HomeMy WebLinkAbout1.21 Wildlife Mitigation PlanTPR 176-25
Underground Injection Control Well
Wildlife Mitigation Plan
CPX Piceance Holdings, LLC
34 S. Wynden Drive, Suite 240
Houston, TX 77056
WILDLIFE MITIGATION PLAN
Well Pad 25A July 2022
CPX Piceance Holdings, LLC (CPX) owns and operates Tepee Park Ranch (TPR) in Garfield County, Colorado.
CPX has prepared this Wildlife Mitigation Plan for continued development of the existing Well Pad 25A on TPR.
The sections below correspond to Colorado Oil & Gas Conservation Commission (COGCC) Rule 304.c.(17) to
prepare a Wildlife Plan consistent with Rule 1201.b and with COGCC Wildlife Protection Guidance (June 25, 2021).
1.0 Site Description and Environmental Setting
CPX owns and operates TPR, predominantly for the exploration and production of natural gas. The area is zoned
Rural by Garfield County. The existing Well Pad 25A is located in the SW ¼ SE ¼ Section 25, Township 7 South,
Range 94 West. This portion of TPR is bounded by U.S. Forest Service land to the north, south, and east.
Well Pad 25A contains two currently operating natural gas wells: TPR 1 and TPR 112-16. A third well, TPR 176-25,
is drilled but uncompleted (DUC). This well is proposed to be converted for use as an underground injection control
(UIC) well. At full build out, CPX proposes an additional 34 natural gas wells on Well Pad 25A. CPX is proposing to
use the existing 2.6-acre Working Pad Surface for well development.
During production, CPX will use existing buried flowlines to transport natural gas, condensate, and produced water
to CPX’s Pad 2 Tanks in Section 13, Township 7 South, Range 94 West. New flowlines will be buried between Well
Pad 25A and the existing CPX Well Pad 36A, approximately 4,010 feet to the south, in the SW ¼ NE ¼ Section 36,
Township 7 South, Range 94 West. The flowline corridor will be adjacent to and in the existing access road.
CPX is evaluating the ability to use the existing Well Pad 36A as a remote frac support pad for SIMOPs during well
drilling on Well Pad 25A. Using Well Pad 36A as a temporary frac support pad to conduct SIMOPs on Well Pad
25A would allow CPX to expedite the completions schedule. The ability of CPX to use Well Pad 36A as a temporary
frac support pad is dependent on COGCC review under a separate Oil and Gas Development Plan (OGDP).
Alternatively, equipment for completions would be located on Well Pad 25A.
A proposed temporary Oil and Gas Location, Pad 25B, will provide a support pad for recycled produced water and
flowback water storage during well development on Well Pad 25A. Its location overlapping the existing Tepee Park
Ranch Road disturbance northeast of Well Pad 25A is shown on the Related Location and Flowline Map submitted
with the Form 2A application. Its construction and use is dependent on separate OGDP review.
The environmental setting for Well Pad 25A is aspen woodland with an understory of native forbs and g rasses.
They include Kentucky bluegrass, blue wildrye, red baneberry, Porter’s licorice-root, tall ragwort, Fendler’s meadow-
rue, Columbian monkshood, Thimbleberry, Tall fleabane, Richardson’s geranium, and Mountain brome . An
environmental field review was conducted for Well Pad 25A and the flowline corridor on September 6, 2021. The
review area consisted of lands adjacent to the existing Well Pad 25A and the proposed flowline corridor. The review
method was field identification of plant species and vegetation sampling. Findings from the environmental review
were included in the Topsoil Protection Plan and Interim Reclamation Plan . In addition to the environmental field
review, CPX conducted a desktop review and mapping using the sources listed in Sec tion 7.0 References.
2.0 High Priority Habitat and Colorado Parks & Wildlife Consultation
Portions of Well Pad 25A are in an area designated High Priority Habitat (HPH) under Rule 1202.c.(1).R, cutthroat
trout designated crucial habitat and native fish and other native aquatic species conservation waters (within 500
feet of ordinary high water mark). The areas affected are north and south portions of Well Pad 25A, which are
between 300 and 500 feet from designated waters. They are shown on the Wildlife Habitat Drawing submitted with
the Form 2A application. The areas represent approximately 1.1 acres of the 2.6-acre Working Pad Surface.
CPX Piceance Holdings, LLC Wildlife Mitigation Plan
Well Pad 25A 2 July 2022
Rule 1202.c.(2).C allows for access road construction and flowline/utility corridor clearing and installation activities
within the HPH identified in Rules 1202.c.(1).Q-S in association with an approved Form 2A, subject to best
management practices (BMPs) or other avoidance measures agreed to in consultation with Colorado Parks and
Wildlife (CPW).
For continued development of Well Pad 25A within the HPH buffer area, CPX conducted a pre-application
consultation with officials from CPW and COGCC on May 27, 2021. CPX provided wildlife habitat mapping, a
presentation, and discussion of COGCC rule requirements regarding HPH. CPX also conducted an on-site field
review of mapped HPH areas and TPR operations. During the field review, agency staff viewed the environmental
setting, mapped water features, and the extensive controls on Well Pad 25A to prevent runoff of soils and sediments
and potential impacts to HPH. The controls include:
• The well pad has been established and stabilized since 2008.
• The well pad represents a centralized, continued use of an existing location, access, and flowlines without
creating new soil disturbance and habitat fragmentation from relocating the well pad.
• Lined steel secondary containment is sized to contain 150 percent of the largest tank to avoid impacts to
the environment from potential spills or leaks.
• The well pad surfaces and berms are hardened and stable to avoid erosion. The berms are 2 feet high and
compacted to 95 percent soil/moisture density. They are vegetated with 80 percent cover on the outside
slopes.
• An engineered 6-inch drain on the center of the well pad flows to a perimeter trench and a stormwater
catchment basin to avoid uncontrolled stormwater runoff. ,
• The surrounding topography and distances to surface water make impacts from the well pad impractical. A
mapped water feature to the south is upgradient from the well pad. A mapped water feature to the north is
cross gradient from the well pad, as confirmed on site by a representative from COGCC on September 14,
2021. Beaver Creek is approximately 1,440 feet away from the well pad to the northeast.
CPX received a waiver from CPW on June 15, 2021 for development within the Rule 1202.c.(1).R buffer.
Specifically, Rule 309.e.(5).D allows CPW to waive the application of Rule 1202.c.(1).R for new ground disturbance
between 300 and 500 feet from designated waters. In its waiver documentation, CPW stated that it incentivizes the
use of already disturbed locations when no adverse impacts are anticipated. C PW further stated that construction
of a new location, instead of continued use of the existing location, would cause more undesired disturbance and
habitat fragmentation, and would pose more risk to high priority habitat and the watershed. The BMPs required by
Rule 309.e.(5).D.i as part of CPW consultation, and additional BMPs required by CPW, are listed in Tables 3 and
4, below. The waiver provided by CPW is attached to this Plan.
CPW provided two additional and related written waivers on May 6, 2022. Under Rule 1202.a.(3), CPW waived the
restriction from staging, refueling, and Chemical storage areas within 500 feet of the Ordinary High Water Mark
(OHWM) of any river, perennial or intermittent stream, lake, pond, or wetland. Under Rule 304.b.(2).B.viii, CPW
waived the requirement to conduct an Alternative Location Analysis where the Operator obtained a waiver from
CPW for a proposed Oil and Gas Location within HPH. Through its waivers, CPW found that, among other
protections, the proposed stormwater and erosion control measures for the location are sufficient to minimize
erosion, transport of sediment, and site degradation, consistent with Rule 1002.f provisions for Stormwater
Management to limit surface water impacts. The waivers provided by CPW are attached to this plan.
CPX consulted with CPW under Rule 1202.c.2.(C) on May 27, 2021 and July 29, 2022 regarding Flowline/utility
corridor clearing and installation activities within HPH identified in Rules 1202.c.(1).Q -S. Documentation is under
separate cover with the Form 2A.
CPX Piceance Holdings, LLC Wildlife Mitigation Plan
Well Pad 25A 3 July 2022
3.0 Other Mapped Species
There are two terrestrial species with habitat mapped by COGCC within 1 mile of the Well Pad 25A Working Pad
Surface: elk and lynx. The Wildlife Habitat Drawing shows the habitat and distances listed in Table 1.
Table 1. Mapped Terrestrial Species
Mapped Habitat
Distance and Direction from
Working Pad Surface
(feet)
Elk Production1 4,350 E
Elk Winter Concentration1 5,170 E
Lynx Denning2 2,660 N and 5,130 S
Lynx Winter2 4,970 S
1COGCC COGIS High Priority Habitat
2U.S. Forest Service Habitat Data: https://www.fs.usda.gov/main/whiteriver/landmanagement/gis
Development on Well Pad 25A will avoid potential impacts to mapped elk habitat. The well pad represents a
continued land use in the area. It is separated from mapped habitat by a ridgeline and by approximately 0.75 miles
of spruce/fir forest and aspen woodlands. Elk use of habitat in the area is concentrated in the Mamm Creek area to
the east and Porcupine Creek area to the west. The combination of topography, forest cover, and distance
attenuates noise and light and avoids potential impacts to mapped habitat .
Development on Well Pad 25A will avoid potential impacts to m apped lynx habitat. The well pad represents
continued activity that has occurred historically on TPR. The well pad is separated from mapped lynx habitat by
0.50 miles of aspen woodlands to the north. It is separated from mapped habitat by approximately 1 mile of spruce/fir
forest, aspen woodlands, and two ridgelines to the south.
In 2017, CPX prepared an Environmental Assessment under the National Environmental Policy Act to support U.S.
Forest Service review of CPX’s proposed pipeline and road construction and road use on Forest Service Land north
of TPR. The affected area was adjacent to the mapped lynx habitat shown to the north of Well Pad 25A and listed
in Table 1. The Forest Service approved CPX’s pipeline and road construction and road use with a Finding of No
Significant Impact and issued a pipeline right-of-way and road use permit. In its Decision Notice (November 3, 2017)
the Forest Service stated its finding that there would be no significant adverse effects on wildlife and their habitat ,
including from construction and road use on National Forest System Road 824 adjacent to the lynx denning habitat
in Section 25, Township 7 South, Range 94 West.
In addition to the Forest Service review described above, the White River National Forest Land and Resource
Management Plan (Forest Plan) (2002) establishes objectives for lynx. The Plan lists protecting water quality and
habitat connectivity in linkage areas; managing vegetation, grazing, and recreation; and discouraging snow
compaction in lynx habitat. There are no references in the Forest Plan to noise or light in relation to lynx. The Forest
Service prepared a Southern Rockies Lynx Amendment (2008) with updated management direction for eight forest
plans, including White River National Forest. In its discussion of energy development, the Amendment discusses
additional guidelines for winter access and for reclamation plans in lynx habitat. There are, again, no references to
noise or light in relation to lynx. The Amendment concludes that any site-specific effects will be determined at an
Application for Permit to Drill (APD) stage or a Geographic Planning stage.
A 2011 CPW study of habitat use by radio-collared lynx reintroduced to Colorado found that the average elevation
for lynx habitat was 10,780 feet with the majority of habitat located between 9,900 feet and 11,620 feet. Well Pad
25A is located at approximately 9,129 feet in elevation, which is almost 800 feet lower in elevation than the majority
of lynx habitat, and approximately 1,630 feet below the average elevation of lynx habitat. Activity on Well Pad 25A
CPX Piceance Holdings, LLC Wildlife Mitigation Plan
Well Pad 25A 4 July 2022
avoids impacts to lynx habitat on a horizontal plane from the distance between the well pad and habitat, and also
on a vertical plane from the difference in elevation.
4.0 Rule 1202.a Requirements
Table 2 describes how the operator will implement Rules 1202.a.(1-10) and 1202.b for the Oil and Gas Location.
Table 2. Rule 1202.a Requirements
Provision Implementation
1202.a.(1) The operator will install and use bear-proof dumpsters and trash receptacles for unsecured
food-related trash at facilities that generate trash.
1202.a.(2) The operator will not withdraw from or discharge into surface waters.
1202.a.(3) The operator will not situate new staging, refueling, or chemical storage areas within 500
feet upgradient of the ordinary high water mark of any river, perennial or intermittent stream,
lake, pond, or wetland.
1202.a.(4) The Oil and Gas Location will have no drilling, production, or other fluid pits.
1202.a.(5) Trenches left open for more than 5 consecutive days during construction of flowlines
regulated under the 1100 Series Rules will have wildlife escape ramps at a minimum of one
ramp per ¼ mile of trench.
1202.a.(6) When conducting interim and final reclamation pursuant to Rules 1003 and 1004, the
operator will use CPW-recommended seed mixes for reclamation when consistent with any
local soil conservation district requirements.
1202.a.(7) The operator will use CPW-recommended fence designs when consistent with any relevant
local government requirements.
1202.a.(8) The operator will conduct all vegetation removal necessary for oil and gas operations outside
of the nesting season for migratory birds (April 1 to August 31). For any vegetation removal
that must be scheduled between April 1 to August 31, the operator will implement appropriate
hazing or other exclusion measures prior to April 1 to avoid take of migratory birds. If hazing
or other exclusion measures are not implemented, the operator will conduct pre-construction
nesting migratory bird surveys within the approved disturbance areas prior to any vegetation
removal during the nesting season. If active nests are located, the operator will provide work
zone buffers around active nests.
1202.a.(9) The Oil and Gas Location will have no drilling, production, or other fluid pits.
1202.a.(10) The Oil and Gas Location is not located between 500 feet and 1000 feet hydraulically
upgradient from an HPH identified in Rule 1202.c.(1).Q-S. The location is downgradient to
the south, cross-gradient to the north, and 1,440 feet to the northeast from waters designated
as HPH. CPX will comply with conditions in Rule 1202.a.(10).A-E as a condition of the CPW
HPH waiver granted under Rule 309.e.(5).D. The conditions are listed in Table 3.
1202.b The operator will bore, rather than trench, flowline crossings of perennial streams identified
as aquatic HPH. Separately, the operator will excavate under existing culverts for crossings
of dry drainages or intermittent streams.
5.0 Rule 309.e.(5) Requirements
Table 3 lists the operator’s BMPs, as required for waivers granted by CPW under Rule 309.e.(5).D.i for Rule
1202.c.(1).R HPH.
CPX Piceance Holdings, LLC Wildlife Mitigation Plan
Well Pad 25A 5 July 2022
Table 3. Rule 309.e.(5).D.i Best Management Practices
Provision Best Management Practices
309.e.(5).D.aa The operator will contain flowback and stimulation fluids in tanks that are placed on a
Working Pad Surface in an area with downgradient perimeter berming.
309.e.(5).D.bb The operator will construct lined containment devices pursuant to Rule 603.o around any
new condensate and produced water storage tanks. There will be no crude oil storage on
the well pad.
309.e.(5).D.cc The operator will inspect the location daily.
309.e.(5).D.dd The operator will maintain adequate spill response equipment on the location during drilling
and completion operations.
309.e.(5).D.ee There will be no construction or utilization of fluid pits.
Table 4 lists the additional BMPs established by CPW under Rule 309.e.(5).A as a condition of granting the Rule
1202.c.(1).R waiver.
Table 4. Rule 309.e.(5).A Best Management Practices
BMP Best Management Practices
Spill Protection
1
To protect against spills from the well pad, existing well pad fill slopes have 2-foot-high high
earthen berms compacted to 95 percent soil/moisture density. The outside slopes of the
berms have 80 percent vegetative cover. The berms are stable with high structural integrity.
2
To protect against spills from tanks, steel secondary containment is sized to 150 percent of
the largest tank. The secondary containment liner is sprayed in to optimize its seal. Spill
response material is permanently stored on Well Pad 25A.
Stormwater Protection
3
To protect against runoff, there is no uncontrolled stormwater on the well pad. The well pad
has a 6-inch drain in the center. The drain is piped outside of the berm to a trench. The
trench drains to a catchment basin. Solids settle in the catchment basin for removal. The
stormwater evaporates.
4
To protect against erosion, the road has a borrow ditch on the upslope side. Stormwater is
diverted to 18 to 24-inch culverts spaced at 600-foot intervals. The frequent culverts prevent
erosion by avoiding long runs of stormwater and slowing velocity.
Stream Protection
5
To protect Beaver Creek, its road crossing was designed in consultation with the U.S. Army
Corps of Engineers. The crossing is an open bottom arch with concrete footers to maintain
the streambed integrity.
6 To protect Beaver Creek, process equipment and tank loadout were relocated to Pad 2,
approximately 3 miles away.
7 To protect Beaver Creek, the existing water pipeline was designed to be bidirectional.
Delivering freshwater to TPR by pipeline eliminates haul traffic for water delivery.
Inspections
8
To minimize potential for undetected spills, runoff, and pipeline leaks, personnel are on site
approximately 5 days/week. Field staff live within 15 minutes of the well pads, which
facilitates consistent on-site presence.
9 Pipelines are monitored for pressure loss and are tested annually.
CPX Piceance Holdings, LLC Wildlife Mitigation Plan
Well Pad 25A 6 July 2022
6.0 General Operating Requirements
Table 5 lists general statewide standard operating requirements to protect wildlife habitat and resources.
Table 5. General Operating Requirements
BMP The Operator Will
1 Inform and educate employees and contractors on wildlife conservation practices, including
no harassment or feeding of wildlife.
2 Consolidate and centralize fluid collection and distribution facilities to minimize impact to
wildlife.
3 Adequately size infrastructure and facilities to accommodate both current and future gas
production.
4 Design road crossings of streams at right angles to all riparian corridors and streams to
minimize the area of disturbance.
5 Implement fugitive dust control measures.
6 Install screening or other devices on the stacks and on other openings of heater treaters or
fired vessels to prevent entry by migratory birds.
7 Minimize rig mobilization and demobilization by completing or re-completing all wells from a
given well pad before moving rigs to a new location.
8 To the extent practicable, share and consolidate new corridors for pipeline rights-of-way to
minimize surface disturbance.
9 Engineer new pipelines to reduce field fitting and reduce excessive right -of-way widths and
reclamation.
10 Mow or brush hog vegetation where appropriate, leaving root structure intact, instead of
scraping the surface, where allowed by the surface owner.
11 Limit access to oil and gas access roads where approved by surface owners, surface
managing agencies, or local government.
12 Post speed limits and caution signs to the extent allowed by surface owners, federal and
state regulations, local government, and land use policies.
13 Use wildlife-appropriate fencing where acceptable to the surface owner.
14 Use topographic features and vegetative screening to create seclusion areas, where
acceptable to the surface owner.
15 Use remote monitoring of well production to the extent practicable.
16 Reduce traffic associated with transporting drilling water and produced liquids through the
use of pipelines, large tanks, or other measures.
17 Store and stage emergency spill response equipment at strategic locations along perennial
water courses so that it is available to expedite effective spill response.
18 Construct all crossings at right angles to the stream.
19 Install automated emergency response systems (e.g., high tank alarms, emergency
shutdown systems).
20 Avoid dust suppression activities within 300 feet of the ordinary high water mark of any
reservoir, lake, wetland, or natural perennial or seasonally flowing stream or river.
CPX Piceance Holdings, LLC Wildlife Mitigation Plan
Well Pad 25A 7 July 2022
7.0 References
1. COGIS High Priority Habitat Layers.
2. Critical Habitat IPaC Report: https://ecos.fws.gov/ipac/.
3. Migratory Birds: https://www.fws.gov/birds/index.php.
4. State Protected Species: https://cpw.state.co.us/learn/Pages/SpeciesProfiles.aspx .
5. Buffer Zones and Seasonal Restrictions for Colorado Raptors:
https://cpw.state.co.us/Documents/WildlifeSpecies/LivingWithWildlife/Raptor -Buffer-Guidelines.pdf.
6. U.S. Forest Service Habitat Data: https://www.fs.usda.gov/main/whiteriver/landmanagement/gis.
7. U.S. Geological Survey, National Hydrography Dataset.
8. Areas of high habitat use from 1999-2010 for radio-collared Canada lynx reintroduced to Colorado: Lynx
habitat use (state.co.us).
Attachments
Colorado Parks and Wildlife Waiver from Rule 1202.c.(1).R (June 15, 2021)
Colorado Parks and Wildlife Waiver from Rule 1202.a.(3) (May 6, 2022)
Colorado Parks and Wildlife Waiver from Rule 304.b.(2).B.viii (May 6, 2022)
From: Ne umann - DNR, Dani e l l e <danielle.neumann@state.co.us>
Se nt: Tuesday, June 15, 2021 1:58 PM
To: nick@cpx pi ce ance.com
Cc: Taylor El m - DNR <taylor.e l m@state.co.us>; ByBee - DNR, Travis <travis.bybe e @state .co.us>; Bryan Cl ark <bryan@cpxpiceance .com>;
gwen.brodsky@aota.tech; Ke nt Ri der <kentrider@hotmail.com>
Subje ct: Re : CPX - Variance Request
Hello Again,
Here is CPW 's s tatement regarding TPR Pad 25A. After reviewing the pres entation you gave to us on May 27, I decided to type up the BMPs for easy
reference. I know these will be detailed in your package but m ore docum entation is better than less! Please let us know if you have any ques tions.
This serves as CPW 's written waiver for the continued us e of Pad 25A, portions of which are affected by Rule 1202.c.(1).R (c utthroat trout des ignated
cruc ial habitat). CPW staff visited this location on May 27, 2021, to determine if a waiver was appropriate. CPW incentiviz es the us e of already
dis turbed loc ations when no adverse impacts are anticipated. Construc tion at a new location, instead of continued use of Pad 25A, would c aus e more
undesired dis turbance and pose more risk to High Priority Habitats and the waters hed. Pad 25A’s location boundary and access road will not expand.
CPX has propos ed a list of 10 BMPs to avoid advers ely im pac ting Beaver Creek, aquatic habitat, and the watershed. CPW m ay is s ue a waiver, with
the application of prescribed BMPs, per rule 309.e.(5).D. CPW expec ts thes e measures to be sufficient and supports the c ontinued use of Pad 25A.
Spill Protection
To protect against spills from the well pad, existing well pad fill s lopes have 2’ high earthen berms compacted to 95% s oil/mois ture density. The
outside s lopes of the berms have 80% vegetative cover. The berm s are stable with high structural integrity.
To protect against spills from tanks, steel sec ondary c ontainm ent is siz ed to 150% of the largest tank. The secondary c ontainm ent liner is
sprayed in to optim ize its seal. Spill response material is permanently stored on Pad 25. TPR has not experienc ed a s pill to date.
Stormwater Protec tion
To protect against runoff, there is no uncontrolled stormwater on the well pads . W ell pads have 6” drains in the center. The drain is piped outside
of the berm to a lined trench. The trench drains to a lined catchm ent. Solids s ettle in the catchment for removal. The s torm water evaporates .
To protect against erosion, the road has a borrow ditc h on the ups lope side. Storm water is diverted to 18”-24” culverts spaced at 600’ intervals .
Frequent culverts prevent erosion by avoiding long runs of stormwater and slowing velocity.
Stream Protec tion
To protect Beaver Creek, the road crossing was designed in consultation with the USACE. It is an open bottom arc h with c onc rete footers to
m aintain the s tream bed integrity.
To protect Beaver Creek, process equipment and tank loadout were reloc ated to Pad 2, approximately 3 miles away.
To protect Beaver Creek, the water pipeline was designed to be bidirectional. Delivering freshwater to TPR by pipeline elim inates haul traffic for
water delivery.
To protect Beaver Creek, no proppant is antic ipated for future well development, which eliminates haul traffic for proppant.
Ins pec tions
To minim ize potential for undetected spills, runoff, and pipeline leaks , personnel are on site approximately 5 days /week. Field staff live within 15
m inutes of the well pads, which facilitates cons istent on-s ite pres enc e.
Pipelines are m onitored for pressure loss and are tes ted annually.
Thank you,
Danielle Neumann
Land Use Specialist
Northwest Region
C: 970-366-1223
0088 Wildlife Way Glenwood Springs CO 81601