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HomeMy WebLinkAbout1.00 General Application Materials_PartM 3 Edge Environmental, Inc. 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 4 Edge Environmental, Inc. 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. 5 Edge Environmental, Inc. 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. 6 Edge Environmental, Inc. 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 7 Edge Environmental, Inc. 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 8 Edge Environmental, Inc. 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. 9 Edge Environmental, Inc. 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. 10 Edge Environmental, Inc. 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 11 Edge Environmental, Inc. 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. 12 Edge Environmental, Inc. 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 13 Edge Environmental, Inc. 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 14 Edge Environmental, Inc. 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. 15 Edge Environmental, Inc. 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. 16 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. 17 Edge Environmental, Inc. 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). 18 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, 19 Edge Environmental, Inc. 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. 20 Edge Environmental, Inc. 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. 21 Edge Environmental, Inc. 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). 22 Edge Environmental, Inc. 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. 23 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 Table of Contents