| Storm Water/Erosion Control | Form: (02A )
400091785
10/19/2010 | SEE ATTACHED. |
| General Housekeeping | Form: (02A )
403232554
4/5/2024 | Light BMPs
Construction Phase:
· During construction of all phases, Owners will only conduct day light operation and there will be no nighttime operations that require lighting.
· Exterior lighting shall be directed away from residential and other sensitive areas or shielded from said areas to eliminate glare. Light spillage beyond the perimeter of the well site shall be minimized.
· Bulbs shall be fully shielded to prevent light emissions above a horizontal plane drawn from the bottom of each fixture.
Drilling Phase:
· Owners will utilize LED fixtures to reduce skyglow.
· Owners 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, Owners will address the complaint and work with all parties involved to ensure the complaint is resolved.
Completions and Flowback Phases:
· Owners will utilize LED fixtures to reduce skyglow.
· Owners 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, Owners will address the complaint and work with all parties involved to ensure the complaint is resolved.
Production Phase:
· Owners will utilize LED fixtures to reduce skyglow.
· Owners 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, Owners will address the complaint and work with all parties
involved to ensure the complaint is resolved.
1) Lighting Cut Sheet Notes for Attachment B
1. Type A Fixtures (Pre-Production Phase)
o Type A fixtures are portable construction light towers with vertical masts. These
units vary significantly depending on supplier, rental agency, inventory, and
current market available fixtures. Allmand Night-Lite Pro II V-Series towers were
selected for this analysis based on previous experience; however specific site
units may vary based on time of construction. Each light tower consists of four
fixtures. All calculations were performed with all four fixtures active. The typical
center of fixtures is raised approximately 26 feet from grade and pointed
downward toward the work area. The fixture mounting for portable light towers
are articulated mountings which allow for both vertical and horizontal plane
adjustments. For this analysis, the light tower fixtures were modeled at the
indicated angles.
2. Type B Fixtures (Pre-Production Phase) are representative of current fixtures used during
drilling operations.
3. Type C Fixtures (Pre-Production Phase) are representative of current fixtures used during
drilling operations. |
| General Housekeeping | Form: (02A )
403232554
4/5/2024 | Waste BMPs
Recycling produced water for Caerus’s completions operations.
Reduction of waste by use of closed loop drilling systems to reduce the volume of drill cuttings.
Waste will be segregated and stored according to its waste classification.
A designated storage area will be established for waste storage. |
| Wildlife | Form: (02A )
403232554
4/5/2024 | Directional drilling is planned to minimize habitat loss and fragmentation. Caerus will implement the BMPs detailed and discussed further in the attached Wildlife Mitigation Plan starting on page 8, which will provide multiple natural resource benefits and promote adaptive management of the landscape. The majority of the BMPs Caerus will commit to are voluntary, however please note that the Wildlife Mitigation Plan derived from pre-OGDP/OGLA application consultation meetings with CPW. Also noted in the CPW-approved WMP are the following modifications to 1202.a.(10). BMPs: Caerus will employ the following minimum Best Management Practices on new Oil and Gas Locations with a Working Pad Surface located between 500 feet and 1000 feet hydraulically upgradient from a High Priority Habitat.
- Contain Flowback and Stimulation Fluids in Tanks that are placed on a Working Pad Surface in an area with downgradient perimeter berming;
- Construct lined berms or other lined containment devices pursuant to Rule 603.o around any new crude oil, condensate, and produced water storage Tanks that are installed after January 15, 2021.
- Inspect the Oil and Location on a daily basis, unless the approved Form 2A provides for different inspection frequency or alternative method of compliance.**
** Caerus requested and CPW granted approval of less than daily site visits based on the following BMP: Critical production equipment will have SCADA instrumentation, set by engineered design, that will notify Caerus of any and all abnormal conditions. Personnel will respond and address the situation immediately. With this remote site monitoring, a physical site inspection frequency of less than once per day will avoid unnecessary disturbances to terrestrial wildlife species in the area.
- Maintain adequate Spill response equipment at the Oil and Gas Location during drilling and completion operations; and
- Caerus will not construct any *new* pits on the existing ELU 396-6A1 location. |
| Storm Water/Erosion Control | Form: (02A )
403232554
4/5/2024 | Caerus' Stormwater Management Plan is attached and addresses site specific Best Management Practices (BMPs) Caerus is committed to during the pre-production and production phases of the well pad's life. BMPs will be implemented during, on, and around the new disturbances associated with the well pad and soil stockpiles. With the proposed location being on top of a ridge line, there is little to no Run-On for this disturbance. BMP sizing was based on the regional 25-year 24-hour storm event. BMP topics include spill prevention and response, material delivery and storage, waste management and disposal, vehicle use and tracking controls, BMPs for potential pollution sources, inspection and maintenance schedules, and well pad control measures. For more detailed information please review the Stormwater Management Plan attached. |
| Storm Water/Erosion Control | Form: (02A )
403232554
4/5/2024 | Topsoil BMPs
Topsoil will be salvaged from the construction area to a depth of six inches (6”).
Topsoil will be stockpiled with slopes no greater than 3:1 when soil volume and stockpile space allows.
Stockpile locations will be marked and clearly identified on site maps and construction drawings available on-site until the soils are redistributed during interim reclamation.
Salvaged topsoil will be seeded and stabilized with mulch while stockpiled.
Caerus employees and contractors will monitor topsoil stockpiles for erosion and establishment of undesirable and noxious weeds.
Weeds will be treated mechanically when feasible. Chemical treatment of weeds will use broad-leaf herbicides only. Soil sterilant and non-selective herbicides will not be used.
Erosion will be repaired as soon as practicable and additional control measures will be
installed as necessary to prevent reoccurrence.
During reclamation, topsoil will be redistributed throughout the interim reclamation area and contoured to match pre-disturbance topography.
The interim reclamation area will be seeded with a mix approved by the surface owner and temporarily stabilized with crimped straw mulch.
Topsoil will be monitored throughout all phases of development to identify potential degradation and make repairs as soon as practicable. |
| Storm Water/Erosion Control | Form: (02A )
403232554
4/5/2024 | Stormwater BMPs
Strive to minimize the area of disturbance.
Implement Control Measures (CMs) to minimize the discharge of pollutants from identified potential pollutant sources at the site.
Implement CMs for Temporary and/or Final Stabilization on our disturbances. Caerus is committed to installing Perimeter Controls until Temporary or Final Stabilization CMs can be implemented.
Minimize erosion and transport of sediment during discharge.
Stormwater runoff from all disturbed areas and soil storage areas must utilize or flow to one or more control measures to minimize erosion or sediment in the discharge.
Structural and nonstructural vehicle tracking controls shall be implemented to minimize vehicle tracking of sediment from disturbed areas and may include tracking pads, minimizing site access, and downgradient sediment control measures. |
| Material Handling and Spill Prevention | Form: (02A )
403232554
4/5/2024 | Please refer to the Fluid Leak Detection Plan attached, which covers BMPs and operational practices for the well pad during all phases of pre- and post-production. Please also review the Waste Management Plan for material handling. To minimize
any leaks during drilling, a closed loop system will be utilized, and personnel are onsite during drilling and completions 24/7 to inspect and monitor all equipment. During the completions phase, equipment is monitored and tracked onsite utilizing Electric Diagnose Controls which have built-in shutdown parameters to catch and prevent failures. Once the wells are turned on, they enter a flowback stage of which personnel is on location 24/7 to monitor and inspect equipment and operations. Wells are eventually connected to a Supervisory Control and Data Acquisition (SCADA) automated monitoring technology that allows real-time monitoring remotely. From there, well pads, with multiple wells are visited no less frequently than weekly and are inspected for any leaks. |
| Material Handling and Spill Prevention | Form: (02A )
403232554
4/5/2024 | Fluid Leak Detection BMPs
Drilling fluid tanks have pit volume sensors and are monitored through the electric drilling recorder.
Equipment, tanks, and lines are regularly checked and monitored as personnel are on-site walking equipment 24/7.
BOPE is pressure tested every 30 days or when a seal is broken.
Pressure relief valves are designed with discharge into tanks.
Adequate spill response equipment will be on site during the drilling and completions operations on the 6A1 location.
Equipment is monitored and tracked on-site with Electric Diagnose Controls. These controls have built-in shutdown parameters to catch & prevent failures. Including Vibration Control Monitoring sensors on Frac Pumps / Iron.
All equipment/tanks are occupied & operated and monitored by personnel to prevent and respond and shutdown due to any failures/leaks/abnormalities not caught by above mention controls
Checking of all temperatures / fluid levels / Packing and normal equipment wear & tear)
Pumps and equipment are placed inside of spill containments and catch pans / berms are in place, where appropriate
Pressure testing of all equipment / iron is conducted before each stage, at pressures above anticipated operating pressure
Use of safety systems to prevent over-pressuring of iron.
Safety iron restraints are installed on all high-pressure iron.
Temporary fluid and flowback tanks will be in an area with downgradient perimeter berming and will be underlain by an impervious synthetic or engineered liner. |
| Dust control | Form: (02A )
403232554
4/5/2024 | Dust BMPs
Pad and Access Road Construction – Fresh water will be periodically applied to disturbance areas during construction to minimize fugitive dust.
Construction During High Wind – The construction crew will monitor wind conditions during the site construction. When necessary, freshwater will be applied to dry soils during high wind events.
Caerus will evaluate site conditions and may temporarily suspend ground disturbance activities to minimize fugitive dust.
Road Surfacing – The proposed access road will have six inches of road surfacing materials applied once constructed.
Speed Restrictions – Caerus has implemented speed restrictions on all lease roads and requires all employees and contractors to adhere to all posted speed restrictions. The access road speed limit will be 20-miles per hour.
Road Maintenance – During long-term production operations, Caerus will conduct annual inspections of the existing and proposed access roads and will perform maintenance as necessary to ensure road integrity and minimize fugitive dust. Road maintenance actions may include, but are not limited to spot graveling, storm water control maintenance and periodic watering of the road(s). Caerus prefers to utilize non-chemical-based dust suppressants wherever possible, but in instances where it becomes necessary due to high wind then Caerus may utilize magnesium chloride.
Site Visitation – Caerus will utilize telemetry equipment to minimize will site visitation, when possible, to reduce fugitive dust from vehicles traveling on the graveled roads.
Wildlife – Caerus will maintain any raptor surveys in line with BLM and Colorado Parks and Wildlife requirements prior to disturbing activities or resurveying of this site concludes there are no active raptor nests in the project area. |
| Construction | Form: (02A )
403232554
4/5/2024 | The pad will be constructed as designed and shown on the Construction Layout and Cross Sections. During Construction, only the minimum amount of vegetation necessary for the construction will be removed. Topsoil will be set aside and preserved during excavation. Topsoil will be re-used as cover on disturbed areas and perimeter berms. No construction or routine maintenance activities are performed during periods when the soil is too wet to adequately support construction equipment. Any stockpile(s) for topsoil and excess cut material will be located in work areas surrounded by the BMPs as shown on the Construction Layout. Stormwater BMPs will be installed as described in the Stormwater Management Plan (SWMP) and as shown on the Construction Layout. Disturbed areas of the site will be left in a surface roughened condition. BMPs will be protected, inspected, and repaired as necessary. Berms or other containment devices shall be constructed to be sufficiently impervious (corrugated steel with synthetic liner) to adequately contain any spilled or released material around crude oil, condensate, and produced water storage tanks, while also ensuring the adequate prevention of significant adverse environmental impacts. |
| Noise mitigation | Form: (02A )
403232554
4/5/2024 | Pursuant to Rule 423.b.(4). for locations in HPH, during pre-application consultations, Caerus and CPW agreed to the Noise BMP of Caerus conducting Stages 1 and 2 of completions operations per well, which are generally considered the loudest stages, during daylight hours to minimize associated sound during the night. |
| Emissions mitigation | Form: (02A )
403232554
4/5/2024 | Caerus will implement enhanced green completions best management practices and route well production to a centralized facility for processing, storage, and sales. Loadout of condensate from storage tanks will use a LACT system, which helps minimize tank gauging activities. The storage tank and truck loadout vapor collection system design will be engineer-approved and controlled with an appropriately-sized enclosed combustor. Real-time on-site air monitoring will trigger alerts for potential emission events to promote data-driven leak-detection and repair efforts. Beyond this, Caerus will comply with all applicable air regulations implemented by the Air Quality Control Commission and Environmental Protection Agency. |
| Drilling/Completion Operations | Form: (02A )
403232554
4/5/2024 | DRILLING: Closed loop system will be utilized. Solids control equipment consisting of shale shakers, centrifuges, and flocculating units may be utilized to separate drill cutting solids from liquid (drilling mud and water). Drill cuttings will be stored in steel bins placed in the compacted Cuttings Management Area on the southeast side of the well pad. Cuttings samples will be collected when drilling is initiated for waste characterization. If cuttings are deemed suitable for onsite disposal, samples will be collected every 1000 cubic yards and will be submitted for laboratory analysis of COGCC Table 915-1 constituents. Based on the analytical results, drill cuttings will be managed and disposed of pursuant to COGCC Rule 905.e. Pursuant to Rule 304.c.(11) cuttings management details can be found in the Waste Management Plan attached. |
| Drilling/Completion Operations | Form: (02A )
403232554
4/5/2024 | FLOWBACK & STIMULATION/CONTAINMENT: Due to limited space available to safely situate equipment on the existing location, Caerus will conduct continuous (not simultaneous) drilling, completions, and flowback operations. During completions operations, 15-20 500 bbl temporary tanks will be situated on location. A temporary, surface, up-to-12" water transfer line will be laid over the existing pipeline right-of-way, which will deliver recycled water to location for completions. The temporary tanks will be placed laid upon an impervious synthetic or engineered liner which would be underlaid by road base. The liner will be sufficient to hold up to 150% of the largest tank on the location. Note, the entire Oil and Gas Location will include a compacted earthen berm perimeter around the operational area. |
| Interim Reclamation | Form: (02A )
403232554
4/5/2024 | Caerus' Stormwater management is addressed through the Stormwater Management Plan (CDPHE Certification #COR400646 North Piceance). Run-on protection and runoff controls will be installed prior to the beginning of construction activities, with consideration given to worker safety, wildlife, and site access. Run-off and sediment control will be addressed when the soil is mostly dry and when seasonal and weather conditions are most favorable. Typically, road and location blading will occur after the winter and spring seasons. For more detailed information please review the Interim
Reclamation Plan attached. |
| Interim Reclamation | Form: (02A )
403232554
4/5/2024 | Interim Reclamation BMPs
Site Evaluation and Description The current and future land use is Rangeland. The surface water flow direction on the well pad disturbance is primarily to the east. The northwest corner of the disturbance will flow northwest. Preexisting drainages are present within the northeast and northwest disturbance boundaries. The pad and southern reach of the pipeline are located in Ecological Site F048AY448CO — Mountain Pinyon. The project area is primarily composed of pinyon/juniper woodlands with an open and sparsely vegetated understory. Erosion Control Measure Deployment Erosion control logs (wattle) will be maintained around the disturbance perimeter throughout the reclamation earthwork phase, at a minimum. The BLM-approved seed mix will be drill seeded throughout the interim reclamation area. Certified weed free grass or wheat origin straw mulch will be uniformly applied at rate of 4,000 lbs./ per acre to cover 100% of the seed bed. Mulch will be properly anchored to the soil surface using a commercial straw crimper with a final orientation along contour. A natural fiber mulch (hydraulically applied) may also be utilized on slopes steeper than 3:1, areas of concentrated stormwater flow, or as tackifier over the straw to prevent loss due to high wind. Soil Management and Placement Topsoil horizon depth was identified based on changes in physical characteristics, as detailed in the associated Topsoil Protection Plan. Salvaged topsoil will be stockpiled, seeded, and the location documented. Topsoil will not be comingled with subsoil materials during recontouring and subsoil preparation operations. Recontouring Subsoils will be recontoured to return topographic conditions of the interim reclamation area to their original relative positions, as detailed in the associated grading plans and surveyor plats. Weed Management Certified weed free grass or wheat origin straw will be utilized for mulching operations. Noxious and invasive weeds within the disturbance boundaries will be identified, inventoried, and treated by licensed contracted herbicide applicators or mechanically removed through mowing, line-trimming, or hand tools. Fence Installation A wildlife friendly cattle exclusion fence will be maintained to mitigate livestock access to the interim reclamation area. |
| Final Reclamation | Form: (02A )
403232554
4/5/2024 | The disturbed areas surrounding the well location, including the access road will be recontoured to blend as nearly possible with the natural topography. Final grading of backfilled and cut slopes will be done to prevent erosion and encourage establishment of vegetation. Previously existing drainages will be re-established. The long-term objective is to establish a self-perpetuating plant community that is compatible with and capable of supporting the identified land use. Noxious weeds will be treated in accordance with applicable COGCC rules and county weed management requirements. For more detailed information please review the Final Reclamation Plan attached. |