| Traffic control | Form: (02A )
402643220
10/28/2022 | Traffic reduction measures shall be employed when feasible: such as, utilizing nearby fresh water sources, supply pipelines for completions.
This site will have a pipeline connect for gas in addition to both oil and water will be directed to Crestone’s Hub facility via pipeline. In addition, efforts are made to load trucks both ways, when possible, such as hauling dirt on the same trucks that haul cuttings.
Haul routes shall be designated and developed in consultation with the COUNTY. Municipalities, with roadways which are part of the haul routes, should be included in such consultation.
The haul route shall be from I-25, trucks will exit Erie Parkway/CR 8 and head west 1,000’, then head south on the I-25 Frontage Rd 1,350’ to the existing location entrance. Trucks leaving the site will follow this route in reverse. |
| Wildlife | Form: (02A )
402643220
10/28/2022 | If the earth disturbance necessary to construct the Oil & Gas Location commences between February 1st and July 31st, Crestone will conduct nesting raptor surveys at least 2 weeks prior to the start of construction and will coordinate with CPW as needed.
CPR will fence and net or install other CPW-approved exclusion devices on new or existing drilling pits, production pits and other pits as determined
necessary by COGCC.
No flowline or other underground utility associated with the Project will cross either a perennial stream or an aquatic HPH.
Install screening or other devices on the stacks and on other openings of heater treaters or fired vessels to prevent entry by migratory birds.
Use wildlife-appropriate fencing where acceptable to the surface owner.
Use topographic features and vegetative screening to create seclusion areas, where acceptable to the surface owner. |
| Storm Water/Erosion Control | Form: (02A )
402643220
10/28/2022 | Drainage swales will be installed along the south and east perimeters of the well and facility pad to divert stormwater runoff from the working surface.
A detention pond will be constructed along the southeast pad perimeter to collect stormwater runoff.
Limits of Construction (LOC) will be delineated and marked with lathe and flagging prior to start of construction.
Access Road Construction will follow location delineation and serve as the primary route for construction and operational purposes.
Vehicle Tracking Controls (VTC) will be installed at the ingress/egress of the location access and be the primary sediment control measure for equipment and vehicle traffic.
Diversion Ditch (DD) will be installed around the location perimeter prior to commencement of surface disturbing activities, and act as the primary stormwater control measure.
Sediment control Log (SCL) will be used for inlet protection, as check dams to reduce flow velocity, and on disturbed slopes to shorten flow lengths.
Sediment Basin (SB) will be installed to capture eroded or disturbed soil transport, prior to discharge from the location and the diversion ditch network.
Culverts are used for diversion ditch crossing(s), or along access roads. Culverts will be 18” minimum, or appropriately sized to accommodate design flows.
Inlet Protection (IP) consists of a sediment control measure such as rock sock, sediment control log, or proprietary inlet insert. Inlet protection will be maintained and based on manufacturer recommendations.
Outlet Protection (OP) includes both sediment control measures and riprap armoring at culvert outlets. It will be specified based on culvert capacity and corrective action prescriptions during construction operations.
Fencing will be installed following completion of construction. Fencing will prevent wildlife from entering equipment and secondary containment and remain in place until final reclamation is achieved.
Seed and Mulch (SM) will be used to stabilize all stockpiles, disturbed areas, and areas no longer in use for production operations, or during interim reclamation.
During construction, inspections shall be conducted every 14 days, and after a major precipitation or melt event, which has the potential to cause surface runoff.
For sites earthwork and construction is completed, but final stabilization is not achieved due to vegetative cover, inspections shall be conducted every 30 days and exclude precipitation or melt event response. Inspections will continue until all reclaimed areas have achieved a cover of 70% the pre-construction reference vegetation (i.e. final stabilization).
Post-construction stormwater inspections will be conducted in accordance with COGCC Rules 1002.f and 1003.e, to document the status of the location, maintenance needs, effectiveness of stormwater control measures, to evaluate pollution sources, and to document reclamation / final stabilization progress. Inspections will be managed by the Stormwater Manager and conducted by their designated representative(s).
Findings, inspection records and site maps are documented electronically and available within 24 hours of any inspection. All inspection records are stored for a minimum of three years after the location has achieved final stabilization.
Action and documentation towards completing repairs identified at the time of inspection shall be made within 24 hours of discovery.
For maintenance items during post-construction, items will be documented and coordinated with production crews.
Timeline for completion of maintenance items are a priority and will depend on scope; but in all cases, shall not be completed until field conditions allow for safe access, and utility clearance has been confirmed for actions requiring ground disturbance / earthwork. |
| Material Handling and Spill Prevention | Form: (02A )
402643220
10/28/2022 | Trucks will use the haul route approved with the WOGLA.
E&P wastes will be transported offsite via truck by a licensed transporter to a licensed third party solid waste disposal facility/landfill. Frequency of these operations will vary by site based on waste volumes but will be temporary in most cases.
Waste will be stored on location in compatible container or containment devices designed or engineered for the purposes for which they will be utilized. These containers will be inspected on a regular basis to ensure that no undue wear, structural issues, sever rust, other defects, which may impact their effectiveness.
Drilling fluids are recovered and will be separated from the cuttings at surface. At the end of its use on a particular well, the liquid synthetic mud will be reused for additional drilling operations, or it will be returned to then vendor who originally supplied the mud. Transportation will occur on a daily basis as required to facilitate on ongoing drilling operations in accordance with COGCC Rule 905d.
Drill cuttings will be separated from liquid mud onsite, and the cuttings will be temporarily stored onsite in steel bins. Accumulated cuttings will be transported for permanent disposal to a licensed solid waste disposal facility. The actual solid waste disposal facility that will be used will depend on geographic proximity to the well being drilled. Transportation will occur on a daily basis as required to facilitate ongoing drilling operations.
Any soils contaminated by E&P waste will be disposed of at a licensed third-party solid waste disposal facility/landfill.
Tank bottoms will be disposed of at licensed third-party solid waste disposal facilities.
Liquid wastes such as produced water will be disposed of at licensed third-party injection facilities such as those run by NGL Water Solutions. |
| Material Handling and Spill Prevention | Form: (02A )
402643220
10/28/2022 | Frequent and thorough inspections throughout all stages of operations.
Procedures and training on equipment use in place to avoid and mitigate spills.
Continuous monitoring and third-party systems will be used to track fluid volumes and monitor for leaks.
Rig will be placed on an impervious plastic liner including four-inch to six-inch high berm walls.
Closed loop drilling systems will be utilized.
Temporary portable containers (e.g., drums) are stored inside plastic lined or other impervious containment.
General secondary containment (impervious liner) will be placed under equipment.
Active drilling fluid tanks will be equipped with a third-party measurement and alarm system (Pason Pit Volume Totalizer) to track tank volumes and changes during the drilling operation.
Fluid storage tanks on the location will be equipped with mechanical (visual) level indicators that are inspected by operation personnel.
Third-party continuous monitoring on integral systems in addition to routine inspections. In the event of an upset condition, Operators are notified and respond immediately.
Regular preventative maintenance schedules followed for equipment.
Qualified third-party inspectors will inspect equipment to evaluate compliance with COGCC Rules and Regulations and applicable technical standards.
Secondary containment will be installed with an impervious liner.
Pressure and Integrity testing prior to placing equipment into service.
All equipment will be installed and tested in accordance with applicable American Society of Mechanical Engineers (ASME) and American Petroleum Institute (API) standards.
Underground piping on the facility will be electronically inspected prior to installation using coating deficiency detectors per COGCC 1102.I.(1).
Flowlines will be inspected by a qualified third-party inspector who is trained in accordance with 1102.h prior to placing into service.
Flowlines will be integrity tested per 1100 Series Rules.
Test ports for integrity testing are installed on insulated tanks.
Inspections of all production equipment including temporary equipment. Routine operational checks on the facility. Documented weekly inspections. Audio, Visual, Olfactory (AVO) inspections in accordance with COGCC Rule 609.d. and Air Quality Control Commission Regulation 7. Annual Spill Prevention and Control Countermeasure Inspections.
Periodic operator training on spill prevention best management practices and equipment operations.
Fluid handling equipment will have valves and caps to mitigate leaks.
Internal and External Tank integrity Inspections.
Annual separator and flow through process equipment cleanouts and integrity evaluations.
Pressure testing of all flowlines.
Response to all spills and release in accordance with COGCC 900 Series Rules including timely reporting, response, and investigation. |
| Dust control | Form: (02A )
402643220
10/28/2022 | Application of fresh water to disturbed areas during earth moving activities.
Application of fresh water or magnesium chloride to graveled surfaces of the Site and associated roads.
Use of high-quality construction materials such as crushed granite road base, which generates less dust than other aggregates.
Limit disturbance of natural vegetation to only that area that is reasonably necessary for construction.
Re-establishment of vegetation on disturbed areas not graveled.
Covered storage containers to be used for sand, silica, proppant, or similar material during hydraulic fracturing.
Establish speed limit on all access roads of 20MPH or less. Personnel failing to comply will be subject to disciplinary action.
Establish speed limit on the Site of 5MPH or less. Personnel failing to comply will be subject to disciplinary action.
Curtail scope of work during high wind conditions (sustained winds 25MPH or greater).
Regular road maintenance will include adding gravel and grading when needed.
Additional management practices such as road surfacing, natural wind breaks and barriers, or automation of wells to reduce truck traffic may also be utilized to minimize fugitive dust emissions.
Crestone will use a rock base tracking pad at the access point to help remove dirt and prevent debris from collecting on all access roads. As necessary, Crestone will sweep roads nearest the access point of dirt and debris to maintain a clean entrance.
Vertically track the stockpile by heavy equipment to prevent wind and water erosion.
During construction, salvaged topsoil will be seeded and monitored for erosion and the establishment of undesirable and noxious weeds routinely.
Seeding and straw mulch application will occur on the long-term topsoil storage stockpile during interim reclamation. |
| Construction | Form: (02A )
402643220
10/28/2022 | During construction, no night work and no permanent lighting will be installed on the Site. Daylight operations only are performed during this phase of operation.
A proposed 32-foot-high sound/visual wall (32-foot wall) will be placed surrounding the working pad surface during drilling and completion phases.
There will be 3-Fixture LED Telescoping Mobile Temporary Lighting Towers and 2-Fixture LED Flood Wall Mounted Lights that may be affixed to the 32-foot wall and lights permanently affixed to equipment. All lighting capable of adjustment will be directed inward, downward and shielded to avoid glare on public roads and to prevent light shining beyond the boundary of the Site, while at the same time providing a safe workplace that is free from recognizable hazards and complies with OSHA, ANSI and IESNA standards.
Drilling rig lights above the 32-foot wall shall be angled and shielded to avid direct light shining beyond the boundary of the site.
The lights will be inward, pointing away from residents and none of the lights are directed outward.
Concurrent to the commencement of any operational changes (e.g., at the end of drilling operations and at the start of hydraulic stimulation operations), a lighting self-audit of the site will be performed to ensure that there is not any rogue light coming from the site that may become a nuisance.
Once wells are in the production phase, no night work is anticipated, and no permanent lighting will be installed on the site. |
| Construction | Form: (02A )
402643220
10/28/2022 | New well equipment and all existing equipment at the Well Pad will be anchored to the extent necessary to resist flotation, collapse, lateral movement, or subsidence in compliance with applicable Federal Emergency Management Agency ("FEMA") and COGCC rules and regulations. All guy-line anchors left buried for future use will be identified by a marker of bright color not less than four feet in height and not greater than one foot east of the guy-line anchor.
Following development, Crestone will complete daily inspections at the Well Pad to identify and document any changes in ground surface (e.g., erosion, depressions, pooling water) and implement corrective actions.
If expansive soils and/or rock are observed at the Well Pad, they may be removed and replaced with compacted engineered fill or pre-wetted native soil. If expansive soils are not removed and will remain in place, they can be mechanically or chemically stabilized. Ground improvements required for slabs or foundations will be specified in design-level geotechnical plans and drawings. Adequate surface drainage will be designed and installed in accordance with a SWMP to reduce ponding and infiltration of water into the sub-surface soils. |
| Noise mitigation | Form: (02A )
402643220
10/28/2022 | This site was selected as an optimal site through an Alternative Location Analysis.
Electric drill rigs will be used.
Quiet-Fleet™ hydraulic fracturing technology will be utilized to decrease noise.
Shipments of tubular deliveries and unloading will be limited to daylight hours.
Truck traffic will be limited to day times hours, whenever possible.
Crestone will install recommended acoustical mitigation measures as outlined in the site-specific acoustical modeling report.
32-foot high STC-43 portable acoustical panels will be installed on 2,220 lineal feet of the well pad on all four sides.
24-foot high panels installed in multiple locations on the pad to reduce or redirect as much of the noise away from the RBUs.
Sound panels, or SK8, will be used on this site to isolate noise from individual pieces of equipment as needed.
Crestone will install “quash” sound damping material in all permanent buildings that house noise sources
Crestone will conduct an ambient sound level survey, noise modeling analysis, and provided continuous sound level monitoring in support of Rule 423 |
| Emissions mitigation | Form: (02A )
402643220
10/28/2022 | Per CDPHE Regulation 7, continuous emissions monitoring will be performed for baseline air quality and monitoring during all pre-production operations through six months of initial production. Conducting weekly forward looking infrared (“FLIR”) camera evaluation of completions operations to minimize leaks.
Using NeoFlo™ Drilling Fluid – a non-toxic and BTEX-free fluid.
Piping fugitive emissions during drilling to a combustor.
Using Tier 4 dual fuel engines for completions.
Fuel augmentation with compressed natural gas for the completion fleet.
Construction of facility and pipeline takeaway prior to flowback operations.
Enclosed flowback equipped with vapor recovery units piped into sales line
Production gas connected to pipeline during flowback (green completion) and production (no flaring of production gas during pipeline downtime)
Production oil connected to pipeline during production utilizing lease automated custody transfer (“LACT”) units
Use of instrument air driven pneumatic controllers and pumps |
| Odor mitigation | Form: (02A )
402643220
10/28/2022 | To mitigate the effects of odor from CPR's operations, CPR employ only International Association of Oil & Gas Producers (IOGP) Group III drilling base fluids with <0.5 weight % aromatics and will not use drilling fluids based on diesel. These Group III drilling fluids are odorless and contain no BTEX.
Drilling mud chillers are used to keep drilling fluid temperatures low. Low drilling fluid temperatures reduce the volume of fluid vaporized into the air.
All drilling fluids will be routed through a closed loop system.
No open earthen pits to store fluids or drill cuttings.
Drill piping is wiped down each time the drilling operation “trips” out of the hole.
Metal bins containing drill cuttings will be removed and transported to the designated waste management facilities as soon as they are full in order to minimize odors.
During the hydraulic fracturing process, diesel-fueled equipment is placed in a way that exhausts are pointed straight up to not direct exhaust towards any occupied buildings.
Cosslett East will be a tankless location. Oil, condensate and water will be piped to the Liquids Handling Hub, a centralized facility, approximately one mile away. |
| Drilling/Completion Operations | Form: (02A )
402643220
10/28/2022 | Dual lines: Install 2 wash lines in the mud-gas separator and use a tank to prevent clogging during drilling. |
| Interim Reclamation | Form: (02A )
402643220
10/28/2022 | Topsoil will be salvaged from the construction area to a depth of 6 inches or to the depth of the topsoil horizon, whichever is deeper. Topsoil depth will be assessed prior to initiation of
ground disturbance operations based on changes in physical characteristics such as color, density, organic content, consistency, or texture at three (3) soil pit locations, within the disturbance boundaries.
The current estimate of 15,513 cubic yards (yd3) of salvaged topsoil will be stored on the western side of the disturbance boundary in a stockpile with slopes no greater than 3:1. The
stockpile will be vertically tracked by heavy equipment to inhibit wind and water erosion.
Salvaged topsoil will be seeded with Quickgaurd brand sterile triticale hybrid grass while stockpiled during drilling and well completions operations. Seeding will occur when earthwork
operations are complete. The stockpile will be monitored for erosion and the establishment of undesirable and noxious weeds routinely by the Operator and during stormwater inspections. Stormwater inspections will occur on a 14-day frequency and within 24 hours after the end of any precipitation or snowmelt event that causes surface erosion. Weeds will be mitigated on an as needed basis via mowing operations or the use of line trimmers when the height of weeds exceeds 6 inches or before seed development. Herbicide application will only occur if necessary due to the establishment of prostrate weed species, for which mowing and line trimming operations are ineffective. Soil sterilant and non-selective herbicides will not be used.
Any identified erosion will be repaired as soon as practicable, typically within 72 hours. Additional stormwater control measures will be deployed as needed. All deployed temporary
stormwater control measures will be maintained and will remain in place until the disturbance achieves final stabilization as defined in the Colorado Department of Public Health and Environment (CDPHE) Water Quality Control Division COR400000 permit.
When the Location enters the production phase of operations, areas no longer in use will be interim reclaimed. Topsoil will be redistributed throughout the interim reclamation area
and contoured to match pre-disturbance topography. The redistributed topsoil will be seeded with native perennial grasses and stabilized with crimped straw mulch. Topsoil will continue to be monitored during routine stormwater inspections on a 30-day inspection frequency until the disturbance achieves final stabilization. Topsoil protection, weed management and erosion control/repair will continue throughout the life of the Location per Colorado Oil and Gas Conservation Commission 1000 Series Rules.
A landscape assessment will be conducted prior to ground disturbance to ensure that the recontoured reclamation surface matches pre-disturbance grade and topography.
Any preexisting drainage features will be reestablished during recontouring.
Subsoils will be cross-ripped to a depth of 18 inches to alleviate compaction and promote root growth.
Subsoils will be packed to ensure proper density for root establishment prior to topsoil application.
Topsoil will be redistributed throughout the interim reclamation area to the depth of predisturbance conditions and final contouring will occur to match pre-disturbance topography.
The seedbed will be disked to ensure that proper grade, soil texture and bulk density is achieved to support the return to crop cultivation by the surface owner.
Soil amendments will be applied to maximize the capability of the disturbance area to support uniform reestablishment of crops.
The interim reclamation area will be seeded with Winter wheat when returned to crop cultivation.
Seeding will be completed by the surface owner or tenant farmer during the fall seeding window |