| General Housekeeping | Form: (02A )
401578308
8/31/2018 | Flammable liquids shall not be stored within fifty (50) feet of the wellbore, except for the fuel in the tanks of operating equipment or supply for injections pumps. Where terrain and location configuration do not permit maintaining this distance, equivalent safety measures should be taken. |
| Storm Water/Erosion Control | Form: (02A )
401578308
8/31/2018 | Crestone will comply with COGCC Rule 1002.f.(2). by utilizing BMPs at the oil and gas location to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, site degradation and protects surface waters. Examples of engineering controls that could be used when needed are:
Surface roughening
Silt fence
Erosion control blanket
Temporary slope drain
Temporary outlet protection
Sediment control log
Vehicle tracking control
Sediment trap
Stabilized staging area |
| Material Handling and Spill Prevention | Form: (02A )
401578308
8/31/2018 | 1. Integrity testing of flowlines connecting wellheads to the separators:
CONSTRUCTION PHASE: The flowlines that Crestone uses are designed/constructed/tested to ASME B31.3/4/8 and API 1104 standards. Only materials with Material Test Reports (MTRs) provided by the pipeline supplier are used in the construction of the flowlines. Construction is tested with 100% x-ray and goes through hydrotest per the applicable B31-code.
OPERATIONS PHASE: Pressure testing of the flowlines is conducted on an annual basis. Additionally, Crestone is already in compliance with 1104.i. Continuous Pressure Monitoring Requirements of the 1100 Series Flowline Regulations. Crestone utilizes a series of standard operating procedures to define our flowline integrity testing program.
2. Frequency on valve and fitting inspections: Crestone Lease Operators inspect all equipment on their locations at a minimum of once every 48 hours, but most sites are inspected every 24 hours. Valves and fittings inspections are part of the daily job duties of our lease operators. Any valve or fitting that is found to be leaking is either repaired immediately by the lease operator or shut-in procedures are implemented as described below. Additionally, lease operators conduct a documented monthly inspection of the facility and this includes inspection of all valves and fittings.
3. Description of Lease Operator Inspections, Monthly Documented Inspections & Environmental Inspections: The Crestone lease operator inspections are done as a routine part of the lease operators job. The lease operator would typically visit each of their assigned locations daily. They conduct a visual inspection of the facility which includes all valves, fittings, wellhead, tanks, vapor control systems and all connections. The lease operator also checks our Cygnet automation system for system pressures and flows. Pressure and flow sensors are placed on multiple points throughout the system and are specifically designed to measure the system for irregularities that would indicate a leak in the system or change in production of oil, water, or gas. The Cygnet system is also set-up with alarms that are triggered by anomalous pressure or flows. Low pressure warnings can activate automatic shut-in of the well and system. The monthly documented inspection is done using an electronic form that is recorded in the EU system. This thorough inspection and documentation requires the lease operator to inspect all aspects of the site and then triggers work orders for any leaks, or housekeeping issues. This inspection would note any leaks of either gas or fluids which triggers an immediate repair or shut-in. The Lease operators also conduct a weekly CDPHE Regulation 7 – Audible, Visual, and Olfactory (AVO)inspection, which focus on the tanks and vapor control system. The Regulation 7 AVO is also a documented inspection. In addition, the sites are inspected with optical gas imaging cameras on a routine schedule, annually for compliance purposes with our Spill Prevention Containment and Countermeasures (SPCC) plan, depending on the status of reclamation the sites are also inspected on either a 14-day, 30-day, annual or rain triggered event in accordance with both the COGCC and the CDPHE Stormwater Management Plans (SWMP).
4. Measures for when leaks are discovered:
• If we suspect a leak we shut in the well and hydrotest the line. If it passes, then the well is brought back onto production.
• If there is an actual leak, well is kept shut in while leak is found and fixed. Not until the line has passed hydrotesting, would the well be brought back online. |
| Dust control | Form: (02A )
401578308
8/31/2018 | Crestone Peak Resources places road base, rock and recycled asphalt to assist with dust abatement. During construction, drilling, completions and reclamations phases, Crestone monitors each site and if needed we will run water trucks. |
| Construction | Form: (02A )
401578308
8/31/2018 | Operator will have an MLVT Design Package, certified and sealed by a licensed professional engineer, which is on file in their office and available upon request. The site shall be prepared in accordance with the specifications of the design package prior to tank installation; including ensuring that proper compaction requirements have been met.
The MLVT will be at least 75 feet from a wellhead, fired vessel, heater-treater, or a compressor with a rating of 200 horsepower or more. It will be placed at least 50 feet from a separator, well test unit, or other non-fired equipment.
All liner seams will be welded and tested in accordance with applicable ASTM international standards.
Operator will be present during initial filling of the MLVT and the contractor will supervise and inspect the MLVT for leaks during filling.
Operator will comply with the testing and re-inspection requirements and associated written standard operating procedures (SOP) listed on the design package.
Signs will be posted on the MLVT indicating that the contents are freshwater.
The MLVT will be operated with a minimum of 1 foot of freeboard at all times.
Access to the MLVT will be limited to operational personnel and authorized regulatory agency personnel.
Operator or contractor will conduct daily visual inspections of the exterior wall and surrounding area for integrity deficiencies.
Operator will have a contingency plan/emergency response plan associated with the MLVT and it is on file at their office.
A fabric reinforced liner will be utilized. In the event that a tank breach were to occur, the fabric reinforced liner will prevent a “zippering” failure from occurring. The liner will meet the specifications per the design package.
Operator acknowledges and will comply with the Colorado Oil & Gas Conservation Commission Policy on the Use of Modular Large Volume Tanks in Colorado dated June 13, 2014. |
| Noise mitigation | Form: (02A )
401578308
8/31/2018 | Crestone will perform a baseline noise survey prior to any operational activity measuring dBA at a distance 350 feet from the noise source or sound levels will be measured at a point twenty-five (25) feet from the structure towards the noise source. In situations where measurement of noise levels at three hundred and fifty (350) feet is impractical or unrepresentative due to topography, the measurement may be taken at a lesser distance and extrapolated to a 350-foot equivalent using the formula stated in Rule 802 of the State of Colorado Oil and Gas Conservation Commission. As necessary, based on the survey, Crestone will install temporary sound walls to minimize noise and light impacts during drilling and completions and will install permanent noise mitigation at the facility location as necessary to meet all COGCC regulations. |
| Odor mitigation | Form: (02A )
401578308
8/31/2018 | Crestone operations will be in compliance with the Department of Public Health and Environment, Air Quality Control Commission, Regulation No. 2 Odor Emission, 5 C.C.R. 1001-4, Regulation No. 3 (5 C.C.R. 1001-5), and Regulation No. 7 Section XVII.B.1 (a-c) and Section XII. Where possible, drilling rig and completion equipment engine exhaust will be directed away from occupied buildings to assist in mitigating potential odors. As necessary, Crestone may utilize chemical additives during drilling operations to mitigate odor impacts. Sealed tanks with pressure relief valves and emissions controls will be utilized for the production facilities. |
| Drilling/Completion Operations | Form: (02A )
401578308
8/31/2018 | Green Completions -Test separators and associated flow lines, sand traps and emission control systems shall be installed on-site to accommodate green completions techniques. When commercial quantities of salable quality gas are achieved at each well, the gas shall be immediately directed to a sales line or shut in and conserved. If a sales line is unavailable or other conditions prevent placing the gas into a sales line, the operator shall not produce the wells without an approved variance per Rule 805.b.(3)C. |
| Drilling/Completion Operations | Form: (02A )
401578308
8/31/2018 | Crestone certifies that the MLVTs are designed and implemented consistent with the June 13, 2014 “Policy on the Use of Modular Large Volume Tanks in Colorado.” Please see attached map for the location of the tanks. |