| Traffic control | Form: (02A )
401471079
3/21/2018 | An access route from the highway or county road to the proposed oil and gas location has been prearranged. Required access road permits will be obtained before construction begins and any special requirements outlined by the municipality will be followed. Emergency routes will be chosen prior to the commencement of operations and will be clearly marked and maintained throughout drilling, completion and production activities. |
| General Housekeeping | Form: (02A )
401471079
3/21/2018 | Any material not in use that might constitute a fire hazard will be removed a minimum of twenty-five (25) feet from the wellhead, tanks and separator. Any electrical equipment installations inside the bermed area will comply with API RP 500 classifications and comply with the current national electrical code as adopted by the State of Colorado. |
| General Housekeeping | Form: (02A )
401471079
3/21/2018 | All surface trash, debris, scrap or discarded material connected with the operations of the property shall be removed from the premises or disposed of in a legal manner. |
| General Housekeeping | Form: (02A )
401471079
3/21/2018 | Crestone Peak Resources places road base, rock and recycled asphalt to assist with dust abatement. During construction, drilling, completions and reclamations phases, Crestone monitors each site and if needed we will run water trucks. |
| General Housekeeping | Form: (02A )
401471079
3/21/2018 | M – Per Rule 604.c(2)M Crestone will install fencing to restrict access to wellheads facilities and equipment. |
| Material Handling and Spill Prevention | Form: (02A )
401471079
3/21/2018 | All loadlines will be capped for every location in the DJ. |
| Material Handling and Spill Prevention | Form: (02A )
401471079
3/21/2018 | Well effluent containing more than ten (10) barrels per day of condensate or within two (2) hours after first encountering hydrocarbon gas of salable quality will be directed to a combination of sand traps, separators, surge vessels, and tanks as needed to ensure safe separation of sand, hydrocarbon liquids, water, and gas and to ensure salable products are efficiently recovered for sale or conserved and that non-salable products are disposed of in a safe and environmentally responsible manner.
First sign of salable gas to be turned to sales
Rules 912 venting or flaring of natural gas: have BMP on well pad 2A associated with temporary flowback flaring. |
| Material Handling and Spill Prevention | Form: (02A )
401471079
3/21/2018 | Leak Detection Program
• Annual hydrostatic test on the oil dump line from the separator to the tank battery.
• Annual hydrostatic “static” tests on our oil tanks.
• Annual hydrostatic “static” tests on our produced water tank and water dump line from the separator to the produced water tank.
• Lease Operator inspections of all equipment not to exceed 48 hours.
• Monthly documented inspections (EU).
• Annual environmental inspections of all battery and well equipment and pads.
• Annual UT inspections of the pressure vessels and input into Crestone’s RIPL Predictive Integrity Maintenance Program. (HLP separators and fuel gas separators) |
| Material Handling and Spill Prevention | Form: (02A )
401471079
3/21/2018 | G – Crestone utilizes 24” tall corrugated galvanized metal berm walls with a capacity in excess of 150% of the largest tank contained within the wall. In addition, Crestone best practices mandates the use of impervious liners that extends under each storage tank and up the walls, permanently affixed to the top of the metal berm wall. Protrusions of piping that come through the liner include a fully sealed “boot” to prevent leakage. |
| Material Handling and Spill Prevention | Form: (02A )
401471079
3/21/2018 |
1. Integrity testing of flowlines connecting wellheads to the separators:
CONSTRUCTION PHASE: The flowlines that Crestone uses are designed/constructed/tested to ASME B31.3/4/8 and API 1104 standards. Only materials with Material Test Reports (MTRs) provided by the pipeline supplier are used in the construction of the flowlines. Construction is tested with 100% x-ray and goes through hydrotest per the applicable B31-code.
OPERATIONS PHASE: Pressure testing of the flowlines is conducted on an annual basis. Additionally, Crestone is already in compliance with 1104.i. Continuous Pressure Monitoring Requirements of the 1100 Series Flowline Regulations. Crestone utilizes a series of standard operating procedures to define our flowline integrity testing program.
2. Frequency on valve and fitting inspections: Crestone Lease Operators inspect all equipment on their locations at a minimum of once every 48 hours, but most sites are inspected every 24 hours. Valves and fittings inspections are part of the daily job duties of our lease operators. Any valve or fitting that is found to be leaking is either repaired immediately by the lease operator or shut-in procedures are implemented as described below. Additionally, lease operators conduct a documented monthly inspection of the facility and this includes inspection of all valves and fittings.
3. Description of Lease Operator Inspections, Monthly Documented Inspections & Environmental Inspections: The Crestone lease operator inspections are done as a routine part of the lease operators job. The lease operator would typically visit each of their assigned locations daily. They conduct a visual inspection of the facility which includes all valves, fittings, wellhead, tanks, vapor control systems and all connections. The lease operator also checks our Cygnet automation system for system pressures and flows. Pressure and flow sensors are placed on multiple points throughout the system and are specifically designed to measure the system for irregularities that would indicate a leak in the system or change in production of oil, water, or gas. The Cygnet system is also set-up with alarms that are triggered by anomalous pressure or flows. Low pressure warnings can activate automatic shut-in of the well and system. The monthly documented inspection is done using an electronic form that is recorded in the EU system. This thorough inspection and documentation requires the lease operator to inspect all aspects of the site and then triggers work orders for any leaks, or housekeeping issues. This inspection would note any leaks of either gas or fluids which triggers an immediate repair or shut-in. The Lease operators also conduct a weekly CDPHE Regulation 7 – Audible, Visual, and Olfactory (AVO)inspection, which focus on the tanks and vapor control system. The Regulation 7 AVO is also a documented inspection. In addition, the sites are inspected with optical gas imaging cameras on a routine schedule, annually for compliance purposes with our Spill Prevention Containment and Countermeasures (SPCC) plan, depending on the status of reclamation the sites are also inspected on either a 14-day, 30-day, annual or rain triggered event in accordance with both the COGCC and the CDPHE Stormwater Management Plans (SWMP).
4. Measures for when leaks are discovered:
If we suspect a leak we shut in the well and hydrotest the line. If it passes, then the well is brought back onto production.
If there is an actual leak, well is kept shut in while leak is found and fixed. Not until the line has passed hydrotesting, would the well be brought back online. |
| Construction | Form: (02A )
401471079
3/21/2018 | Crestone will comply with COGCC Rule 1002.f.(2). by utilizing BMPs at the oil and gas location to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, site degradation and protects surface waters.
Examples of engineering controls that could be used when needed are:
o Surface roughening
o Silt fence
o Erosion control blanket
o Temporary slope drain
o Temporary outlet protection
o Sediment control log
o Vehicle tracking control
o Sediment trap
o Stabilized staging area |
| Noise mitigation | Form: (02A )
401471079
3/21/2018 | Crestone will complete a noise survey for the facility pad location. Crestone uses lower profile and removable sound walls, inside the facility, to mitigate any noise from the compression area. |
| Emissions mitigation | Form: (02A )
401471079
3/21/2018 | Flow lines, separators, and sand traps capable of supporting green completions as described in Rule 805 will be installed on subject location at which commercial quantities of gas are reasonably expected to be produced based on existing adjacent wells within 1 mile.
First sign of salable gas to be turned to sales
all storage tanks (condensate and produced water) will be controlled by enclosed combustors that achieve at least 95% destruction |
| Emissions mitigation | Form: (02A )
401471079
3/21/2018 | Crestone will follow and comply with all leak detection and repair and storage tank emission management plan conditions as
required by Colorado Air Quality Control Commission Regulation Number 7. This will include at least monthly Audible,
Visual and Olfactory (AVO) inspections of the components and tanks at our Production Facilities at most weekly or at least
monthly starting on January 1, 2017. In addition, Crestone will perform infra-red camera inspections of these components and the storage tanks at most monthly or at least annually. |
| Odor mitigation | Form: (02A )
401471079
3/21/2018 | Crestone operations will be in compliance with the Department of Public Health and Environment, Air Quality Control Commission, Regulation No. 2 Odor Emission, 5 C.C.R. 1001-4, Regulation No. 3 (5 C.C.R. 1001-5), and Regulation No. 7 Section XVII.B.1 (a-c) and Section XII. Where possible, drilling rig and completion equipment engine exhaust will be directed away from occupied buildings to assist in mitigating potential odors. As necessary, Crestone may utilize chemical additives during drilling operations to mitigate odor impacts. Sealed tanks with pressure relief valves and emissions controls will be utilized for the production facilities. |
| Drilling/Completion Operations | Form: (02A )
401471079
3/21/2018 | All newly installed or replaced crude oil and condensate storage tanks will be designed, constructed, and maintained in accordance with National Fire Protection Association (NFPA) Code 30 (2008 version). Crestone will maintain written records verifying proper design, construction, and maintenance, and will make these records available for inspection by the Director. In addition, onsite inspections are conducted internally to insure guidelines are met. |
| Drilling/Completion Operations | Form: (02A )
401471079
3/21/2018 | Closed-top tanks will utilize backpressure systems that exert a minimum of four (4) ounces of backpressure and a maximum that does not exceed the pressure rating of the tank to facilitate gathering and combustion of tank. |
| Final Reclamation | Form: (02A )
401471079
3/21/2018 | T – Crestone will clear the well site of all non-essential equipment, trash and debris after ninety days of a well P&A. |
| Storm Water/Erosion Control | Form: (04 )
402000444
8/4/2020 | 1. Fill slopes were surface roughened
2. A drainage swale was constructed along the down-slope edge / east edge
3. Temporary sediment traps are being installed at the terminal points of discharge from the disturbance allowance; and
4. Temporary / permanent seeding will also be used to achieve the larger interim reclamation objectives at the location |
| Storm Water/Erosion Control | Form: (04 )
402000444
8/4/2020 | Maintain perimeter diversion swales, and temporary sediment control measures at the terminal points of discharge, and surrounding working surfaces of the well pad / production facility, and temporary stockpile areas. |
| Storm Water/Erosion Control | Form: (04 )
402000444
8/4/2020 | Stockpiles which are idle, or anticipated to be idle, for 14 or more calendar days will be surface roughened and temporarily stabilized. |
| Storm Water/Erosion Control | Form: (04 )
402000444
8/4/2020 | BMPs / stormwater control measures will continue to be inspected and maintained per 1002.f rules and requirements, as well as the Colorado Department of Public Health & Environment construction general permit. |
| Storm Water/Erosion Control | Form: (04 )
402000444
8/4/2020 | If BMPs require maintenance, or on / off-site erosion is identified, repairs will be completed with a BMP maintenance team. |