| Planning | Form: (02A )
402932354
9/21/2022 | • Prior to submittal of the APDs, Form 2, and the Form 2A, TEP conducted on-sites and meetings with the Bureau of Land Management (BLM), Colorado Parks and Wildlife (CPW), and Rio Blanco County. These on-sites and meetings were held to discuss TEP’s proposed development plan for the Federal 298-13-1 pad and associated support facilities. Changes were made to the proposed development plan based on feedback received from all stakeholders and included in the APD.
• The development plan for the Federal 298-13-1 pad was prepared to minimize surface impacts to the greatest extent possible through the development of multiple wells from one location by utilizing directional drilling technology and utilizing existing facilities and infrastructure where possible, which minimizes the surface area needed to conduct operations on the oil and gas location.
• Existing infrastructure operated by Williams and TEP will be utilized for transportation of natural gas and produced water to minimize the surface disturbance required for tying into gathering facilities. |
| Planning | Form: (02A )
402932354
9/21/2022 | • Per the Colorado Department of Public Health and Environment (“CDPHE”) Air Pollution Control Division (“APCD”) requirements, TEP will implement ambient air quality monitoring on site during drilling, completion, and the first six (6) months of production operations; an air monitoring plan will be submitted 60 days prior to start of drilling operations;
• TEP will properly maintain vehicles and equipment;
• Other than safety devices, TEP will use non-emitting pneumatic controllers; and
• TEP will have adequate and committed pipeline take away capacity for all produced gas. |
| Pre-Construction | Form: (02A )
402932354
9/21/2022 | • Prior to commencement of construction activities, TEP will hold a pre-construction meeting with contractors to review proposed site construction and installation of stormwater control measures. The site will be staked for construction prior to the preconstruction meeting. Staking will identify the boundaries of the proposed site to protect existing vegetation in areas that should not be disturbed. |
| General Housekeeping | Form: (02A )
402932354
9/21/2022 | • Vehicular traffic will be minimized as much as possible to reduce nuisance dust and prevent soil erosion;
• Any trash generated during the project will be disposed of properly at a commercial disposal facility;
• Any chemicals used will be kept to a minimum;
• Any chemical or hydrocarbon spills will be cleaned up immediately in accordance with established company procedures;
• All materials will be stored in a neat and orderly manner in their appropriate containers; and
• TEP will follow manufacturers’ recommendations and company policies for proper use and disposal of products. |
| Wildlife | Form: (02A )
402932354
9/21/2022 | • TEP will inform and educate all employees and contractors on wildlife conservation practices, including no harassment or feeding of wildlife;
• TEP will install a proposed water pipeline from the Oil and Gas Location to TEP’s existing water management system to minimize truck traffic to the location and minimizing potential impacts to wildlife;
• TEP will minimize direct impacts to wildlife habitat by utilizing existing infrastructure and disturbance corridors whenever possible; and
• Well telemetry equipment will be installed to minimize site visitation through remote monitoring of production operations. |
| Material Handling and Spill Prevention | Form: (02A )
402932354
9/21/2022 | • Audio, Visual, and Olfactory (AVO) inspections: AVO inspections will be conducted monthly at the Federal 298-13-1 oil and gas location throughout the life of the location.
• Routine inspection of all production equipment, wellheads, temporary equipment, etc.; As described above, routine inspections to be conducted at the Federal 298-13-1 oil and gas location will include: Routine physical inspections of production equipment (by TEP production personnel); Air Compliance inspections and monitoring (by TEP Air Compliance staff); SPCC Inspections (by 3rd party contractor), Storm Water Management inspections (by 3rd party contractor), and continuous, dedicated SCADA monitoring of fluid production rates and pressures, and fluid storage volumes (by TEP production personnel).
• As part of our LDAR, STEM, ooooa inspection / compliance programs, TEP will adhere to the use of Approved Instrument Monitoring Methods (AIMM) for inspecting production equipment and facilities at the Federal 298-13-1 oil and gas location.
• Spill prevention training is provided to all field employees on a monthly basis. The monthly training consists of reviewing past incidents, root causes of the incidents, and what specific actions (lessons learned) could be taken to prevent the reoccurrence of such incidents in the future.
• Flowlines will be integrity-tested per the 1100 Series rules.
• TEP spill response procedures will be adhered to for any spills or releases occurring at the Federal 298-13-1 oil and gas location. All spills will be managed in accordance with the COGCC 900 Series rules.
• Leak Detection and Repair (LDAR) inspections are performed at all locations; however, the inspection frequency is tiered based upon the level of emission controls that are required / employed at each location.
• Storage Tank Emission Monitoring (STEM) inspections are performed monthly at any location where emissions must be controlled (> 2 tpy).
• OOOOa inspections are performed semi-annually on any facility constructed after 2015.
• Flare Logs are completed daily for all locations where active flares and emissions controls are required.
• Spill prevention training will be provided to all field employees on an annual basis;
• Any leaks or spills detected during monitoring will be reported within 24 hours in accordance with Rule 912.b;
• Annual flowline testing will also occur according to COGCC rules 1101 and 1102. Inspection and record retention of flowline testing will be in accordance per COGCC regulation; all records will be made available to the COGCC upon request;
• All load lines will be bull plugged or capped;
• All on-location flowlines will be inspected and tested per Rule 1104;
• All equipment deficiencies will be corrected immediately or as soon as practical (all identified problems and corrections/repairs will be documented and records will be maintained in the TEP’s office);
• TEP will track and clean up all spills, including those that are not reportable;
• TEP will temporarily shut in all production wells on the pad in the event of any upset condition;
• All piping is pressure tested and inspected for leaks prior to flowback; and
• Automation technology will be utilized at this location; this technology includes the use of fluid level monitoring for the tanks and high-level shut offs. |
| Material Handling and Spill Prevention | Form: (02A )
402932354
9/21/2022 | • If PFAS-containing foam is used at a location, TEP will perform appropriate soil and water sampling to determine whether additional characterization is necessary and inform the need for and extent of interim or permanent remedial actions;
• If PFAS-containing foam is used at a location, TEP will properly capture and dispose of PFAS contaminated soil and fire and flush water; and
• If PFAS-containing foam is used at a location: TEP will properly characterize the site to determine the level, nature and extent of contamination. |
| Material Handling and Spill Prevention | Form: (02A )
402932354
9/21/2022 | Water Resource Protection:
• Informal inspections of all tanks and storage facilities will occur daily during drilling, completions, and production operations;
• A closed loop drilling system will be employed;
• 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;
• Temporary frac tanks placed on location will have proper secondary containment including a perimeter berm around the Working Pad Surface and containment under the frac tanks;
• Flowback and stimulation fluids will be sent to enclosed tanks, separators, or other containment/filtering equipment before the fluids are placed into any pipeline storage vessel, other open top containment located on the well pad, or into tanker trucks for offsite disposal; no open top tanks will be used for initial flowback fluids containment;
• Any temporary surface or permanent surface/buried pipelines (flowlines from wellheads to separators to tanks; and any temporary surface lines used for hydraulic stimulation and/or flowback operations) will be pressure tested in accordance with the 1100-series rules prior to being placed into initial service and following any reconfiguration of the pipeline network; all permanent flowlines from wellheads to separators and from the separators to the tank will also be pressure tested annually;
• Tank batteries will be placed within engineered, steel secondary containment with an impervious liner system or other secondary containment systems;
• Pollution control containers (spill boxes) to be used on truck loading lines within the limits of the secondary containment systems;
• TEP will properly characterize and dispose of all waste streams at facilities approved for acceptance of each waste stream;
• All wells located on this pad will be equipped with remote shut-in capabilities; and
• The use of cathodic protection on buried steel lines to mitigate corrosion. |
| Dust control | Form: (02A )
402932354
9/21/2022 | • Pad / Road Construction: Fresh water will be periodically applied to disturbance areas during construction to minimize fugitive dust.
• TEP will not use produced water or other process fluids for dust suppression.
• During High Wind: Contractor will monitor wind conditions during site construction; during wind events in excess of 13 miles per hour, TEP construction contractors will apply freshwater from an approved source to the disturbance area of the pad, road, or pipeline corridor to minimize or mitigate propagation of fugitive dust; accessibility and worker safety will be considered prior to application; during periods of sustained high winds over 20 miles per hour, TEP construction contractors may temporarily suspend work to minimize potential for migration of fugitive dust, ensure worker safety, and to minimize impacts to public health, safety, welfare, the environment, and wildlife;
• Road Surfacing: The existing lease road will be spot graveled during site construction to ensure there is sufficient gravel on the road to minimize fugitive dust.
• Speed Restrictions: TEP has implemented speed restrictions on all lease roads and requires all TEP employees and contractors to adhere to all posted speed restrictions; the speed limit for the existing access road is and will be twenty-five (25) miles per hour;
• Road Maintenance: During long-term production operations, TEP will conduct annual inspections of the existing road and will perform maintenance actions as necessary to ensure road integrity and minimize fugitive dust. Road maintenance actions may include, but not limited to, regrading, spot graveling, storm water control maintenance, and application of magnesium chloride (MgCl2) and / or fresh water.
• Site Visitation: TEP will utilize telemetry equipment to minimize well site visitation when possible to reduce fugitive dust from vehicles traveling the dirt / gravel roads.
• When / if sand / proppant is used during completion operations, an enclosed sand storage and delivery system will be utilized to eliminate possible fugitive sand dust emissions; and
• Topsoil and stockpiled soils will be stabilized through either tackifiers, seeding practices, or erosion control blankets. |
| Noise mitigation | Form: (02A )
402932354
9/21/2022 | • Any operations involving the use of a drilling rig, workover rig, or fracturing and any equipment used in the drilling, completion, or production of a well are subject to and will comply with the Agricultural maximum permissible noise levels in Rule 423.a.(2).A. of 65 db(A) in the hours between 7:00 a.m. to 7:00 p.m. and 60 db(A) in the hours between 7:00 p.m. to 7:00 a.m.; and
• If a noise complaint is made to either TEP directly, the COGCC, or the local government, and TEP is notified of the complaint, noise levels will be measured within 48 hours of receipt of the complaint; TEP will contact the concerned party (if contact information is available) to discuss the complaint and the results of the noise measurements. |
| Emissions mitigation | Form: (02A )
402932354
9/21/2022 | • TEP will install equipment designed specifically to aid in the mitigation of VOC emissions from this location; this equipment includes emission control devices (ECDs) and tank load out controls; if one of these pieces of equipment is not operational, facility controls will automatically shut-in the pad until the equipment is back on line;
• Test separators and associated flowlines, sand traps, and emission control systems will be installed onsite to accommodate green completions techniques.
• Venting/Flaring - TEP will not flare or vent gas during completion or flowback, except in upset or emergency conditions, or with prior written approval from the Director for necessary maintenance operations. |
| Odor mitigation | Form: (02A )
402932354
9/21/2022 | • Water/bentonite-based mud (WBM) drill cuttings are circulated up the annulus and through the rig flowline to a mud-gas separator, where any gas entrained in the mud is separated and flows off the separator’s overhead to an internal combustion device; the drilling cuttings then flow with the drilling mud over two sets of drying shakers and then through a centrifuge to further dry the cuttings; the dried cuttings are placed into steel bins where they are temporarily stored on location prior to placement into the cuttings trench;
• If odor complaints are received and it is determined that they are caused by the drilling fluids, then an odor neutralizing agent or similar product will be added to the system to eliminate the odor; and
• Hydrocarbon odors from production facilities will be minimized by keeping produced fluid hydrocarbons and natural gas contained within pipes, separators, tanks, and combustors; all tanks will be sealed with thief hatches and gaskets; tank vapors will be captured with properly sized piping and combustors. |
| Drilling/Completion Operations | Form: (02A )
402932354
9/21/2022 | • Site lighting shall be shielded and directed downward, inward, away from the nearby areas where wildlife may be present, and toward operations to avoid glare on nearby public roads or possible wildlife areas;
• A closed loop system will be implemented during drilling;
• All cuttings generated during drilling will be managed within the proposed cuttings trench prior to disposition;
• The moisture content of any water/bentonite-based drilling mud (WBM) generated cuttings shall will be minimized through good engineering practices and mechanical process to prevent the accumulation of liquids greater than de minimis amounts;
• Solids control and separation equipment will be utilized to separate WBM-generated cuttings solids from liquids (water/bentonite drilling mud);
• In the event that the drill cuttings analytically demonstrate constituents above able 915-1 standards, the cuttings will be remediated prior to interim reclamation activities to levels below all applicable standards of Table 915-1; No liners will be used of disposed of cuttings trench;
• No offsite disposal of water-based bentonite drilling cuttings to another oil and gas location or third party commercial disposal facilities shall occur without prior approval of an amended Waste Management Plan specifying disposal location and waste characterization method;
• Recycled produced water will be utilized for well completion operations minimizing the amount of fresh water required for development of the proposed wells on this location;
• TEP will use pipelines to transport water for hydraulic fracturing to and from location;
• TEP will recycle or beneficially reuse flowback and produced water for use downhole;
• TEP will properly characterize and dispose of all waste at the appropriate landfill/waste disposal location that allows for acceptance of the particular waste stream;
• Cuttings from each well will be placed in steel containment bins. Baseline samples of the cuttings will be collected to assess constituent levels listed in COGCC Table 915-1, the cuttings pile will then be thoroughly mixed with clean fill material to create a composite of the stored materials prior to placement in the cuttings trench. This contingency Sampling of the water/bentonite based drill cuttings will occur regardless of whether the original "background" or "baseline" samples collected from each well drilled are compliant with Table 915-1. The 7-point composite from each well may be used for preliminary analysis and waste profiling; however, discrete sample results will be required for confirmation sampling. The operator will close out the cuttings trench with a Form 27. The operator will propose the number of discrete samples, the locations, and depth intervals for the confirmation samples in the Form 27. The depth intervals will be selected to provide sufficient coverage between 0 and 19 feet below the final top surface of the
cuttings within the trench. Upon approval of the Form 27, TEP will collect the proposed samples and analyze them for the Table 915-1 constituents;
• Locally sourced fresh water will be used to minimize fugitive dust during construction, drilling, completion, and production operations. |
| Interim Reclamation | Form: (02A )
402932354
9/21/2022 | Topsoil Protection:
• Protection from Contamination - based on changes in physical characteristics (e.g., organic content, color, texture, density, or consistency) soil horizons will be segregated and stockpiled separately; stockpiles of different soil types will be separated by compacted earthen berms, sediment control logs, straw bale barriers, etc.; and topsoil stockpiles will be stabilized to control erosion and sedimentation;
• Protection from Compaction - topsoil stockpiles will be indicated on site with signage; stockpiles will be placed in areas away from vehicle and equipment traffic; and when stockpiling, compaction will be minimized by limiting the number of equipment passes, limiting stockpile height, and using vegetation;
• Protection from Wind Erosion - surface roughening, applying hydro-seed/mulch, using soil tackifier, covering stockpiles with rolled erosion control products or other similar measures;
• Protection from Water Erosion - surface roughening, applying hydro-seed/mulch, using soil tackifier, covering stockpiles with rolled erosion control products or other similar measures; and
• Weed Establishment Prevention - TEP uses Cultural, Mechanical, Biological, and Chemical controls to prevent the establishment of weeds. |
| Interim Reclamation | Form: (02A )
402932354
9/21/2022 | • Interim reclamation will occur within six (6) months following completion of well drilling and completion operations;
• The areas identified to be interim reclaimed will be re-contoured to blend as nearly as possible with the natural topography during site reclamation; all topsoil will be moved from the stockpile area and placed over the facility’s cut and fill slopes to a uniform depth to ensure long term topsoil health including protection from erosion, prevention of weed establishment, and maintaining soil microbial activity until final reclamation;
• The location will be reseeded by drill, broadcast, or hydroseed methods; drill seeding will be utilized wherever soil characteristics and slope allow for effective operation of a rangeland seed drill.;
• The seed bed will be prepared on all topsoiled areas to alleviate compaction and minimize the potential for erosion;
• Topsoiled areas will be planted with desirable species or a seed mixture provided by the Surface Owner for this particular location;
• Protection from Wind and Water Erosion - topsoiled areas will be covered with certified weed free mulch at an application rate specified by the product’s manufacturer, or a specification sheet that follows good engineering practices; and
• Weed Establishment Prevention - TEP uses Cultural, Mechanical, Biological, and Chemical controls to prevent the establishment of weeds.
• Erosion control will be implemented per the Stormwater Management Plan included in the Form 2A for this location and will be inspected and maintained as required by Federal, State, and Local regulation; and
• Noxious weeds which may be introduced due to soil disturbance during reclamation will be treated by methods approved by the BLM Authorized Officer. |