| Planning | Form: (02A )
400530496
3/29/2014 | 604c.(2).R. Tank Specifications: A geosynthetic liner will be laid under the tanks on this location and a metal containment will be constructed. Storage tanks will be designed, constructed and maintained in accordance with National Fire Protection Association (NFPA) Code 30 (2008 version). KMG will maintain written records to verify proper design, construction and maintenance. All records will be available for inspection by the Director. |
| Planning | Form: (02A )
400530496
3/29/2014 | 604c.(2).S. Access Roads: KMG will utilize a lease access road from Weld County Road 36 for drilling operations and maintenance equipment. The road will be properly constructed and maintained to accommodate for local emergency vehicle access.
Water will be placed on dirt access roads to mitigate dust as needed. If feasible, magnesium chloride will also be used as needed on access roads to further abate dust.
|
| Traffic control | Form: (02A )
400530496
3/29/2014 | 604c.(2).D. Traffic Plan: If required by the local government, a traffic plan will be coordinated with the local jurisdiction prior to commencement of operations. |
| General Housekeeping | Form: (02A )
400530496
3/29/2014 | 604c.(2).P. Removal of Surface Trash: A commercial size trash bin for removing debris will be located on site. This bin will be for use by all parties affiliated with the operation. |
| Storm Water/Erosion Control | Form: (02A )
400530496
3/29/2014 | 604c.(2).W. Site-Specific Measures: KMG maintains a Stormwater Management Plan that assesses erosion control for every KMG operated location. This location will be added to this plan once construction begins. This site will be inspected every fourteen (14) days during construction activities, every thirty (30) days after construction is completed, and after any major weather event. |
| Material Handling and Spill Prevention | Form: (02A )
400530496
3/29/2014 | 604c.(2).F. Leak Detection Plan: Automation technology will be utilized at this facility. This technology includes the use of fluid level monitoring for the tanks and produced water sumps, high-level shut offs, and electronic sensors to monitor the interstitial space of double-walled produced water sumps. All automation is monitored by Kerr-McGee’s Integrated Operations Center (IOC,) which is manned 24 hours per day, 7 days per week. |
| Material Handling and Spill Prevention | Form: (02A )
400530496
3/29/2014 | 604c.(2).N. Control of Fire Hazards: KMG and its contractors will employ best management practices during the drilling and production of its wells and facilities and will comply with appropriate COGCC rules concerning safety and fire. KMG will ensure that any material that might be deemed a fire hazard will remain no less than twenty-five (25) feet from the wellhead(s), tanks and separator(s). |
| Construction | Form: (02A )
400530496
3/29/2014 | 604c.(2).G. Berm Construction: A geosynthetic liner will be laid under the tanks on this location and a metal containment will be constructed. Berms or other secondary containment devices will be constructed around crude oil, condensate, and produced water storage tanks and shall enclose an area sufficient to contain and provide secondary containment for 150% of the largest single tank.
Kerr McGee will create tertiary containment by construction of a berm or diversion dike, site grading, or other comparable measures, sufficient to further protect the wetlands located 675’ south of the oil and gas location. |
| Drilling/Completion Operations | Form: (02A )
400530496
3/29/2014 | 604c.(2).C. Green Completions: KMG will install Vapor Recovery Unit(s) (VRU) to prevent uncontrolled venting of flash gas. Environmental Control Devices or Volatile Organic Compound Combustors (VOC) will be used to control working and breathing vapor losses for oil and water tanks. Temporary above ground polyethylene water pipelines will deliver water to location operations from larger trunk lines to reduce truck traffic and minimize air pollution. |
| Drilling/Completion Operations | Form: (02A )
400530496
3/29/2014 | 604c.(2).K. Pit Level Indicators: All tanks (used in lieu of pits) contain pit level monitors with Electronic Drilling Recorders (EDR). KMG uses EDRs with pit level monitor(s) and alarm(s) for production rigs. Basic level gauges are used on tanks utilized for the surface rig. |
| Planning | Form: (02A )
402958562
9/23/2022 | • Ozone mitigation on forecasted high ozone days: operator will postpone the refueling of vehicles, as feasible, given the number of ozone action days, the operations ongoing at the time, and safety considerations.
• Ozone mitigation on forecasted high ozone days: operator will suspend or delay the use of fossil fuel powered ancillary equipment, as feasible, given the number of ozone action days, the operations ongoing at the time, and safety considerations.
• Ozone mitigation on forecasted high ozone days: operator will postpone construction activities, as feasible, given the number of ozone action days, the operations ongoing at the time, and safety considerations.
• Ozone mitigation on forecasted high ozone days: operator will reschedule non-essential operational activities such as pigging, well unloading and tank cleaning, as feasible, given the number of ozone action days, the operations ongoing at the time, and safety considerations. |
| Traffic control | Form: (02A )
402958562
9/23/2022 | • Access Road: Access Road: KMOG will utilize an existing access road from CR 36 for production operations, including maintenance equipment. The road will be properly constructed and maintained to accommodate for emergency vehicle access. |
| General Housekeeping | Form: (02A )
402958562
9/23/2022 | • Wastes will be stored in containers or on lined containment that are chosen for compatibility and checked periodically for leaks or integrity problems. Examples of containment include but are not limited to 3-sided steel tanks, steel tanks, lined containment, plastic totes, drums, etc.
• All specific wastes in the attached site-specific Table will have a detailed Safety Data Sheet available which includes information such as the properties of the wastes; the physical, health, and environmental health hazards; protective measures; and safety precautions for handling, storing, and transporting the chemical.
• The proper personal protective equipment will always be worn when handling waste. Employees will refer to the Safety Data Sheet for additional information.
• Good housekeeping measures will be implemented in the operating area and to ensure safety and environmental well-being.
• Wastes will be segregated and stored according to its waste type.
• When feasible, wastes will be recycled, re-used, or treated onsite. As a BMP fluid are generally re-used from location to location if possible. No onsite treatment or recycling is planned onsite for this location. In the event, that onsite treatment or recycling is feasible, a written management plan will be submitted to the COGCC Director for approval on a Form 4. |
| General Housekeeping | Form: (02A )
402958562
9/23/2022 | • Removal of Surface Trash: A commercial size trash bin for removing debris will be located on site. This bin will be for use by all parties affiliated with the operation. Upon completion of operations, the commercial trash bin will be removed from the location and disposed of in an appropriate manner.
• Good housekeeping measures will be implemented to prevent sediment, trash and toxic or hazardous substances from entering surface waters or impacting soils. Housekeeping practices include routine inspections, regular cleaning, site and equipment organization and maintenance, and appropriate chemical storage.
• Materials stored on Berry Farms 8-8HZ Facility will be kept away from direct traffic to prevent accidents.
• Dumpsters and trash receptacles will be enclosed and/or covered to prevent dissemination of rubbish when not in use.
• Storage areas will be swept for trash / rubbish, and cleanup coordinated by construction personnel.
• Drums and chemical storage containers will be clearly labeled, and an appropriate SDS kept on file to be made available for on-site personnel as needed.
• Loadlines: All loadlines shall be bullplugged or capped. |
| Wildlife | Form: (02A )
402958562
9/23/2022 | • An environmental assessment will be conducted immediately prior to pad construction, drilling, and completion operations.
• Openings greater than 2” on equipment not running 24 hours a day will have avian protection installed.
• Approximately two weeks prior to construction start, the approved location will be surveyed by 3rd party biological contractor for nests.
• A site-specific spill prevention, control, and countermeasure plan complaint with EPA rule 40 CFR 112 Subpart A, B, C will be created for this location.
• Automated emergency response systems and emergency shutdown systems will be installed.
• Remote monitoring systems will be utilized at this location.
• Vegetation will be controlled on the active location throughout the life of the project.
• Water On Demand system and pipelines will be utilized to minimize truck traffic on location.
• Periodic inspections for nests and of avian protection will occur throughout the life of the project.
• Training is provided to employees and contractors on wildlife conservation practices, including no harassment, feeding of wildlife, or illegal hunting.
• Fluids will be consolidated and centralized for collection and distribution to minimize impact to wildlife.
• Infrastructure and facility are adequately sized to accommodate planned production.
• Employees and contractors visiting location will follow Kerr-McGee Oil & Gas Onshore LP rules for accessing location, including speed limits and access timing. |
| Storm Water/Erosion Control | Form: (02A )
402958562
9/23/2022 | Structural Control Measures
Limits of Construction (LOC)
• Limits of construction will be used to designate the area of intended development and areas intended for surface disturbing activities.
• The LOC will be identified prior to commencement of surface disturbing activities, on the location grading plan, and in-field with wooden survey lathe / staking to delineate the boundary.
• The LOC surrounds the entirety of Berry Farms 8-8HZ Facility.
• LOC will remain in-place until interim reclamation activities are complete.
Vehicle Tracking Control (VTC)
• Vehicle tracking controls will serve as a stabilized site access point which removes sediment from vehicle tires and mitigates off-site tracking onto paved surfaces.
• VTC will be installed prior to commencement of surface disturbing activities.
• VTC will be installed at the primary access for Berry Farms 8-8HZ Facility, which is along the northeastern portion of the access road. The access road adjoins / intersects Weld County Road 36.
• VTC will remain in place until interim reclamation activities are complete.
Temporary Diversion Ditch and Berm (DD)
• A diversion ditch and berm will be implemented to divert stormwater run-on & run-off throughout Berry Farms 8-8HZ Facility to a designated outlet structure(s).
• This BMP will be installed prior surface disturbing activities and will surround the entirety of the location to create continuous perimeter control.
• A diversion ditch and berm will serve as a continuous perimeter control for the location.
• Diversion ditch and berm will remain in-place until interim reclamation activities are complete.
Temporary Spillway and Outlet (SW/O)
• A temporary spillway and/or outlet are designed to capture sediment transported in surface runoff and slowly release flows to allow time for settling of sediment prior to discharge from the location.
• Spillway and/or outlet will be installed concurrently with the facility diversion ditch and berm, and prior to commencement of surface disturbing activities.
• A temporary spillway/outlet will be installed in the southcentral & southwestern segments of the facility ditch and berm for Berry Farms 8-8HZ Facility.
• All spillways and outlets will remain in-place until interim reclamation activities are complete.
Culvert (C)
• Culverts are used to move water under a road or crossing, or to direct flow to a designated endpoint, and are sized to manage anticipated watershed and flow rates.
• Culverts will be installed at the Weld County Road 36 access road crossing for Berry Farms 8-8HZ Facility. Culverts will be evaluated at the time of construction and installed as needed.
• Culverts will be reinforced with inlet and outlet protection to mitigate sediment transport and surface erosion
• These BMPs will remain in place throughout the life of production for Berry Farms 8-8HZ Facility and removed during final reclamation. 5.1.6 Inlet / Outlet Protection (IP/OP)
• Inlet / outlet protection is a permeable barrier installed around a drain or culvert to filter runoff and remove sediment.
• This BMP will be installed prior to commencement of surface disturbing activities.
• Inlet and outlet protection will be installed for all culverts, temporary spillways, and temporary outlets at Berry Farms 8-8HZ Facility.
• Inlet and outlet protection will remain in place throughout the life of production for Berry Farms 8-8HZ Facility and removed with culverts and outlets during final reclamation.
Seed & Mulch (SM)
• Seed and mulch are utilized in disturbed areas to establish stabilization through vegetative cover.
• Seeding will take place once surface disturbing activities are complete. Topsoil stockpiles will be stabilized with seed and mulch no longer than 14-days after completion of stockpiling efforts unless weather or ground conditions are not suitable to properly create a seedbed and promote successful germination.
• Seed and mulch will be installed on all disturbed areas no longer utilized for construction, and on all topsoil stockpiles which will remain on Berry Farms 8-8HZ Facility for use during interim and final reclamation. Anticipated topsoil stockpiles will be situated along the southern and eastern perimeters of the well pad.
• Seed and mulch will be disturbed and re-applied during topsoil application and final reclamation practices.
Non-Structural Control Measures
Construction Phasing & Sequencing
• Construction phasing and sequencing will be implemented at Berry Farms 8-8HZ Facility to minimize the amount of surface disturbance and exposed soils to the greatest extent practicable.
Construction Site Waste Management
• All waste from materials imported to Berry Farms 8-8HZ Facility will be placed in containment bins, and removed for disposal/recycling at an approved, licensed facility.
• Self-contained port-o-lets will be placed on both the facility and well pad at Berry Farms 8-8HZ Facility and maintained by a licensed contractor at a frequency appropriate based on daily use.
• No waste materials will be buried or dumped on Berry Farms 8-8HZ Facility.
Protection and Preservation of Existing Vegetation
• Pre-existing vegetation cover will only be removed where necessary for the operation of construction and development at Berry Farms 8-8HZ Facility. Trees will only be cut or trimmed to facilitate clearing, grading and safe installation of the location.
• Vegetative buffers will be preserved to the greatest extent practicable for construction and development.
Training and Certification
• All personnel involved with construction and stormwater activities will be adequately trained and familiarized with the applicable CDPS stormwater permit, local/State regulations, requirements for the stormwater permit, and identification of potential pollutant sources.
• Training(s) will cover information and procedures identified in this SWMP, and will be conducted prior to the start of construction, and as needed.
• Training is considered initial and ongoing for all personnel involved with construction and development at Berry Farms 8-8HZ Facility. |
| Material Handling and Spill Prevention | Form: (02A )
402958562
9/23/2022 | Production
• The temporary produced water storage tanks will be staged on a geosynthetic liner and surrounded by an earthen berm. The berms will enclose an area sufficient to provide secondary containment for 150% of the volume of the largest single tank and will be sufficiently impervious to contain spilled or released material. Berms and the liner and all Kerr-McGee Oil & Gas Onshore LP (KMOG) Fluid Leak Detection Plan – Berry Farms Facility 8-8HZ 5 secondary containment devices will be inspected at the same time as stormwater inspections, with personnel on location, daily inspections will occur.
• During non-active, but while under construction, site inspections will occur every 14 days. During the production phase, a geosynthetic liner will be laid under the permanent tanks on this location and a metal containment will be constructed. Secondary containment devices will be constructed around crude oil, condensate, and produced water storage tanks and will enclose an area sufficient to contain and provide secondary containment for 150% of the largest single tank. Secondary containment devices will be inspected at the same time as stormwater inspections, with personnel on location, daily inspections will occur. During non-active, but while under construction, site inspections will occur every 14 days. When construction is completed and the Location is on production, site inspections will occur every 28 days.
Production
• Berm Construction: A geosynthetic liner will be laid under the permanent tanks on this location and a metal containment will be constructed. Secondary containment devices will be constructed around crude oil, condensate, and produced water storage tanks and will enclose an area sufficient to contain and provide secondary containment for150% of the largest single tank. Secondary containment devices will be inspected at the same time as stormwater inspections, with personnel on location, daily inspections will occur. During non-active, but while under construction, site inspections will occur every 14 days. When construction is completed and the Location is on production, site inspections will occur every 28 days.
• Automation technology will be utilized at this facility. This technology includes the use of fluid level monitoring for the tanks and produced water sumps, high-level shut offs, and electronic sensors to monitor the interstitial space of double-walled produced water sumps. All automation is monitored by Kerr-McGee's Integrated Operations Center (IOC), which is manned 24 hours per day, 7 days per week.
• Field Inspections include the following: Field-Constructed Above Ground Containers; Secondary Containment Structures; Shop-Built Containers; Generators / Fuel Tanks and associated secondary containment; Pressure Vessels (separators, heater treaters, pigging stations); Portable Containers and all Manifolded Piping; Onsite and Offsite Pipelines (flowlines, production piping, gathering lines) Field Drainage Systems (oil traps, sumps, or skimmers); and Additional equipment used during separation, storage, containment, or transferring of produced fluids.
• All personnel on location on behalf of KMOG are trained in AVO techniques. All personnel are empowered with ‘Stop Work Authority’ and to report any leaks immediately.
Recording Keeping
• Inspections resulting in findings are reported to the IOC. These are entered into an internal management system. Corrective actions are automatically assigned when necessary. SPCC required inspection records are kept in accordance with US EPA requirements.
• Maintenance or repair records are managed through an internal management system. These are tracked from assignment through completion of the tasks.
• Leak records: All leaks are reported immediately to the IOC and logged in internal management systems. Leak reports are reviewed daily. Any additional investigation is conducted by trained personnel and records in the system. All leaks are tracked until final resolution. Records are retained per federal, state, and local guidelines.
• Training Records: KMOG retains AVO training records for all personnel with access to the location in an internal management system. Records are retained per federal, state, and local guidelines.
• During production operations, the following site-specific best management practices will be used: Automation technology will be utilized at this facility. This technology includes the use of fluid level monitoring for the tanks and produced water sumps, high-level shut offs, and electronic sensors to monitor the interstitial space of double-walled produced water sumps. All automation is monitored by Kerr-McGee's Integrated Operations Center (IOC), which is manned 24 hours per day, 7 days per week. All personnel on location on behalf of KMOG are trained in AVO techniques. All personnel are empowered with ‘Stop Work Authority’ and to report any leaks immediately. |
| Material Handling and Spill Prevention | Form: (02A )
402958562
9/23/2022 | Recording Keeping
• Inspections resulting in findings are reported to the IOC. These are entered into an internal management system. Corrective actions are automatically assigned when necessary. SPCC required inspection records are kept in accordance with US EPA requirements.
• Maintenance or repair records are managed through an internal management system. These are tracked from assignment through completion of the tasks.
• Leak records: All leaks are reported immediately to the IOC and logged in internal management systems. Leak reports are reviewed daily. Any additional investigation is conducted by trained personnel and records in the system. All leaks are tracked until final resolution. Records are retained per federal, state, and local guidelines.
• Training Records: KMOG retains AVO training records for all personnel with access to the location in an internal management system. Records are retained per federal, state, and local guidelines.
• During production operations, the following site-specific best management practices will be used: Automation technology will be utilized at this facility. This technology includes the use of fluid level monitoring for the tanks and produced water sumps, high-level shut offs, and electronic sensors to monitor the interstitial space of double-walled produced water sumps. All automation is monitored by Kerr-McGee's Integrated Operations Center (IOC), which is manned 24 hours per day, 7 days per week. All personnel on location on behalf of KMOG are trained in AVO techniques. All personnel are empowered with ‘Stop Work Authority’ and to report any leaks immediately. |
| Dust control | Form: (02A )
402958562
9/23/2022 | • KMOG will proactively deploy fresh water to suppress dust along access road to facility pad during all phases of pre-production operations
• Speed limits will be reduced to 10 mph on access road and 5 mph once vehicles reach the facility
• Access roads and Vehicle Tracking Control will receive maintenance as needed throughout operations
• In the event of high winds that generate dust that cannot be mitigated with an application of water, KMOG will shut down construction operations
• KMOG will proactively deploy fresh water on CR W36 from access road entrance east to WCR 17 as needed. |
| Construction | Form: (02A )
402958562
9/23/2022 | • Construction: Operator will only conduct operations during day light and there will be no nighttime operations that require lighting.
• Construction: Operator will only conduct during day light and there will be no nighttime operations that require lighting.The wells from the Berry Farms 8-8HZ Facility are commingled into a bulk and test facility design. This reduces the total number of separators on location on a per well basis which in turn allows KMOG to have a smaller facility footprint. Reducing the total number of separators per well also reduces the total noise and emissions from the separator burners.
• Fencing Requirements: The completed location will be surrounded with a fence and gate with adequate lock to restrict access to authorized personnel only. KMOG personnel will monitor the location upon completion of the wells. Authorized representatives and/or KMOG personnel shall be on-site during construction.. |
| Noise mitigation | Form: (02A )
402958562
9/23/2022 | • KMOG has conducted a Noise Impact Assessment for production operations to assess operational noise levels against the maximum allowable dBA and dBC noise levels stated in the Regulation.
• The operator will comply with maximum permissible noise levels adjusted based on the results of the ambient noise survey. The adjusted noise levels are outlined in the Noise Mitigation Plan at respective compliance points:
- Completion Compliance Points 1 and 3 – 65 db(A) Day / 605 db(A) Night – 65 db(C) Day / 65 db(C) Night
- Completion: Compliance Point 2 – 65 db(A) Day / 60 db(A) Night – 76 db(C) Day / 65 db(C) Night
- Production: Compliance Points 1 and 3 – 60 db(A) Day / 55 db(A) Night – 60 db(C) Day / 60 db(C) Night
- Production: Compliance Point 2 – 70 db(A) Day / 62 db(A) Night – 75 db(C) Day / 67 db(C) Night
• KMOG will utilize a Quiet Completions Fleet for completions operations on the facility pad for the Berry farms 8-8HZ Well Pad.
• At the Directors request, KMOG agrees to acquire an additional ambient at all three noise points of compliance 30 to 90 days prior to the commencement of operations. If the new ambient noise levels change any components of this Noise Mitigation Plan, a Form 4 sundry will be submitted to update the plan accordingly.
• KMOG will deploy continuous monitoring for all completions and any operations that lasts longer than 24 continuous hours. Monitor locations will coincide with the three noise points of compliance outlined in Figure 2 in Section 5 of this document.
• If the completions fleet is changed prior to commencement of operations, the mitigation measures will be equally or more protective. A Form 4 will be submitted per Rule 404.d to outline any changes.
• KMOG will post contact information to receive and address noise complaints arising from pre-production operations around the clock, 24-hours, 7 days per week. Upon receipt of a complaint, either directly to KMOG or from the COGCC, KMOG will contact relative stakeholder within 48 hours of receipt. |
| Emissions mitigation | Form: (02A )
402958562
9/23/2022 | • Temporary ECD(s) will be utilized to mitigate releases of emissions from temporary produced water storage tanks for the duration which the tanks are on location and being used.
• Operator uses pipelines to transport hydrocarbons (oil & gas) from the production facility eliminating odors that could occur during truck loading.
• Operator will implement ambient air quality monitoring on site.
• Operator will use non-emitting pneumatic controllers.
• Test separators and associated flow lines, sand traps and emission control systems shall be installed on-site to accommodate completions techniques. 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, KMOG shall not produce the wells.
• Ozone Action Days ±KMOG will comply with the follow mitigation measures, as feasible, on forecasted Ozone Action Days:
a. Operator will minimize vehicle and engine idling
b. Operator will reduce truck traffic and worker traffic
c. Operator will postpone the refueling of vehicles
d. Operator will postpone construction activities
e. Operator will reschedule non-essential operational activities such as pigging, well unloading and tank cleaning
f. Operator will postpone flowback if emissions cannot be adequately captured with an ECD. |
| Odor mitigation | Form: (02A )
402958562
9/23/2022 | • KMOG uses pipelines to transport hydrocarbons (oil & gas) from the nearby Berry Farms 8-8HZ Well Pad to the Berry Farms 8-8HZ Facility Pad and then off location via pipelines, eliminating odors that could occur during truck loading. |
| Interim Reclamation | Form: (02A )
402958562
9/23/2022 | • Interim reclamation will commence within twelve months from first date of production for all disturbed areas affected by construction and drilling operations which are no longer in use or needed for production. Interim reclaimed areas will be returned to their original condition as practicable, or their final land use as designated by the surface owner.
• Seed and mulch are utilized in disturbed areas to establish stabilization through vegetative cover.
• Seeding will take place once surface disturbing activities are complete. Topsoil stockpiles will be stabilized with seed and mulch no longer than 14-days after completion of stockpiling efforts unless weather or ground conditions are not suitable to properly create a seedbed and promote successful germination.
• Seed & mulch will be installed on all disturbed areas no longer utilized for construction, and on all topsoil stockpiles which will remain on Berry Farms 8-8HZ Facility for use during final reclamation. Anticipated topsoil stockpiles will be situated along the southern and eastern perimeters of the facility pad.
• Seeding will remain in place until re-disturbed during final reclamation efforts.
• In areas to be returned to crop, the seed bed will be prepared and left for surface owner to plant during next agricultural season.
• Cropland Per rule 1003.b., “All segregated soil horizons removed from crop lands shall be replaced to their original relative positions and contour and shall be tilled adequately to re-establish a proper seedbed. Any perennial forage crops that were present before disturbance shall be re-established”. All cropland locations will be reclaimed within three months from completion final ground disturbing activities. |
| Final Reclamation | Form: (02A )
402958562
9/23/2022 | • Well Site Cleared: The wellsite will be cleared of all non-essential equipment within ninety (90) days after all wells associated with the pad have been plugged and abandoned.
• Identification of Plugged and Abandoned Wells: Once the well has been plugged and abandoned, KMOG will identify the location of the wellbore with a permanent monument that will detail the well name and date of plugging. |