| PROPOSED BMPs | Form: (07 )
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1/23/2012 | Based on Sundry Form 4 doc no 400800848 and meets COA requirements regarding sound Form 4 Sundry doc no 400795097 - GWOG did a preconstruction reconnaissance visit with construction, operations and regulatory personnel to delineate pad location, layout, access, and an site specific mitigations that would be prudent. Based on this visit it was determined that sound mitigation efforts would be focused along the southern edge of the location and that no baseline noise survey was likely necessary. GWOG will install a 554-foot long, 32-foot high, fabric sound wall on the south edge of the pad for noise mitigation in the direction of a single residence to the south approximately 800 feet from the pad. There are additional residences farther south and southeast of the pad. In addition, exhaust ports for engines on location will be directed away from the nearby residences to the south. |
| Planning | Form: (02A )
400752458
2/6/2015 | Closed Loop Drilling Systems - Pit Restrictions (Rule 604.c.(2)B.
GWOC is utilizing a Closed Loop Drilling System on the subject facility. No open pit storage of water is foreseen for this facility. If open pit storage of fresh water is required, a Form 15 will be submitted and approved prior to use of such pit, and appropriate signage and escape provisions will be provided as required. Cuttings and drilling fluids will be removed from location and properly treated or disposed of according to applicable regulations.
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| Planning | Form: (02A )
400752458
2/6/2015 | Green Completions (Rule 604.c.(2)C.
As applicable, per COGCC Rule 805, GWOC will utilize all reasonable and cost-efficient best practices, including but not limited to those listed in Rule 805, to maximize resource recovery and mitigate releases to the environment.
• Initial frac and drillout effluent is routed through a sand catcher/trap and a junk/sand tank to remove sand and well frac debris.
• Once any hydrocarbons are detected but prior to encountering salable quality combustible gas or significant volumes of liquid hydrocarbons (condensate or oil) (greater than 10 barrels per day average) the effluent is routed through a high-pressure separator and closed-top tanks to minimize emissions to the environment. Hydrocarbon liquids, produced water, and sand are separated utilizing the high-pressure separator.
• Any accumulation of liquid hydrocarbons on the surface of a tank, greater than a residual amount (maximum of 20 barrels)will be removed as soon as practicable but within a maximum of 24 hours in all cases. The quality (combustibility) of the gas is typically monitored directly at the high-pressure separator. When salable (combustible) quality gas is measured/detected the gas stream is immediately diverted to the sales pipeline or the well is shut in.
• Venting or flaring of combustible gases is not performed except in rare ‘upset’ type situations for safety reasons.
• The separated produced water and hydrocarbon liquids (condensate/oil) are directed to specific tanks for storage until being unloaded and hauled to disposal or sales as appropriate.
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| Planning | Form: (02A )
400752458
2/6/2015 | Multi-well Pads (Rule 604.c.(2)E.
GWOC strives to utilize multi-well pads wherever technically and economically practicable to minimize potential impacts to neighbors and the environment. Multi-well pads are not always feasible due to numerous possible issues including but not limited to; landowner requirements, topographic constraints, well bore reaches, setback requirements, etc. This pad will be constructed in such a manner that noise mitigation may be installed and removed without disturbing the site or landscaping. The pad has all weather access roads to allow for operator and emergency response. This pad has been placed as far as possible from building units.
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| Planning | Form: (02A )
400752458
2/6/2015 | Leak Detection Plan (Rule 604.c(2)F.
GWOC designs its new facilities to both avoid leaks or releases as well as to help detect them in a time-efficient manner to minimize potential impacts. Oil and produced water storage tanks are in secondary containment areas. A minimum containment capacity of 150% of the single largest storage vessel inside the containment is constructed around any storage area. Tanks and all visible pipelines and valves etc. are inspected informally on a daily basis by company lease operators. In addition, GWOC also conducts formal annual SPCC inspections, and formal site specific and random audits, by third-party consultants to inspect for general site conditions as well as condition of tanks, pipelines, and containment structures. In addition, our company lease operators and Production staff review production records, including volumes and pressures, looking for irregularities that may indicate a problem with a tank or pipeline. If an irregularity is detected that may indicate a potential release the suspect tank and/or pipeline(s) are removed from service, isolated, and either pressure tested or visibly inspected for indications of a potential leak.
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| Planning | Form: (02A )
400752458
2/6/2015 | BOPE for well servicing (Rule 604.c.(2)J
A BOPE with a minimum pressure rating of 3,000 psi will be utilized. At a minimum it will consist of 2 ram preventers and 1 annular preventer. The blind rams will be positioned below the pipe rams. A backup system of pressure control will be onsite consisting of at a minimum 1,000 psi accumulator (backup pressure). Accumulator is tested to 1,000 psi. Operator may use fixed sized pipe rams matching the tubular size. The annular preventer will be pressure tested to 250 psi low and 2,000 psi high for 10 minutes each. The ram preventers will be tested to 250 psi low and 2,500 psi high for 10 minutes each. All remaining well control equipment will be tested to 250 psi low and 2,500 psi high for 10 minutes each. The pressure tests will be conducted when the equipment is first installed and every 30 days thereafter. Pipe rams and blind rams will be function tested before every well service operation. Annual BOP inspections and pressure tests will be performed by the service company and will be charted & retained for 1 year. Backup stabbing valves shall be used on operations that require reverse circulation. Valves will be pressure tested before each well service operation in low pressure and high pressure range. The GWOC onsite representative will be certified in Well Control Operations by a Well-Cap certified training service.
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| Planning | Form: (02A )
400752458
2/6/2015 | Drill stem tests (Rule 604.c.(2)L
Conventional drill stem tests will not be conducted on DJ Basin horizontal wells currently being executed or planned by GWOC. If plans change in the future a well specific drill stem testing plan will be prepared for that particular well. Note that GWOC may elect to use one of several available wireline deployed tools for the purpose of measuring downhole formation pressures and/or collecting downhole fluid samples from the target formation(s) of a particular well.
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| Planning | Form: (02A )
400752458
2/6/2015 | Identification of P&A wells (Rule 604.c.(2)U
GWOC shall identify the location of the P&A wellbore with a permanent monument as specified in Rule 319.a.(5). The operator shall also inscribe or imbed the well number and date of plugging upon the permanent monument. P&A wellbores shall be cutoff well below ground surface in agricultural areas to provide for landowners to safely farm the reclaimed well area.
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| Planning | Form: (02A )
400752458
2/6/2015 | Development from existing well pads (Rule 604.c.(2)V
Where possible, GWOC shall provide for the development of multiple reservoirs by drilling on existing pads. GWOC strives to utilize multi-well pads wherever technically and economically practicable to minimize potential impacts to neighbors and the environment. Multi-well pads are not always feasible due to numerous possible issues including but not limited to; landowner requirements, topographic constraints, well bore reaches, setback requirements, etc.
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| Planning | Form: (02A )
400752458
2/6/2015 | CERTIFICATION STATEMENT:
Great Western Operating Company certifies that the MLVTs on this location will be designed and implemented consistent with the COGCC Policy on the use of MLVTs in the state of Colorado. |
| Traffic control | Form: (02A )
400752458
2/6/2015 | Traffic Plan (Rule 604.c.(2)D.
GWOC works closely with all municipalities as appropriate to develop a mutually acceptable road traffic access plan addressing site specific traffic-related issues. These plans may address issues such as; routes, construction specification of access roads, maintenance, dust control, jake brake limits, traffic controls, enforcement, emergency response, etc. GWOC will work with municipalities, the County’s Planning Department and/or Road Department to address complaints related to traffic or dust issues as appropriate. Dust control measures may include surface stabilization, or dust control with appropriate chemical or water applications.
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| General Housekeeping | Form: (02A )
400752458
2/6/2015 | Removal of Surface Trash (Rule 604.c.(2)P
All surface debris, trash, unusable scrap, or solid waste from the facility will be properly temporarily stored on location in a secure container and ultimately removed and disposed of in a legal manner.
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| General Housekeeping | Form: (02A )
400752458
2/6/2015 | Well site cleared (Rule 604.c.(2)T
Within ninety (90) days after a well is plugged and abandoned, the well site shall be cleared of all non-essential equipment, trash, and debris.
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| General Housekeeping | Form: (02A )
400752458
2/6/2015 | General housekeeping will consist of neat and orderly storage of materials and fluids. Wastes will be temporarily stored in sealed containers and regularly collected and disposed of at offsite, suitable facilities. If spills occur prompt cleanup is required to minimize any commingling of waste materials with storm water runoff. Routine maintenance will be limited to fueling and lubrication of equipment. Drip pans will be used during routine fueling and maintenance to contain spills or leaks. Any waste product from maintenance will be containerized and transported offsite for disposal or recycling. There will be no major equipment overhauls conducted onsite. Equipment will be transported offsite for major overhauls. Cleanup will consist of patrolling the roadways, access areas, and other work areas to pick up trash, scrap debris, other discarded materials, and any contaminated soil. These materials will be disposed of properly and promptly. |
| Storm Water/Erosion Control | Form: (02A )
400752458
2/6/2015 | Storm Water Management Plans (SWMP) are in place to address construction, drilling and operations associated with Oil and Gas development throughout the state of Colorado in accordance with Colorado Department of Public Health and Environment (CDPHE). Barriers will be constructed around the perimeter of the site prior to construction. Typically, GWOC utilizes a ditch and berm system of storm water control at its sites. BMP’s used are determined just prior to construction by a third-party storm water contractor and may vary according to the location. Storm water controls will remain in place until the pad is stabilized or reaches final reclamation. |
| Material Handling and Spill Prevention | Form: (02A )
400752458
2/6/2015 | Spill Prevention Control and Countermeasures (SPCC) plans in place to address any possible spills associated with Oil and Gas operations throughout the state of Colorado in accordance with CFR 112.
In accordance with COGCC Rule 1002.f.(2)A. & B., shall provide a designated storage area for dry bulk chemicals and miscellaneous fluids. The storage area shall be covered to prevent contact of precipitation with chemicals, shall be elevated above storm- or standing water, and shall provide sufficient containment to prevent release of spilled fluids or chemicals from impacting soil, surface water or groundwater and will prevent the co-mingling of spilled fluids or chemicals with other E & P Waste.
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| Construction | Form: (02A )
400752458
2/6/2015 | Berm Construction (Rule 604.c.(2)G.
A minimum containment capacity of 150% of the single largest storage vessel inside the containment will be constructed around any liquids storage area. For this location, steel containment with sealed liners will be utilized at all storage facilities on this location.
Tanks and all visible pipelines and valves etc. will be inspected informally on a daily basis by company lease operators. In addition, GWOC also conducts formal annual SPCC inspections, and formal site specific and random audits, by third-party consultants to inspect for general site conditions as well as condition of tanks, pipelines, and containment structures.
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| Construction | Form: (02A )
400752458
2/6/2015 | Pit level indicators (Rule 604.c.(2)K
GWOC does not typically utilize pits in any of its operations. If a pit was to be used proper pit Level indicators would be installed to indicate pit levels and compliance with pit volume rules.
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| Construction | Form: (02A )
400752458
2/6/2015 | Fencing requirements (Rule 604.c.(2)M
At a minimum GWOC installs appropriate fencing to restrict access by any unauthorized persons. This fencing may vary depending on site-specific situations. Fencing will be properly noted on facility layout diagrams for both drilling/completion and the production phases of operations.
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| Construction | Form: (02A )
400752458
2/6/2015 | Control of Fire Hazards (Rule 604.c.(2)N
GWOC constructs and operates our facilities to meet state and API codes, as appropriate, including API RP 500 electrical classifications inside bermed areas. Any unused potentially flammable materials are moved a minimum distance of 25-feet from wellhead, tanks, and separator areas. In addition, GWOC implements a Hot Work Permit Program for employees and contractors doing any defined ‘Hot Work’ activities on GWOC locations.
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| Construction | Form: (02A )
400752458
2/6/2015 | Load lines (Rule 604.c.(2)O
Load line containment is a necessary part of a complete secondary containment system. All loadlines are capped or bullplugged or locked shut to reduce the likelihood of a release occurring. In addition, GWOC places all load line receivers/valves inside secondary containment areas or in a proper load line containment device or both.
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| Construction | Form: (02A )
400752458
2/6/2015 | Guy line anchors (Rule 604.c.(2)Q
Guy line anchors left buried for future use shall be identified by a brightly colored marker at least 4-feet in height and within 1-foot to the east of the anchor.
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| Construction | Form: (02A )
400752458
2/6/2015 | Tank specifications (Rule 604.c.(2)R
All newly installed or replaced crude oil and condensate storage tanks shall be designed, constructed, and maintained in accordance with National Fire Protection Association (NFPA) Code 30 (2008 version). GWOC shall maintain written records verifying proper design, construction, and maintenance, and shall make these records available for inspection by the Director. Only the 2008 version of NFPA Code 30 applies to this rule.
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| Construction | Form: (02A )
400752458
2/6/2015 | Access Roads (Rule 604.c.(2)S
All access roads are designed, constructed, and maintained such that heavy equipment, including emergency response vehicles, can readily access and exit the location. In addition, GWOC will implement manual mud mitigation measures (eg. tracking control rock aprons) at location exits onto paved roads as necessary and in conjunction with county requirements.
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| Noise mitigation | Form: (02A )
400752458
2/6/2015 | Noise (Rule 604.c.(2)A.
The subject Great Western Operating Company, L.L.C. (GWOC) location will operate in accordance with maximum permissible noise levels per COGCC Rule 604.c.(2)A. and 802, as applicable. GWOC will utilize reasonable and cost-effective best practices to endeavor to reduce noise levels below these limits in areas where occupied structures occur within a Designated Setback Zone. Where possible, drilling rig and completion equipment engine exhaust will be directed away from occupied buildings to assist with noise mitigation. No noise compliance issues are expected from the production area.
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