| Planning | Form: (02A )
401120263
8/24/2018 | Maximize equipment and wellhead setbacks from occupied buildings and residences to the extent feasible and practicable, as determined by Crestone Peak Resources.
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| Traffic control | Form: (02A )
401120263
8/24/2018 | A traffic plan shall be coordinated with the local jurisdiction prior to commencement of move in and rig up. Any subsequent modification to the traffic plan will be coordinated with the local jurisdiction.
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| General Housekeeping | Form: (02A )
401120263
8/24/2018 | All surface trash, debris, scrap or discarded material connected with the operations of the property shall be removed from the premises or disposed of in a legal manner.
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| General Housekeeping | Form: (02A )
401120263
8/24/2018 | The well site will be cleared of all non-essential equipment, trash and debris after ninety days of a well P&A.
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| General Housekeeping | Form: (02A )
401120263
8/24/2018 | Crestone Peak Resources will identify plugged and abandoned wellbores according to Rule 319.a.(5). including the location of the wellbore with a permanent monument as specified in Rule 319.a.(5). Crestone Peak Resources will also inscribe or imbed the well number and date of plugging upon the permanent monument.
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| General Housekeeping | Form: (02A )
401120263
8/24/2018 | Crestone Peak Resources will install down cast lighting or some other form of lighting that mitigates light pollution and spill-over onto adjacent properties; provided, however, that Crestone Peak Resources may still use lighting that is necessary for public and occupational safety.
Crestone Peak Resources will have light filtering mesh placed in the drilling rig derrick. All of the derrick lights will be tinted with automobile tint, and all drill rig working floor lighting will be cast downward. There will be 40 ft walls so the lighting on the floor will be below any view shed from the public on that pad.
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| General Housekeeping | Form: (02A )
401120263
8/24/2018 | Crestone Peak Resources will recycle and reuse water at the pad sites and otherwise minimize waste water production to the extent that it determines such recycling, reuse, and waste water minimization is technically and economically feasible.
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| Material Handling and Spill Prevention | Form: (02A )
401120263
8/24/2018 | "• Annual hydrostatic test on the oil dump line from the separator to the tank battery.
• Annual hydrostatic “static” tests on our oil tanks.
• Annual hydrostatic “static” tests on our produced water tank and water dump line from the separator to the produced water tank.
• Lease Operator inspections of all equipment not to exceed 48 hours.
• Monthly documented inspections (EU).
• Annual environmental inspections of all battery and well equipment and pads.
• Annual UT inspections of the pressure vessels and input into Crestone Peak Resources’s RIPL Predictive Integrity Maintenance Program. (HLP separators and fuel gas separators)"
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| Material Handling and Spill Prevention | Form: (02A )
401120263
8/24/2018 | Well effluent containing more than ten (10) barrels per day of condensate or within two (2) hours after first encountering hydrocarbon gas of salable quality will be directed to a combination of sand traps, separators, surge vessels, and tanks as needed to ensure safe separation of sand, hydrocarbon liquids, water, and gas and to ensure salable products are efficiently recovered for sale or conserved and that non-salable products are disposed of in a safe and environmentally responsible manner.
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| Material Handling and Spill Prevention | Form: (02A )
401120263
8/24/2018 | All loadlines will be capped for every location in the DJ.
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| Material Handling and Spill Prevention | Form: (02A )
401120263
8/24/2018 | 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. |
| Construction | Form: (02A )
401120263
8/24/2018 | The pad will be constructed in such a manner that noise mitigation may be installed and removed without disturbing the site or landscaping.
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| Construction | Form: (02A )
401120263
8/24/2018 | Crestone Peak Resources utilizes 24” tall corrugated galvanized metal berm walls with a capacity in excess of 150% of the largest tank contained within the wall. In addition, Crestone Peak Resources best practices mandates the use of impervious liners that extends under each storage tank and up the walls, permanently affixed to the top of the metal berm wall. Protrusions of piping that come through the liner include a fully sealed “boot” to prevent leakage.
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| Construction | Form: (02A )
401120263
8/24/2018 | Crestone Peak Resources will install fencing to restrict access to wellheads and equipment.
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| Construction | Form: (02A )
401120263
8/24/2018 | At the time of construction, all leasehold roads will be constructed to accommodate local emergency vehicle access requirements, and will be maintained in a reasonable condition.
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| Construction | Form: (02A )
401120263
8/24/2018 | 803 - To the extent practicable, site lighting shall be directed downward and inward and shielded so as to avoid glare on public roads and Building Units within one thousand (1000) feet.
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| Construction | Form: (02A )
401120263
8/24/2018 | 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. |
| Noise mitigation | Form: (02A )
401120263
8/24/2018 | 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. Crestone will not exceed 60 dBA from the measurement point as Rule 802 per the agreement with Erie.
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| Noise mitigation | Form: (02A )
401120263
8/24/2018 | Crestone Peak Resources will install 40 ft walls, using the SK8 panels and will box in all auxiliary equipment. We will have quash material in the noisier equipment containers to absorb the ‘C’ scale sound waves and we will perform ambient sound analysis the prior to construction / drilling activity. |
| Emissions mitigation | Form: (02A )
401120263
8/24/2018 | 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.
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| Emissions mitigation | Form: (02A )
401120263
8/24/2018 | Crestone Peak Resources will follow and comply with all leak detection and repair and storage tank emission management plan conditions as required by Colorado Air Quality Control Commission Regulation Number 7. This will include at least monthly Audible, Visual and Olfactory (AVO) inspections of the components and tanks at our Production Facilities at most weekly or at least monthly starting on January 1, 2015. In addition, Crestone Peak Resources will perform infra-red camera inspections of these components and the storage tanks at most monthly or at least annually.
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| Emissions mitigation | Form: (02A )
401120263
8/24/2018 | Current Crestone Peak Resources drilling operations into and through productive horizons are planned to keep a hydrostatic “over-balance” on the formation. Crestone Peak Resources does not intentionally drill ahead with flares and in cases where we do have flares, they are intermittent and only kept for the amount of time it takes to raise our drilling fluid weight to be over-balanced again. In more extreme cases of Well Control Operations, it’s possible to encounter a prolonged flare. This is required in order to bring operations back to normal and ensure proper safety of the rig/rig crews involved during this operation. These flaring instances are rare, but do occur. Crestone Peak Resources typically has a good understanding of the pore pressures and will plan accordingly in order to help mitigate potential light impacts to nearby residents.
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| Emissions mitigation | Form: (02A )
401120263
8/24/2018 | "Well leak detection and repair
(a) To identify leaks, Crestone Peak Resources will perform audio, visual and olfactory inspections on a monthly basis at all of its new and existing wells and related facilities and equipment within Erie’s Town Limits, provided that such related facilities and equipment are located on the pads for such wells, are part of adjacent tanks used for such pad sites, or are part of storage tanks for such pad sites authorized under Article IV, Section 4 of the Operator Agreement. Crestone Peak Resources will also inspect each such well with an infra-red camera on a monthly basis. The initial baseline inspections will occur within sixty (60) calendar days after the Effective Date. After a well has produced for twelve (12) months, the frequency of such inspections shall decrease from monthly to quarterly. If Crestone Peak Resources determines that any repairs are required based on these inspections, Crestone Peak Resources will promptly initiate these repairs.
(b) Crestone Peak Resources will report to Erie on the inspection results and any associated repairs the month after the inspection or repair occurs. This information will be collectively reported on a monthly basis in the same format that Crestone Peak Resources uses for reporting to the Air Pollution Control Division under Regulation 7, but that is specific to wells located within the Erie Town Limits. Erie will make this information publicly available.
(c) This BMP will terminate five (5) years after the Effective Date, after which Crestone Peak Resources will continue to comply with the leak detection, repair, and reporting requirements of Regulation 7, as such requirements may be amended.
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| Drilling/Completion Operations | Form: (02A )
401120263
8/24/2018 | Crestone Peak Resources will utilize a closed loop system for drilling operations at this location.
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| Drilling/Completion Operations | Form: (02A )
401120263
8/24/2018 | Crestone Peak Resources will not utilize pits.
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