Loading...
HomeMy WebLinkAbout1.00.d Project NarrativeCPX Piceance Holdings, LLC 34 S. Wynden Drive, Suite 240 Limited Impact Review Garfield County, Colorado Houston, TX 77056 TPR Well Pad 36A Article 9 Oil and Gas Permit Application Project Narrative 1 Project Narrative I. Introduction CPX Piceance Holdings, LLC (“CPX”), the Applicant, requests an Oil and Gas Permit for the continued use of existing TPR Well Pad 36A (“Pad 36A”). Pad 36A is an existing Oil and Gas Location (COGCC Loc ID 334460) owned and operated by CPX on Tepee Park Ranch (“TPR”). TPR is an approximate 5,000-acre privately owned ranch with existing natural gas operations and infrastructure located approximately twelve miles south of Rifle in Garfield County, Colorado. The Parcel Number is 245306100005 and the parcel size is 1,664 acres. The parcel is zoned Rural. II. Project Description CPX proposes to drill, complete, and operate thirty-two directionally drilled natural gas wells from Pad 36A. Of these thirty-two proposed wells, seven wells will be directionally drilled into federal minerals leased by CPX, and twenty-five wells will be directionally drilled into fee minerals underlying TPR and owned 100% by CPX. In addition to the thirty-two proposed wells, there are three previously permitted wells located on Pad 36A. None of these wells are, or ever were, actively producing. Concurrent with this Application, CPX submitted an application to the Colorado Oil and Gas Conservation Commission (“COGCC”) for an Oil and Gas Development Plan (“OGDP”) and a Rule 502 variance to COGCC Rule 1202.c.(1).R. The OGDP application requests approval for the continued use of the existing 5.45-acre Pad 36A Oil and Gas Location and an approximate 377-acre Mineral Development Area for the development and production of the thirty-two natural gas wells proposed for development from Pad 36A. The OGDP application also requests approval to use Pad 36A as a remote frac location to support completions operations for natural gas wells already approved for development from the existing TPR Well Pad 25A (“Pad 25A”) (COGCC Loc ID 334457). On November 8, 2022, prior to submittal of the COGCC OGDP and Variance application, CPX sent formal notice to Garfield County under COGCC Rule 302.e. A. Location Description Pad 36A is an existing Oil and Gas Location located on TPR on the below lands in Garfield County: SW¼NE¼, Section 36, Township 7 South, Range 94 West, 6th P.M. The existing Pad 36A Oil and Gas Location is 5.45 acres with a Working Pad Surface of 2.06 acres. After interim reclamation, the Working Pad Surface will be reduced to approximately 1.34 acres. CPX is not proposing any additional surface disturbance beyond the existing footprint of the Oil and Gas Location. An Overview Map for the Pad 36A Location is included, below: 2 B. Support Facilities 3 CPX will utilize two existing Oil and Gas Locations and one approved, but not yet completed, Oil and Gas Location as support facilities during drilling, completion, and production operations associated with the proposed wells on Pad 36A. Pad 25A (COGCC Loc ID 334457) is proposed to be utilized as a remote frac support location for well stimulation operations for the thirty-two proposed wells on Pad 36A. Pad 25A is an existing Oil and Gas Location located on private surface on TPR in SW¼SE¼, Section 25, Township 7 South, Range 94 West. Pad 25A has two existing, producing natural gas wells and one drilled-but-uncompleted well. On September 21, 2022, the COGCC approved the TPR Pad 25A OGDP authorizing CPX to drill and produce thirty-four new natural gas wells on TPR Pad 25A and convert the existing drilled-but-uncompleted well into a Class II UIC well. CPX plans to utilize the proposed Class II Underground Injection Control (UIC) well to be located on Pad 25A to dispose of excess completions water from well development on Pad 36A and to dispose of produced water during production operations on Pad 36A. This will significantly reduce truck traffic associated with well development and production operations on Pad 36A. Temporary Water Support Pad 25B (Pad 25B) (COGCC Loc ID 482984) is an approved, but not yet constructed, Oil and Gas Location that will be utilized for temporary storage of recycled produced water and water from well completions to support the development of the Pad 36A wells. Pad 25B will be constructed on private surface on TPR in SW¼SE¼, Section 25, Township 7 South, Range 94 West. COGCC approved the TPR Pad 25B OGDP on September 21, 2022. The TPR Pad 2 Tank Facility (Pad 2) (COGCC Loc ID 455779) is an existing Oil and Gas Location located on CPX private property in Section 13, Township 7 South, Range 94 West. Pad 2 is a centralized tank facility with no producing wells. Recycled produced water to support completions on Pad 36A is anticipated to be delivered to Pad 25B using CPX’s existing buried bidirectional water flowline located within the road corridor of Forest Service Road (“FSR”) 824. Water will be sourced as recycled produced water from TEP Rocky Mountain LLC’s Beaver Creek Pit through a Water Share Agreement with TEP. CPX anticipates using treated recycled produced water and water from well completions on TPR to support completion operations at Pad 36A. CPX will install temporary steel surface frac lines connecting Pads 25A, 25B, and 36A to transfer this water across TPR. CPX also plans to install buried flowlines located adjacent to the existing TPR road between Pads 25A and 36A to transfer produced water, condensate, and natural gas during production operations from Pad 36A to Pad 25A. CPX anticipates that the majority of produced water will be injected using the proposed Class II UIC well on Pad 25A. Condensate and natural gas, and any excess produced water, will be transported to Pad 2 using the existing system of buried flowlines. CPX does not propose any other pipelines to support the development and operation of the wells on Pad 36A. 4 B. Project Schedule Construction activities for Pad 36A are scheduled to begin July 2023. Drilling operations for the proposed thirty-two directional wells are scheduled to begin in January 2024 and are expected to take approximately 32 weeks to complete. Well completion operations are expected to begin in March 2024 and are expected to take approximately 32 weeks to complete. Interim reclamation will begin in June 2025, within six months following completion of well construction and stimulation activities. After well drilling and completion, the Working Pad Surface on Pad 36A will be reduced to 1.34 acres through interim reclamation. The area to be reclaimed will be tilled or disked and hydro-seeded. Production is expected to begin in May 2024. III. Type of Permit Being Submitted Pad 36A is subject to the Oil and Gas Permit application requirements of Article 9 of the Garfield County Land Use and Development Code (“LUDC”) because the continued use of the existing Oil and Gas Location requires an Alternative Location Analysis (“ALA”) under COGCC Rules 304.b.(2).B.vii and viii. See LUDC § 9-201.F.1. CPX prepared a comprehensive ALA in accordance with COGCC’s Operator Guidance for Rule 304.b.(2) Alternative Location Analyses (December 15, 2020). The ALA was submitted with CPX’s October 21, 2022 pre-application letter to Garfield County and is included with this Application as Appendix I. IV. Pre-Application Process and Required Materials A. Pre-Application Conference Request and Summary Pursuant to LUDC § 9-203.A, CPX requested a pre-application conference with Garfield County prior to submittal of this Oil and Gas Permit Application. CPX provided the first written pre-application meeting request to Garfield County on August 25, 2021. The request package contained background information, mapping for the location and location alternative, a record of correspondence with CPW, a detailed location description, and cultural feature setback distances and bearings. See Appendix F. CPX and Garfield County held an initial pre-application meeting on September 15, 2021. The September 15, 2021 pre-application meeting was attended by the Garfield County Community Development Director, Principal Planner, Oil and Gas Liaison, and permitting consultant. Participants from COGCC included the Planning and Permitting Manager, Environmental Manager, and Oil and Gas Location Assessment Specialists for the Western, Northeast, and Southeast regions. CPX submitted a request for a follow-up pre-application meeting to Garfield County on October 21, 2022. This request package refreshed the previous information and provided a detailed ALA containing four alternative locations, photographs, a written narrative, and a comparative matrix of alternatives. See Appendix F. CPX, the Garfield County Oil and Gas Liaison, and two Garfield County permitting consultants held a second pre-application meeting on November 28, 2022. 5 The pre-application summaries for the September 15, 2021 meeting and November 28, 2022 meeting, provided in accordance with LUDC § 9-203.E, are attached as Appendix G. B. Neighborhood Meeting During the second pre-application meeting, Garfield County instructed CPX that a formal neighborhood meeting under LUDC § 9-203.D is not required for Pad 36A because the only neighboring property owner is the U.S. Forest Service, which has been consulted extensively regarding the proposed development. CPX’s own Operations Manager, who is integrally involved in the permit process, also grazes cattle on Tepee Park Ranch as a grazing licensee. CPX has summarized its consultation meetings with the Forest Service and the grazing licensee in Appendix H. V. Oil and Gas Permit Application Materials The following sections address the Oil and Gas Permit Application requirements under § 9-204 of the LUDC. A. Applicant’s Name and Email Address A Land Use Change Permit Application Form is included as Appendix A and includes the applicant’s name and contact information. See LUDC § 9-204.B.1.a. B. Type of Application Being Submitted CPX is applying for an Oil and Gas Permit under Article 9 of the LUDC. The existing Pad 36A is located within 300 feet of mapped designated cutthroat trout HPH and located upgradient of a mapped visible riparian corridor. CPX is required to complete an ALA under COGCC Rules 304.b.(2).B.vii and viii. Under LUDC § 9-201.F.1, this Oil and Gas Location requires an approved Oil and Gas Permit from Garfield County. See LUDC § 9-204.B.1.b. C. Vicinity Map A Vicinity Map depicting the current location of Pad 36A is included as Appendix B. The vicinity map depicts Section/Township/Range and nearby public roads as required by LUDC § 9-204.B.1.c. D. Name and Contact Information for the Applicant Per LUDC § 9-204.B.1.d., the name and contact information (including email) for the designated CPX representative is included on the Land Use Change Permit Application Form. See Appendix A. E. Topographic Map A topographic map is included in Appendix C. This map depicts all the applicable requirements identified in LUDC § 9-204.B.1.e. 6 F. Access Roads Existing access roads will be used to access Pad 36A. From Rifle, Colorado, Pad 36A may be accessed using the following roads: • West on 7th St. • South on Garden Lane • West on County Road 320 (CR 320 or “Rifle-Rulison Rd.”) for 3 miles • South on County Road 317 (CR 317) for 5.5 miles • South on Forest Service Road 824 (FSR 824) for 2.75 miles • South on Tepee Park Ranch Road, privately owned by CPX, for 1.5 miles For county road use on CR 317 and CR 320, CPX conducted a third-party Traffic Analysis in December 2022 of trip generation, trip distribution, and potential traffic impacts. The Traffic Analysis concluded that CPX-related traffic will be successfully incorporated into the existing roadway network. No improvements or recommendations are anticipated to be needed based on very low CPX traffic volumes on CR 317 and CR 320. CPX’s commercial use of FSR 824 is authorized by a perpetual Forest Road Easement granted to CPX. CPX conducts road maintenance in accordance with the provisions of an operation and maintenance agreement between CPX and the Forest Service and an annual operating agreement. CPX financed and self-performed significant road realignment and stormwater control improvements to FSR 824 following a National Environmental Policy Act review conducted by the Forest Service. The road realignment moved portions of the road away from Beaver Creek. The stormwater improvements consisted of culvert installations with armored upstream and downstream inlets and outlets. CPX privately owns the existing Tepee Park Ranch Road on TPR. The road is 20 feet wide and crowned in the center for drainage. It has a crushed shale surface for dust control. It has a borrow ditch and stormwater culverts placed at approximately 600-foot intervals for stormwater control. CPX waters the road using freshwater purchased from a commercial third-party, which is transported by water truck to wet the road and form a crust for sediment control. G. Legal and Factual Grounds for Alternative Location Analysis An ALA is required for Pad 36A under COGCC Rules 304.b.(2).B.vii and viii. The Pad 36A ALA comprehensively evaluates four proposed alternatives in addition to Pad 36A. CPX determined through the ALA process that the existing Pad 36A is the preferred alternative as this location minimizes the potential impact to public health, safety, welfare, the environment, and wildlife resources. The ALA also demonstrates that the continued use of Pad 36A will minimize impacts to County resources, by reducing truck 7 traffic associated with the construction of a new location. The Pad 36A ALA is included with the Form 2A for the TPR 36A Oil and Gas Location. See Appendix I. The use of Pad 36A helps realize over five years of thoughtful development, planning, and coordination with COGCC, Garfield County, the U.S. Forest Service, and BLM. As part of these efforts, CPX rerouted FSR 824 away from cutthroat trout HPH; built stormwater diversions and armored culverts along FSR 824; buried natural gas, condensate, and water flowlines; and built a new pad for condensate and produced water loadout off TPR that will significantly reduce truck traffic associated with the production of the proposed wells. The improvements were conducted with the goal of developing TPR in the least impactful and most efficient manner possible by relying on the existing well pads and infrastructure already constructed on TPR—the continued use of TPR Pad 36A is an integral component of this long-term planning. The Pad 36A ALA demonstrates that the requested variance will minimize new surface disturbance, erosion, and construction-related truck traffic associated with the proposed well development. See Appendix I §§ 2–5 (description of alternatives). The existing location has been established since 2008. Disturbance is complete. The location is stable and has multiple layers of spill, stormwater, and erosion controls to protect surface water. H. Evidence of Liability Insurance Per LUDC § 9-204.B.1.g., a Certificate of Liability Insurance is included in Appendix D. The provided insurance certificate meets the requirements of LUDC § 9-211. I. Report, Study, or Plan Assessing Impacts CPX has attached the following plans as appendices to address the requirements of LUDC § 9-204.B.1.h: Cumulative Impacts Plan, Appendix K Noise Mitigation Plan, Appendix J Light Mitigation Plan, Appendix J Wildlife Plan, Appendix K Electricity will be supplied using electric generators during the drilling and completion phases of the project. During production, the location will use source gas to power an electric generator. No local utilities serve the location. Pad 36A is located entirely on private land. Pad 36A does not require public road rights-of-way or construction of new access roads. Access road construction is complete. Access to Pad 36A uses existing CR 320, CR 317, FSR 824, and the private TPR Road. The continued use of the existing Pad 36A will result in less impacts on County resources when compared to construction of an alternative location not subject to County permitting under Article 9. 8 J. Additional Information Requested by Garfield County In the November 28, 2022 pre-application meeting, Garfield County requested that CPX submit a Grading and Drainage Plan consistent with LUDC § 4-203.E. See LUDC § 9-204.B.1.i. The Grading and Drainage Plan is attached as Appendix M. At the request of Garfield County, information serving as a Noise and Light Mitigation Plan is attached in Appendix J. K. Statement of Authority A copy of the executed and notarized Garfield County Statement of Authority for CPX’s Principal Nicholas Kurtenbach is included as Appendix E. See LUDC § 9-204.B.1.j. L. Application Fees The appropriate fees associated with this Oil and Gas Permit application are included with this submittal as required under LUDC § 9-204.B.1.k. A copy of the Payment Agreement Form is included as Appendix N. M. Information Required by COGCC and Traffic Study The required plans submitted to COGCC with CPX’s OGDP and Variance Application and Form 2A are included in Appendix K per LUDC § 9-204.B.2.a.-b.: Submitted Form 2A Materials and Attachments • Cultural Distances Table – Rule 304.b.(3) • Location Pictures – Rule 304.b.(4) • Site Equipment List – Rule 304.b.(5) • Flowline Descriptions – Rule 304.b.(6) • Drawings – Rule 304.b.(7) o Location Drawing o Layout Drawings o Wildlife Habitat Drawing o Hydrology Map o Access Road Map o Related Location and Flowline Map o Geologic Hazard Map • Geographic Information System (“GIS”) Data – Rule 304.b.(8) • Land Use Description and Reference Area Data – Rule 304.b.(9) • NRCS Map Unit Description – Rule 304.b.(10) • Best Management Practices – Rule 304.b.(11) • Surface Owner Information – Rule 304.b.(12) • Dust Mitigation Plan – Rule 304.c.(5) • Transportation Plan – Rule 304.c.(6) • Operations Safety Management Plan – Rule 304.c.(7) • Emergency Response Plan – Rule 304.c.(8) 9 • Waste Management Plan – Rule 304.c.(11) • Topsoil Protection Plan – Rule 304.c.(14) • Stormwater Management Plan – Rule 304.c.(15) • Interim Reclamation Plan – Rule 304.c.(16) • Wildlife Plan – Rule 304.c.(17) • Water Plan – Rule 304.c.(18) • Cumulative Impacts Plan – Rule 304.c.(19) Several plans are not required under COGCC Rule 304.c. They are: • Emergency Spill Response Program – Rule 304.c.(1) • Flood Shut-In Plan – Rule 304.c.(9) • Noise Mitigation Plan – Rule 304.c.(2) • Light Mitigation Plan – Rule 304.c.(3) • Odor Mitigation Plan – Rule 304.c.(4) • Community Outreach Plan – Rule 304.c.(20) • Geologic Hazard Plan – Rule 304.c.(21) At the request of Garfield County, information serving as a Noise and Light Mitigation Plan is attached in Appendix J. The Traffic Study required under LUDC § 9-204.B.2.c is attached as Appendix L. VI. Notice Package CPX will comply with the notice and publication requirements identified under LUDC §§ 9-208 and 4-1001.E. A preliminary draft of the Notice Package including an executed Certification of Mineral Owner Research and list of notice recipients is included as Appendix P. CPX will send notice to the U.S. Forest Service as the only adjacent property owner within a 200-foot radius of the subject parcel under LUDC § 4-1001.E.b.3 and the only owner of property within 2,000 feet of the Working Pad Surface under LUDC § 9-208.1. CPX will send notice to the U.S. Bureau of Land Management as the owner of minerals subject to development under the proposed project as required under LUDC § 4-1001.E.b.4. CPX will send notice to the Director of the COGCC as required under LUDC § 9-208.3. The project is located in Garfield County. There are no other local governments within one mile of the project site. CPX will send notice to Garfield County under LUDC § 9-208.2. There are no tenants of any residential or commercial properties within 2,000 feet of the TPR Pad 36A Working Pad Surface under LUDC § 9-208.1. CPX will provide notice to its grazing licensee, Bryan Clark, who is also Operations Manager for CPX.