| Planning | Form: (02A )
403052471
12/2/2022 | Access Road: KMOG will utilize an existing access road from CR 32 for drilling, completions, and production operations, including maintenance equipment. The road will be properly constructed and maintained to accommodate for emergency vehicle access. |
| Planning | Form: (02A )
403052471
12/2/2022 | The wells are commingled into a bulk and test facility design. This reduces the total number of separators on location on a per well basis which in turn allows KMOG to have a smaller facility footprint. Reducing the total number of separators per well also reduces the total noise and emissions from the separator burners. |
| Planning | Form: (02A )
403052471
12/2/2022 | KMOG commits to plugging and abandoning the wells listed in the Ecosystem and Wildlife Resources section of the Pikes Peak Cumulative Impacts Plan within one year of all wells associated with this OGDP (Hethcock Fed 6-5HZ, Moser Fed 3-21HZ, Wardell Fed 13-7HZ) being fully turned over to production through permanent facility equipment. If unanticipated delays are encountered associated with safety concerns, wildlife stipulations, landowner considerations, offset operations, or rig availability, KMOG will provide staff with an updated schedule for plugging and abandonment via a Form 4. |
| Planning | Form: (02A )
403052471
12/2/2022 | Lighting Mitigation Plan
Construction Phase:
• During construction of all phases, KMOG will only conduct day light operation and there will be no nighttime operations that require lighting.
Drilling Phase:
• KMOG will utilize LED fixtures to reduce skyglow.
• KMOG will position all lights to point in a downward direction where vertical lighting is not required. Where it is required, lights are angled in a vertical direction to provide task lighting for safety and operations involving personnel.
• Derrick mast lighting in Section 6.1 is facing horizontally to provide adequate lighting for safe operation.
• Lighting is angled to mitigate the amount of light leaving the location boundary, and away from surrounding off site buildings.
• Lighting within the Drilling area has been reduced to provide a minimum acceptable value for safe operation.
• Light masts are automatically switched off/on based on lighting sensors.
• Lights are switched off when not required.
• Low power (63 W) LED lights are used for the drill rig.
• In the event of a lightning complaint, KMOG will address the complaint and work with all parties involved to ensure the complaint is resolved.
Completions and Flowback Phases:
• KMOG will utilize LED fixtures to reduce skyglow.
• KMOG will position all lights to point in a downward direction where vertical lighting is not required. Where it is required, lights are angled in a vertical direction to provide task lighting for safety and operations involving personnel.
• Lighting is angled to mitigate the amount of light leaving the location boundary, and away from surrounding off site buildings.
• Lighting within the Completion and Flowback areas have been reduced to provide a minimum acceptable value for safe operation.
• Light masts are automatically switched off/on based on lighting sensors.
• Lights are switched off when not required.
• Lights are directed to task areas only.
• In the event of a lightning complaint, KMOG will address the complaint and work with all parties involved to ensure the complaint is resolved.
Production Phase:
• KMOG will utilize LED fixtures to reduce skyglow.
• KMOG will position all lights to point in a downward direction, in order to mitigate light leaving the location boundary.
• Lighting within the Production areas have been reduced to provide a minimum acceptable value for safe operation.
• In the event of a lighting complaint, KMOG will address the complaint and work with all parties involved to ensure the complaint is resolved. |
| General Housekeeping | Form: (02A )
403052471
12/2/2022 | Loadlines: All loadlines shall be bullplugged or capped.
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| General Housekeeping | Form: (02A )
403052471
12/2/2022 | Removal of Surface Trash: A commercial size trash bin for removing debris will be located on site. This bin will be for use by all parties affiliated with the operation. Upon completion of operations, the commercial trash bin will be removed from the location and disposed of in an appropriate manner. |
| Wildlife | Form: (02A )
403052471
12/2/2022 | An environmental assessment will be conducted immediately prior to pad construction, drilling, and completion operations. |
| Wildlife | Form: (02A )
403052471
12/2/2022 | An environmental assessment, including a survey for raptor & burrowing owl nests, will be completed no more than 7 days prior to the start of pre-production operations. If during the environmental assessment an active nest is identified within the buffer recommend by CPW, KMOG will consult with CPW prior to beginning pre-production operations. If pre-production operations are planned between 3/15 – 8/31, CPW’s three-survey protocol for determining the presence or absence of the western burrowing owl will be used. The CPW-protocol recommends that the surveys occur seven days apart, meaning that the first survey should be performed at least 14 or 15 days before the proposed start of activities at the Location. The final survey of the protocol will be no more than 7 prior to the start of pre-production operations. If active burrowing owl habitat is found within ¼ mile buffer of the WPS, pad construction will occur outside the STIP window of 3/15 – 8/31. |
| Material Handling and Spill Prevention | Form: (02A )
403052471
12/2/2022 | Pit Level Indicators: All storage tanks used for active drilling operations (used in lieu of pits) contain pit level monitors with Electronic Drilling Recorders (EDR). KMG uses EDRs with pit level monitor(s) and alarm(s) for production rigs. Basic level gauges are used on tanks utilized for the surface rig. |
| Material Handling and Spill Prevention | Form: (02A )
403052471
12/2/2022 | Operator will not use PFAS on location |
| Material Handling and Spill Prevention | Form: (02A )
403052471
12/2/2022 | Operator will utilize its tankless design for its facilities at the location; the term tankless has been used for the design to designate that we have no oil storage on site. |
| Dust control | Form: (02A )
403052471
12/2/2022 | • KMOG will proactively deploy fresh water to suppress dust along access road to well pad/ facility during all phases of pre-production operations.
• Speed limits will be reduced to 10 mph on access road and 5 mph once vehicles reach well pad/facility.
• Access roads and Vehicle Tracking Control will receive maintenance throughout operations.
• In the event of high winds that generate dust that cannot be mitigated with an application of water, KMOG will shut down construction operations.
• During the Completions phase, KMOG will utilize a fully enclosed sand containerized proppant delivery system that eliminates the use of pneumatic transfer on location. This methodology utilizes a gravity choke feed system that reduces dust significantly. The dust levels from this system are minimal and below Occupational Safety and Health Administration (OSHA) permissible exposure limit which eliminates the need for additional Personal Protective Equipment (PPE). |
| Construction | Form: (02A )
403052471
12/2/2022 | Fencing Requirements: The completed wellsites will be surrounded with a fence and gate with adequate lock to restrict access to authorized personnel only.
KMOG personnel will monitor the wellsites upon completion of the wells. Authorized representatives and/or KMOG personnel shall be on-site during drilling and completion operations. |
| Construction | Form: (02A )
403052471
12/2/2022 | Construction: Operator will only conduct during day light and there will be no nighttime operations that require lighting. |
| Noise mitigation | Form: (02A )
403052471
12/2/2022 | Ambient Survey
• An ambient sound level survey will be conducted at the site approximately 60-90 days before commencement of operations.
Drilling Noise Model:
• Developed noise model representing drilling to assess operational noise levels against COGCC allowable dBA and dBC noise levels.
• Noise mitigation not required.
• The drilling rig will be a modified rig designed to reduce noise levels below compliance levels. This will include low noise level shale shakers and modifications to the generator house to reduce noise levels from the exhaust vents and radiator fans.
• Additional noise reduction modifications may also be implemented depending on the rig contractor utilized following a noise survey study.
Completions Noise Model:
• A quiet completions fleet will be utilized during operations.
• Developed noise model representing completions to assess operational noise levels against COGCC allowable dBA and dBC noise levels.
• Noise mitigation not required.
Flowback Operations:
• Flowback operations follow completions but utilize a fraction of similar pump trucks resulting in a smaller noise impact.
• Noise mitigation not required based on completions noise modeling.
Production Noise Model:
• Developed noise model representing production to assess operational noise levels against COGCC allowable dBA and dBC noise levels.
• Noise mitigation not required.
Continuous Monitoring Evaluation:
• Noise points of compliance were not identified for the site due to the absence of RBU’s within 2000-feet of working pad surface.
• Continuous noise monitoring not required.
Complaint Response:
• In response to a complaint, Operators will measure sound levels at 25 feet from the complainant’s occupied structure towards the noise source for low frequency (dBC). For high frequency (dBA), measurements will be conducted at the nearest point of compliance.
• KMOG will post contact information to receive and address noise complaints arising from pre-production operations around the clock, 24 hours, 7 days per week. Upon receipt of a complaint, either directly to KMOG or from the COGCC, KMOG will contact relative stakeholder with in 48 hours of the receipt. |
| Emissions mitigation | Form: (02A )
403052471
12/2/2022 | Temporary ECD(s) will be utilized to mitigate releases of emissions from temporary produced water storage tanks for the duration which the tanks are on location and being used. |
| Emissions mitigation | Form: (02A )
403052471
12/2/2022 | Test separators and associated flow lines, sand traps and emission control systems shall be installed on-site to accommodate 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, KMOG shall not produce the wells.
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| Emissions mitigation | Form: (02A )
403052471
12/2/2022 | Operator uses pipelines to transport hydrocarbons (oil & gas) from the production facility eliminating odors that could occur during truck loading.
|
| Emissions mitigation | Form: (02A )
403052471
12/2/2022 | Operator will implement ambient air quality monitoring on site. |
| Emissions mitigation | Form: (02A )
403052471
12/2/2022 | Operator will use non-emitting pneumatic controllers. |
| Emissions mitigation | Form: (02A )
403052471
12/2/2022 | Ozone Action Days KMOG will comply with the follow mitigation measures, as feasible, on forecasted Ozone Action Days:
a. Operator will minimize vehicle and engine idling
b. Operator will reduce truck traffic and worker traffic
c. Operator will postpone the refueling of vehicles
d. Operator will postpone construction activities
e. Operator will reschedule non-essential operational activities such as pigging, well unloading and tank cleaning
f. Operator will postpone flowback if emissions cannot be adequately captured with an ECD |
| Drilling/Completion Operations | Form: (02A )
403052471
12/2/2022 | Guy line anchors will not be used. Base Beams will be used to stabilize the rig and
removed after drilling. |
| Interim Reclamation | Form: (02A )
403052471
12/2/2022 | Topsoil will be managed during construction by a combination of site-specific erosion and sediment control measures including: a temporary diversion ditch & berm around the entire location to manage run-on and run-off; short term management of topsoil will include track packing to prevent wind and water erosion, long term management includes seeding with a native seed mix and crimping straw mulch for erosion control and water retention; vegetation establishment on stockpiles and weed control will reduce erosion as well as maintain microbial activity; during the construction phase topsoil will be stockpiled ~6 feet tall and with 5:1 slope to minimize erosion potential. Topsoil managed during interim and production phases will be maintained with BMPs including seeding with a native seed mix and crimped straw mulch; weed monitoring; the long-term topsoil stockpile will be ~3 feet tall at a 5:1 slope to maintain microbial activity for an extended time. Inspections will review all control measures / BMPs implemented, their status, and whether repair or replacement is needed, including weed maintenance when necessary. Maintenance and repair will be completed as soon as practicable, immediately in most cases. |
| Interim Reclamation | Form: (02A )
403052471
12/2/2022 | Structural Control Measures
Diversion Ditch and Berm (DD)
• A diversion ditch and berm will be installed around the northern and eastern sides MOSER FED 3-21HZ facility pad to divert stormwater run-on & run-off to a designated outlet structure.
• This BMP will be installed during construction disturbance reduction, and prior to removal of
construction perimeter controls.
• Diversion ditch and berm will remain in-place until final reclamation activities commence.
Spillway and Outlet (SW/O)
• A spillway and/or outlet are designed to capture sediment transported in surface runoff and
slowly release flows to allow time for settling of sediment prior to discharge from the location.
• Spillway and/or outlet will be installed concurrently with the facility diversion ditch and berm.
• A temporary spillway/outlet will be installed in the northeastern and southeastern slope of the
facility pad for MOSER FED 3-21HZ.
• All spillways and outlets will remain in-place until final reclamation activities are complete.
Culvert (C)
• Culverts are used to move water under a road or crossing, or to direct flow to a designated
endpoint, and are sized to manage anticipated watershed and flow rates.
• Culverts will be installed at the eastern access off the location, as well as along the eastern portion of the access road for MOSER FED 3-21HZ intersecting with Weld County Road 32. Culverts will be evaluated at the time of construction and installed as needed.
• Culverts will be reinforced with inlet and outlet protection to mitigate sediment transport and
surface erosion.
• These BMPs will remain in place throughout the life of production for MOSER FED 3-21HZ and
removed during final reclamation.
Inlet / Outlet Protection (IP/OP)
• Inlet / outlet protection is a permeable barrier installed around a drain or culvert to filter runoff
and remove sediment.
• This BMP will be installed congruently with spillways and outlets.
• Inlet and outlet protection will be installed for all culverts at MOSER FED 3-21HZ.
• Inlet and outlet protection will remain in place throughout the life of production for MOSER FED
3-21HZ and removed with culverts and outlets during final reclamation.
Seed & Mulch (SM)
• Seed and mulch are utilized in disturbed areas to establish stabilization through vegetative cover.
• Seeding will take place once surface disturbing activities are complete. Topsoil stockpiles will be stabilized with seed and mulch no longer than 14-days after completion of stockpiling efforts
unless weather or ground conditions are not suitable to properly create a seedbed and promote
successful germination.
• Seed & mulch will be installed on all disturbed areas no longer utilized for construction, and on all topsoil stockpiles which will remain on MOSER FED 3-21HZ for use during final reclamation.
Anticipated topsoil stockpiles will be situated along the southern perimeter of the facility and well
pads.
• Seeding will remain in place until re-disturbed during final reclamation efforts.
• In areas to be returned to crop, the seed bed will be prepared and left for surface owner to
plant during next agricultural season.
Non-Structural Control Measures / BMPs
Construction Phasing & Sequencing
• Construction phasing and sequencing will be implemented at MOSER FED 3-21HZ to minimize the amount of surface disturbance and exposed soils to the greatest extent practicable.
Protection and Preservation of Existing Vegetation
• Pre-existing vegetation cover will only be removed where necessary for the operation of
construction and development at MOSER FED 3-21HZ. Trees will only be cut or trimmed to
facilitate clearing, grading and safe installation of the location.
• Vegetative buffers will be preserved to the greatest extent practicable for construction and
development.
Good Housekeeping
• Good housekeeping measures will be implemented to prevent sediment, trash and toxic or
hazardous substances from entering surface waters or impacting soils. Housekeeping practices
include routine inspections, regular cleaning, site and equipment organization and maintenance,
and appropriate chemical storage. |
| Drilling/Completion Operations | Form: (04 )
403559780
11/9/2023 | The MLVT will be in compliance with the following Energy & Carbon Management Commission (ECMC) safety setbacks. 1)Seventy-five (75) feet from a wellhead, fired vessel, heater-treater, or a compressor with a rating of 200 horsepower or more; 2)Fifty (50) feet from a separator, well test unit, or other non-fired equipment.
Signs shall be posted on each MLVT to indicate that the contents are fresh water and that no E&P waste fluids are allowed. Location and additional signage shall conform to Rule 210.
MLVT will be operated with a minimum of 1 foot freeboard at all times. Access to the tanks shall be limited to operational personnel. Construction and installation of the tank structure, liner and sub-grade shall meet or exceed the manufacturer specifications. KMOG follows manufacturers Standard Operating Procedures (SOPs) and will provide these SOPs upon request to the ECMC.
KMOG will conduct daily, visual inspections of the exterior wall and general area for any integrity deficiencies before, during, and after filling the MLVTs. If deficiencies are noted, KMOG will repair them as soon as practicable. Records of repairs will be maintained per Rule 205.
KMOG will follow pre-construction risk assessment measures to address safety concerns and minimize environmental impacts and property damage in the unlikely event of a MLVT release.
In the event of a catastrophic MLVT failure, KMOG shall notify the ECMC as soon as practicable but not more than 24 hours after discovery, submit a Form 22 - Accident Report within 10 days after discovery, conduct a root cause analysis and provide same to ECMC on a Form 4-Sundry Notice within 30 days of the failure.
All MLVT liner seams shall be welded and tested in accordance with applicable ASTM international standards. Any repairs to liners shall be made using acceptable practices and applicable standards.
The MLVT shall be constructed and operated in accordance with a design package certified and sealed by a Licensed Professional Engineer either in Colorado or the state where the MLVT was designed or manufactured.
The MLVT will be designed and implemented consistent with ECMC's MLVT policy.
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