| Planning | Form: (02A ) 402202966 6/5/2020 | Prior to submittal of the Application for Permit to Drill (BLM APD/COGCC Form 2) and the Oil and Gas Location Assessment (COGCC Form 2A), TEP conducted onsites and meetings with the Bureau of Land Management (BLM), Colorado Parks and Wildlife, and the associated private landowners. These onsites and meetings were held to discuss TEP’s proposed development plan for the GM 12-20 pad and associated support facilities. Changes were made to the proposed development plan based on feedback received from all stakeholders and included in the Federal APD and COGCC Form 2A.
The development plan for the GM 12-20 pad was prepared to minimize surface impacts to the greatest extent possible through the development of multiple wells from one location by utilizing directional drilling technology, collocating access road and utility corridors within the same area, and through the transportation of fluids to a centralized storage location at the Chevron Tank Facility and the Starkey Production Pit (Pit 14-28-696; Facility ID: 414554) minimizing the surface area needed to conduct operations on the GM 12-20 pad location. |
| Pre-Construction | Form: (02A ) 402202966 6/5/2020 | Prior to commencement of construction activities, TEP will hold a pre-construction meeting with contractors to review proposed construction activities and installation of stormwater control measures. The site will be staked for construction prior to 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 ) 402202966 6/5/2020 | Storage of material and fluids on location during drilling, completion, and production operations will be conducted in a neat and orderly manner and with regards to potential fire hazards on site. Disposal of garbage, trash, and debris will occur
approximately once per week during drilling and completions operations. |
| Storm Water/Erosion Control | Form: (02A ) 402202966 6/5/2020 | During pad construction, the location will be constructed in a manner to control run-on and run-off, prevent offsite transport of sediments or contaminants, and minimize site degradation (particularly to the north-northeast towards the intermittent drainage).
Stormwater BMP’s will include a minimum 2.5-foot compacted earthen perimeter berm on all fill slope portions around the working pad surface. There currently is a complete system of exterior diversion ditches around the entire disturbed area. These ditches tie into two sediment catchment basins (one along the northern portion at the toe of the fill slope of the pad and one just west of the pad/access road intersection). The access road will have waddles and rocked check dams. Site degradation control measures will include grading, slope stabilization (seeding, mulching, surface roughening of the topsoil and excess soil stockpiles), and the use of gravel and roadbase materials for surfacing.
Stormwater controls will be installed with consideration given to worker safety, wildlife, and site access. A post-construction stormwater program will be developed for the facility as required per Rule 1002.f.(3). Stormwater is also addressed under a field-wide Stormwater Management Plan (CDPHE Certification COR404626). For further details, see the Construction Layout Drawings attachment for the existing and planned stormwater / erosion control measures at the site. |
| Dust control | Form: (02A ) 402202966 6/5/2020 | Fugitive dust control measures will be employed during all phase of development to minimize dust pollution. Dust control measures include but are not limited to the application of fresh water via water truck along access road during construction,
drilling, and completion operations, speed restrictions, periodic road maintenance, road surfacing (i.e. gravel), and automation of wells to reduce truck traffic. Dust control measures will be employed on an as needed based during all phases of development. |
| Construction | Form: (02A ) 402202966 6/5/2020 | All construction equipment and materials will be contained within the proposed limits of the oil and gas location, access roads, and pipeline corridors. Topsoil will be stripped from the site and segregated from subsoil for reuse during pad reclamation. |
| Emissions mitigation | Form: (02A ) 402202966 6/5/2020 | Dual fuel generators will be utilized during drilling operations to minimize air emission associated with the use of diesel fuel. Green completion practices will be employed to reduce emissions of gas and condensate vapor utilizing separators, tanks, sand traps, and other facilities to minimize emissions. |
| Odor mitigation | Form: (02A ) 402202966 6/5/2020 | To minimize odors during the flowback phase of well completion operations, all fluids will be ran through high pressure separation and low pressure separation before being sent to sealed top flowback tanks. The sealed top flowback tank vents will be manifolded and piped to a combustion unit to incinerate all odor causing vapors. Emergency relief valves (ERV) on the sealed flowback tanks will be piped to an additional sealed tank. All water flowing into the sealed top flowback tanks will be pumped off site to produced water storage facilities. All temporary flowback fluid storage tanks will have secondary containment. |
| Drilling/Completion Operations | Form: (02A ) 402202966 6/5/2020 | Closed loop drilling system will be utilized during drilling of all wells at this location. TEP will utilized remote centralized hydraulic fracturing operations during well completion operations minimizing un-necessary traffic and activities at the pad location. TEP will ensure 110 percent secondary containment for any volume of fluids contained at the well site during drilling and completions operations. |
| Interim Reclamation | Form: (02A ) 402202966 6/5/2020 | Certified weed-free native seed in seed mixes that have been agreed to by BLM and CPW will be used. |