| Planning | Form: (02A )
401258468
6/19/2017 | • To the extent practicable, share and consolidate new corridors for pipeline rights-of-way and roads to minimize surface disturbance.
• Engineer new pipelines to reduce field fitting and reduce excessive right-of-way widths and therefore subsequent reclamation requirements.
• Plan new transportation networks and new oil and gas facilities to minimize surface disturbance and the number and length of oil and gas roads through the utilization of common roads, rights of way, and access points to the extent practicable.
|
| General Housekeeping | Form: (02A )
401258468
6/19/2017 | • Post speed limits and caution signs to the extent allowed by surface owners, Federal and state regulations, local government, and land use policies, as appropriate.
• Use remote monitoring of well production to the extent practicable.
• Maintain pre and post development site inspection records and monitor operations for compliance.
• Ensure that staging, refueling, and chemical storage areas are established outside of riparian zones and floodplains, as appropriate.
• Store and stage emergency spill response equipment at strategic locations so that it is available to expedite effective spill response.
|
| Wildlife | Form: (02A )
401258468
6/19/2017 | • Install and maintain adequate measures to exclude birds and big game from all fluid pits to the greatest extent possible (e.g. fencing, netting, and other appropriate exclusionary measures).
• Construct fluid pit fences and nets that are capable of withstanding animal pressure and environmental conditions and that are appropriately sized for the wildlife encountered.
• Skim and eliminate oil from produced water ponds and fluid pits at a rate sufficient to prevent oiling of birds or other wildlife that could gain access to the pit and as consistent with COGCC skimming requirements.
• Treat fresh water pits and any associated pit containing water that provides a medium for breeding mosquitoes with Bti (Bacillus thuringiensis v. israelensis) or other similar products, or take other effective action to control mosquito larvae that may spread West Nile Virus to wildlife, especially grouse.
• Reclaim reserve pits as quickly as practical after drilling and completions to ensure that pit contents do not offer the possibility of unnecessary environmental liability to the environment or local biota.
|
| Construction | Form: (02A )
401258468
6/19/2017 | • Use minimum practical construction widths for new rights-of-way where pipelines cross riparian areas, streams, and critical habitats, where possible.
• Perform routine inspections of netting and pit liner systems to ensure proper function and condition for preventative maintenance and incident deterrence.
• Strip and segregate topsoil prior to construction. Appropriately configure topsoil piles and seed as immediate as practicable to control erosion, prevent weed establishment and maintain soil microbial activity.
• Where allowed by the surface owner, mow or brushhog vegetation for temporary staging areas where appropriate, leaving root structure intact, instead of scraping the surface.
|
| Drilling/Completion Operations | Form: (02A )
401258468
6/19/2017 | • Minimize rig mobilization and demobilization where practicable by completing or recompleting all wells from a given well pad before moving rigs to a new location.
• Maximize the use of directional drilling to minimize habitat loss/fragmentation. |
| Interim Reclamation | Form: (02A )
401258468
6/19/2017 | • Commensurate with the language set forth in the surface agreement, interim and final reclamation shall be performed as early as practical and to the greatest extent possible.
• Apply a weed management plan. Utilize an adaptive management strategy that permits effective response(s) to monitored findings and reflects local site geography and conditions.
• Perform interim reclamation on all disturbed areas not needed for active support of production operations consistent with applicable timing restrictions and requirements.
• Control listed noxious weeds in areas surrounding reclamation areas, as reasonable, in order to reduce weed competition.
• Educate employees and contractors about weed issues.
• Utilize GIS technologies to assess the initial and final extent of disturbance and document reclamation progression.
|
| Planning | Form: (02A )
403369764
1/17/2024 | Prior to submittal of the Application for Permit to Drill Form 2 and the Oil and Gas Location Assessment (Form 2A), TEP conducted meetings with the Colorado Parks and Wildlife (CPW), and surface owner. These meetings were held to discuss TEP’s proposed development plan for the TR 32-28-597 pad and associated support facilities. Changes were made to the proposed development plan based on feedback received from all stakeholders and included in the application. |
| Planning | Form: (02A )
403369764
1/17/2024 | The development plan for the TR 32-28-597 pad was prepared to minimize surface impacts to the greatest extent possible through the development of multiple wells from one existing 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. |
| Planning | Form: (02A )
403369764
1/17/2024 | Existing infrastructure operated by 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 )
403369764
1/17/2024 | 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 roads or wildlife areas |
| Pre-Construction | Form: (02A )
403369764
1/17/2024 | 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 pre-construction 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 )
403369764
1/17/2024 | Any chemicals used will be kept to a minimum. |
| General Housekeeping | Form: (02A )
403369764
1/17/2024 | Any chemical or hydrocarbon spills will be cleaned up immediately in accordance with established company procedures. |
| General Housekeeping | Form: (02A )
403369764
1/17/2024 | All materials will be stored in a neat and orderly manner in their appropriate containers. |
| General Housekeeping | Form: (02A )
403369764
1/17/2024 | TEP will follow manufacturers’ recommendations and company policies for proper use and disposal of products. |
| Wildlife | Form: (02A )
403369764
1/17/2024 | WILDLIFE BEST MANAGEMENT PRACTICES The following wildlife Best Management Practices will be employed by TEP during development of the TR 32-28-597 pad:
1. TEP will inform and educate all employees and contractors on wildlife conservation practices, including no harassment or feeding of wildlife.
2. 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 minimize the potential impacts to wildlife.
3. TEP will minimize direct impacts to wildlife habitat by utilizing existing infrastructure and disturbance corridors whenever possible.
4. Well telemetry equipment will be installed to minimize site visitation through remote monitoring of production operations. Remote shut-in capabilities will also be utilized on this location.
5. TEP will minimize potential impacts to downstream surface water features by staging spill response equipment on location during drilling and completion operations; TEP will also have spill response equipment located at the TR 41-35-597 pad or a nearby location to assist with spill response during drilling, completion, and long-term production operations; Spill response equipment and material will also be available at TEP’s Operations Center near Parachute, Colorado.
6. Black Bear BMPs: a. Wildlife – Avoidance: The operator agrees to report bear conflicts immediately to CPW staff. b. Wildlife – Avoidance: TEP will install and utilize bear proof dumpsters and trash receptacles for food- related trash at all facilities that generate trash.
7. Raptors BMPs: a. Wildlife – Minimization: Exclusionary devices will be installed to prevent birds and other wildlife from accessing equipment stacks, vents, and openings. b. Wildlife - Avoidance: TEP will conduct vegetation removal activities outside the migratory bird nesting season (April 1 - August 30). If vegetation removal must occur during the nesting season, TEP will implement hazing or other exclusionary measures prior to April 1 to avoid take of migratory birds. Alternatively, TEP may conduct a migratory bird survey prior to vegetation removal as required by COGCC Rule 1202.a.(8) to avoid take of migratory birds.
8. Greater Sage-Grouse BMPs:
a. Wildlife – Avoidance: Project construction activities (pad and pipeline) will not occur during the sage-grouse lekking season between March 1 – April 30 annually.
b. Wildlife – Minimization: Project construction activities (pad, road, and pipeline) and associated vehicle traffic will be restricted to daylight hours (7 am to 6 pm from May to August and 8 am to 4 pm from September to February).
c. Wildlife – Minimization: Remote frac pumping operation associated with development of the proposed wells on the TR 32-28-597 pad will be located on the existing TR 34-16-597 pad, which is located approximately 2.09 miles north of the nearest sage-grouse lek site, further minimizing potential impacts to greater sage-grouse.
d. Wildlife – Minimization: Project related vehicle traffic during production operations will be restricted to daylight hours (7 am to 6 pm) except in the event of an emergency.
e. Wildlife – Minimization: A native seed mix beneficial to greater sage-grouse as determined by CPW and approved by the surface owner, will be used during interim reclamation and final reclamation re-seeding activities.
f. Wildlife – Minimization: The operator will implement a reclamation and weed management plan to promote growth of desirable plant species and minimize weeds within the proposed project area and Sage Grouse habitat.
g. Wildlife – Minimization: TEP agrees to make use of tanks and other facilities designed such that they do not provide perches or nest substrates for raptors, crows, and ravens.
h. Wildlife – Minimization: Raptor perch deterrents will be installed on equipment, fences, cross arms and pole tops associated with the proposed project.
i. Wildlife - Minimization: To minimize the potential for impacts to Sage Grouse, TEP has implemented speed restrictions for all lease roads and requires that all TEP employees and contractors adhere to these posted speed restrictions.
j. Wildlife – Minimization: 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 described 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.
k. Wildlife – Minimization: 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 roads or wildlife habitat areas;
|
| Storm Water/Erosion Control | Form: (02A )
403369764
1/17/2024 | The following Best Management Practices for stormwater management will be utilized during development
of the TR 32-28-597 Oil and Gas Location:
1) Stormwater control measures will be in place during all phases of development to control
stormwater runoff in a manner that minimizes erosion, transportation of sediment offsite, and site
degradation.
2) Stormwater control measures will include perimeter controls and site degradation control
measures; these will include a minimum 1.5-foot compacted earthen perimeter berm around the
entire working pad surface and around the cuttings trench near the north side of the well pad;
topsoil will be stockpiled near the northeast end of the location within the disturbance area and
segregated from all subsurface material; there will be a system of exterior diversion ditches
around the entire Oil and Gas Location; these diversion ditches will be fitted with rocked check
dams and will discharge into sediment catchment basins along the perimeter of the Oil and Gas
Location; site degradation control measures will include grading, slope stabilization (seeding,
mulching, surface roughening of the topsoil stockpile), straw wattles along the toe of all fill
slopes, and the use of gravel and road base materials for surfacing; wattles will be placed around
the entire perimeter of the topsoil stockpile to minimize potential for loss of organic materials.
3) Outlet protection should be used when a conveyance discharges onto a disturbed area where there
is potential for accelerated erosion due to concentrated flow;
4) TEP will conduct stormwater inspections immediately after storm events;
5) Bi-weekly inspection of the pad and stormwater control measures (berms, ditches, sediment
basins), and the cuttings trench (berms and precipitation buildup). When necessary, precipitation
within the cuttings trench will be pumped out and sent into the TEP proposed produced water
management system for disposal.
6) Documentation / Stormwater Management Plan – if it is infeasible to install or repair a control
measure immediately after discovering a deficiency, TEP will document and keep on record in
the stormwater management plan: (a) a description of why it is infeasible to initiate the
installation or repair immediately; and (b) a schedule for installing or repairing the control
measure and returning it to an effective operating condition as soon as possible.
7) A post-construction stormwater program will be developed for the facility as required per Rule
1002.f.(3). Stormwater control is also addressed under a field-wide Stormwater Management Plan.
|
| Material Handling and Spill Prevention | Form: (02A )
403369764
1/17/2024 | 1) TEP will properly characterize and dispose of all waste streams at facilities approved for acceptance of each waste stream;
2) TEP will properly characterize and dispose of all waste at the appropriate specific landfill/waste disposal location that allows for acceptance of the particular waste stream.
3) No offsite disposal of cuttings to another Oil and Gas Location shall occur without prior approval of an amended Waste Management Plan specifying disposal location and waste characterization method; commercial disposal of drill cuttings and drilling fluids will only require the operator to maintain documentation (manifests, bills of lading) of drill cuttings and drilling fluids disposal; the operator will implement measures (covers, misting) in trucks to reduce dust and particulate matter (PM) emissions during transport of water-based muds, solids, and drill cuttings materials from the well pad location;
4) A closed loop drilling system will be employed;
5) The moisture content of any water/bentonite-based drilling mud (WBM) generated cuttings will be minimized through good engineering practices and mechanical processes to prevent the accumulation of liquids greater than de minimis amounts;
6) All cuttings generated during drilling will be managed within the proposed cuttings trench prior to disposition;
7) Solids control and separation equipment will be utilized to separate WBM-generated cuttings solids from liquids (water/bentonite drilling mud);
8) 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 or are within background limits; No liners will be used or disposed of in the cuttings trench;
9) Any trash generated during the project will be disposed of properly at a commercial disposal facility
|
| Material Handling and Spill Prevention | Form: (02A )
403369764
1/17/2024 | SITE SPECIFIC FLUID LEAK DETECTION BMPs TEP will use the following site-specific BMPs at the TR 32-28-597 pad to evaluate / determine that all above ground and below ground onsite (and offsite) fluid handling, storage, transmission, and transportation equipment have integrity and comply with the applicable standards cited in the COGCC rules include the following:
• Audio, Visual, and Olfactory (AVO) inspections: AVO inspections will be conducted monthly at the Oil and Gas Location throughout the life of the facility.
• Routine inspection of all production equipment, wellheads, temporary equipment, etc.; Routine inspections to be conducted at the 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, OOOO a inspection / compliance programs, TEP will adhere to the use of Approved Instrument Monitoring Methods (AIMM) for inspecting production equipment and facilities at the Oil and Gas Location.
• 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.
• 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.
• TEP spill response procedures will be adhered to for any spills or releases occurring at the Oil and Gas Location. All spills will be managed in accordance with the COGCC 900 Series rules.
• Temporary flowback tanks placed on location will have proper secondary containment including a perimeter berm around the Working Pad Surface and containment under the flowback tanks;
• Any temporary surface or permanent surface/buried pipelines (on-location / off-location flowlines; 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;
• Permanent 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;
• The use of cathodic protection on buried steel lines to mitigate corrosion.
• Storage Tank Emission Monitoring (STEM) inspections are performed monthly at any location where emissions must be controlled (> 2 tpy).
• OOOO a 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.
• 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);
• 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.
|
| Dust control | Form: (02A )
403369764
1/17/2024 | 6. Fugitive Dust Suppression During Windy Conditions: During dry and windy weather conditions
the following dust suppression methods will be utilized:
a. During wind events in excess of 13 miles per hour, TEP’s construction contractors will
apply fresh water from an approved fresh water 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.
b. During sustained high wind event over 20 miles per hour, TEP construction contractors
may temporarily suspend work to minimize potential for migration of fugitive dust,
Page 4 of 4
ensure worker safety, and to minimize impacts to public health, safety, welfare, the
environment, and wildlife.
7. Best Management Practices: The following Best Management Practices will be utilized during
development of the TR 32-28-597 Oil and Gas Location to minimize or mitigate fugitive dust:
a. Pad / Road Construction: Fresh water will be periodically applied to disturbance areas
during construction to minimize fugitive dust.
b. Fresh water will be used to minimize fugitive dust during construction, drilling,
completion, and production operations.
c. TEP will not use produced water or other process fluids for dust suppression.
d. Construction 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’s 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.
e. 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.
f. 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 (20) miles per hour, unless
otherwise posted.
g. 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 are not limited to, regrading, spot graveling, storm water control maintenance, and
application of magnesium chloride (MgCl2) and / or fresh water.
h. 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.
i. Soil Management: Topsoil and stockpiled soils will be stabilized through either tackifiers,
seeding practices, or erosion control blankets.
|
| Construction | Form: (02A )
403369764
1/17/2024 | BMPs for Short-Term Stabilization Proper stockpile construction (e.g., away from drainages, with 2:1 slopes, proper heights, and control measures downgradient) and management should help to preserve the chemical and biological integrity of topsoil. According to site conditions, the following BMPs may be used to stabilize topsoil stockpiles in the initial phase of construction.
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 stockpile surfaces will be stabilized to control for 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, etc.
Protection from Water Erosion: surface roughening, applying hydro-seed/mulch, using soil tackifier, covering stockpiles with rolled erosion control products, etc.
Weed Establishment Prevention: TEP uses cultural, mechanical, biological, and chemical controls to prevent the establishment of weeds. TEP’s complete Weed Control plan is included in Requirement 12 below. BMPs for Long-Term Stabilization Interim reclamation: When drilling, completion operations and recontouring of the site are complete (as described in the Interim Reclamation Plan), all topsoil will be moved from the stockpile area and placed over the facility’s cut and fill slopes to ensure long term topsoil health including protection from erosion, prevention of weed establishment, and maintenance of soil TEP TR 32-28-597 Topsoil Protection Plan 9 microbial activity until final reclamation. The following BMPs will be used after topsoil placement is complete on cut and fill slopes.
The seedbed 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 the location(s).
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.
Weed Establishment Prevention: TEP uses cultural, mechanical, biological, and chemical controls to prevent the establishment of weeds. TEP’s complete Weed Control plan is included in Appendix C. Final reclamation: During final reclamation, topsoil will be stripped from cut and fill slopes and stockpiled during the final recontouring of the facility. BMP practices listed in the short-term stabilization will be used. Once recontouring is complete, topsoil will be moved from the stockpile area and placed over surfaces recontoured for final reclamation. The following BMPs will be used after topsoil placement is complete on finally reclaimed surfaces.
The seedbed 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 the location(s).
Protection from Wind and Water Erosion: topsoiled areas will be covered with certified weed free mulches at an application rate specified by the product’s manufacturer, or a specification sheet that follows good engineering practices.
Weed Establishment Prevention: TEP uses cultural, mechanical, biological, and chemical controls to prevent the establishment of weeds. TEP’s complete Weed Control plan is included below in Appendix C.
|
| Construction | Form: (02A )
403369764
1/17/2024 | Total Soil Disturbance: The total project disturbance of the TR 32-28-597 OGDP, including the
pad and the associated production facilities, is approximately 5.912-acres. The total surface
disturbance associated with the TR 32-28-597 OGDP including all existing support locations is
approximately 13.668-acres. Please see the Plan of Development attached to the Form 2A for a
detailed breakdown of the project disturbance by project component.
|
| Noise mitigation | Form: (02A )
403369764
1/17/2024 | 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. |
| Noise mitigation | Form: (02A )
403369764
1/17/2024 | 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. |
| Odor mitigation | Form: (02A )
403369764
1/17/2024 | 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. |