| OGLA | Form: (02A)
400720918
12/29/2014 | Notify the COGCC 48 hours prior to start of pad construction, rig mobilization, spud, start of hydraulic stimulation operations, start of flowback operations, and pipeline testing using Form 42 (the appropriate COGCC individuals will automatically be email notified, including the LGD for hydraulic stimulation operations).
Operator will implement sufficient public notification of proposed oil and gas activities. These may include the following: (1) provide 30 day advance notice and community awareness to neighborhood; (2) schedule changes will be communicated to the community at meetings or emails; (3) notify local emergency response agencies (Fire/Police) of schedule changes; and (4) notify all homes within a ¼-mile radius and local emergency responders (Fire/Police) 7 days prior to mobilization in, rig up (MIRU). If the operator, local emergency response agencies (Fire/Police), and the nearby community have agreed on other means of notification, that will satisfy this COA.
Operator will review local governmental requirements for access from public roads. At a minimum the following traffic requirements will apply: (1) operator will work with the Garfield County Road and Bridge Department to develop and implement a traffic control plan that, at a minimum: a) establishes designated haul routes, b) designates haul routes to avoid school zones and schedules heavy equipment movement to avoid school bus operation hours, c) provides for additional signage on major and/or local roads to be employed during heavy activity periods warning of increased truck traffic, d) restricts all oil and gas related construction, drilling, and operational traffic to access the location from a single point, e) provides for flaggers and/or pilot vehicles as ecessary, and f) schedules work to avoid peak traffic flow. |
| OGLA | Form: (02A)
400720918
12/29/2014 | Operator must ensure secondary containment for any volume of fluids contained at well site during drilling and completion operations; including, but not limited to, construction of a berm or diversion dike, diversion/collection trenches within and/or outside of berms/dikes, site grading, or other comparable measures (i.e., best management practices (BMPs) associated with stormwater management) sufficiently protective of nearby surface water. Any berm constructed at the well pad location will be stabilized, inspected at regular intervals (at least every 14 days and after precipitation events), and maintained in good condition.
Since the proposed access road crosses an intermittent stream, the access road will be constructed and maintained as to not allow any sediment to migrate from the access road to nearby surface water or any drainages or ditches leading to surface water.
Strategically apply fugitive dust control measures, including encouraging established speed limits on private roads, to reduce fugitive dust and coating of vegetation and deposition in water sources.
Operator has indicated they have prepared a job specific Emergency Management/Response Plan. Operator will provide temporary engineering controls to prevent uncontrolled public access during drilling and completion activities. Site security shall include, but not be limited to, appointing a Health and Safety Officer that will insure the Emergency Management/Response Plan is adhered to and who is authorized to shut down operations at any time when health and safety risk is present.
Temporary perimeter sound walls (consisting of earthen berms and/or metal, synthetic, or wood sheeting) shall be used, at a minimum, on the west and south perimeters of the location during drilling and completion activities to provide noise relief to nearby residents. Operator shall conduct noise monitoring as described in 802.c. at a minimum once during each phase of activity (pad construction, drilling, completion and production), and submit the results to the COGCC. The COGCC may require additional noise mitigation if measures taken are deemed insufficient.
Operator will take aggressive action to establish vegetation on cut and fill slopes to prevent storm water erosion and the generation of fugitive dust. Operator shall install and maintain native vegetative visual buffering on the west and east sides in conjunction with site stabilization. Visual mitigation shall also include the use of low profile tanks.
Berms or other containment devices shall be constructed to be sufficiently impervious (corrugated steel with poly liner) to contain any spilled or released material around permanent crude oil, condensate, and produced water storage tanks. |
| OGLA | Form: (02A)
400720918
12/29/2014 | The moisture content of drill cuttings managed onsite shall be kept as low as practicable to prevent accumulation of liquids greater than de minimis amounts.
Lighting abatement measures beyond the requirements of Rule 803. shall be implemented, including the following, at a minimum: (1) rig oriented to direct light away from nearby residents; (2) install lighting shield devices on all of the more conspicuous lights; and (3) rig shrouded on the west and south sides.
For purposes of reducing impacts to nearby residents, flares (such as TCI's portable flare with high combustion rate, low noise, and low visibility flare) will be utilized.
Emissions from condensate, crude oil, and produced water tanks and from glycol dehydrators shall be controlled as described in Rule 805.b.(2), not-withstanding the exceptions for production facilities emitting less than five tons per year (TPY) of volatile organic compounds (VOC).
Air quality and odor controls will be implemented and will include the following : (1) flowback stream to be routed from wellhead to a “four-phase” separator and then to a sealed flowback tank, with non-salable gas sent to a temporary flare or VOC combustor; (2) oil or condensate captured during separation process will be sent to a tank with emissions controls; (3) frac/flowback storage tank hatches shall operate with hydrocarbon absorbing blankets to control odors; and (4) operator will comply with the green completions section under Rule 805.b.(3).
Flowback and stimulation fluids must be sent to tanks, separators, or other containment/filtering equipment before the fluids can be placed into any pipeline or storage vessel located on the well pad; or into tanker trucks for offsite disposal. The flowback and stimulation fluid tanks, separators, or other containment/filtering equipment must be placed on the well pad in an area constructed to be sufficiently impervious to contain any spilled or released material. |
| OGLA | Form: (02A)
400720918
12/29/2014 | Operator shall pressure test pipelines in accordance with Rule 1101.e.(1) prior to putting into initial service any temporary surface or permanent buried pipelines and following any reconfiguration of the pipeline network.
Operator will utilize, to the extent practical, all existing access and other public roads, and/or existing pipeline right-of-ways, when placing/routing the surface pipelines. This will reduce surface disturbance. |
| OGLA | Form: (04)
401062603
06/14/2016 | Operator shall incorporate drill cuttings brought from the nearby Tompkins Pad (OGCC ID#438312) and beneficially reuse them for the interim reclamation of cut and fill slopes, as well as for base and buildup material for berms to be constructed for noise and visual mitigation. Drill cuttings will be covered or capped with a minimum of 3’ of native soil. |
|
| Planning | Form: (02A )
400720918
1/15/2015 | GENERAL – PLANNING
• This is a new oil and gas location and will include construction of a well pad and 16 proposed wells.
• Prior to initiation of the COGCC Form 2A permitting process, Ursa held internal meetings and onsites to determine the feasibility of the location, and identified all compliance requirements, guidance and policies needed to permit the location and proposed oil and gas operations. All COGCC permitting requirements under the 200 through 1200 series rules were incorporated, as appropriate into this Form 2A and related attachments.
• The best management practices (BMPs) incorporated herein also considered other Federal, state and county agency requirements and guidance, including those under the jurisdiction of the Environmental Protection Agency (EPA), U.S. Fish and Wildlife Service (USFWS), U.S. Army Corps of Engineers (ACOE), Federal Emergency Management Agency (FEMA), Colorado Department of Public Health and Environmental (CDPHE), Colorado Parks and Wildlife (CPW), and Garfield County (GARCO), among others.
• Planning and permitting information relevant to the location based on Federal, state and county regulations, guidance and policies is documented as appropriate in Ursa’s “Site Assessment Checklist/Map”. A copy of this was provided to Dave Kubeczko at the onsite held on October 23, 2014.
• Upon approval of the Form 2A, Ursa holds Pre-Construction, Pre-Spud, Pre-Completions and Pre-Production meetings with contractors performing work at the location, as applicable to the proposed activity. As a BMP, Ursa has developed checklists for these meetings to review regulations, COAs, NTOs and related requirements.
• Traffic and Public Safety – Ursa developed a site-specific Emergency Response Plan (SSERP) and Haul Route Map which are communicated to local emergency response agencies, affect communities and stakeholders, as well as contractors performing work at the location.
|
| Community Outreach and Notification | Form: (02A )
400720918
1/15/2015 | COMMUNITY / STAKEHOLDER OUTREACH AND NOTIFICATIONS
• An SUA has been signed with the landowner allowing this location to be constructed, drilled and operated in accordance with the Form 2A submitted.
• Ursa routinely communicates proposed plans and operations schedules to stakeholders through Community Counts, the GARCO Energy Advisory Board, Battlement Mesa Concerned Citizens, NW Colorado Oil & Gas Forum and others. In addition, periodic stakeholder meetings are held with landowners and affected parties.
• Communication with Kirby Wynn and municipal LGDs are also held routinely in addition to communication required by COGCC regulations, as appropriate.
|
| General Housekeeping | Form: (02A )
400720918
1/15/2015 | ENVIRONMENTAL STEWARDSHIP AND COMPLIANCE / HOUSEKEEPING
• AGENCY INSPECTIONS AND CORRECTIVE ACTIONS – Ursa will implement corrective actions necessary in response to all Federal and state agency inspections in a timely manner. Inspections resulting in the potential for immediate or significant environmental impacts will be addressed immediately, subject to safety and weather considerations.
• URSA VOLUNTARY INSPECTIONS – Ursa conducts voluntary inspections and corrective actions of all locations at least monthly using a self-implemented checklist of key actions (including environmental) that require compliance with COGCC, Federal, and other state and county requirements.
• AESTHETICS AND NOISE – Lighting, noise, odors, dust and related nuisances are managed in accordance with COGCC 600 and 802, 803, 804 and 805 Series Rules, and in accordance with Ursa policies, procedures and checklists.
• AIR PERMITTING AND COMPLIANCE – Ursa will comply with CDPHE regulations regarding air permitting, compliance monitoring, inspections and reporting. All air sources will be assigned AIRS ID numbers by the CDPHE and tracked for compliance and reporting purposes. In addition, Ursa is required to track, monitor and report Greenhouse Gas (GHG) emissions to EPA annually.
• CHEMICAL & MATERIAL HANDLING – All materials and chemicals will be managed to minimize environmental contamination in accordance with MSDS sheets and EPA, COGCC and CDPHE regulations. Materials and chemicals that are not a waste may be reused or recycled.
• SETBACK MITIGATION REQUIREMENTS – Ursa has incorporated the mitigation requirements identified in COGCC Rule 604, as applicable on a site-specific basis into its Operations Checklists, Voluntary and Mandatory Site Inspections, and Environmental Programs plans, status monitoring, and policies and procedures.
• NOXIOUS WEEDS – Weeds will be managed in accordance COGCC Rule 1003.f. and 1004.e. as incorporated into Ursa’s Noxious Weed plan; to include up to three treatments per year depending upon the species being managed and mapping as needed, throughout the life cycle of the location (construction – final reclamation).
• SAFETY – Safety requirements and buffers as required by the COGCC 602, 603, and 606A and 606B Series Rules, among others, and the Office of Safety and Health Administration (OSHA) will be observed at all time. Daily safety briefings and Job Safety Assessments (JSA’s) are routinely conducted in all phases of operations. In addition, Ursa employees a full-time safety manager to oversee all field contractors.
• SPILLS / INCIDENTS – Spill prevention and response are addressed in Ursa’s Spill Prevention and Management Plan. This includes training of employees and contractors personnel on at least an annual basis. Spill response includes notifications, reporting, response actions, remediation and corrective actions. The spill criteria in Ursa’s plan requires that waste be properly classified as E&P or non-E&P wastes. For E&P waste, all spills greater than 1 barrel the COGCC will be reported to the COGCC using a Form 19. Should remediation be required, a Form 27 will be submitted as well. Spills related to non-E&P waste will be managed in accordance with CDPHE and EPA regulations depending on the volume spilled. As a BMP, Ursa tracks and cleans up all spills, including those that are not reportable.
• SPCC / CONTAINMENT – All production tanks and tanks used for completions activities will be installed, labeled, contained, operated, and decommissioned in accordance with Ursa’s SPCC/Containment Plan, which is required by EPA regulations (40 CFR 112). The plan, in combination with Ursa’s Spill Prevention and Management plan, addresses COGCC 600 and 900 Series Rules, among others, regarding the management of tanks.
• WASTE - The location will be managed in accordance with COGCC 907 and 907A Rules, which are incorporated into Ursa’s Waste Management Plan, which addresses both E&P and non-E&P waste, including those under the jurisdiction of the CDPHE and EPA. The plan, in combination with Ursa’s Spill Prevention and Management Plan, minimizes the potential for any exploration and production wastes, chemicals, fluids, etc. from leaving the location, using BMPs including berms, barriers, and use of spill control materials.
• WILDLIFE - A Wildlife Mitigation Plan is in place that allows for 90+ well pads.
|
| Wildlife | Form: (02A )
400720918
1/15/2015 | 1. Closed loop (pitless) drilling systems.
2. Annual raptor and other bird surveys will be conducted in accordance with protocols provided by CPW.
3. Rig shift changes will take place when practical at 6am and 6pm and will utilize one (1) vehicle to minimize impacts to wildlife.
4. Development program is planned to include four phases as a means for mitigating wildlife impacts. These phases will be based on infrastructure construction schedules and will be coordinated with affected land owners, the Battlement Mesa Services Association (BMSA), local municipalities, Garfield County, COGCC, and CDPHE during the Comprehensive Drilling Plan and the Major Land Use Impact Review process.
5. Well pad location visits during the production phase of operations (post drilling and completion for all wells on a well pad location) will be restricted when/where possible to between the hours of 10am and 3pm to minimize impacts to wildlife unless operational concerns warrant pad visits outside this timeframe.
6. Buried water and gas pipelines will be utilized as means to reduce truck traffic and impacts to wildlife.
7. Restrict rig operation to no more than 2 rigs per section (or equivalent acreage) within the big-game seclusion areas during the winter.
8. Maintaining a ¼ mile no surface occupancy buffer around active bald eagle nests.
9. New pad construction not to exceed 3 acres of working surface.
10. Pad density not to exceed 1 pad per 160 acres.
11. Bury all gas and water pipelines adjacent to roads whenever possible.
12. A weed management plan will be developed and implemented to monitor and control noxious and invasive weeds.
13. Noxious weed control includes three treatments per year.
14. Existing weed infestations will be mapped prior to the development of each pad, access road and pipeline when practicable.
15. Antero (now Ursa) has completed all habitat restoration contributions contained within the WMP. |
| Construction | Form: (02A )
400720918
1/15/2015 | CONSTRUCTION AND SITE STABILIZATION
• The BMPs below entitled “Environmental Stewardship and Compliance” provide additional information that is applicable to one or more phases of operations.
• CONSTRUCTION (General) – The location will be constructed and maintained in accordance with COGCC 1002 Rules regarding soil and stormwater management, and surface disturbance minimization as incorporated into Ursa’s plans, policies and procedures.
• DUST CONTROL - The pad and access road will be graveled to reduce fugitive dust and maintained as required by COGCC rules. In addition, water and other dust suppressants are used as required, dependent upon the level of activity, moisture conditions, etc. throughout all phases of operations
• RECLAMATION (Interim) - The site/soils will be stabilized as soon as practical during and immediately following construction. Once wells at the location are drilled, Ursa will complete interim reclamation in accordance with the COGCC 1003 rules using seed mixes and materials compatible with soil types, moisture, and local climate conditions as specified by the appropriate agency and/or in landowner surface use agreements, or locally acceptable industry practices.
• STORMWATER - The location will be constructed / maintained in accordance with the CDPHE and COGCC 1002.f. (1) and (2) stormwater regulations as implemented by Ursa’s Stormwater Management Plan, so as to control sediment run-off. Stormwater BMPs will also serve as secondary or tertiary containment in the event of a spill. Site specific plans (i.e. diagrams) will be developed and inspected against at the frequency required by CDPHE regulations, to include 14 day, 30 day, and major storm event inspections until 70% reclamation is achieved. Corrective actions and maintenance will be tracked and implemented. The post-construction stormwater program will be managed in accordance with COGCC Rule 1002.f. (3). Inspections and corrective actions will be conducted through 80% interim reclamation and annually thereafter. These inspections are also tracked and corrective actions implemented. Native soils will be used whenever available to construct stormwater BMPs, supplemented by non-native materials based on site-specific conditions.
• WATER WELL SAMPLING (COGCC Rule 609) – Water well sampling will be conducted prior to setting conductors; followed by post-sampling requirements and reporting the landowner and COGCC.
• For safety purposes, the location and site layout has been designed to accommodate all operations within the limits of disturbance while meeting Federal and state safety regulations, including required buffers and distances between operating components and combustion sources.
• FLOODPLAIN IMPACTS – Ursa completed a floodplain assessment and found that this location did not meet criteria to be designated within the 100 year floodplain.
|
| Drilling/Completion Operations | Form: (02A )
400720918
1/15/2015 | DRILLING
• Drilling multiple wells from this location using directional / horizontal drilling will be implemented to avoid the need for additional well pads; reducing potential environmental impacts to include habitat loss and fragmentation, noise, traffic concerns, and related impacts to air, land and water.
• MIRU – Unless waived, Notice to all Building Unit owners will be sent at least 30 days, but no more than 90 days within the Buffer Zone prior to the Move-In, Rig-Up of the drilling rig when more than 1
year has elapsed since previous notice or since drilling activity last occurred, or if no notice had previously been required in accordance with the four examples provided in the COGCC MIRU policy.
• No cuttings pits are proposed.
|
| Drilling/Completion Operations | Form: (02A )
400720918
1/15/2015 | COMPLETIONS
• The BMPs below entitled “Environmental Stewardship and Compliance” provide additional information that is applicable to one or more phases of operations.
• TEMPORARY COMPLETIONS FACILITIES - Completions at the location may be supported by staging temporary tanks / water pumping station at adjacent existing location(s), including the Watson Ranch Pad. This will support lease operations as authorized under COGCC regulations.
• AIR & ODORS - Well completions will utilize flowback completion technologies and/or flares to reduce odors from plug drillout, and venting of salable and non-salable gas
• CHEMICAL USE – All chemicals used will be tracked and reported in accordance with COGCC rules and submitted through FracFocus within 120 days of initiating well stimulation.
• WASTE MANAGEMENT OF WATER – Flowback water used for well completions will be recycled and treated to the maximum extent practical at the location. Water that can’t be recycled will be injected through the use of wells approved by COGCC and Garfield County, or transported via truck or pipeline to the COGCC and Garfield County approved Wasatch E&P Facility.
• WASTE - No stimulation or flowback pits will be constructed.
|
| Drilling/Completion Operations | Form: (02A )
400720918
1/15/2015 | PRODUCTION
• The BMPs below entitled “Environmental Stewardship and Compliance” provided more detailed information regarding environmental protection applicable general operations.
• All production equipment to include separators, produced water and condensate tanks, pipelines and flowlines will be constructed and managed in accordance with COGCC 605 and 1100 Series Rules.
• AIR & ODORS - Combustor controls will be used to mitigate odors from production tanks. Ursa will perform inspections on at least a monthly basis to ensure potential emissions sources are properly managed. In addition, Ursa’s pumper crew inspects each location on a daily basis.
• REMOTE MONITORING - Remote monitoring will be used to reduce truck traffic, fugitive dust to the extent practical.
• VISUAL IMPACTS - Above-ground facilities (e.g. production tanks) will be managed to minimize visual effects (e.g. painted to blend with environment)
• WILDLIFE – All separators/dehydrators and heater –treater equipment are outfitted with bird cones.
• WATER RECYCLING – Produced water used for well completions will be recycled and treated to the maximum extent practical. Water that can’t be recycled will be injected through the use of wells approved by COGCC and Garfield County, or transported via truck or pipeline to the COGCC and Garfield County approved Wasatch E&P Facility.
|
| Planning | Form: (02A )
400778315
3/27/2015 | GENERAL – PLANNING
• This pad is constructed. Based on the public input, Ursa revisited development in the Battlement Mesa
area and determined that it may be feasible to add additional wells to pads outside the Planned Unit
Development (PUD), and potentially eliminate some pads with the PUD. As a result, this Form 2A is
only for the addition of wells to an existing location; no pad expansion is proposed under this
application.
• Prior to initiation of the COGCC Form 2A permitting process, Ursa held internal meetings and onsites to
determine the feasibility of the location, and identified all compliance requirements, guidance and
policies needed to permit the location and proposed oil and gas operations. All COGCC permitting
requirements under the 200 through 1200 series rules were incorporated as appropriate into this Form
2A, including related attachments.
• The best management practices (BMPs) incorporated herein also considered other Federal, state and
county agency requirements and guidance, including those under the jurisdiction of the Environmental
Protection Agency (EPA), U.S. Fish and Wildlife Service (USFWS), U.S. Army Corps of Engineers
(ACOE), Federal Emergency Management Agency (FEMA), Colorado Department of Public Health and
Environmental (CDPHE), Colorado Parks and Wildlife (CPW), and Garfield County (GARCO), among
others.
• Planning and permitting information relevant to the location based on Federal, state and county
regulations, guidance and policies is documented as appropriate in Ursa’s “Site Assessment
Checklist/Map”. A copy of this was provided to Dave Kubeczko at the onsite held on October 23, 2014.
• Upon approval of the Form 2A, Ursa holds Pre-Construction, Pre-Spud, Pre-Completions and Pre-
Production meetings with contractors performing work at the location, as applicable to the proposed
activity. As a BMP, Ursa has developed checklists for these meetings to review regulations, COAs,
NTOs and related requirements.
• Traffic and Public Safety – Ursa developed a site-specific Emergency Response Plan (SSERP) and Haul
Route Map which are communicated to local emergency response agencies, affect communities and
stakeholders, as well as contractors performing work at the location. |
| Community Outreach and Notification | Form: (02A )
400778315
3/27/2015 | COMMUNITY / STAKEHOLDER OUTREACH AND NOTIFICATIONS
• The SUA signed with the landowner allows for the addition of wells.
• Ursa routinely communicates proposed plans and operations schedules to stakeholders through
Community Counts, the GARCO Energy Advisory Board, Battlement Mesa Concerned Citizens, NW
Colorado Oil & Gas Forum and others. In addition, periodic stakeholder meetings are held with
landowners and affected parties.
• Communication with Kirby Wynn and municipal LGDs are also held routinely in addition to
communication required by COGCC regulations, as appropriate. |
| General Housekeeping | Form: (02A )
400778315
3/27/2015 | ENVIRONMENTAL STEWARDSHIP AND COMPLIANCE / HOUSEKEEPING
• AGENCY INSPECTIONS AND CORRECTIVE ACTIONS – Ursa will implement corrective actions
necessary in response to all Federal and state agency inspections in a timely manner. Inspections
resulting in the potential for immediate or significant environmental impacts will be addressed
immediately, subject to safety and weather considerations.
• URSA VOLUNTARY INSPECTIONS – Ursa conducts voluntary inspections and corrective actions of
all locations at least monthly using a self-implemented checklist of key actions (including
environmental) that require compliance with COGCC, Federal, and other state and county requirements.
• AESTHETICS AND NOISE – Lighting, noise, odors, dust and related nuisances are managed in
accordance with COGCC 600 and 802, 803, 804 and 805 Series Rules, and in accordance with Ursa
policies, procedures and checklists.
• AIR PERMITTING AND COMPLIANCE – Ursa will comply with CDPHE regulations regarding air
permitting, compliance monitoring, inspections and reporting. All air sources will be assigned AIRS ID
numbers by the CDPHE and tracked for compliance and reporting purposes. In addition, Ursa is required
to track, monitor and report Greenhouse Gas (GHG) emissions to EPA annually.
• CHEMICAL & MATERIAL HANDLING – All materials and chemicals will be managed to minimize
environmental contamination in accordance with MSDS sheets and EPA, COGCC and CDPHE
regulations. Materials and chemicals that are not a waste may be reused or recycled.
• SETBACK MITIGATION REQUIREMENTS – Ursa has incorporated the mitigation requirements
identified in COGCC Rule 604, as applicable on a site-specific basis into its Operations Checklists,
Voluntary and Mandatory Site Inspections, and Environmental Programs plans, status monitoring, and
policies and procedures.
• NOXIOUS WEEDS – Weeds will be managed in accordance COGCC Rule 1003.f. and 1004.e. as
incorporated into Ursa’s Noxious Weed plan; to include up to three treatments per year depending upon
the species being managed and mapping as needed, throughout the life cycle of the location
(construction – final reclamation).
• SAFETY – Safety requirements and buffers as required by the COGCC 602, 603, and 606A and 606B
Series Rules, among others, and the Office of Safety and Health Administration (OSHA) will be
observed at all time. Daily safety briefings and Job Safety Assessments (JSA’s) are routinely conducted
in all phases of operations. In addition, Ursa employees a full-time safety manager to oversee all field
contractors.
• SPILLS / INCIDENTS – Spill prevention and response are addressed in Ursa’s Spill Prevention and
Management Plan. This includes training of employees and contractors personnel on at least an annual
basis. Spill response includes notifications, reporting, response actions, remediation and corrective
actions. The spill criteria in Ursa’s plan requires that waste be properly classified as E&P or non-E&P
wastes. For E&P waste, all spills greater than 1 barrel outside containment and 5 barrels within
designed secondary containment, will be reported to the COGCC using a Form 19. Should remediation
be required, a Form 27 will be submitted as well. Spills related to non-E&P waste will be managed in
accordance with CDPHE and EPA regulations depending on the volume spilled. As a BMP, Ursa tracks
and cleans up all spills, including those that are not reportable.
• SPCC / CONTAINMENT – All production tanks and tanks used for completions activities will be
installed, labeled, contained, operated, and decommissioned in accordance with Ursa’s
SPCC/Containment Plan, which is required by EPA regulations (40 CFR 112). The plan, in combination
with Ursa’s Spill Prevention and Management plan, addresses COGCC 600 and 900 Series Rules,
among others, regarding the management of tanks.
• WASTE - The location will be managed in accordance with COGCC 907 and 907A Rules, which are
incorporated into Ursa’s Waste Management Plan, which addresses both E&P and non-E&P waste,
including those under the jurisdiction of the CDPHE and EPA. The plan, in combination with Ursa’s
Spill Prevention and Management Plan, minimizes the potential for any exploration and production wastes, chemicals, fluids, etc. from leaving the location, using BMPs including berms, barriers, and use of spill control materials.
• WILDLIFE - A Wildlife Mitigation Plan is in place that allows for 90+ well pads. |
| Construction | Form: (02A )
400778315
3/27/2015 | CONSTRUCTION AND SITE STABILIZATION
• The BMPs entitled “Environmental Stewardship and Compliance” provide additional information that is
applicable to one or more phases of operations.
• CONSTRUCTION (General) – The location will be constructed and maintained in accordance with
COGCC 1002 Rules regarding soil and stormwater management, and surface disturbance minimization
as incorporated into Ursa’s plans, policies and procedures.
• DUST CONTROL - The pad and access road will be graveled to reduce fugitive dust and maintained as
required by COGCC rules. In addition, water and other dust suppressants are used as required,
dependent upon the level of activity, moisture conditions, etc. throughout all phases of operations
• RECLAMATION (Interim) - The site/soils will be stabilized as soon as practical during and
immediately following construction. Once wells at the location are drilled, Ursa will complete interim
reclamation in accordance with the COGCC 1003 rules using seed mixes and materials compatible with
soil types, moisture, and local climate conditions as specified by the appropriate agency and/or in
landowner surface use agreements, or locally acceptable industry practices.
• STORMWATER - The location will be constructed / maintained in accordance with the CDPHE and
COGCC 1002.f. (1) and (2) stormwater regulations as implemented by Ursa’s Stormwater Management
Plan, so as to control sediment run-off. Stormwater BMPs will also serve as secondary or tertiary
containment in the event of a spill. Site specific plans (i.e. diagrams) will be developed and inspected
against at the frequency required by CDPHE regulations, to include 14 day, 30 day, and major storm
event inspections until 70% reclamation is achieved. Corrective actions and maintenance will be tracked
and implemented. The post-construction stormwater program will be managed in accordance with
COGCC Rule 1002.f. (3). Inspections and corrective actions will be conducted through 80% interim
reclamation and annually thereafter. These inspections are also tracked and corrective actions
implemented. Native soils will be used whenever available to construct stormwater BMPs,
supplemented by non-native materials based on site-specific conditions.
• WATER WELL SAMPLING (COGCC Rule 609) – Water well sampling will be conducted prior to
setting conductors; followed by post-sampling requirements and reporting the landowner and COGCC.
• For safety purposes, the location and site layout has been designed to accommodate all operations within
the limits of disturbance while meeting Federal and state safety regulations, including required buffers
and distances between operating components and combustion sources.
• FLOODPLAIN IMPACTS – Ursa completed a floodplain assessment and found that this location did
not meet criteria to be designated within the 100 year floodplain. |
| Drilling/Completion Operations | Form: (02A )
400778315
3/27/2015 | DRILLING
• Drilling multiple wells from this location using directional / horizontal drilling will be implemented to
avoid the need for additional well pads; reducing potential environmental impacts to include habitat loss
and fragmentation, noise, traffic concerns, and related impacts to air, land and water.
• MIRU – Unless waived, Notice to all Building Unit owners will be sent at least 30 days, but no more
than 90 days, within the Buffer Zone prior to the Move-In, Rig-Up of the drilling rig when more than 1
year has elapsed since previous notice or since drilling activity last occurred, or if no notice had
previously been required in accordance with the four examples provided in the COGCC MIRU policy.
• No cuttings pits are proposed. |
| Drilling/Completion Operations | Form: (02A )
400778315
3/27/2015 | COMPLETIONS
• The BMPs entitled “Environmental Stewardship and Compliance” provide additional information that is
applicable to one or more phases of operations.
• TEMPORARY COMPLETIONS FACILITIES - Completions at the location may be supported by
staging temporary tanks / water pumping station at adjacent existing location(s), including the Watson
Ranch Pad, which is closely adjacent to this location. This will support lease operations as authorized
under COGCC regulations.
• AIR & ODORS - Well completions will utilize flowback completion technologies and/or flares to
reduce odors from plug drillout, and venting of salable and non-salable gas
• CHEMICAL USE – All chemicals used will be tracked and reported in accordance with COGCC rules
and submitted through FracFocus within 120 days of initiating well stimulation.
• WASTE MANAGEMENT OF WATER – Flowback water used for well completions will be recycled
and treated to the maximum extent practical at the location. Water that can’t be recycled will be injected
through the use of wells approved by COGCC and Garfield County, or transported via truck or pipeline
to the COGCC and Garfield County approved Wasatch E&P Facility.
• WASTE - No stimulation or flowback pits will be constructed. |
| Drilling/Completion Operations | Form: (02A )
400778315
3/27/2015 | PRODUCTION
• The BMPs entitled “Environmental Stewardship and Compliance” provided more detailed information
regarding environmental protection applicable general operations.
• All production equipment to include separators, produced water and condensate tanks, pipelines and
flowlines will be constructed and managed in accordance with COGCC 605 and 1100 Series Rules.
• AIR & ODORS - Combustor controls will be used to mitigate odors from production tanks. Ursa will
perform inspections on at least a monthly basis to ensure potential emissions sources are properly
managed. In addition, Ursa’s pumper crew inspects each location on a daily basis.
• REMOTE MONITORING - Remote monitoring will be used to reduce truck traffic, fugitive dust to the
extent practical.
• VISUAL IMPACTS - Above-ground facilities (e.g. production tanks) will be managed to minimize
visual effects (e.g. painted to blend with environment)
• WILDLIFE – All separators/dehydrators and heater –treater equipment are outfitted with bird cones.
• WATER RECYCLING – Produced water used for well completions will be recycled and treated to the
maximum extent practical. Water that can’t be recycled will be injected through the use of wells
approved by COGCC and Garfield County, or transported via truck or pipeline to the COGCC and
Garfield County approved Wasatch E&P Facility. |
|