| Material Handling and Spill Prevention | Form: (02A )
401667379
8/31/2018 | 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. |
| Material Handling and Spill Prevention | Form: (02A )
401667379
8/31/2018 | All loadlines will be capped for every location in the DJ. |
| Material Handling and Spill Prevention | Form: (02A )
401667379
8/31/2018 | 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. |
| Construction | Form: (02A )
401667379
8/31/2018 | 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. |
| Noise mitigation | Form: (02A )
401667379
8/31/2018 | The subject location will be constructed to allow potential future noise mitigation installation without disturbance. |
| Emissions mitigation | Form: (02A )
401667379
8/31/2018 | 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. |
| Emissions mitigation | Form: (02A )
401667379
8/31/2018 | Temporary flowback flaring and oxidizing equipment will include: adequately sized equipment to handle 1.5 times the largest flowback volume of gas experienced in a ten mile radius. If there is overrun, Crestone will shut in the well versus freely venting. First sign of salable gas will be turned down the line. |
| Emissions mitigation | Form: (02A )
401667379
8/31/2018 | 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, the operator shall not produce the wells without an approved variance per Rule 805.b.(3)C.
Salable gas will be from the facility location and the wells will be connected to a third party gas pipeline. Wells will be shut in versus freely venting/flaring. |
| Drilling/Completion Operations | Form: (02A )
401667379
8/31/2018 | 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. |