| PROPOSED BMPs | Form: (07 )
0
1/23/2012 | Proposed BMPs for `Watson Ranch' Pad Oil & Gas Location Assessment
1. Wildlife Production Best Management Practices - Drilling and Production
• Antero, will in good faith, conduct its construction, drilling and well completion
activities between April 16 and November 30` However, if lease terms or APD
permitting schedules require one or more of these activities to occur between
December 1 and April 15 Antero will notify and offer to consult with CDOW
for guidance on COAs and BMPs prior to undertaking such activities.
• Remote monitoring using SCADA systems to reduce well pad visits
• Water pipeline infrastructure will be installed concurrently with the gas pipeline
infrastructure where possible.
• Pipeline systems to be located next to existing and planned roadways where
possible
• Closed -loop pit less drilling technology to be utilized to eliminate open reserve
pits and frac flowback pits
• Existing vegetation to be protected where possible using state -of -the -art
technology
• Exclusionary devices to be used on heater treater stacks
• Above -ground facilities will be located to minimize visual effects (e.g. production
tanks will be low profile tanks)
• Trench plugs, earthen ramps or other means as necessary will be employed to
ensure that open pipeline trenches do not trap wildlife and that pipe strings do not
impair wildlife movement
• Combustor controls to be used to mitigate odors from production tanks
• Well pad will be graveled to reduce fugitive dust and sediment run -off
• Well pad size will be minimized (250ft x 350ft)
• Directional drilling will be implemented to minimize habitat loss and habitat
fragmentation
• The Mitigation Assessment including the mitigation opportunities /projects
associated with this well pad to be defined and detailed in the upcoming
Battlement Mesa CDP
2. Invasive Non - Native Vegetation Control
• Weed management plan will be developed and implemented to monitor and
control noxious and invasive weeds
• Existing weed infestations will be mapped prior to the development of each pad,
access road and pipeline
• Reclamation/revegetation will be used as a weed management tool
3. Seed Mixes
• Seed mixes will be certified weed -free
• Sites will be reclaimed with wildlife friendly seed -mixes in consultation with
CDOW
4. Planning Infrastructure and Development Activities ?
• Well pad perimeter will be bermed and sloped toward frac tank and -p tL71
tank area to provide additional spill containment
• High level alarms will be installed on all production tanks
• SPCC inspections will be conducted quarterly
• Water used for well completions will be recycled as technologically practicable
• Production tank containment area will be lined with plastic
• Water well testing to be performed for permitted water wells within 1/2 mile of
down -hole location
• Annual planning meeting to be conducted with Battlement Mesa Community
• Well completions will utilize use green completion technologies to reduce odors
• The Frac /Flowback tank area will be lined to mitigate seepage losses from the
unintended spillage of well completion fluids.
5. Stormwater Management
• Facility will be operated with a Water Quality Control Division (WQCD)
stormwater construction permit.
• Stormwater BMPs in accordance with the COGCC Post Construction Stormwater
Program will be implemented in a manner that minimizes erosion, transport of
sediment offsite, and site degradation.
• Inspections will be conducted in accordance with WQCD General Permit to
confirm that applicable BMPs are in place, maintained and operating properly.
|
| Storm Water/Erosion Control | Form: (02A )
400256441
4/11/2012 | Stormwater Management
• Facility will be operated with a Water Quality Control Division (WQCD) stormwater construction permit.
• Stormwater BMPs in accordance with the COGCC Post Construction Stormwater Program will be implemented in a manner that minimizes erosion, transport of sediment offsite, and site degradation.
• Inspections will be conducted in accordance with WQCD General Permit to confirm that applicable BMPs are in place, maintained and operating properly. |
| General Housekeeping | Form: (02A )
400256441
4/11/2012 | Invasive Non-Native Vegetation Control
• Weed management plan will be developed and implemented to monitor and control noxious and invasive weeds
• Existing weed infestations will be mapped prior to the development of each pad, access road and pipeline
• Reclamation/revegetation will be used as a weed management tool |
| Interim Reclamation | Form: (02A )
400256441
4/11/2012 | Seed Mixes
• Seed mixes will be certified weed-free
• Sites will be reclaimed with wildlife friendly seed-mixes in consultation with CDOW |
| Drilling/Completion Operations | Form: (02A )
400256441
4/11/2012 | RESIDENTIAL COAs:
Operator will implement sufficient public notification of proposed oil and gas activities, including: (1) provide 30 day advance notice and community awareness to neighborhood that the monthly Battlement Mesa Oil and Gas
Committee meetings will be the forum for communications regarding schedule and activities; (2) schedule changes will
be communicated to the community at aforementioned meetings via attendance or emails to the Committee (3) notify
local emergency response agencies (Fire/Police) of schedule changes; and (4) notify all homes within a ¼-mile radius
and local emergency responders (Fire/Police) 7 days prior to mobilization in, rig up (MIRU).
Notify the local emergency responders (Fire/Police) and the COGCC (using the new Form 42) 48 hours prior to location construction and 48 hours prior to hydraulic fracturing treatment. Notify the local emergency responders (Fire/Police) and COGCC Oil and Gas Location Assessment (OGLA) Specialist for Western Colorado (Dave Kubeczko; email dave.kubeczko@state.co.us), and the COGCC Field Inspection Supervisor for Northwest Colorado (Shaun Kellerby; email shaun.kellerby@state.co.us) 24 hours prior to MIRU.
Operator will review local governmental requirements for access from public roads. At a minimum the following
traffic requirements will apply: (1) operator will work with the Garfield County Road and Bridge Department to develop
and implement a traffic control plan that, at a minimum: a) establishes designated haul routes, b) designates haul routes to avoid school zones and schedules heavy equipment movement to avoid school bus operation hours, c) provides for additional signage on major and/or local roads to be employed during heavy activity periods warning of increased truck traffic, d) restricts all oil and gas related construction, drilling, and operational traffic to access the location from a single point, e) provides for flaggers and/or pilot vehicles as necessary, and f) schedules work to avoid peak traffic flow. In addition, the operator will require safe driving training for employees and contractors.
Operator will prepare a job specific Emergency Management/Response Plan that will be developed with input
from the local emergency responders (Fire/Police). Operator will provide temporary engineering controls to prevent
uncontrolled public access during drilling and completion activities. Site security shall include, but not be limited to,
appointing a Health and Safety Officer that will insure the Emergency Management/Response Plan is adhered to and
who is authorized to shut down operations at any time when health and safety risk is present.
Operator will take aggressive action to establish vegetation on cut and fill slopes to prevent storm water
erosion and the generation of fugitive dust. Operator shall install and maintain native vegetative visual buffering on the
west and east sides in conjunction with site stabilization. Visual mitigation shall also include the use of low profile tanks.
Lighting abatement measures beyond the requirements of Rule 803. shall be implemented, including the
following, at a minimum: (1) rig oriented to direct light away from nearby residents; (2) install lighting shield devices on all of the more conspicuous lights; (3) low density sodium lighting; and (4) rig shrouded on the west and east sides.
For purposes of reducing impacts to nearby residents, flares (such as TCI's partable flare with high combustion
rate, low noise, and low visibility flare) will be utilized.
Emissions from condensate, crude oil, and produced water tanks and from glycol dehydrators shall be
controlled as described in Rule 805.b.(2), not-withstanding the exceptions for production facilities emitting less than five
tons per year (TPY) of volatile organic compounds (VOC).
Access roads to well sites, completion staging sites and production facilities shall be constructed to meet the
requirements of emergency responders, including all weather surface.
Land-farming of E&P waste is prohibited on the location. This shall not preclude onsite disposal of E&P waste
in accordance with COGCC Rules and permit conditions. |
| Storm Water/Erosion Control | Form: (02A )
400256441
4/11/2012 | SENSITIVE AREA (SURFACE WATER AND GROUNDWATER PROTECTION) COAs:
Operator must ensure 110 percent secondary containment for any volume of fluids (excluding freshwater) contained at well site during drilling and completion operations; including, but not limited to, construction of a berm or diversion dike, diversion/collection trenches within and/or outside of berms/dikes, site grading, or other comparable measures (i.e., best management practices (BMPs) associated with stormwater management) sufficiently protective of nearby surface water. Any berm constructed at the well pad location will be stabilized, inspected at regular intervals (at least every 14 days), and maintained in good condition.
Location is in a sensitive area because of proximity to a domestic water well and potential for shallow groundwater; therefore either the reserve pit (if constructed) must be lined or a closed loop system (which has already been indicated by Antero on the Form 2A) must be implemented during drilling; Antero will be using a closed loop drilling system, therefore, a reserve pit will not be constructed.
Flowback and stimulation fluids must be sent to tanks, separators, or other containment/filtering equipment before the fluids can be placed into any pipeline or pit located on the well pad or into tanker trucks for offsite disposal. The flowback and stimulation fluid tanks, separators, or other containment/filtering equipment must be placed on the well pad in an area with additional downgradient perimeter berming. The area where flowback fluids will be stored/reused must be constructed to be sufficiently impervious to contain any spilled or released material. |
| Pre-Construction | Form: (02A )
400256441
4/11/2012 | WATER RESOURCES (WATER QUALITY TESTING PROGRAM) COA:
Water Testing: Prior to drilling operator shall sample the two (2) closest domestic water wells, springs, or surface water features within a one (1) mile radius of the proposed oil and gas location. Testing preference shall be given to domestic
water wells and springs over surface water. Testing of surface water features shall only be conducted if two (2) water
wells or springs do not exist within a one (1) mile radius of the selected oil and gas location. If possible, the water wells or springs selected should be on opposite sides of the oil and gas location not exceeding a one (1) mile radius. If water
wells or springs on opposite sides of the oil and gas location cannot be identified, then the two (2) closest wells or springs within a one (1) mile radius of the oil and gas location shall be sampled. The sample location shall be surveyed in
accordance with Rule 215.
Initial baseline testing shall include laboratory analysis of all major cations and anions, total dissolved solids, iron and
manganese, nutrients (nitrates, nitrites, selenium), dissolved methane, pH, specific conductance, and benzene, toluene,
ethylbenzene, and xylenes (“BTEX”). Sampling shall be performed by qualified individuals using methods consistent with
commonly accepted environmental sampling procedures. Field observations such as pH, temperature, specific
conductance, odor, water color, sediment, bubbles, and effervescence shall also be included.
After 90 days, but less than 180 days of completion of the first proposed well a “post-completion” test shall be performed for the same analytical parameters listed above and repeated one (1), three (3) and six (6) years thereafter. If no significant changes from the baseline have been identified after the third test (i.e. the six-year test), no further testing shall be required. Additional “post-completion” test(s) may be required if changes in water quality are identified during follow-up testing. The Director may require further water well sampling at any time in response to complaints from water well owners.
If free gas or a methane concentration level greater than 1 mg/l is detected in a water quality testing well, gas
compositional analysis, and stable isotopes of both the carbon and hydrogen isotopes of methane shall be performed to
determine gas type (thermogenic, biogenic or a mixture).
Copies of all analytical data described above shall be provided to the Director and the landowner where the water quality
testing well is located within three (3) months of collecting the samples used for the test. The analytical data and
surveyed well locations shall also be submitted to the Director in an electronic data deliverable format. Operator will
furnish to the Director any analytical results from groundwater or surface water monitoring activities conducted
associated with this location in a timely manner. |
| Wildlife | Form: (02A )
400256441
4/11/2012 | Wildlife Production Best Management Practices - Drilling and Production
• Antero, will in good faith, conduct its construction, drilling and well completion activities between April 16th and November 30th. However, if lease terms or APD permitting schedules require one or more of these activities to occur between December 1st and April 15th, Antero will notify and offer to consult with CDOW for guidance on COAs and BMPs prior to undertaking such activities.
• Remote monitoring using SCADA systems to reduce well pad visits
• Water pipeline infrastructure will be installed concurrently with the gas pipeline infrastructure where possible.
• Pipeline systems to be located next to existing and planned roadways where possible
• Closed-loop pit less drilling technology to be utilized to eliminate open reserve pits and frac flowback pits
• Existing vegetation to be protected where possible using state-of-the-art technology
• Exclusionary devices to be used on heater treater stacks
• Above-ground facilities will be located to minimize visual effects (e.g. production tanks will be low profile tanks)
• Trench plugs, earthen ramps or other means as necessary will be employed to ensure that open pipeline trenches do not trap wildlife and that pipe strings do not impair wildlife movement
• Combustor controls to be used to mitigate odors from production tanks
• Well pad will be graveled to reduce fugitive dust and sediment run-off
• Well pad size will be minimized (250ft x 350ft)
• Directional drilling will be implemented to minimize habitat loss and habitat fragmentation
• The Mitigation Assessment including the mitigation opportunities/projects associated with this well pad to be defined and detailed in the upcoming Battlement Mesa CDP |
| Pre-Construction | Form: (02A )
400256441
4/11/2012 | Planning Infrastructure and Development Activities
• Well pad perimeter will be bermed and sloped toward frac tank and production tank area to provide additional spill containment
• High level alarms will be installed on all production tanks
• SPCC inspections will be conducted quarterly
• Water used for well completions will be recycled as technologically practicable
• Production tank containment area will be lined with plastic
• Water well testing to be performed for permitted water wells within ½ mile of down-hole location
• Annual planning meeting to be conducted with Battlement Mesa Community
• Well completions will utilize use green completion technologies to reduce odors
• The Frac/Flowback tank area will be lined to mitigate seepage losses from the unintended spillage of well completion fluids. |