| Planning | Form: (02A )
403249702
10/5/2023 | Operator will not use fracturing fluids which contain PFAS compounds.
Operator will coordinate with the fire district to determine what if any assistance is need to transition away from PFAS-containing foam. |
| Wildlife | Form: (02A )
403249702
10/5/2023 | • Ensure all personnel and contractors are aware of and adhere to applicable wildlife protection measures and BMPs;
• Personnel and contractors will not harm any wildlife observed on site and will maintain recommended buffer distances related to wildlife;
• Personnel and contractors will report any wildlife concerns, including the discovery of injured or orphaned wildlife, to on-site management and applicable EHSR personnel;
• Consult CPW and/or other applicable agencies/personnel, upon the discovery of new wildlife constraints, as needed;
• Use qualified third-party contractors for wildlife surveys, monitoring, and other consultation purposes; and
• Document any wildlife-related issues or changes.
Operator will conduct additional avian surveys prior to the commencement of construction to ensure no conflicts have developed since the prior survey(s).
Operator will work with Colorado Parks and Wildlife to determine an acceptable placement of above ground lay flat water pipeline within Barr Lake State Park. |
| Storm Water/Erosion Control | Form: (02A )
403249702
10/5/2023 | Berms will be placed along the downslopes of the sediment basin, and along the top of pad fill sections northeast and east pad edges. Berms and ditches will divert surface water to the on-pad sediment/detention basin. Berms will be 24”H with 4:1 slope. During the production phase there will be a concrete forebay with 9’ x 9’ square area with 1.5’H x 6”D vertical concrete berm and 8” drain pipe at the entrance of the private extended detention basin.
This site will consist of one (1) pad ditch. The Pad ditch-1 will be constructed on the north side, diverting water north, east, and south around the pad edge into the sediment basin. During the production phase the pad ditch-1 will moved inward, surrounding the extent of the interim reclamation pad area. The pad ditch will consist of 24” depth minimum and 4:1 slope and a minimum slope of 0.25%.
During the production phase, this site will have an outlet culvert constructed on the southeast side of the site. Dimensions 18’ x 68’ RCP with FES, a minimum slope of 0.5% and a 12” minimum cover.
This site will have a sediment basin constructed along the southeast side of the pad with a bottom width of 50’ x 100’, bottom elevation 5750, 8’ riser pipe with hole diameter 1/2”, spillway length 10’W. Sediment basin will be reclaimed and replaced with a private detention basin, during the production phase of the site.
This site will have a private extended detention pond constructed during the production phase with a trickle channel outlet structure. The detention pond will be constructed on the southeast side of the pad with bottom dimensions 34’ x 84’, depth of 6.0’, emergency spillway 25’. The trickle channel dimensions 2’W x 6”D and will have a 0.4% slope.
The sediment control log will be placed surrounding the topsoil stock pile, along the east side of the site.
Seeding and mulching will be completed to the northwest and east of the site, and on the pad cut and fill slopes along the perimeter of the site.
There will be one (1) OP on the southeast side of the site outletting from the sediment basin. Dimensions consist 6’W x 6’L x 2’D. |
| Material Handling and Spill Prevention | Form: (02A )
403249702
10/5/2023 | 1. Consistent with good materials and waste management practices, Operator maintains records of material/waste source, transporter, and final disposition or disposal. These records are maintained under usual and customary practice and are made available upon request. Depending on operational considerations, the type of waste in question, and approved disposal profiles, Operator may send waste to one or more approved facilities on a single, individual project.
2. Operator minimizes the generation of waste by ensuring that material products are fully used for their intended purpose. If unused materials remain following an activity, contractors are required to take unused product with them for reuse at the next applicable project. Contractors are contractually required to comply with applicable material and waste management practices.
3. In the event of an unintended release of material by a contractor, Operator requires the contractor to report the release, and to remediate impacts in accordance with applicable cleanup standards. Operator tracks all contractor releases to closure by requiring formal documentation, supported by laboratory analysis demonstrating cleanup of site impacts, any required waste characterization, waste disposal approval, and manifests or load tickets tracking waste from source, through transport, to final disposal.
4. If there are unanticipated hazardous waste streams not listed in the attached Waste Streams Spreadsheet, the hazardous waste will be stored and disposed of in compliance with all rules and regulations applicable to that specific waste.
5. Produced water with no commercial value or reuse potential is typically disposed of via underground injection. In all instances, produced water is disposed of at an offsite location(s) via properly permitted disposal facilities including but not limited to UIC wells intended specifically for produced water disposal.
6. Soils impacted with produced fluids will be transported offsite for disposal at a disposal facility permitted to receive E&P waste. All incidents are reported in accordance with COGCC 900-Series Rules.
7. All drill cuttings generated during drilling operations are transported offsite with proper manifesting for disposal at facilities properly permitted to receive E&P waste. Drilling fluids will be stored on-site and recycled for use in future drilling operations.
8. All surface trash, debris and material not intrinsic to the operation of the oil and gas facility shall be removed, stored in a |
| Material Handling and Spill Prevention | Form: (02A )
403249702
10/5/2023 | Drilling/Completions Operations
• Frequent and thorough inspections throughout all stages of operations.
• Procedures and training on equipment use in place to avoid and mitigate spills.
• Double-walled storage tanks will used where applicable.
• Continuous monitoring and third-party systems will be used to track fluid volumes and monitor for leaks.
• Rig will be placed on an impervious plastic liner including four-inch to six-inch high berm walls.
• Closed loop drilling systems will be utilized.
• Temporary portable containers (e.g., drums) are stored inside plastic lined or other impervious containment.
• General secondary containment (impervious liner) will be placed under equipment.
• Active drilling fluid tanks will be equipped with a third-party measurement and alarm system (Pason Pit Volume Totalizer) to track
tank volumes and changes during the drilling operation.
• Fluid storage tanks on the location will be equipped with mechanical (visual) level indicators that are inspected by operation personnel.
• Third-party continuous monitoring on integral systems in addition to routine inspections. In the event of an upset condition, Operators are notified and respond immediately.
• Regular preventative maintenance schedules followed for equipment.
Facility Construction
• Qualified third-party inspectors will inspect equipment to evaluate compliance with COGCC Rules and Regulations and applicable technical standards.
• Secondary containment will be installed with an impervious liner.
• Secondary containment will be sized to 150% of the largest storage tank.
• Production tanks will be lined where applicable.
• Pressure and Integrity testing prior to placing equipment into service.
• All equipment will be installed and tested in accordance with applicable American Society of Mechanical Engineers (ASME) and American
Petroleum Institute (API) standards.
• Underground piping on the facility will be electronically inspected prior to installation using coating deficiency detectors per COGCC 1102.I.(1).
• Flowlines will be inspected by a qualified third-party inspector who is trained in accordance with 1102.h prior to placing into service.
• Flowlines will be integrity tested per 1100 Series Rules.
• All production tanks are built in accordance with API 12F standards.
• Produced water production tanks at the facility utilize an internal liner.
• Test ports for integrity testing are installed on insulated tanks.
Spill Prevention and Material Handling
• Inspections of all production equipment including temporary equipment.
o Routine operational checks on the facility.
o Documented weekly inspections.
o Audio, Visual, Olfactory (AVO) inspections in accordance with COGCC Rule 609.d. and Air Quality Control Commission Regulation 7
o Annual Spill Prevention and Control Countermeasure Inspections.
• Periodic operator training on spill prevention best management practices and equipment operations.
• Fluid handling equipment will have valves and caps to mitigate leaks.
• Internal and External Tank integrity Inspections.
• Annual separator and flow through process equipment cleanouts and integrity evaluations.
• Pressure testing of all flowlines.
Spill Response
• Response to all spills and release in accordance with COGCC 900 Series Rules including timely reporting, response, and investigation. |
| Dust control | Form: (02A )
403249702
10/5/2023 | • Application of fresh water to disturbed areas during earth moving activities.
• Application of fresh water or magnesium chloride to graveled surfaces of the Site and associated roads.
• Use of high-quality construction materials such as crushed granite road base, which generates less dust than other aggregates.
• Limit disturbance of natural vegetation to only that area that is reasonably necessary for construction.
• Re-establishment of vegetation on disturbed areas not graveled.
• Covered storage containers to be used for sand, silica, proppant or similar material during hydraulic fracturing.
• Establish speed limit on all access roads of 20MPH or less. Personnel failing to comply will be subject to disciplinary action.
• Establish speed limit on the Site of 5MPH or less. Personnel failing to comply will be subject to disciplinary
action.
• Curtail scope of work during high wind conditions (sustained winds 25MPH or greater).
• Regular road maintenance will include adding gravel and grading when needed per the executed Road Maintenance Agreement between the Operator and City of Aurora.
• Additional management practices such as road surfacing, natural wind breaks and barriers, or automation of wells to reduce truck traffic may also be utilized to minimize fugitive dust emissions.
• Crestone will use a rock base tracking pad at the access point to help remove dirt and prevent debris from collecting on all access roads. As necessary, Crestone will sweep roads nearest the access point of dirt and debris to maintain a clean entrance.
• Vertically track the stockpile by heavy equipment to prevent wind and water erosion.
• During construction, salvaged topsoil will be seeded and monitored for erosion and the establishment of undesirable and noxious weeds routinely.
• Seeding and straw mulch application will occur on the long-term topsoil storage stockpile during interim reclamation. |
| Construction | Form: (02A )
403249702
10/5/2023 | • Most work operations will take place 7-days a week & 24-hour a day. Care will be taken to keep lighting levels at the specified levels on the lighting plans while providing safe, well-lit working areas during night-time and other low-light conditions. Care will also be taken to prevent unintended light from leaving the site and becoming a hazard or nuisance to the public or surrounding wildlife habitat.
• During the Pad Construction Operations, no night-time work is anticipated. Daylight work will be performed during this work operation.
• No permanent lighting is proposed for this project. All lighting shall conform to Federal, State, and Industry recognized standards for both on-site workplace safety and off-site public protection (OSHA, FAA, COGCC, IESNA, and ANSI). No direct light, except those governed by FAA standards, shall shine beyond the boundaries of the WPS, especially onto public roads, adjacent properties, and/or high priority habitats. All lighting shall conform with all COGCC, county, municipal, and any applicable governing body’s standards.
• Temporary lighting will be 4-head LED flood lights on mobile 25-foot telescoping towers (BUG Rating is B3-U3-G5). All lighting will be capable of adjustment and will be directed inward and between 45-65° downward towards working areas on the WPS. No light should shine above the horizontal plane passing through the center point of the light source. Lights will be shielded with a photometric diffusion fabric or membrane tint to prevent direct or reflected direct light from leaving the site.
• For workplace safety, no direct or reflected direct light shall shine towards the entrance of the WPS.
• Watch for and remove glare and reflection points during all work operations of the project from temporary or permanent structures, temporary lighting, vehicles, construction equipment, and clothing/PPE.
• Any lighting damaged and/or improperly directed or angled will be promptly fixed and/or corrected to conform to the lighting plan.
• Equipment shall be operated and/or orientated and/or shielded in such a manner that lights permanently affixed to equipment do not shine above the horizontal plane passing through the center point of the light source or shine beyond the boundary of the WPS.
• For all work operations, once temporary lighting is in place, a lighting self-audit of the site will be performed to ensure that no unintended light will leave the site and become a hazard or a nuisance.
• For any change to the lighting during any work operations, a lighting self-audit of the site will be performed to ensure that no unintended light will leave the site and become a hazard or a nuisance.
• For non-working or shut-down days where no personnel are on-site or in working areas, non-essential temporary lighting will be turned off. If no personnel are on-site and essential temporary lighting is needed, the essential temporary lighting will be inspected every 24 hours.
• All redundant, unused, or not-needed lights will be turned off.
• Any additional light units used to address workplace safety concerns that are not shown on the lighting photometric plans will be verified by a lighting engineer to ensure that the modified lighting will remain within the required lighting standards stated in this report. |
| Noise mitigation | Form: (02A )
403249702
10/5/2023 | Idling Equipment – While idling engine/equipment, maintain at the lowest frequency possible, as well as, in a position/location that will prevent sound from carrying to nearby residents.
Unnecessary Sounds – Unnecessary sounds such as honking the horn, revving vehicle engines, loud music, and unwarranted metal hammering/banging are all examples of sound that can create nuisance; failure to eliminate unnecessary sound from location will be subject to an internal compliance assessment if reported by a landowner.
Patterson Rig 345 is scheduled to be utilized for the drilling of the Watkins location. Rigs have been designed and equipped with sound mitigating equipment including devices to minimize squeaking from the draw works brakes.
A quiet frac fleet will be used during the completion phase.
Pursuant to City of Aurora Section 135-5 (d)1.e. - Unloading pipe. The Operator shall not unload pipe from delivery trucks between 8:00 p.m. and 7:00 a.m.
Crestone will install “quash” sound damping material in all permanent buildings that house noise sources if necessary.
Operator shall provide a 24-hour contact number for noise complaints on the facility sign. |
| Emissions mitigation | Form: (02A )
403249702
10/5/2023 | Utilize closed-loop, pit-less fluid management system.
Use of freshwater to minimize the generation and transportation of dust.
Employ the practice of “block and isolate” whenever possible on equipment, piping, and/or tank connections.
Use of sealed containers (e.g., sandboxes) for the storage and transportation of sand used in hydraulic fracturing.
Any gas encountered during drill-out will be combusted with a minimum of 98% destruction efficiency.
Any fluids encountered during drill-out will be sent to a controlled tank and stored until transferred for disposal (e.g., water) or sale (e.g., oil).
Any gas encountered during flowback will be routed to a gas sales pipeline or combusted with a minimum of 98% destruction efficiency.
Any fluids encountered during flowback will be sent to a controlled tank and stored until transferred for disposal (e.g., water) or sale (e.g., oil).
Lease Automated Custody Transfer (LACT) will be used to transfer fluids from the oil production tanks.
Instrument air skids will be used to generate compressed air for all pneumatic actuation.
Vapor Recovery Towers (VRT) will be used for separation of the production stream.
Production Facilities will be powered by electricity sourced from the regional power grid.
Wells, facilities, and equipment will be equipped to be shut-in remotely.
Crestone monitors wells during each operational phase through its FLIR camera program to verify that sites are operating correctly and in compliance with regulations. Additionally, Crestone adopted a real-time, continuous air quality monitoring program at its horizontal well sites, representing about 80% of total production. Crestone will implement continuous monitoring at the Watkins 30-5-5H facility per CDPHE Regulation 7. The monitoring will follow all CDPHE requirements. These monitors will be located based on the prevailing winds determined during the baseline monitoring period as well as to avoid sounds walls and equipment. They will continuously monitor for methane, total VOCs, particulate matter, and meteorological conditions.
Operator will install a polyethylene liner on location during drilling and completions operations.
Operator will install an engineered containment system around/beneath production facilities.
Operator will develop a site-specific SPCC plan. |
| Odor mitigation | Form: (02A )
403249702
10/5/2023 | 1. Operator will use a filtration system and additives to the drilling and fracturing fluids to minimize odors
2. Operator shall utilize a closed-loop, pit-less mud system for managing drilling fluids.
3. Operator shall employ the use of drilling fluids with low to negligible aromatic contact (IOGP Group III) during drilling operations after the surface casing is set and freshwater aquifers are protected.
4. Operator shall remove drill cuttings daily and as soon as waste containers are full.
5. Operator shall employ pipe cleaning procedures when removing the drill pipe from the hole; these procedures may include “wiping” the pipe before racking it in the derrick. |
| Interim Reclamation | Form: (02A )
403249702
10/5/2023 | • Sediment Control Log
o Sediment control logs will be installed around all sides of the topsoil stockpile at any time it is not be actively accessed. The sediment control logs will be made of excelsior, straw, coconut fibers, or wood chips, and will be anchored to the ground with wooden stakes. The sediment control logs will function to reduce water flow velocities in order to mitigate rill erosion formation. Additionally, the erosion control logs will capture sediment in order to mitigate topsoil loss from the stockpile.
• Stockpile Management
o Topsoil will be stockpiled along the southern edge of the proposed pad. In order to mitigate topsoil loss and migration of soil offsite, the stockpile will undergo surface roughening, seeding, and mulching.
• Surface Roughening
o Once topsoil segregation and stockpiling are complete, the stockpile surface will undergo surface roughening. A tracked vehicle will drive over the surface in order to imprint horizontal ridges to encourage sediment entrapment, improve infiltration, and reduce runoff velocity.
• Seeding
o Once topsoil segregation, stockpiling, and surface roughening are complete, the stockpile will be seeded to mitigate erosion. Establishing vegetative cover will help to stabilize the soil, reduce wind and water erosion, minimize rill erosion, and reduce overall surface runoff. The stockpile will be regularly monitored for noxious weed growth. Re-seeding will occur as necessary, over the course of active construction in order to achieve wide spread uniform vegetative cover.
• Mulching
o Post seeding, a layer of straw or hay mulch will be installed via crimping along the stockpile, in order to promote seed germination and further stabilization of the soil. Mulching helps to mitigate the impacts of rainfall and increase soil moisture retention. Mulching will be monitored and re-applied as necessary, until vegetative growth is established.
• Seeding and mulch application will be completed within 24 hours of seedbed preparation, weather permitting.
• The seed mix will be drill seeded throughout the interim reclamation area.
• All seed will be certified weed free and pure live seed (PLS) rated per federal, state, county, and municipal standards.
• Certified weed free grass or wheat origin straw mulch will be uniformly applied at a rate of 3,000 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 north to south.
• Topsoil horizon depth will be identified based on changes in physical characteristics.
• Topsoil will be separated from the disturbance area to the depth of the topsoil horizon, determined by topsoil samples.
• Salvaged topsoil will be stockpiled, seeded, and the location marked or documented.
• All efforts will be taken to ensure topsoil will not be comingled with subsoil materials during recontouring and subsoil preparation operations.
• The grade of the interim reclamation area is between 0-2%.
• The surface elevation will be returned as close to the original relative position and contour as practicable during pad size reduction and grading operations.
• Seeding will be completed with range-type drill methods.
• Certified weed free grass or wheat origin straw will be utilized for mulching operations.
• Mowing operations will be commenced when the height of weeds exceeds 6 inches or before seed development.
• Herbicide applications will be utilized as needed to treat prostrate, low growing, or perennial noxious weed species for which mowing methods are ineffective.
• Herbicide applications will be spot-specific.
• Any pre-existing drainage features will be reestablished during recontouring.
• Reseeding will be completed with species consistent with the adjacent plant community.
• The proposed seed mix for this location is the Loamy Plains Seed Mix.
• Crestone Peak Resources, LLC will consult with the surface owner regarding the future land use and acceptability of the proposed seed mix.
• Seeding will occur throughout the interim reclamation area.
• A wildlife fence will be maintained to mitigate wildlife and/or livestock access to the interim reclamation area. |
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