASSOCIATES Battlement Mesa PUD Phase II LUMA Consultation Comment Response Page 1 of 5 LUMA Consultation Comments Ursa Response Morgan Hill, Garfield County, Environmental Specialist MH 1 The A Pad should utilize extensive best management practices to prevent any spills from either the natural gas production wells or the injection well from entering groundwater or running into the river, regardless of if the A Pad is below Battlement Mesa's drinking water intake. A bentonite clay layer should be installed at the pad as a tertiary containment for spill protection. Ursa does not proposed to line the entire pad with bentonite as all production tanks and injection tanks will be placed inside a secondary lined containment ring. Pad construction by design is planned in a manner to not trap storm water, but to provide opportunities to trap sediment and release water. The main sediment/stormwater trap will act as tertiary containment in the event of a catastrophic spill that escapes primary containment, secondary containment and travels across the entire pad and enters into our stormwater controls. MH 2 Alternatives to the M pad should be examined to eliminate the need for this pad. It is very close to homes, the bike path, and golf course, and would disrupt a wetland. As discussed with County Staff, should all Phase II applications receive approval, the BMC M pad will not be required for full development of the area and would be removed from Ursa's plans. MH 3 In their application, I would like to see Ursa include an analysis of the proximity of the L Pad to both the neighborhood to the northeast of the pad and the church/preschool that is just across the road and discuss the optimal locations for their equipment and tank locations on the pad to minimize impacts. Public Health is happy to provide wind rose data to assist with this decision making. Please refer to Siting Rationale and Alternatives Analysis provided with the application documents. Ursa has been able to site the pad so all wells and production equipment maintains a >1000' setback from the homes to the north and from the church to the east. Kent Kuster, CDPHE, Environmental Protection Specialist KK 1 I only observation from the URSA site visits last week concerned the location of the production facilities on the BMC L pad. I recommended that URSA consider moving the production facilities to the north side of the well pad as far as possible away from the Church/Daycare. It is my understanding that URSA has looked into this recommendation and are make the appropriate changes. Production tanks have been relocated to the north side of the pad location as depicted on the site plans provided with the application. Steve Anthony, Garfield County, Vegetation Manager SA 1 An Integrated Vegetation and Management Plan to include: Noxious weed survey was completed for BM PUD Phase II project areas September 12-14, 2016. Please • A noxious weed survey, inventory and map of Garfield County Listed noxious weeds. • A management plan of inventoried noxious weeds. refer to the weed management plan attached to the application. SA 2 • Best management practices that include: Ursa will adopt these measures as BMPs. o Prior to delivery to site, equipment should be cleaned of soils and other materials remaining from previous construction sites. o Equipment and material handling should be done on established sites to reduce the area and extent of soil compaction. o Temporary disturbance should be kept to a minimum. o Live topsoil handling. o Use only weed free straw or mulch and weed -free wattles for sediment retention work. SA 3 • A reclamation & revegetation plan that includes: o A site specific plan. Please refer to reclamation plan included in application materials. o Plant materials list to include scientific and common name. o Seeding rates in terms of Pure Live Seed/acre. o Planting schedule which includes timing, methods and mulching. SA 4 Also please follow best management practices that will address: • Site stability - The reclaimed areas shall be stable and exhibit none of the following: o Large rills and gullies. Please refer to reclamation plan included in application materials. o Perceptible soil movement or head -cutting in drainages. o Slope instability on or adjacent to the reclaimed area. o Slopes shall be stabilized using appropriate reshaping and earthwork measures, including proper placement of soils and materials. SA 5 • Soil management o Topsoil management shall be salvaged from areas to be disturbed and managed for later use In reclamation. Please refer to reclamation plan included in application materials. Page 1 of 5 Battlement Mesa PUD Phase II LUMA Consultation Comment Response Page 2 of 5 LUMA Consultation Comments Ursa Response o Erosion prevention Please refer to reclamation plan included in application materials. SA 6 • Soil surface must be stable and have adequate surface roughness to reduce run- off, capture rainfall and snow melt, and allow for revegetation. Ursa will comply - see SWMP for details SA 7 • Soil conservation measures shall be utilized. SA 8 • Sediment retention structures or devices shall be located as close to the source of the sediment -generating activities as possible to increase their effectiveness and reduce environmental impacts. In regards to Location A, (would encourage you to seek comments, if you haven't yet, from the Division of Colorado Parks & Wildlife on the following issues: SA 9 •Does CPW have any concerns about the location of that pad impacting the migration corridor of wildlife from Monument Gulch down to the river bottom and the cottonwood forest? CPW Consultation for Phase II pads discussed with CPW. All mitigation efforts agreed to between Ursa (Antero) and CPW for the Battlement Mesa area have been completed including mitigation feed plots and mitigation subsidies. No additional concerns from CPW to be addressed. Raptor survey completed for Phase II pads and pipeline routes September 12-14, 2016, no NSO or RSO stipulations, no high-quality habitat or occupied raptor nests anticipated to be impacted by development. Please refer to Biological Impact analysis for additional information. SA 10 • Are they concerned about impacts of the pad to mule deer and elk winter range in the same area? SA 11 • Do they feel a raptor survey is necessary in the old growth cottonwood forest? Greg Deranleau, COGCC, Environmental Manager L Pad GD 1 Pad design is focused on visual mitigation and appears to have effectively addressed this with siting and cut/fill design. Correct. GD 2 Access road will require a left turn to exit the site, requiring a cut through the center median. Traffic issues including volume, haul routes, and entry/egress hazards should be addressed by the county. Traffic study analysis provided in Phase II application documents. GD 3 The access road layout comes very close to the drainage to the west. This drainage will need to be adequately protected from runoff and sedimentation from the road. Gas gathering pipelines and water flowlines will follow the access road to the pad. With the relocation of the pad to the North ^'115', the access road has also been moved away from the drainage. Any other drainage concerns will be mitigated as necessary according to our site specific stormwater plan. GD 4 Site is situated approximately equidistant between residences to the northeast and a church to the southwest. The church may have a licensed operating day care. If so, the day care facility needs to be evaluated to determine if it meets the COGCC definition for a High Occupancy Building Unit. If so, this location would require a hearing before the Commission for approval. L pad location shifted north' 115' to maintain >1000' from homes and HOBU (Church), no hearing is required. GD 5 Based on the premise that the church does include a day care facility, CDPHE recommended that the operator consider moving the production storage tanks (potential emission source) across the southern edge of the pad to the eastern corner, approximately 400' farther from the day care. That puts them closer to the homes, but likely still beyond 1,000'. COGCC supports this consideration. Production tanks were moved to the north side of the pad. Please refer to site plans included with the Phase II submittal. GD 6 There is a subtle drainage cutting through the pad site; stormwater flow which would normally flow through this drainage feature will need to be addressed during construction of the access road and pad. With the relocation of the pad to the North ^'115', the access road has also been moved away from the drainage. Any other drainage concerns will be mitigated as necessary according to our site specific stormwater plan. GD 7 The site design calls for a temporary completions area on the fill (downhill) side of the pad. COGCC will expect that sufficiently engineered secondary containment will be included in the final site design to accommodate 150% capacity of the largest single vessel within the containment and that the containment will be constructed with an impermeable liner material. COGCC will expect that operator will employ best management practices proven to reduce odors and emissions during flowback to these tanks. Secondary containment for temporary completion tanks (i.e.frac tanks) will be designed to accommodate 150% of the largest tank within the berm. Ursa plans to employ green completion and flowback techniques. GD 8 It was explained that the L -Pad was relocated from farther north, down the hill and nearer the golf course and neighborhoods. The proposed location is more desireable for a number of reasons: farther from residences, much better visual mitigation, farther from valued community recreational area, desired by surface owner, better access, ability to consolidate more wells on fewer pads, etc. Correct. Since the site visit, the pad has shifted slightly further north to maintain >1000' setbacks from all homes / HOBU in the area. Page 2 of 5 Battlement Mesa PUD Phase II LUMA Consultation Comment Response Page 3 of 5 LUMA Consultation Comments Ursa Response F Pad GD 9 Although not a LUMAF pad, the group reviewed this site, as part of Phase 2 proposal. Correct. GD 10 This site is proposed on a ridge between 2 significant drainages which flow down toward the community and the Colorado River. Correct. GD 11 The site is proposed as a temporary site (3 — 5 years) for the handling of produced water and flowback for reuse and recycling purposes. Based on the use, the operator must consider the application of Rule 908 for Centralized E&P Waste Management Facilities. Ursa commits to a 3 year timeframe from first use to decommissioning therefore Ursa does not anticpate a need for a Form 28. GD 12 The site is proposed with 100 500 -barrel frac tanks in four separate secondary containment batteries. Each battery is proposed to have secondary containment capable of holding 150% of the maximum tank size within the containment. The secondary containment should be designed to be structurally sufficient and be lined with an impermeable liner material. Black base will be used for areas where tanks will be placed to help alleviate permeability into soil should a leak occur. Secondary containment will be constructed of an earthen berm and will be designed to accommodate 150% of the volume of the largest tank within the berm. GD 13 Emissions controls and odor controls will need to be part of the site design for this facility. Ursa will utilize carbon fiber blankets on hatches. Due to the temporary nature of the site/operations, emission controls are not planned as the tanks are not designed to hold pressure. GD 14 Although low probability, a significant spill going off site would be a high consequence event, therefore, this site should be regarded as high risk. Noted. As a BMP, this facility will be manned 24 hours a day while in use (transferring or receiving water) GD 15 Rigorous flowline design, installation, operations, and monitoring is necessary. Flowlines will be tested after installation, prior to first use. Subsequent flowline testing will be completed in accordance with COGCC 1100 series rules and COAs as applicable. A Pad GD 16 The A Pad is situated in a narrow portion of land between the bluff and the Metro Water and Wastewater District Treatment Plant. The A Pad is proposed to include production wells and equipment and 1 UIC well and associated tanks. Correct. GD 17Correct. The pad is located in an area that is down gradient from the PWS treatment system and surface flow from this site is to the west and to the Colorado River at a point well downstream from the PWS intake. GD 18 The pad design requires significant cuts into the bluff upon which numerous trailer homes are sited. A geotechnical investigation will be necessary to demonstrate that the pad can be designed and built without compromising the integrity of the hillside, and the safety and stability of the trailer homes. Please refer to detailed site plans and geotechnical report. GD 19 The A Pad is located very close to 500' from Building Units. The operator could not confirm that the Location is designed outside the Exception Zone. If the proposed Location is an Exception Zone Designated Setback Location and within an Urban Mitigation Area, then wiavers will need to be obtained from Building Unit owners. Since the Building Units are somewhat mobile in nature, operator should communicate with Building Unit owners, trailer pad site owners, and tenants/occupants. The production facilities planned for the BMC A pad fall within 500' of the mobile home park. Ursa has met with several owners and tennants within the development and has obtained exception zone setback waivers from applicable mobile home owners that fall within the 500' exception zone setback. GD 20 If sufficient geotechnical engineering can be done to stabilize the cut slopes and the integrity of the bluff, this could be a very good location, with visual mitigation maximized and disturbance minimized. It places the UIC well down gradient from the PWS system which is an important consideration. COGCC is supportive of locating the UIC well at the A Pad. Please refer to detailed site plans and geotechnical report for slope stabilization details. GD 21 The topographic relief provided by the steep hillside will provide noise mitigation and with prevailing winds should also help with preventing odors from affecting the nearest residents. Correct. GD 22 Due to the geotechnical challenges of this site, an alternative might be to shift it toward the flat area currently owned by the water/wastewater district. This was described as an administrative challenge, but does not seem insurmountable, and may be a better alternative than significant cuts into the hillside. Please refer to the alternatives analysis provided with the application. Shifting the pad toward the Metro district property would encroach upon existing easements and property lines and would move the pad location closer to the Colorado River. Additionally, natural visual mitigation being provided by the hillside would be less effective. GD 23 This site should be considered individually with respect to wildlife. Due to the water/wastewater district property fence, the area of this pad could be a corridor for deer to access the river area. Additionally large trees along the river could be roosting areas or nesting sites for raptors, and the proposed pad encroaches on or is immediately adjacent to a mapped bald eagle roost buffer. CPW consultation complete, no issues or futher mitigation required. Page 3 of 5 Battlement Mesa PUD Phase II LUMA Consultation Comment Response Page 4 of 5 LUMA Consultation Comments Ursa Response GD 24 The area of this pad appears to have a high runon potential due to its placement at the foot of the bluff and adjacent to the water/wastewater district property. An incised drainage was observed running east to west along the northern edge of the proposed site. Flow through this drainage must be addressed by the site design and engineering. Please refer to detailed site plans and stormwater management plan included with this application. M Pad GD 25 1. Design considerations described in the proposed L Pad and A Pad have allowed Ursa to remove the M Pad from its future operations plans. Correct. GD 26 2. COGCC is supportive of the elimination of this pad. It is situated in an undesirable location that would be unnecessarily intrusive into the community. Noted. Additional General Comments GD 27 1. To avoid future uncertainty with respect to pipeline construction, COGCC would recommend that Ursa initiate activities on their Oil and Gas Location before other entities are granted access. These sites should be considered Oil and Gas Locations from the moment ground is disturbed for any oil and gas related activity. Ursa (or their successors in interest) should maintain primary responsibility for the Oil and Gas Locations until production operations have ceased and the sites meet COGCC requirements for final reclamation. Noted. GD 28 2. Although not explicitly required by Rule, as a Best Management Practice (BMP) to protect topsoil, COGCC would suggest that Ursa propose a program to evaluate the topsoil thickness and horizons prior to commencing operations with heavy equipment. This could be hand dug test holes, test holes dug with a backhoe or similar equipment, or shallow soil borings. This information would allow Ursa to optimize their efforts at topsoil protection and minimize the amount of subsoil removed. Ursa employs qualified dirt contractors who are able to determine topsoil thickness easily during construction. Glenn Hartmann, Garfield County, Senior Planner Well Pad 1: GH 1 Visual buffering of the site was discussed including topography and existing vegetation. The Applicant indicated buffering for the site would include transplanting if possible of existing trees/shrubs and reuse for landscape buffers. Correct. GH 2 Applicant indicated that distance from the well pad corner to the Church / Daycare south of the site was approximately 920 ft. Since the site visit, the L pad location has been shifted to the North ^'115'. The church (HOBU) now falls >1000' from the wells and prodcution facilities. GH 3 Applicant indicated that they would use low profile 300 bbl tanks on the site with a height of approximately 12 ft. Low profile tanks planned to be utilized on this location are 15.5' diameter and 9' height GH 4 Access to the site would require a cut in the existing median on Spencer Parkway. Correct. Ursa working with GarCo road and bridge to obtain necessary approvals. GH 5 They estimated that the pad would have an approximately 12 ft. cut on the south side of the pad. Cut at south side of pad is approx. loft at new pad location GH 6 The group discussed the need for extra attention to stormwater Management on the west side of the site nearest to an existing/significant drainage gulch. With the relocation of the pad to the North ^'115', the access road has also been moved away from the drainage. Any other drainage concerns will be mitigated as necessary according to our site specific stormwater plan. GH 7 The group discussed shifting the tank storage to the NE corner of the pad away from the Church on the south side of Spencer Parkway. The Applicant discussed the need to review distances to residences if the tanks are shifted. Production tanks were moved to the north side of the pad. Please refer to site plans included with the Phase II submittal. GH 8 Adjacent existing and future land uses were discussed. A map of adjacent zoning and the potential for future development including housing should be provided and reviewed. Information included with county application submittals (please refer to project narratives for additional information) F Pad Temporary Water Storage: GH 9 The temporary time frame was described as 3 —5 years. Ursa commits to a 3 year timeframe from first use to beginning decommissioning and site reclamation. GH 10 Methods for minimizing any vapors from the tanks were discussed including "hydro carbon blankets" and combustion options. Ursa will utilize carbon fiber blankets on hatches. Due to the temporary nature of the site/operations, emission controls are not planned as the tanks are not designed to hold pressure. GH 11 The site was anticipated to have a 14' 6" cut and 6' of fill to create the level pad. Correct. Page 4 of 5 Battlement Mesa PUD Phase II LUMA Consultation Comment Response Page 5 of 5 LUMA Consultation Comments Ursa Response GH 12 Stormwater and spill containment was discussed. Berms on the site are proposed and valve separation techniques. Correct. GH 13 The Applicant generally represented that containment for 150% of one complete tank failure would be provided. Additional information on containment and volumes needs to be provided. Correct. Please refer to application documents for additional information on containment and volumes. Well Pad A: GH 14 The Applicant described the location set into the adjacent hillside with an estimated cut of approximately 27'. Fill on the downslope side was estimated at 16'. Correct. GH 15 Slope stability was discussed and it was indicated that a geotechnical analysis was either being completed or would be completed. Geotechnical report included with Phase 11 application submittal documents. GH 16 The Applicant indicated that two sets of tanks were anticipate on the site for a total storage of 3,600 bbls. Correct. 1 production tank battery and 1 injection tank battery. GH 17 The Applicant indicated that they would utilize low profile tanks on this site also. Correct. GH 18 Drainage from the site was discussed and it's location generally down slope and down gradient from adjacent facilities including the water system treatment and intake and the waste water treatment facilities. Correct. GH 19 The Applicant indicated that the water intake was approximately 2,200 ft. from the well pad and the pad was also approximately 2,000 ft. from the Colorado River. Correct. GH 20 The distance from the Metro District Settling Pond was noted. No concerns regarding the proximity to the settling pond were noted by those attending the site visit. Noted. GH 21 Potential off site drainage from the Pad downstream toward the Colorado River was discussed and the potential inclusion of settling ponds or sediment traps in the Stormwater drainage plans for the site. Please refer to the stormwater plan included with Phase 11 application documents. GH 22 Proximity to the mobile home residences on the mesa above the pad was discussed. Noted. GH 23 Questions were asked of the Applicant regarding any wildlife issues and the potential for Cottonwood Trees northwest of the Pad to be roosting trees. Noted. GH 24 Visual impacts were noted as being mitigated by the slopes between the pad and the residences to the south. Noted. GH 25 Noise mitigation was discussed. Noted. GH 26 The Applicant indicated that BMP would be used on this site consistent with the Well Pad B. Correct. Well Pad M: GH 27 Discussion covered the potential location and benefits associated with eliminating the need for the pad. Correct. GH 28 Proximity to the drainage swale/stream was noted. Noted. Page 5 of 5