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HomeMy WebLinkAbout1.24 Article 7 Division 1 (General Approval Standards Narrative) Administrative Review CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 TPR 176-25 Underground Injection Control Well General Approval Standards Narrative TPR 176-25 UIC Well Article 7: Standards - Division 1. General Approval Standards General Approval Standards Narrative Administrative Review 1 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 1. Introduction The following narrative addresses the requirements for the General Approval Standards under Article 7, Division 1 of the Garfield County Land Use and Development Code (LUDC). 2. Section 7-101. ZONE DISTRICT USE REGULATIONS. The Land Use Change shall comply with Article 3, Zoning, including any applicable zone district use restrictions and regulations. The proposed facility will comply with all zone district restrictions and regulations. The subject parcel is zoned Rural and meets all setback requirements of the Rural zone district. The proposed Class II underground injection control (UIC) well will be located approximately 2,200 feet from the nearest property line. Adjacent parcel owners and adjacent property figure are located in the Parcel Details tab. 3. Section 7-102. COMPREHENSIVE PLAN AND INTERGOVERNMENTAL AGREEMENTS. The Land Use Change is in general conformance with the Garfield County Comprehensive Plan and complies with any applicable intergovernmental agreement. The Applicant is not aware of any applicable Intergovernmental Agreement. The proposed UIC well is located within the Comprehensive Plan’s Residential Medium High (RMH) with a density of 1 dwelling unit per 2 to 6-acres land use designation. While the subject parcel has been designated RMH in the Comprehensive Plan, the subject parcel is not located adjacent to a County Road and must be accessed via a forest service road. The parcel does not border any current residential parcels and is topographically isolated from any public utilities and county roads. The RMH density of residential uses states “Within this range, density is determined by the degree of clustering and the amount and quality of land preserved in open condition.” The TPR 176-25 UIC well site meets the following applicable goals and policies listed in the Comprehensive Plan for Mineral Extraction. 3.1. Comprehensive Plan Mineral Extraction: Vision Ensure that mineral extraction is regulated appropriately to promote responsible development and provide benefit to the general public. The proposed use, Small Injection Well, will comply with all Garfield County and Colorado state regulations. CPX submitted a Form 31 Underground Injection Formation TPR 176-25 UIC Well Article 7: Standards - Division 1. General Approval Standards General Approval Standards Narrative Administrative Review 2 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 Permit Application – Intent, a Form 33 Injection Well Permit Application – Intent, and a Form 2 Application for Permit to Recomplete and Operate for the TPR 176-25 UIC Well to COGCC concurrent with CPX’s submission of an Oil and Gas Development Plan (OGDP) application for the TPR Pad 25A OGDP. The installation of the proposed UIC well will benefit the general public by being located within close proximity to CPX’s producing wells and within CPX’s Tepee Park Ranch (TPR) operations area. The proposed UIC well will significantly reduce truck traffic on public roads. The UIC well will serve as a central location for disposal of produced water and flowback water, rather than having to haul produced water on public county roads to a disposal facility. Ensure that mineral extraction activities mitigate their effects on the natural environment, including air quality, water quality, wildlife habitat or important visual resources. In compliance with the Garfield County Comprehensive Plan (GCCP), the UIC well is designed to minimize any impact to adjacent land. CPX is utilizing an existing uncompleted well. A UIC well on TPR will significantly reduce truck traffic on public roads. Reducing traffic truck will minimize impacts on air quality and potential impacts to water quality. Details on the facility equipment and design are located in the Project Description Narrative (Application tab). Floodplain areas are not located in the site perimeter or within the vicinity of the site. There are no streams, areas subject to flooding, high ground water areas, and lakes within the perimeter of Well Pad 25A. Well Pad 25A was constructed with stormwater and drainage control features to mitigate potential surface run-off. The UIC well is not located within one mile of any residential buildings units or designated outdoor areas. The proposed UIC well is located approximately 2,200 feet from the nearest parcel boundary (owned by a different surface owner) to the north. CPX will adhere to the Wildlife Mitigation Plan developed for Well Pad 25A and to best management practices agreed upon with CPW and COGCC. 3.2. Comprehensive Plan Mineral Extraction: Policy and Strategy Policy 1. Strategy vii. Continue to consider the use of facilities that are appurtenances to oil/gas development activities (compressors, etc.) appropriate in all land uses so long as they meet the respective mitigation requirements of the LUCD to maintain compatibility with surrounding land uses. The proposed UIC well is a necessary accessory to natural gas extraction performed by CPX. The location of the proposed UIC well was designed to achieve optimal efficiency while minimizing impacts. The proposed site will meet the criteria for the current LUDC’s TPR 176-25 UIC Well Article 7: Standards - Division 1. General Approval Standards General Approval Standards Narrative Administrative Review 3 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 Rural Zone District standards and setbacks. The proposed UIC well is located on a 1,664-acre parcel. The UIC well will provide support to current and proposed oil and gas operations within CPX’s TPR and will reduce truck traffic on public roads. Policy 2: Mineral resource extraction activities will protect critical wildlife habitat as identified by state and federal agencies and preserve or mitigate natural drainage patterns from the impacts of extraction activities. The TPR 176-25 well and Well Pad 25A were previously constructed. CPX received a waiver from Colorado Parks and Wildlife (CPW) for a location between 300 and 500 feet of cutthroat trout high priority habitat (HPH) and will comply with all applicable BMPs. The nearest mapped terrestrial HPH is Elk Production HPH 4,350 feet to the east. The well pad represents a continued land use that is separated from mapped elk habitat by a ridgeline, approximately 0.75 miles of spruce/fir forest and aspen woodlands, and a drop of approximately 400 feet from the ridge into the next drainage, the Mamm Creek drainage. The combination of topography, forest cover, and distance avoids impacts to mapped HPH The conversion of the existing well into an injection well not result in additional surface disturbance nor fragment wildlife habitat. CPX will not impact natural drainage patterns by utilizing an existing location. Policy 2. Strategy ii. Preserve or mitigate natural drainage patterns so the cumulative impact of mineral extraction activities will not cause storm drainage/floodwater patterns to exceed the capacity of natural or constructed drainage ways, or subject other areas to increased flooding, erosion or sedimentation, resulting in pollution to streams, rivers or other natural bodies of water. The well pad was constructed in approximately 2008. Cut and fill work is complete. The working pad surface and cut slope are stable and compacted. The well pad fill slopes have 2-foot-high earthen berms, which are 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. There is no uncontrolled stormwater on the well pad. The well pad has a 6-inch-diameter drain at the center of the well pad. 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. The well pad is not in a 100-year floodplain. An unnamed drainage is approximately 316’ uphill to the south. An unnamed drainage is approximately 485’ cross gradient to the north. The drainage contains woody debris and no stream features. The well pad berm, cross- gradient topography, and distance prevent flow from the well pad from reaching the drainage. TPR 176-25 UIC Well Article 7: Standards - Division 1. General Approval Standards General Approval Standards Narrative Administrative Review 4 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 4. Section 7-103. COMPATIBILITY. The nature, scale, and intensity of the proposed use are compatible with adjacent land uses. The proposed site will be located in an unpopulated, remote area surrounded by numerous natural resource facilities and operations. Adjacent land uses consist of natural resource development, agricultural grazing, and public lands. The installation of the proposed site will benefit the general public by reducing truck traffic on public roads. The proposed UIC well is designed to minimize any impact to adjacent land and is located within the boundaries CPX private property. 5. Section 7-104. SOURCE OF WATER. All applications for Land Use Change Permits shall have an adequate, reliable, physical, long-term, and legal water supply to serve the use, except for land uses that do not require water, or that contain Temporary Facilities served by a licensed water hauler. CPX requests a waiver to the standard Sufficient Adequate, Legal, and Physical Source of Water, Section 7-104 of the Garfield County LUDC. The standard is not applicable to the proposed use, a Small Injection Well. The proposed facility will not require a long- term water source for personnel or for the proposed use. A temporary and limited amount of water will be needed for initial well conversion. CPX plans to use recycled produced water sourced from a third-party operator for this. A long-term is not required for continued operation of the well. In regard to personnel, during conversion and initial operational activities, personnel will access the site daily until the injection well is in full operation. Once operations are established, Well Pad 25A will be accessed approximately daily for inspections and other regular operational work. But Well Pad 25A and TPR 176-25 well will not have personnel staffed at the site on a regular continuous basis. Due to the minimal and intermittent presence of employees onsite, drinking water use will not be required onsite during operations. Drinking water will be provided to personnel in the form of bottled water. 6. Section 7-105. CENTRAL WATER DISTRIBUTION AND WASTEWATER SYSTEMS. The land use shall be served by a water distribution system that is adequate to serve the proposed use and density and a wastewater system that is adequate to serve the proposed use and density. CPX requests a waiver to the standard “Adequate Central Water Distribution and Wastewater Systems,” Section 7-105 of the Garfield County LUDC. The standard is not TPR 176-25 UIC Well Article 7: Standards - Division 1. General Approval Standards General Approval Standards Narrative Administrative Review 5 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 applicable to the proposed use. The subject use, Small Injection Well, is not served by an existing public collection system or treatment facility nor is an on-site wastewater treatment system proposed. During operations, personnel will not be required to be manned at the site full-time. Due to the minimal presence of personnel onsite, a wastewater use will not be required onsite. 7. Section 7-106. PUBLIC UTILITIES. CPX requests a waiver for the standard “Public Utilities,” Section 7-106 of the Garfield County LUDC. The standard is not applicable to the proposed use. The proposed use, Small Injection Well, does not require the use or installation of any public utilities. 8. Section 7-107. ACCESS AND ROADWAYS. All roads shall be designed to provide for adequate and safe access and shall be reviewed by the County Engineer. In accordance with Policy 01-14 Waiver for Roads and Demonstration of Compliance, CPX requests a waiver for the Roadway and Design Standards, Section 7-107 of the Garfield County Land Use and Development Code for CPX’s existing private access road. CPX’s private access road on Tepee Park Ranch was constructed, and is maintained, to provide safe access to the existing well pads and natural gas wells on Tepee Park Ranch. The proposed use of the Tepee Park Ranch road to develop the TPR 176-25 UIC Well is consistent with the existing use of the road, and the road is adequate for the proposed use. The road does not provide for any public access. A Professional Engineer (P.E.) from Mountain Civil Consulting assessed the private roadways the Tepee Park Ranch access road and determined that the access road is safe and adequate for the proposed, and current, industrial traffic. The P.E. Assessment Letter (Policy 01-14), which includes photos and cross sections, compares the existing roadways to Table 7-107 Roadway Standards is provided in the Access Road Waiver in the Standards tab. 9. Section 7-108. USE OF LAND SUBJECT TO NATURAL HAZARDS. Land subject to identified Natural and Geologic Hazards, such as falling rock, landslides, snow slides, mud flows, radiation, flooding, or high water tables, shall not be developed unless it has been designed to eliminate or mitigate the potential effects of hazardous site conditions as designed by a qualified professional engineer and as approved by the County. The Geologic Hazard Assessment, prepared by a Ken Walter, P.G. at Walter Environmental and Engineering Group, Inc. and John Withers, of Geotechnical Engineering Group, determined that landslides, flooding, rockfall, collapsible soils, and TPR 176-25 UIC Well Article 7: Standards - Division 1. General Approval Standards General Approval Standards Narrative Administrative Review 6 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 avalanches are not a hazard at the location. The Geologic Hazards Assessment and site photos are located in the Impact Analysis tab. 10. Section 7-109. FIRE PROTECTION. 10.1. Section 7-109.A. Adequate Fire Protection. Adequate fire protection will be provided for each land use change as required by the appropriate fire protection district. The proposed site is located within the Grand Valley Fire Protection District. The site was designed to meet all requirements of the Grand Valley Fire Protection District. CPX will maintain a weed and vegetation control perimeter to prevent wildfire from entering the site. 10.2. Section 7-109.B. Subdivisions. All divisions of land must be reviewed and approved by the appropriate fire protection district for adequate primary and secondary access, fire lanes, water sources for fire protection, fire hydrants, and maintenance provisions. CPX requests a waiver for the standard “Fire Protection: Subdivisions”, Section 7-109 B. of the Garfield County LUDC. The standard is not applicable to the proposed use. The site will be an industrial use and no division of land will occur. AL RESOURCE PROTECTION