| PROPOSED BMPs | Form: (07 )
0
1/23/2012 | Statement and/or procedures to be followed for covering materials (1002.f (2) A
The following procedures and practices will be implemented to minimize contact of precipitation and stormwater runoff with materials, wastes, equipment, and activities with potential to result in discharges causing pollution of surface waters:
Diversion ditches and/or berms will be used above pad cut slopes as well as around equipment and chemical storage areas to prevent stormwater run -on from contacting materials, wastes, equipment, and activities that could result in discharges of pollution.
Dry chemical storage areas will provide overhead cover to provide protection from direct precipitation.
Statement and/or procedures to be followed for material handling /spill prevention (1002.f (2) B)
The following materials handling and spill prevention procedures and practices will be implemented for material handling and spill prevention of materials used, stored, or disposed of that could result in discharges causing pollution of surface waters.
Storage containers, fuel tanks, and equipment used during construction activities will be visually inspected routinely for leaks. These inspections will be conducted by site and contractor personnel as they perform their routine duties;
Dry chemical storage areas will provide overhead cover and adequate secondary
containment.
Drums will be properly labeled so an enclosed substance can be quickly
identified. OSHA - approved labeling and sign systems will be followed for all secondary containers;
Erosion damage to the earthen berms, outfalls, silt barriers, collection channel, containment ponds, and any erosion and sediment control will be repaired as soon as practical;
Areas of stained soil will be inspected in order to identify the sources of the staining. Contaminated soil will be removed and properly disposed;
Energy dissipating material, such as riprap, cobbles or gravel will be placed, or existing materials will be utilized at the stormwater outfalls to prevent erosion damage; and
Stormwater management structures will be cleared of debris and replaced/repaired when necessary; and surface runoff controls such as berms, culverts, and ditches will be used to control runoff.
Routine maintenance of any oil- containing equipment is performed by trained personnel at the location of the equipment utilizing soaker pads and the available secondary containment structures and/or drip pans as warranted.
Each permanent storage tank or vessel has a system in place that has been designed and installed in accordance with good engineering practice to prevent discharges. These features may include: adequate containment volume to avoid overfill during normal operations; and, high level sensors and controls to stop
liquid flow. All discharge features are inspected at regular intervals.
Statement and/or procedures to be followed for self inspection, maintenance, good - housekeeping (1002.f.(2) D)
The following self - inspection, maintenance, and good housekeeping procedures and schedules will be implemented to facilitate identification of conditions that could cause
breakdowns or failures of BMPs.
Self Inspection:
Routine inspection and maintenance of erosion and sediment controls will take into account seasonal factors, such as winter snow cover and spring runoff from snowmelt, to
ensure site conditions and controls are adequate and in place to effectively manage stormwater.
The stormwater inspection program includes the following:
1. A trained and qualified person familiar with the stormwater program and stormwater controls conducts facility inspections and records inspection results.
2. Inspections cover these areas:
Evidence of surface erosion for disturbed areas;
Material and chemical storage areas;
Best Management Practices (BMPs);
Surface water diversions and downgradient areas;
New access roads and ditches; and
Locations where vehicles enter or exit the site.
3. Inspections are not conducted for disturbed areas when snow cover exists over the entire site for an extended period as long as melting conditions do not exist.
4. Water quality is visually assessed for all receiving streams and discharge areas during each inspection, if present.
5. Disturbed areas and material storage areas that are exposed to precipitation are inspected for evidence of pollutants entering nearby drainages.
6. Check dams, wattles, and other BMPs are inspected for evidence of deterioration, under- cutting, and build up of sediment. Sediment needs to be removed when it has built up one -third to one -half the height of the BMP structure.
7. Roads used for vehicle access are inspected for evidence of off -site sediment transport. |
| PROPOSED BMPs | Form: (07 )
0
1/23/2012 |
8. An inspection report summarizing the scope of the inspection, the name of the person conducting the inspection, date of inspection, and observations is prepared and stored in the field office.
9. Actions taken to correct deficiencies associated with an inspection are recorded, including the date the deficiency was corrected, the company responsible for the correction, and correction comments.
Maintenance:
When deficiencies are discovered during inspections, or otherwise, work orders will be generated and reviewed by Noble to direct designated subcontractors to perform maintenance or replacement of existing BMPs, or installation of additional BMPs.
Maintenance will include prompt adjustments and repairs to erosion and sediment control structures that are found to be performing inadequately or deteriorating. Signs of rill or
gully surface erosion shall be repaired as quickly as practical.
Good Housekeeping
The following items will be addressed in order to maintain a clean and orderly pad during the development, production, and abandonment phases of work:
Inspect pad areas routinely;
Correct deficiencies noted during inspections;
Clean and maintain stormwater management structures and components;
Routine trash collection and proper disposal;
Familiarize employees and contractors with spill clean-up equipment and storage locations; and
Familiarize employees and contractors with good housekeeping procedures and pad pollution prevention procedures.
The following good housekeeping practices will be followed at the material storage areas:
Storage containers will be stored away from direct traffic to prevent accidents. They will also have proper labels;
Dumpsters and trash receptacles will be enclosed in order to prevent the dissemination of refuse;
Storage areas will be kept free of refuse;
Chemical substances used at pads will be properly labeled and will have proper spill containment; and
Chemical substance containers will be clearly labeled with an MSDS kept on file.
Statement and/or procedures to be followed for spill response procedures (1002.f. (2) E)
In the event of a release, the facility has trained personnel and equipment available to contain and clean up minor volumes of oil. On -site equipment and materials include spill kits, shovels, and sorbent materials (booms, pads, etc.) that may be used to dike, contain and remove minor releases.
In the event of a larger release, specific response procedures have been developed and are included in Noble Energy's Oil Spill Contingency Plan. As part of these procedures,external resources (contractors) have been identified to assist facility personnel. To ensure the commitment of these external resources, Noble Energy, Inc. maintains a service agreement with each selected contractor. A list of approved contractors is kept at
the facility and at the Noble district office in Denver, Colorado. At a minimum, contractors identified to assist in a spill response will have the capabilities to provide emergency response, industrial power vacuuming, tank and pipeline cleaning, equipment decontamination, excavation/earthmoving and waste transportation and disposal services.
Materials recovered during a spill event will be appropriately containerized or will be remediated on site in accordance with Colorado Oil and Gas Conservation Commission (COGCC)stipulations. Soils and other solids will be placed in 55- gallon drums or roll -off containers, or in other approved containers as warranted. Liquids will be placed in 55-gallon drums or will be collected in a tank truck using industrial power vacuuming.
Recovered materials will be labeled, characterized and disposed/recycled in accordance with applicable federal, state and local regulations.
Statement and/or procedures to be followed for items under 1002.f (3)
Upon termination of the stormwater permit issued by the Colorado Department of Public Health and Environment for this oil and gas facility, Noble Energy Inc. shall have developed a Post - Construction Stormwater Program in compliance with this section. |
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