| Wildlife | Form: (02 )
400526366
3/24/2014 | Marathon has established an evaluation process for operations within the Piceance Basin that addresses wildlife concerns. This listing of Items 1-6 represents our specific actions that are considered avoidance and minimization actions by the Colorado Parks and Wildlife (CPW). Marathon has developed these BMPs as part of our Standard Operating Procedures (SOP) to provide operational and wildlife management for the Piceance Basin.
1. Riparian Area Protection for Wildlife
• Marathon will locate roads as far from riparian areas and bottoms of drainages as possible and outside of riparian habitat. However, Marathon is limited in areas where landowners dictate utilization of roads.
2. Company Vehicle Guidelines and Traffic Reductions for Wildlife Protection
• Marathon has 25 mph limit for all roads (speed limit signs are posted); additionally it is Marathon’s policy to prohibit the use of radios/cell phones while driving to enhance driving awareness. Car pooling for major projects is encouraged for all Marathon contractors to reduce traffic; carpooling is evaluated and used where practical for major projects.
• Marathon utilizes SCADA/Automation system to better understand and operate wellsite operations. The SCADA/Automation system provides a real-time view of the site with the ability to remotely start-up and shut-down certain operations. The system can be used to eliminate unnecessary trips to the production pad. Marathon currently has twenty-two pads in production and all pads are monitored by the SCADA/Automation system. The SCADA/Automation is a key component to safe, efficient, and environmentally friendly operations.
• When actively drilling, Marathon utilizes one Temporary Living camp to house the resources needed to support the drilling operations within the Piceance Basin. The site supports approximately 50 personnel that function on 12-hour shifts. The shift work schedule is 2-weeks on and 2-weeks off. This is a traffic reduction of 25 vehicles per day, 7-days per week. There is an understanding that the reduction of traffic as a whole reduces the opportunity for wildlife impacts.
3. Infrastructure Layout for Wildlife Protection
• Marathon has installed consolidated and centralized fluid collection facilities and water pipelines to manage fluids in the field. Through 2011, Marathon has installed approximately 50 miles of pipelines to manage existing production as well as future developments. The majority of the water pipelines are located adjacent to existing roads and within existing ROWs. The installation of most of the water pipelines was performed in conjunction with the installation of gas gathering lines performed by Enterprise. During the installation, both Marathon and Enterprise utilized the same contractor to reduce the overall disturbance and traffic by making one ground disturbance; thereby, reducing manpower, pieces of equipment and installation schedule.
• From 2008 through 2011, Marathon has utilized the fluid infrastructure to move approximately 2.2 million barrels of water throughout the field. The use of the pipelines and central facilities has saved approximately 22,000 truck loads and over 330,000 trucking miles. As Marathon continues to produce from this field, there will be continued utilization of this infrastructure to manage fluids which will continue to reduce disturbances and traffic. Produced water can be pumped via pipeline to Pad 18A for storage and offsite disposal. Produced water can be pumped via pipeline to Pad 32C for storage and enhanced evaporation. The use of Pads 18A and 32C for managing produced water effectively minimize truck traffic within the field.
• Based on development to date, future development of the field will utilize the infrastructure that has been installed. Each future well requires approximately 25,000 barrels of water to drill and complete. The water trucks used for transport carry approximately 100 barrels per load. As a result, continuing to utilize the infrastructure will save up to 250 truck loads per well during future development. Total development will require an average of eight wells per pad to achieve 20 acre spacing. This equates to 2,000 truck loads per pad and would increase with more aggressive development. As stated earlier, the traffic reduction will continue as long as the wells are producing and the water pipelines and facilities are utilized to manage fluids.
4. Drilling and Completions Operations for the Protection of Wildlife
• Marathon will review annually the scheduled civil construction, drilling and completion activities (Plan of Development [POD]) to avoid portions of SWH, specifically for the GrSG. Additionally, Marathon through the POD will schedule our activities in an effort to avoid and/or minimize operations near and within lek sites, elk production areas and active raptor nests.
The POD will be submitted to the CPW by the end of January for each calendar year. This component of the WMP will be a living document. Marathon will utilize C-K Associates, LLC (C-K) as our third party review team jointly with our regulatory compliance group to balance developments and ecological concerns within the Piceance Basin.
Marathon’s goal during the annual POD scheduling is to avoid at a minimum 66% of the GrSG SWH.
• If for some reason an area cannot be avoided, Marathon will attempt to avoid the timing period associated with the wildlife category of concern. - Lek avoidance is from March 1 through May 15 for major activities; - Elk Production is rotation of production areas on a seasonal basis; - 4-mile buffer for GrSG March 1-June 30 (4-months)
Note: there is an overlap of geographical areas between the elk production areas and the 4-mile GrSG buffer area (SWH). In Marathon’s effort to meet the timing for an elk production area, we also achieve avoidance for a portion of the 4-mile buffer area.
• Marathon has agreed to seasonal rotation development activities for the elk production areas.
• As of January 2012, Marathon has closed all drilling reserve pits.
• No drilling has occurred since June 2010; no completions have occurred since December 2010.
5. Additional Minimizations for Wildlife Protection
• Marathon is following the rule requirements for noise. Regarding raptor perch deterrents, Marathon will provide deterrents in areas where surrounding habitats do not provide natural perches.
• Marathon joint ownership properties can utilize approved seed mixes and restore disturbed sagebrush. In lease areas the land owner dictates the decision on seed mix and restoration of sagebrush. There are discussions with land owners on decisions regarding high priority habitat (lek areas and adjacent lands) where sagebrush can be restored. In other areas the approved land owner seed mix would be applied.
• Marathon conducts raptor surveys and utilizes the CPW’s approach to evaluate survey data protocols.
6. Additional Awareness for Wildlife Protection
• Marathon requires that each individual (company and contractor) go through orientation prior to working on locations and annually thereafter. Wildlife awareness is discussed.
• Marathon shares a general site map that includes Marathon locations, roads, personnel contacts, etc. In addition, the map highlights Wildlife Timing Periods and the two lek sites within Marathon’s acreage. The map is shared with company employees, contractors, and other operators.
• Marathon conducts monthly HES mtg (1/yr on wildlife issues) |
| Drilling/Completion Operations | Form: (02 )
400526366
3/24/2014 | Well Surveying & Anti-Collision Policy
Scope - An anti-collision risk assessment will be performed during the planning of all directional wells or vertical wells drilled in a field with directional wells. Wellbore anti-collision evaluation is part of WWD&C’s risk assessment policy. An anti-collision report will be included in the well plan utilizing both existing wells and planned wells as offset wells.
Policy - to obtain accurate directional surveys of its wellbores in order to 1) fulfill the requirements of applicable governmental regulations, 2) intersect geologic targets within established tolerances, and 3) provide survey data in order to maintain the minimum allowable separation between wells.
During the well planning phase, the directional plan will be designed to have a separation factor greater than or equal to 1.75 (S.F. = 1.75) in order to allow some deviation from the planned path when the well is drilled. If the directional path cannot be planned greater than or equal to 1.75 then the drilling manager’s approval is required for the directional plan. If the planned well path has a separation factor less than or equal to 1.0 (S.F. = 1.0) then the approval from the WWD&C General Manager is required.
During drilling operations, wellbore anti-collision will be monitored by calculating a separation factor of the projected well path ahead of the bit and applying the actions listed below.
Separation Factor = 1.5 Drill ahead
1.0 < Separation Factor = 1.5 Drilling manager approval required. Implement precautions and procedures developed in the risk assessment
Separation Factor = 1.0 Stop drilling. Drilling may not proceed without the WWD&C General Manager approval or until the separation factor has been increased above a 1.0
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