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year 2024. Diesel vehicle miles for various project activities have also been estimated (see
Table 3).
Table 1
Pre-Production Pollutant Emissions (tons) for the South Leverich 13-09 OGDP
Component NOx CO VOCs CH4 C2H6 CO2 N2O
Process Heaters or Boilers 0.56 0.47 0.03 0.01 0.02 676.77 0.01
Storage Tanks 0.00 0.00 0.00 0.00 0.00 1.04 0.00
Venting or Blowdowns - - - - - - -
Combustion Control Devices - - - - - - -
Non-road Internal
Combustion Engines 170.87 141.16 7.51 38.28 3.12 15,898.15 0.00
Drill Mud - - 1.55 -- - - -
Flowback or Completions 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Loadout 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total Emissions 171.43 141.63 9.09 38.29 3.14 16,575.96 0.01
Table 2
One Year Production Pollutant Emissions (tons) for the South Leverich 13-09 OGDP
Component NOx CO VOCs CH4 C2H6 CO2 N2O
Stationary Engines or
Turbines - - - - - - -
Process Heaters or Boilers 1.53 1.29 0.08 0.04 0.05 1,835.74 0.00
Storage Tanks 1.77 8.07 8.82 8.21 3.98 2,186.96 0.06
Dehydration Units - - - - - - -
Pneumatic Pumps - - - - - - -
Pneumatic Controllers - - 1.26 8.38 1.14 0.02 -
Separators - - - - - - -
Fugitives - - 0.17 1.12 0.15 0.00 -
Venting or Blowdown - - - - - - -
Combustion Control Devices - - - - - - -
Non-Road Internal
Combustion Engines - - - - - - -
Loadout 0.06 0.25 0.21 0.19 0.09 68.26 0.00
Well Bradenhead - - - - - - -
Well Maintenance - - 0.57 3.78 0.52 0.01 -
Total Emissions 3.36 9.61 11.11 21.72 5.93 4,090.99 0.06
Table 3
Diesel Vehicle Miles for the South Leverich 13-09 OGDP
Activity Miles
Construction 207
Drilling 1,455
Completion 1,812
Interim reclamation 22
Production (1st year only) 135
Total 3,631
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The total criteria pollutant emissions (NOx, CO, and VOCs) for the South Leverich 13-09 OGDP
pre-production and production activities are estimated as: 174.8, 151.2, and 20.2 tons per year
(tpy), respectively. Project emissions of the greenhouse gases CO2, CH4, and N2O from pre-
production and production activities are quantified in terms of CO2 equivalents (CO2e). GHGs
have various capacities to trap heat in the atmosphere, which are known as global warming
potentials (GWPs). GWPs are related to different time intervals to fully account for the gases’
ability to absorb infrared radiation (heat) over their atmospheric lifetimes. Carbon dioxide has a
GWP of 1, so for the purposes of the analysis, a GHG GWP is generally standardized to a
CO2e, or the equivalent amount of CO2 mass the GHG would represent. Methane has a current
estimated GWP between 28 (gas alone) and 36 (with climate feedbacks). N2O has a GWP of
298. The total pre-production and production GHG emissions (sum of CH4, CO2, and N2O
emissions reported as CO2e in units of million metric tons [MMT]) are estimated as 0.02 MMT.
The BLM developed an Environmental Assessment (EA) for the Upper Beaver Creek Project
(BLM, 2022a). As part of the air quality assessment performed for the EA, an air emissions
inventory was compiled that included the proposed development of 18 wells on the Honea 19-
05 well pad, and 21 wells on the South Leverich 13-09 well pad. The emissions inventory
includes criteria pollutant emissions (NOx, CO, and VOCs) and greenhouse emissions (CO 2,
CH4, and N2O) from pre-production and production activities. Air quality modeling was
performed using project NOx emissions to estimate 1-hour NO2 concentrations at nearby
residences in the vicinity of the well pads. Model impacts were estimated to be below the
National Ambient Air Quality Standards (NAAQS) and Colorado Ambient Air Quality Standards
(CAAQS). Also, as part of the air assessment, the Colorado Air Resource Management
Modeling Study – version 2.0 (CARMMS) (BLM, 2017a) was used to estimate reasonably
foreseeable future near-field air quality conditions for the area surrounding the proposed project.
The CARMMS analysis included cumulative air emissions for year 2015 and future year
emissions of NOx and VOCs from increased total (Federal and non-Federal) oil and gas
development/operations through year 2025 (post-2015) in the area surrounding the proposed
project, which includes the South Leverich 13-09 OGDP NOx and VOC emissions.
CARMMS analysis predicted that the contributions to cumulative air quality from Federal
project-specific maximum potential annual emissions (full development plus one full year of
production occurring in the same year) would be below applicable project-level Significant
Impact Levels (SILs) for 1-hour ozone and 1-hour NO2 concentrations, and that NO2 1-hour and
annual concentrations and ozone 1-hour concentrations are expected to be below the NAAQS
and CAAQS.
In addition, as part of air quality assessment performed for a BLM EA of a similar nearby TEP
project for the Proposed Balzac Gulch – Phase I Oil and Gas Master Development Plan Project
(Balzac Gulch EA) (BLM 2017b), CO and NOx emissions from pre-production and production
operations were quantified. The total CO and NOx emissions, 92.3 and 131.2 tpy respectively,
are of similar magnitude to the level of project emissions presented above (CO – 151.2 tpy and
NOx – 174.8 tpy).
Air quality modeling was performed to estimate near-field impacts of CO and NO2
concentrations from project activities. Predicted CO and NO2 concentrations were estimated to
be below the applicable NAAQS and CAAQS.
Therefore, based on the analyses performed for the Upper Beaver Creek and Balzac Gulch
projects, it is estimated that the CO and NOx emissions resulting from the expansion of the
South Leverich 13-09 and drilling of 21 natural gas wells from the well pad would not cause or
contribute to any exceedance of the CO and NO2 ambient air quality standards.
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Cumulative Impacts
The BLM Colorado State Office air resource specialists prepared an Annual Report (Version
2.0) as a comprehensive assessment tool to assist in the preparation of project level NEPA for
oil and gas development projects (BLM 2022b). The Annual Report 2.0 provides up-to-date
information on oil and gas development (current regulations, rates for drilling and production,
emission inventories, etc.) and the state of the atmosphere (air pollutant concentration trends,
air quality related values, etc.) for each applicable Colorado field office or planning area. The
report also places this information in the context of the CARMMS, which provides cumulative
analyses for multiple projected oil and gas development scenarios in Colorado through year
2025 for CARMMS 2.0 (BLM 2017a).
Section 4.1 of the BLM Annual Report presents data for cumulative emissions from new Federal
oil and gas development within the BLM Colorado River Valley Field Office (CRFVO) as
compared to the emissions scenarios analyzed by CARMMS and qualitatively scales the
CARMMS projected impacts to the cumulative report year emissions (year 2020) to provide a
context for the current cumulative impacts. This section is referenced to set the context for the
project’s current cumulative impacts at field office scales. As described in the BLM Annual
Report, CRFVO specific contributions to cumulative air quality concentrations and air quality
related values (visibility, deposition, etc.) for sensitive areas around the region (with the
exception of the Eagles Nest and Flat Tops Wilderness Areas) are predicted to be minimal and
insignificant with respect to accepted impact thresholds for new foreseeable Federal oil and gas
development post-2015 through year 2025. However, the report year (2020) data indicates that
the nitrogen deposition impacts are exceeding the project level deposition analysis threshold
(DAT) (0.005 kilogram per hectare per year [kg/ha-yr]) at the Eagles Nest Wilderness, and also
at the Flat Tops Wilderness Area (0.008 kg/ha-yr).
No adverse project impacts to air resources are anticipated as a result of construction (short-
term) and production (long-term) operations for the South Leverich 13-09 OGDP. Adverse
cumulative impacts are not expected as a result of project implementation.
Specific Measures Taken to Avoid or Minimize Cumulative Adverse Impacts
Implementation of BMPs and the Dust Mitigation Plan provided in the Form 2A, as well as the
implementation of an Air Monitoring Program as required by CDPHE avoids and minimizes
project impacts to air resources and therefore, no adverse cumulative impacts are expected.
Measures to Mitigate or Offset Cumulative Adverse Impacts
As mentioned above, no project or cumulative adverse impacts to air resources are anticipated
from the development of the South Leverich 13-09 OGDP and therefore, no mitigation or offsets
are proposed.
Public Health
A quantitative evaluation of the incremental increase in total hazardous air pollutant (HAPs)
emissions (benzene, toluene, ethylbenzene, xylene, 2,2,4-trimethylpentane, hydrogen sulfide,
formaldehyde, and methanol) and for specific HAPs emissions with known health impacts were
estimated for the entire proposed development plan for the South Leverich 13-09 OGDP. The
emissions estimate includes both stationary and mobile sources of emissions during all pre-
production activities (see Table 4) and both stationary and mobile sources of emissions for the
first year of production based on all proposed wells and equipment (see Table 5). The estimated
number of vehicle trips is listed in Table 6.
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Table 4
Pre-Production Hazardous Air Pollutants Emissions (lbs) for the South Leverich 13-09 OGDP
Component Benzene Toluene
Ethyl
benzene Xylenes n-Hexane
2,2,4-
Trimethylp
entane
Hydrogen
sulfide Formaldehyde Methanol
Total
HAPs
Process Heaters or Boilers - - - - - - - 0.85 - 0.85
Storage Tanks 0.08 - - - 0.09 - - - - 0.17
Venting or Blowdowns - - - - - - - - - -
Combustion Control
Devices - - - - - - - - - -
Non-road Internal
Combustion Engines 261 121 7 60 68 - - 3,561 - 4,078
Drill Mud - 112 152 6 112 - - - 112 494
Flowback or Completions - - - - - - - - - -
Loadout - - - - - - - - - -
Total Emissions 261.08 233.00 159.00 66.00 180.09 0 0 3,561.95 112.00 4,573.00
Table 5
One Year Production Hazardous Air Pollutants Emissions (lbs) for the South Leverich 13-09 OGDP
Component Benzene Toluene
Ethyl
benzene Xylenes n-Hexane
2,2,4-
Trimethylp
entane
Hydrogen
sulfide Formaldehyde Methanol
Total
HAPs
Stationary Engines or
Turbines - - - - - - - - - -
Process Heaters or Boilers - - - - - - - 2 - 2
Condensate Tanks 86 - - - 362 - - 448
Produced Water Tanks 3 - - - 3 - - 6
Dehydration Units - - - - - - - - - -
Pneumatic Pumps - - - - - - - - -
Pneumatic Controllers 13 20 0 9 83 9 - - - 134
Separators - - - - - - - -
Fugitives 2 5 7
Venting or Blowdowns - - - -- - - - - - -
Combustion Control
Devices - - - - - - - - - -
Non-Road Internal
Combustion Engines - - - - - - - - - -
Loadout 1 - - - 7 - - - - 8
Well Bradenhead - - - - - - - - - -
Well Maintenance 6 9 4 38 4 - - - 61
Total Emissions 111.00 29.00 0 13.00 498.00 13.00 0 2.00 0 666.00
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Table 6
Estimate Number of Vehicle Trips for the South Leverich 13-09 OGDP
Activity
Vehicle Trips
(monthly)
Vehicle Trips
(annually)
Construction 199 399
Drilling 577 2,329
Completion 221 1,546
Interim reclamation 77 77
Production 38 454
Qualitative Evaluation of Potential Acute or Chronic, Short- or Long-Term Incremental Impacts
Pre-Production. The EA developed for the Upper Beaver Creek Project included an emissions
inventory of total HAPs (2.85 tpy) from pre-production activities for the proposed development of
18 wells on the Honea 19-05 well pad, and 21 wells on the South Leverich 13-09 well pad, as
compared to the total HAPs pre-production emissions (2.29 tpy) prepared specifically for the
South Leverich 13-09 well pad as shown above in Table 4. However, no HAP impact analyses
were performed for the EA.
As part of an air quality assessment performed for the Balzac Gulch EA (BLM 2017b), individual
HAP emissions from pre-production operations were quantified. The total HAPs emissions, 0.20
tpy include benzene, toluene, ethylbenzene, xylenes, n-hexane, and formaldehyde emissions of
0.08, 0.04, 0.0005, 0.02, 0.04, and 0.007 tpy, respectively. These HAP emissions are of similar
magnitude to the level of project pre-production HAP emissions (benzene, toluene,
ethylbenzene, xylenes, n-hexane, and formaldehyde) presented above (0.13, 0.12, 0.08, 0.03,
0.09, and 1.78 tpy, respectively).
Impacts from pre-production HAP emissions were not estimated or analyzed as part of the
Balzac Gulch EA (BLM 2017b) given that the emissions from pre-production activities are from
short-term activities and do not occur over the lifetime of the project. Also, these HAP emissions
are less than those which could occur from production activities. As part of the Balzac Gulch EA
(BLM 2017b) impacts from production HAP (benzene, toluene, ethylbenzene, xylenes, n-
hexane, and formaldehyde) emissions in the vicinity of the well pads were analyzed and the
potential maximum acute (short-term; 1-hour) and long-term (annual) HAP concentrations were
estimated to be well below applicable health thresholds for these HAPs. Therefore, it is
estimated the HAP emissions resulting from the reconstruction of the South Leverich 13-09 well
pad and drilling of 21 natural gas wells would not cause or contribute to any potential acute or
chronic, short-or long-term incremental impacts to public health.
2,2,4-trimethylpentane, hydrogen sulfide, and methanol HAP emissions from pre-production
activities were estimated and are shown in Table 4. These emissions are estimated as 0.0, 0.0,
and 0.06 tpy, respectively. Although these HAPs were not specifically modeled in the BLM 2017
study, the emissions levels are less than the project benzene emissions (which were modeled).
Given that the applicable short-term; 1-hour) and long-term (annual) health thresholds for these
HAPs are above the levels applicable to benzene it is estimated the short-term and long-term
concentrations for these HAPs would be well below applicable health thresholds.
Production. The EA developed for the Upper Beaver Creek Project included an emissions
inventory of total HAPs (1.67 tpy) from production activities for the proposed development of 18
wells on the Honea 19-05 well pad, and 21 wells on the South Leverich 13-09 well pad, as
compared to the total HAPs production emissions (0.33 tpy) prepared specifically for the South
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Leverich 13-09 well pad as shown above in Table 5. However, no HAP impact analyses were
performed for the EA.
As part of an air quality assessment performed for the Balzac Gulch EA (BLM 2017b), individual
HAP emissions from production operations were quantified. The total HAPs emissions, 1.01 tpy
include benzene, toluene, ethylbenzene, xylenes, n-hexane, and formaldehyde emissions of
0.16, 0.23, 0.01, 0.09, 0.48, and 0.04 tpy, respectively. These HAP emissions are of similar
magnitude to the level of project production HAP emissions (benzene, toluene, ethylbenzene,
xylenes, n-hexane, and formaldehyde) presented above (0.06, 0.01, 0.0, 0.01, 0.2, and 0.001
tpy, respectively).
As part of the Balzac Gulch EA (BLM 2017b) , impacts from production HAP emissions
(benzene, toluene, ethylbenzene, xylenes, n-hexane, and formaldehyde) in the vicinity of the
well pads were analyzed and the potential maximum acute (short-term; 1-hour) and long-term
(annual) HAP concentrations were estimated to be well below applicable health thresholds for
these HAPs. In addition, long-term exposures to emissions of suspected carcinogens (benzene,
ethylbenzene and formaldehyde) were evaluated based on estimates of the increased latent
cancer risk over a 70-year lifetime. The estimated cancer risk from these HAPs is shown to be
below acceptable cancer risk levels. Therefore, it is estimated the HAP emission resulting from
the production activities from 21 natural gas wells on the South Leverich 13-09 pad would not
cause or contribute to any potential acute or chronic, short-or long-term incremental impacts to
public health.
2,2,4-trimethylpentane, hydrogen sulfide, and methanol HAP emissions from production
activities were estimated and are shown in Table 5. These emissions are estimated as 0.007,
0.0, and 0.0 tpy, respectively. Although these HAPs were not specifically modeled in the Balzac
Gulch EA (BLM 2017b) study, the emissions levels are less than the project benzene emissions
(which were modeled). Given that the applicable short-term (1-hour) and long-term (annual)
health thresholds for these HAPs are above the levels applicable to benzene, it is estimated that
the short-term and long-term concentrations for these HAPs would be well below applicable
health thresholds.
Cumulative Impacts
HAP impacts from direct project activities were estimated and provided above. Benzene,
toluene, ethylbenzene, xylene, 2,2,4-trimethylpentane, hydrogen sulfide, formaldehyde, and
methanol emissions in the vicinity of the well pads were analyzed, and the potential maximum
acute (short-term; 1-hour) and long-term (annual) HAP concentrations were estimated to be well
below applicable health thresholds. In addition, as part of the Balzac Gulch EA (BLM 2017b),
long-term exposures to emissions of suspected carcinogens (benzene, ethylbenzene, and
formaldehyde) were evaluated based on estimates of the increased latent cancer risk over a 70-
year lifetime. The estimated cancer risk from these HAPs is shown to be below acceptable
cancer risk levels.
No adverse project impacts to public health are anticipated as a result of construction (short-
term) and production (long-term) operations for the South Leverich 13-09 OGDP. Adverse
cumulative impacts are not expected as a result of project implementation.
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Specific Measures Taken to Avoid or Minimize Cumulative Adverse Impacts
Implementation of BMPs included in the Form 2A and the Dust Mitigation Plan attached to the
Form 2A, as well as the implementation of an Air Monitoring Program as required by CDPHE
avoids and minimizes project impacts to public health and therefore, no adverse cumulative
impacts are expected.
Measures to Mitigate or Offset Cumulative Adverse Impacts
As mentioned above, no project or cumulative adverse impacts to public health are anticipated
from the development of the South Leverich 13-09 OGDP and therefore, no mitigation or offsets
are proposed.
Water Resources
The total planned on-location storage volumes of oil, condensate, produced water, and other
hydrocarbons, chemicals, and waste fluids are listed in Table 7. TEP would follow measures
described in the Waste Management Plan attached to the Form 2A, such as identification and
cleanup of localized spills and excavation of any impacted soils to avoid and minimize impacts
resulting from spills.
Table 7
Planned On-Location Storage Volumes for the South Leverich 13-09 OGDP
Material Stored
Number of
Tanks
Individual
Capacity
(barrels)
Total
Capacity
(barrels)
Oil 0 0 0
Condensate 6 500 3,000
Produced water 0 0 0
Gun Barrel 0 0 0
Blowdown/vent tank 2 80 160
Chemicals 4 12 48
Total 12 -- 3,208
The Hydrology Map, attached to the Form 2A, shows the presence and distance to surface
water and groundwater features (see Table 8). The South Leverich 13-09 well pad is located in
close proximity (within 0.5 mile) of Beaver Creek (a perennial stream that flows year-round) and
therefore, this pad location is designated as a sensitive area for water resources (see Sensitive
Area Determination, attached to the Form 2A for a detailed summary of this classification).
Beaver Creek is located 640 feet to the west within the downgradient area of the South Leverich
13-09 well pad. Identified intermittent streams are not located within 0.25 mile of the well pad.
Intermittent streams identified within the 0.5-mile site radius are located 2,255 feet and 2,493
feet north of the well pad. These intermittent drainages eventually join to the north into a single
intermittent drainage. Although the drainages are downgradient of the site, the drainage’s lack
of a defined bed and bank pathway promotes sheet flow rather than concentrated flow, thus
limiting the potential for offsite migration to these drainages. The perennial and intermittent
drainages eventually discharge to the Colorado River near Rifle.
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Table 8
Distance to Nearest Downgradient Surface Waters
and Public Water Systems for the South Leverich 13-09 OGDP
Description
Distance
(feet) Direction Baseline Condition
Riparian Corridor 640 NW Perennial Stream; Beaver Creek
Wetlands 640 NW Perennial Stream; Potential wetland
(NWI-Riverine); Beaver Creek
Surface Waters of the State 640 NW Perennial Stream; Beaver Creek
Public Water System Intake >5,280 N No PWS intakes within 1-mile of the
working pad surface (WPS)
Additional Information
Sensitive Area Yes
Estimated Depth to
Groundwater >90 feet
Evaluation of the potential
impacts to the Public Water
System Intake within 5,280
feet of the WPS
None, No PWS intakes within 1 -mile of WPS. The City of Rifle
Beaver Creek water intake is on longer in use as a public water
supply. Please see Ordinance No. 7-2018 attached to the Form 2A
for details.
A spring, located 1,460 feet northeast of the South Leverich 13-09 pad is oriented along a
topographic contour relative to the well pad; thus, lacking potential head for a spill release to
reach and impact the spring. Three ponds qualifying as Waters of the United States (WOUS)
are located 1,654 feet northeast, 1,892 feet east, and 2,187 feet northeast of the pad. The
nearest surface water body, similar to the spring, is oriented along a topographic contour
relative to the well pad, which therefore lacks potential head to reach this surface water body.
The two furthermost surface water bodies are higher in elevation than the well pad and are, thus
physically incapable of being impacted by a potential spill release. Site grading would provide
erosion control measures minimizing potential fluid migration off site. Best Management
Practices (BMPs) would be installed during site construction which would eliminate preferential
pathways for offsite depression flow using earthen berms and diversion ditches. All newly
constructed BMPs would be closely monitored and maintained to ensure complete on-site
containment of a potential release. This includes measures taken by TEP to route pipelines
around the pad. During post-construction, earthen berms and diversion ditches would be
installed to prevent a potential pollution and sediment release from impacting spring water
quality.
TEP has implemented and maintains a Spill Prevention, Control and Countermeasure Plan
(SPCC), which is a basin wide emergency spill response plan as required by Title 40, Code of
Federal Regulations, Part 112 (40 CFR 112) as administered by the EPA. This plan describes
measures implemented by TEP to prevent discharges from occurring and response measures
to mitigate the impacts of a potential discharge. TEP has also implemented and maintains a
Drilling and Workover Facilities Integrated Spill Prevention, Control, and Countermeasures Plan,
as required by 40 CFR Part 112.10, which describes measures to prevent spills and releases
during drilling, completions, and workover operations.
The working pad surface (WPS) of the South Leverich 13-09 pad is not within 2,640 feet of a
Groundwater Under the Direct Influence of Surface Water (GUDI) well, a Type III Well as
defined by Rule 411.b.(1).B and 411.b.(1).D, or a surface water feature segment that is 15 miles
or less upstream from a Public Water System intake. TEP overlaid the available GUDI well and
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Type III Well data from the COGCC to determine if the proposed operations would be within
2,640 feet of these wells. Additionally, TEP identified the Public Water System intake locations
downstream of the South Leverich 13-09 pad and determined that all proposed operations
would not fall within 15 stream miles of an active Public Water System intake. The City of Rifle
Beaver Creek intake is no longer included within the City of Rifle Watershed District, per
Ordinance No. 7-2018, and therefore was excluded from this evaluation.
State Engineers Office and USGS records were reviewed indicating only one permitted
monitoring well (permit no. 314384) located 1,089 feet west of the South Leverich 13-09 pad.
The well is 160 feet deep, with solid casing from 0 to120 feet and perforated pipe from 120 to
165 feet. The static water level is 90 feet with an estimated well yield of 15 gallons per minute
(gpm). Dominant upland vegetation indicates unsaturated soil conditions without hydric
indicators of shallow groundwater conditions. Evidence of springs or seeps, other than the
identified spring discussed above, were not detected during site reconnaissance and vegetation
assessment (WestWater 2022). Hydrogeological indicators do not support the occurrence of
shallow groundwater at the site, and depth to groundwater is probably greater than 90 feet in
the underlying bedrock. Potential impact to groundwater resources is deemed to be low based
on the site hydrogeology.
The use of fresh water would be limited to that used for drilling and for dust control. Water use
would be reduced by recycling produced water for completion operations. It is estimated that
3,000 barrels of fresh water would be required for construction, 4,000 barrels of fresh water
would be required to drill a single well (84,000 barrels for 21 wells), and 500 barrels of fresh
water per well would be required for dust control (10,500 barrels for 21 wells) for a total of
97,500 barrels of fresh water. In addition, 120,000 barrels of water (recycled produced water)
would be required for completion of a single well (2,520,000 for 21 wells). Fresh water would be
transported by truck from either the Giles Fresh Water Takeout (located on the Colorado River
on TEP property) or Airport Land Partners Limited Takeout (located on the Last chance Ditch
north of the Rifle Airport). Water trucks would utilize existing county and lease roads and would
follow existing truck routes where applicable. Water for well completion would be sourced from
recycled produced water. Estimated water usage is listed in Table 9. A total of 96 percent of the
total water used for drilling and completion would be recycled.
Table 9
Drilling and Completion
Estimated Water Usage for the South Leverich 13-09 OGDP
Type
Volume
(barrels)
Surface water 97,500
Groundwater 0
Recycled water (produced water) 2,520,000
Recycled water (non-produced water) 0
Unspecified source 0
Total 2,617,500
Percentage recycled 96
Based on the project design and implementation of the measures described above, potential
impacts to surface water and groundwater is deemed to be low.
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Cumulative Impacts
No adverse impacts to water resources are anticipated as a result of construction (short-term)
and production (long-term) operations for the South Leverich 13-09 OGDP. Adverse cumulative
impacts are not expected as a result of project implementation.
Specific Measures Taken to Avoid or Minimize Cumulative Adverse Impacts
Implementation of the measures described above and those included in the Stormwater
Management Plan ( attached to the Form 2A) to avoid and minimize project impacts to water
resources would also avoid and minimize cumulative impacts and therefore, no adverse
cumulative impacts are expected.
Measures to Mitigate or Offset Cumulative Adverse Impacts
As mentioned above, no project or cumulative adverse impacts to water resources are
anticipated from the development of the South Leverich 13-09 OGDP and therefore, no
mitigation or offsets are proposed.
Terrestrial and Aquatic Wildlife Resources and Ecosystems
The South Leverich 13-09 pad is not located within High Priority Habitat (HPH); however, HPH
including Aquatic Native Species Conservation Water, Cutthroat Trout Designated Crucial
Habitat, Elk Production Area, and Elk Winter Concentration Area are located within 1 mile of the
South Leverich 13-09 working pad surface (WPS), see Table 10 and Wildlife Habitat Drawing
attached to the Form 2A.
Table 10
High Priority Habitats within 1 Mile of the South Leverich 13-09 Working Pad Surface
Type
Distance (feet)
from WPS
HPH Disturbed
(acres)
Aquatic Native Species Conservation Water 141 0
Cutthroat Trout Designated Crucial Habitat 141 0
Elk Production Area 4,456 0
Elk Winter Concentration Area 5,244 0
The proposed temporary surface frac pipeline would cross into Cutthroat Trout Designated
Crucial Habitat near the Youberg RU-44-7 pad. Also, the existing access road to the South
Leverich 13-09 pad crosses through Cutthroat Trout Designated Crucial Habitat. Per COGCC
Rule 309.e.(2).A, consultation is required if a “proposed Oil and Gas Location or associated new
access road, utility, or pipeline corridor falls within High Priority Habitat…”. TEP held a pre-
application consultation meeting with Colorado Parks & Wildlife (CPW) on June 23, 2022 to
discuss potential impacts associated with facility installation and the existing access. The pre-
application consultation meeting with CPW was necessary to ensure TEP’s planned operation
would be protective of wildlife and to discuss BMPs that TEP would implement to avoid and/or
minimize impacts to wildlife (see Appendix A of the Wildlife Plan attached to the Form 2A for a
detailed summary of CPW consultation). TEP’s Wildlife Plan addresses the implementation of
the operational requirements outlined under COGCC Rule 1202.a. It provides an assessment of
wildlife impacts from the proposed oil and gas activities, compliance with the applicable
operating requirements under Rule 1202, CPW consultation, and best management practices
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that will be implemented to avoid, minimize, and mitigate impacts to wildlife from the proposed
oil and gas activities.
The South Leverich 13-09 pad is located within Non-Crop Land - Rangeland and Non-Crop
Land - Forestry. When applying a 1-mile buffer to the proposed Oil and Gas Location there are
approximately 2,060 acres of existing rangeland and 198 acres of forestry. A quantitative
vegetative assessment was conducted for the project area during October 2021 following the
methodology described in "The Monitoring Manual for Grassland, Shrubland, and Savanna
Ecosystems, Volume 1: Core Methods" (Herrick et al 2015) to assist with interim and final
reclamation.
After well development is complete, TEP would reclaim the area surrounding the wellhead and
production facilities not required for long-term production operations. The area would be
reclaimed using species and methods described in TEP's Reclamation Plan, which is attached
to the Form 2A. Reclamation would comply with Federal, State, and local reclamation
standards and would occur within 6 months following completion of well construction.
Composition of species used for reclamation would also consider the October 2021 vegetative
assessment. Construction and Interim Reclamation disturbance acreages are show in Table 11.
Table 11
Disturbance by Component for the South Leverich 13-09 OGDP
Component
Total Short-Term
(acres)
Total Long-Term
(acres)
South Leverich 13-09 pad 6.43 1 1.74
8-inch gas pipeline 1.83 2 0.69 4-inch water pipeline
Total 8.26 2.43
1 Includes 1.71 acres of existing disturbance, 3.73 acres of re-disturbance, and 0.99 acres
of new disturbance.
2 Includes 0.70 acre of existing disturbance, 0.99 acre of re-disturbance, and 0.14 acre of
new disturbance.
The loss of mature mountain shrubs, including Gambel oaks, would be long-term, but these
species are common throughout the region, and the loss would be negligible at both a project
and regional level. Gradual re-establishment of a portion of the affected shrubland is likely
following reclamation.
TEP has designed the project to incorporate existing infrastructure in order to minimize impact
to the ecosystem and wildlife that rely on available habitats in the vicinity surrounding the
existing South Leverich 13-09 pad to be re-constructed. As a result of incorporating existing
infrastructure into the development plan, impacts to existing wildlife habitat would be minimal
and impacts on wildlife would be reduced compared to less developed or undeveloped areas
because some habituation of the animals to oil and gas operation and other human activities
would be expected (see Wildlife Plan attached to the Form 2A for detailed BMPs proposed to
minimize impacts to wildlife).
Hydraulic fracturing operations would use recycled produced water pumped through an existing
buried water collection system avoiding use of truck traffic to deliver water for well completions
and avoiding potential wildlife impacts. TEP would also install five temporary surface steel frac
lines to support remote frac and flowback operations for the 21 wells on the South Leverich 13-
09 pad. The temporary surface frac lines would be installed following the existing access roads
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and existing pipeline rights-of-ways minimizing short-term disturbance to wildlife during
hydraulic fracturing.
To minimize traffic during operations, TEP would install buried natural gas and produced water
pipelines. As mentioned above, disturbance associated with pipeline construction would be
promptly revegetated with native species consistent with CPW’s recommended seed mix when
the pipeline is completed (see Reclamation Plan attached to the Form 2A). TEP would utilize
remote telemetry equipment to minimize well site visitation reducing the vehicles traveling on
dirt/gravel roads. To minimize the potential for wildlife related traffic accidents, TEP would
implement speed restrictions for all roads and will require that all TEP employees and
contractors adhere to posted speed limits.
TEP has scheduled reconstruction of the South Leverich 13-09 pad and installation of pipeline
infrastructure during November 2022, which is outside the nesting season for migratory birds
(April 1 to August 31). If vegetation removal must occur during the nesting season, TEP will
implement hazing or other exclusionary measures prior to April 1 to avoid take of migratory
birds. Alternatively, TEP may conduct a migratory bird survey prior to vegetation removal as
required by COGCC Rule 1202.a.(8) to avoid take of migratory birds. Additionally, TEP would
conduct raptor surveys within 0.25 mile or 0.5 mile of proposed well development activities prior
to construction and implement appropriate buffers around active nests during the species’
nesting seasons to avoid impacts.
To minimize the potential spread and infestation of invasive, non-native plants within areas used
for expansion of the South Leverich 13-09 pad and installation of infrastructure that could
degrade wildlife habitat and out-compete native vegetation, TEP would implement a weed
management program. This includes control or reduction of invasive weeds and non-native
populations that have been established in the South Leverich 13-09 OGDP prior to
development, as well invasive plant species that may be introduced during project development
and reclamation activities. Interim and final reclamation of disturbed areas would use seed
mixes that are certified to be weed-free. Reclamation would be monitored annually until
reclamation is successful, and if noxious weeds are documented, TEP would use methods to
treat the weeds as outlined within the Pesticide Use Permit on record with BLM (see
Reclamation Plan attached to the Form 2A). These measures would minimize impacts on
existing vegetation communities within the Project area as well as maintain native vegetation for
the continued use of wildlife in the Project area.
Cumulative Impacts
No adverse impacts to terrestrial and aquatic wildlife resources and ecosystems are anticipated
as a result of construction (short-term) and production (long-term) operations for the South
Leverich 13-09 Project. Adverse cumulative impacts are not expected as a result of project
implementation.
Specific Measures Taken to Avoid or Minimize Cumulative Adverse Impacts
Implementation of the measures described above and those included in the Wildlife Plan
(attached to the Form 2A) and the Reclamation Plan (attached to the Form 2A) to avoid and
minimize project impacts to terrestrial and aquatic wildlife resources and ecosystems would also
avoid and minimize cumulative impacts and therefore, no adverse cumulative impacts are
expected.
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Measures to Mitigate or Offset Cumulative Adverse Impacts
As mentioned above, no project or cumulative adverse impacts to terrestrial and aquatic wildlife
resources and ecosystems are anticipated from the development of the South Leverich 13-09
OGDP and therefore, no mitigation or offsets are proposed.
Soil Resources
Reconstruction of the South Leverich 13-09 pad would require 6.43 acres (4.31 acres of Morval-
Tridell complex, 6 to 25 percent slopes and 2.12 acres of Cimarron loam, 2 to 12 percent
slopes). Of the 6.43 acres of disturbance 1.71 acres is existing disturbance, 3.73 acres would
be re-disturbance, and 0.99 acres would be new disturbance. After drilling and completion, 4.69
acres would be reclaimed leaving 1.74 acres disturbed during long-term production. The South
Leverich 13-09 OGDP has been designed to disturb the minimum area possible while
maintaining safety standards. In addition to 0.7 acre of existing disturbance, 0.99 acre of various
soil types would be re-disturbed and 0.14 acre would be new disturbance to support utilities for
a total of 1.83 acres (see Table 12). After utility installation is complete, 1.14 acres would be
reclaimed leaving 0.69 acres disturbed during long-term production for utilities.
Table 12
Soil Types Disturbed by Construction of the South Leverich 13-09 OGDP
Map
Unit
Number Soil Type
South Leverich
13-09 Pad
(acres)
Access/Utilities
(acres)
45 Morval-Tridell complex, 6 to 25 percent slopes 4.31 0.21
16 Cimarron loam, 2 to 12 percent slopes 2.12 1.58
333B Fughes-Godding families complex, 5 to 40
percent slopes 0.00 0.04
Total 6.43 1.83
TEP has prepared and would follow their Topsoil Protection Plan (attached to the Form 2A) to
address compliance with Federal, State, and local requirements regarding topsoil management
and preservation. TEP has also prepared and would follow a Reclamation Plan (attached to the
Form 2A). Proper management of topsoil during initial site construction would ensure topsoil is
preserved for site reclamation following construction and to ensure adequate organic material is
available for re-establishment of desirable vegetation at reclamation. During reconstruction of
the South Leverich 13-09 pad and construction of the proposed pipeline infrastructure, topsoil
stripped during initial construction of these project components would be managed according to
use and duration of development. Prior to separation and storage of the topsoil horizon, or top 6
inches, from the well pad facility and pipeline corridor, woody vegetation would be mulched and
stormwater control measures properly installed to control erosion and sedimentation during
precipitation events (see Stormwater Management Plan attached to the Form 2A). When
separating soil horizons, TEP would segregate each horizon based upon noted changes in
physical characteristics, such as organic content, color, texture, density, or consistency. To the
extent feasible, stockpiled soils would be protected from degradation due to contamination,
compaction, and from wind and water erosion during drilling and production operations. Surface
roughening, temporary seeding and mulching, erosion control blankets, or soil binders would be
used as needed, and BMPs implemented, to prevent weed establishment and to maintain soil
microbial activity.
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Edge Environmental, Inc.
During reconstruction of the South Leverich 13-09 well pad, the topsoil horizon would be
stripped between the top of cut and toe of fill and the soil would be stockpiled south of the
existing well pad. The topsoil volume disturbed for the reconstructed well pad is estimated at
2,920 cubic yards. Topsoil would be segregated from all other subsurface materials. Wattles
would be placed around the base of the topsoil stockpile to control sedimentation and a metal
sign would be placed on the north (pad) side of the stockpile area. Upon completion of well pad
construction activities, hydro-seed/mulch would be applied to topsoil stockpiles to stabilize the
soils and promote the growth of desirable plants until interim reclamation can be completed.
During construction of the pipeline infrastructure, the topsoil horizon would be stripped within the
50-foot construction right-of-way width and placed along the downhill side. Topsoil would be
segregated from subsurface materials and stockpiled upslope of the trench. When construction
is complete and the pipeline right-of-way has been re-contoured to pre-construction slopes,
stripped topsoil would be uniformly replaced across the disturbance. It is estimated that
approximately 1,476 cubic yards would be disturbed for pipeline installation.
Cumulative Impacts
No adverse impacts to soil resources are anticipated as a result of construction (short-term) and
production (long-term) operations for the South Leverich 13-09 OGDP. Adverse cumulative
impacts to soil resources are not expected as a result of project implementation.
Specific Measures Taken to Avoid or Minimize Cumulative Adverse Impacts
Implementation of the measures described above, and the measures included in the Topsoil
Protection Plan (attached to the Form 2A) and Reclamation Plan (attached to the Form 2A) to
avoid and minimize project impacts to soil resources would also avoid and minimize cumulative
impacts and therefore, no adverse cumulative impacts are expected.
Measures to Mitigate or Offset Cumulative Adverse Impacts
As mentioned above, no project or cumulative adverse impacts to soil resources are anticipated
from the development of the South Leverich 13-09 Project and therefore, no mitigation or offsets
are proposed.
Public Welfare
This section considers a qualitative evaluation of incremental adverse impacts to public welfare
(noise, light, odor, dust, and recreation and scenic values) as a result of pre-production
operations (short-term) and production operations (long-term) of the South Leverich 13-09 well
pad. Pre-production activities associated with reconstruction of the South Leverich 13-09 pad
include construction, drilling, and completion operations and installation of pipeline
infrastructure. Production activities associated with the expanded South Leverich 13-09 pad
include standard well and facility maintenance operations and inspection activities.
During initial site planning of the Oil and Gas Location, TEP evaluated receptors for noise, light,
and odor where members of the public or wildlife resources may be located and impacted from
the proposed activities. These receptors include public roads, railroads, building units,
residential building units, high occupancy building units, school property or facilities, designated
outdoor activity areas, childcare centers, disproportionately impacted communities, trails, and
wildlife habitat.
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As provided in the Cultural Distance section of the Form 2A and in Table 13 below, there are 8
residential building units within 1 mile of the proposed South Leverich 13-09 WPS including 4
residential building units within 2,000 feet of the proposed WPS. The nearest residential building
unit is located 1,195 feet from the proposed WPS and is owned and occupied by Mr. and Mrs.
Fischer. Another residential building unit is owned by the surface owner of the South Leverich
13-09 pad and is unoccupied, and the other two residential building units are owned by TEP and
are unoccupied.
Table 13
Building Units from the Edge of the South Leverich 13-09 Working Pad Surface
Type Number
Residential building units (0 to 2,000 feet) 4
Residential building units (2,001 to 5,280 feet) 8
Non-school and non-child care center high
occupancy building units (0 to 2,000 feet) 0
Non-school and non-child care center high
occupancy building units (2,000 to 5,280 feet) 0
Schools facilities (0 to 2,000 feet) 0
Schools facilities (2,000 to 5,280 feet) 0
Child care centers (0 to 2,000 feet) 0
Child care centers (2,000 to 5,280 feet) 0
TEP reviewed HPH within 1 mile of the South Leverich 13-09 pad and associated permanent
pipelines. The pad and associated permanent pipelines are located outside of all HPH
boundaries. HPH identified within 1 mile of the South Leverich 13-09 WPS includes Elk
Production Area, Elk Winter Concentration Area, Cutthroat Trout Designated Crucial Habitat,
and Aquatic Native Species Conservation Water (see Wildlife Habitat Drawing attached to the
Form 2A). After review of the HPH layers and review of the topography within 1 mile of the
location, TEP and CPW determined that the majority of the HPH is topographically isolated by a
ridge line southeast and northwest of the Oil and Gas Location. Based on this evaluation, it is
unlikely either pre-production or production operations would adversely affect wildlife resources.
Noise. Pre-production (short-term) activities are typically shorter in nature and emit a higher
noise level than long-term production operations. Noise from these activities could have impacts
on surrounding receptors if located within close proximity of the proposed WPS.
During planning of the South Leverich 13-09 pad, TEP determined through on-site surveys and
review of available aerial imagery that there are 4 residential building units within 2,000 feet of
the proposed WPS (see Cultural Distances Map attached to the Form 2A). The nearest
residential building unit is located approximately 1,195 feet from the WPS and is owned and
occupied by Mr. and Mrs. Fischer. Another residential building unit is owned by the surface
owner of the South Leverich 13-09 pad and is unoccupied, and the other two residential building
units are owned by TEP and are unoccupied. A Noise Mitigation and Monitoring Plan was
prepared by Behrens and Associates Environmental Noise Control for the planned operations
associated with the South Leverich 13-09 OGDP in accordance with COGCC Rule 304.c.(2)
based on the requirements outlined under COGCC Rule 423. Predictive noise modeling was
completed based on TEP planned operations on the South Leverich 13-09 pad and evaluated
based on the permissible noise levels described in Rule 423 to demonstrate compliance with
noise standards. Only drilling operations were evaluated because well completion operations
will be conducted remotely from the Youberg RU 44-7 pad. As described in the Noise Mitigation
Plan, the unmitigated noise modeling for drilling operations shows compliance with the high
frequency (dBA) and low frequency (dBC) standards outline in Rule 423.b.(2).
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Edge Environmental, Inc.
Prior to planned drilling operation, an ambient sound level survey would be completed
approximately 60 to 90 days prior to commencement of operations on the Oil and Gas Location.
Continuous noise monitoring would be completed during drilling and completion operations as
required by Rule 423.c.(1) as described in the Noise Mitigation Plan attached to the Form 2A.
With implementation of the measures included in TEP’s Noise Mitigation Plan, it is unlikely for
noise generated during pre-production operations (short-term) or production operations (long-
term) to adversely affect members of the public.
TEP reviewed HPH within 1 mile of the South Leverich 13-09 pad and associated permanent
pipelines. The pad and associated permanent pipelines are located outside of all HPH
boundaries. HPH identified within 1 mile of the South Leverich 13-09 WPS includes Elk
Production Area, Elk Winter Concentration Area, Cutthroat Trout Designated Crucial Habitat,
and Aquatic Native Species Conservation Water (see Wildlife Habitat Drawing attached to the
Form 2A). After review of the HPH layers and review of the topography within 1 mile of the
location, TEP and CPW determined that the majority of the HPH is topographically isolated by a
ridge line southeast and northwest of the Oil and Gas Location. Based on this evaluation, it is
unlikely that noise during pre-production and production operations would adversely affect
wildlife resources.
Cumulative
Adverse cumulative noise impacts to members of the public and wildlife are not expected given
that noise impacts from the project are expected to be nonexistent or minimal.
Light. Pre-production activities are typically shorter in nature and require sufficient lighting to
ensure the safety of employees and contractors. Lighting from these activities could have
minimal impacts on surrounding receptors if located within close proximity of the proposed
WPS.
During planning of the South Leverich 13-09 pad, TEP determined through on-site surveys and
review of available aerial imagery that there are 4 residential building units within 2,000 feet of
the proposed WPS (see Cultural Distances Map attached to the Form 2A). The nearest
residential building unit is located approximately 1,195 feet from the WPS and is owned and
occupied by Mr. and Mrs. Fischer. Another residential building unit is owned by the surface
owner of the South Leverich 13-09 pad and is unoccupied, and the other two residential building
units are owned by TEP and are unoccupied. TEP has developed and would follow a Lighting
Mitigation Plan in accordance with COGCC Rule 304.c.(3) and based on the requirements
outlined in COGCC Rule 424. It describes methods TEP would use to minimize lighting intensity
outside the boundary of the Oil and Gas Location and ensure compliance with standards
outlined under COGCC Rule 424. TEP’s Lighting Mitigation Plan complies with COGCC Rule
424 and provides BMPs to reduce potential impacts from lighting.
With implementation of the BMPs included in TEP’s Lighting Mitigation Plan, it is unlikely for
lighting used during pre-production operations (short-term) to adversely affect members of the
public.
TEP reviewed HPH within 1 mile of the South Leverich 13-09 pad and associated permanent
pipelines. The pad and associated permanent pipelines are located outside of all HPH
boundaries. HPH identified within 1 mile of the South Leverich 13-09 WPS includes Elk
Production Area, Elk Winter Concentration Area, Cutthroat Trout Designated Crucial Habitat,
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and Aquatic Native Species Conservation Water (see Wildlife Habitat Drawing attached to the
Form 2A). After review of the HPH layers and review of the topography within 1 mile of the
location, TEP and CPW determined that the majority of the HPH is topographically isolated by a
ridge line southeast and northwest of the Oil and Gas Location. Based on this evaluation, it is
unlikely that lighting during pre-production operations would adversely affect wildlife resources.
TEP does not plan to install any on-site lighting during production operations (long-term) and
does not anticipate conducting any nighttime well maintenance operations requiring temporary
lights. Therefore, light impacts to members of the public and wildlife resources are expected to
be nonexistent during production operations (long-term).
Cumulative
Adverse cumulative light impacts are not expected given that light impacts from the project are
expected to be nonexistent or minimal.
Odor. Pre-production and production activities have the potential to generate odors. Potential
sources of odors during drilling operations include drilling rig generators, third-party vehicles,
drying shaker assembly and centrifuge solids, drill cuttings storage, water base/bentonitic
drilling mud, and mud tanks. Potential sources of odors during completion operations include
frac pumps, bender, and frac tanks. Potential sources of odors during flowback operations
include separators and tanks, and during production operations include separators, tanks,
emissions combustion devices, and natural gas generators.
During planning of the South Leverich 13-09 pad, TEP determined through on-site surveys and
review of available aerial imagery that there are 4 residential building units within 2,000 feet of
the proposed WPS (see Cultural Distances Map attached to the Form 2A). The nearest
residential building unit is located approximately 1,195 feet from the WPS and is owned and
occupied by Mr. and Mrs. Fischer. Another residential building unit is owned by the surface
owner of the South Leverich 13-09 pad and is unoccupied, and the other two residential building
units are owned by TEP and are unoccupied. TEP has developed and would follow an Odor
Mitigation Plan in accordance with Rule 304.c.(4) and Rule 426. It describes how TEP would
comply with Rule 426 and provides BMPs to reduce potential impacts from odor.
With implementation of the BMPs included in TEP’s Odor Mitigation Plan, it is unlikely for odor
generated during pre-production operations (short-term) or production operations (long-term) to
adversely affect members of the public.
Cumulative
Adverse cumulative odor impacts are expected to be nonexistent or minimal given that odor
impacts from the project are expected to be minimal.
Dust. TEP has prepared a Dust Mitigation Plan as required by COGCC Rule 304.c.(5) based on
the requirements outlined in COGCC Rule 427. Fugitive dust is created during construction and
from vehicular travel on dirt or gravel roads. Table 6 provides a list of the estimated vehicle trips
during construction and operation. Fugitive dust can also be propagated from disturbed areas
during high wind events. TEP would implement the BMPs outlined in the Dust Mitigation Plan
including application of fresh water during construction, application of fresh water on road
surfaces, and speed restriction.
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TEP would be utilizing proppant during well completion operations. Proppant would be trucked
to location using pre pneumatic dry bulk trailers. On location, the proppant is transferred via
hose pneumatically from the air blower on the dry bulk trailer to the sand storage silos. Sand
storage silos utilize a self-contained filtration system to capture dust while off-loading sand.
Sand is transferred from the sand storage silo to the blender bulk hopper via gravity feed chute.
The blender hopper would be covered with a vacuum system and fugitive dust would be
contained to filtered cannisters. All dust is contained during this transfer process and no silica
dust would leave the location.
With implementation of the measures outlined in the Dust Mitigation Plan and described above,
no adverse impacts related to dust are anticipated as a result of construction (short-term) and
operation (long-term) under the South Leverich 13-09 OGDP.
Cumulative
The BMPs in the Dust Mitigation Plan would be applied to the proposed Oil and Gas Location,
proposed pipeline corridor, and existing access roads. Adverse cumulative dust related impacts
are expected to be minimal and not adverse with proper implementation of the BMPs included in
the Dust Mitigation Plan (attached to the Form 2A).
Recreation and Scenic Values. No State Parks, State Trust Lands, or State Wildlife Areas exist
within 1 mile of the South Leverich 13-09 pad. Additionally, there are no Designated Outdoor
Activity Areas within 1 mile of the South Leverich 13-09 location.
There is one mapped trail/road within 1 mile of the South Leverich 13-09 pad called Beaver
Creek Road. Beaver Creek Road is approximately 1,250 feet from the South Leverich 13-09
pad.
No adverse impacts to Recreation and Scenic Values are anticipated as a result of construction
(short-term) and operation (long-term) of the South Leverich 13-09 OGDP.
Cumulative Impacts
No adverse project or cumulative impacts to recreation and scenic values are expected as a
result of project implementation.
Specific Measures Taken to Avoid or Minimize Cumulative Adverse Impacts
Implementation of the measures described in the Noise Mitigation Plan, Light Mitigation Plan,
Odor Mitigation Plan, and Dust Mitigation Plan (attached to the Form 2A) to avoid and minimize
project impacts to public welfare would also avoid and minimize cumulative impacts and
therefore, no adverse cumulative impacts are expected.
Measures to Mitigate or Offset Cumulative Adverse Impacts
As mentioned above, no project or cumulative adverse impacts to public welfare are anticipated
from the development of the South Leverich 13-09 OGDP and therefore, no mitigation or offsets
are proposed.
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SURROUNDING OIL AND GAS IMPACTS
This section provides a baseline evaluation of the existing landscape level impacts within the
area surrounding the existing South Leverich 13-09 pad proposed for expansion. This
information is required per COGCC Rule 303.a.(5).C and is necessary when evaluating
cumulative impacts. The information provided below gives context to existing and proposed
activities within the vicinity of the proposed Oil and Gas Location.
The existing South Leverich 13-09 pad is located in an area of the Piceance Basin with existing
Oil and Gas operations. There are four active Oil and Gas Locations within 1 mile of the existing
South Leverich 13-09 WPS as listed in Table 14. The total disturbance acreage for the active Oil
and Gas Locations including the South Leverich 13-09 pad is 22.29 acres. A breakdown of the
acreage by facility is provided in Table 14. For existing TEP operated Oil and Gas Locations,
TEP provided the actual post-construction disturbance acreage based on field measurement
utilizing a GPS receiver. For non-TEP operated Oil and Gas Locations, TEP reviewed recent
aerial photos to calculate the acreage of disturbance.
Table 14
Existing Oil and Gas Locations within 1 Mile of the South Leverich 13-09 Working Pad Surface
O&G Location Name Operator
COGCC
Location ID Status
Disturbance
Acreage
Source
Information
GL-67S93W 18SWSE Caerus 311604 Active/Built 2.95 Aerial
Honea 19-05 Pad TEP 335038 Active/Built 6.10 Field Observation
S. Leverich 13-09 Pad TEP 335045 Active/Built 5.25 Field Observation
S. Leverich 18-13 Pad TEP 335039 Active/Built 6.17 Field Observation
Tepee Park Ranch
Pad 2 Tanks CPX 455779 Active/Built 1.82 Field Observation
Total 22.29 Aerial
There are a total of 11 active producing oil and natural gas wells, 18 proposed oil and natural
gas wells, and one plugged and abandoned well within 1 mile of the South Leverich 13-09 WPS
as shown in Table 15. TEP reviewed the COGCC database to compile a list of the existing
and/or permitted wells within 1 mile of the South Leverich 13-09 pad. The wells proposed on the
South Leverich 13-09 pad are not listed in Table 15.
Table 15
Existing/Proposed Wells within 1 Mile
of the South Leverich 13-09 Working Pad Surface
Well Status Count
Active oil and gas wells 11
Permitted but not drilled 0
Proposed 18
Plugged and abandoned 2
Total 31
TEP reviewed COGCC location files and permitting documents to determine the permitted
storage capacity within 1-mile of each Oil and Gas Location within the South Leverich 13-09
OGDP (Table 16). TEP also reviewed available aerial imagery and facility diagrams prepared
following recent site visits to determine the existing storage capacity for each Oil and Gas
location with the South Leverich 13-09 OGDP (Table 16).
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Table 16
Permitted/Existing Storage Capacity within 1 Mile
of the South Leverich 13-09 Working Pad Surface
Storage Count
Source of
Count
Permitted onsite storage capacity (oil) 0 COGCC
Permitted onsite storage capacity (condensate) 11 COGCC
Permitted onsite storage capacity (water) 2 COGCC
Permitted onsite storage capacity (pits) 0 COGCC
Existing onsite storage capacity (oil) 0 FO/COGCC
Existing onsite storage capacity (condensate) 9 FO/COGCC
Existing onsite storage capacity (water) 2 FO/COGCC
Existing onsite storage capacity (pits) 0 FO/COGCC
FO=Field Observation
COGCC=Colorado Oil & Gas Commission - Records/Permits
As described above, there are existing landscape level impacts associated with oil and gas
development (i.e., existing Oil and Gas Locations, wells, and fluid storage facilities) present on
the landscape within the vicinity of the proposed South Leverich 13-09 pad expansion.
Furthermore, there are existing access roads and pipeline infrastructure supporting oil and gas
operations for these locations and facilities in the vicinity of the South Leverich 13-09 OGDP. No
adverse impacts to resources are expected from expansion of the South Leverich 13-09 pad.
OTHER INDUSTRIAL IMPACTS
Per COGCC Rule 303.a.(5).D, the operator is required to identify existing industrial facilities
within 1 mile of the proposed Oil and Gas Location. During review of this location no industrial
facilities were identified within 1 mile of the pad location. The South Leverich 13-09 pad is in a
remote area of Garfield County, Colorado with oil and gas development and grazing activities.
BENEFICIAL IMPACTS
The South Leverich 13-09 OGDP does not include any proposed direct incremental beneficial
impacts associated with the development of the proposed wells on the South Leverich 13-09
pad, as summarized in Table 17, Beneficial Impacts List (Form 2B). However, there are indirect
beneficial impacts associated with the development the proposed location which include
broader benefits to the community and the environment. A qualitative evaluation of beneficial
impacts to the local community and to the environment is provided below.
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Edge Environmental, Inc.
Table 17
Beneficial Impacts List for the South Leverich 13-09 OGDP (Form 2B)
Total number of existing wells that are
planned to be plugged and abandoned as
part of this Oil and Gas Development Plan
(OGDP).
0
Estimated number of truck trips that are
planned to be avoided from the above-
mentioned facility closures and equipment
upgrades (on an annual basis).
0
Total number of existing locations that are
planned to be closed and undergo final
reclamation as part of this OGDP.
0
Total number of Oil Tanks planned to be
removed from existing locations through
the approval of this OGDP.
0
Total number of acres that are planned to
be reclaimed through the closing of
existing locations.
0
Total number of Condensate Tanks
planned to be removed from existing
locations through the approval of this
OGDP.
0
Total number of existing pits that are
planned to be closed and undergo final
reclamation as part of this OGDP.
0
Total number of Produced Water Tanks
planned to be removed from existing
locations through the approval of this
OGDP:
0
Beneficial Impacts to Surrounding Community
The communities of Rifle and Silt would benefit most notably from the employment and tax
revenues generated by the proposed development plan. In addition to the direct jobs created by
the project, the development plan would support jobs in local businesses that support the
project and its employees, including retail trade, lodging and eating establishments,
construction, real estate, and other services.
Taxes paid by TEP on production would support infrastructure and community services in Rifle
and across the county. In Garfield County ad valorem (property) taxes on production fund local
governments; education and health care facilities; and fire protection, water conservation, and
sanitation services including the City of Rifle, Garfield School District No. Re-2, Rifle Downtown
Development District, Grand River Hospital, West Divide Water Conservancy District, Rifle
Branch of the Garfield County Public Library District, and Colorado River Fire Rescue.
In addition to ad valorem taxes, Rifle and other Garfield County residents would receive a
portion of state severance taxes and federal mineral royalties paid on production in the OGDP
through services provided. Severance tax on oil and gas production in Colorado is progressive,
starting at 2% and increasing with sales volume. Half of severance taxes paid to the state is
returned to local governments impacted by oil, gas, and mineral production. Nearly half (49%) of
federal mineral royalties, which are generally 12.5% of production value, are returned to
Colorado, a portion of which is allocated to local governments and school districts impacted my
mineral development.
While production-based taxes would produce the greatest benefits to local governments,
Garfield County and the City of Rifle would also receive tax revenues from property taxes paid
on physical assets and sales and use taxes paid on equipment purchases associated with the
development plan.
24
Edge Environmental, Inc.
Beneficial Impacts to Surrounding Wildlife and Ecosystems
A detailed discussion of the benefits to surrounding wildlife and ecosystem is included above
under the section titled “Terrestrial and Aquatic Wildlife Resources and Ecosystems.” As
discussed above, TEP would minimize impacts to wildlife and surrounding ecosystems by using
existing infrastructure, recycling produced water thereby reducing truck trips, installation of
buried pipelines, coordination with CPW, ground clearing outside of migratory bird habitat
restrictions, and implementation of a weed management program.
REFERENCES
Bureau of Land Management. 2017a. Colorado Air Resource Management Modeling Study
(CARMMS), 2025 CAMx Modeling Results for the High, Low, and Medium Oil and Gas
Development Scenarios. CARMMS 2.0 Final Report. Prepared by Ramboll
Environmental. Accessed online at: https://www.blm.gov/programs/natural-
resources/soil-air-water/air/colorado.
_____. 2017b. Environmental Assessment for the Proposed Balzac Gulch – Phase I Oil and
Gas Master Development Plan Project, DOI-BLM-CO-N040-2017-0093-EA. BLM
Colorado River Valley Field Office. September 2017.
_____. 2022a. Environmental Assessment for the TEP Rocky Mountain LLC Upper Beaver
Creek Project: Existing Honea 19-05 and South Leverich 13-09 Pads, DOI-BLM-CO-
G020-2022-0053-EA. BLM Colorado River Valley Field Office. June 2022.
_____. 2022b. Annual Report 2.0 - 2020. BLM Colorado State Office. Accessed online at:
https://www.blm.gov/programs/natural-resources/soil-air-water/air/colorado. Accessed
February 15, 2022.
Herrick, J.E., J.W. Van Zee, S.E. McCord, E.M. Courtright, J.W. Karl, and L.M. Burkett. 2015.
Monitoring Manual for Grassland, Shrubland, and Savanna Ecosystems, Second
Edition, Volume 1: Core Methods. USDA-ARS Jornada Experimental Range, Las
Cruces, New Mexico.
WestWater Engineering. 2021. Biological Survey Report, TEP Rocky Mountain, LLC South
Leverich 13-09 Well Pad. October.
Appendix M: Garfield County Payment Agreement Form
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