| General Housekeeping | Form: (02A )
400872197
10/26/2015 | All surface trash, debris, scrap or discarded material will be removed daily or weekly as necessary and in a legal manner. |
| Storm Water/Erosion Control | Form: (02A )
400872197
10/26/2015 | Storm Water Management Plan (SWMP) will be in place to address construction, drilling and operations associated with oil and gas development through the state of Colorado in accordance with CDPHE General Permit Rules. BMP’s will vary according to location and will remain in place until the pad reaches final reclamation. |
| Material Handling and Spill Prevention | Form: (02A )
400872197
10/26/2015 | Spill prevention control and countermeasure plan is in place to address construction, drilling and operations associated with oil and gas development throughout the state of Colorado in accordance with CFR 112. |
| Drilling/Completion Operations | Form: (02A )
400872197
10/26/2015 | Preferred Option: It is the intent of the County that operators utilize closed-loop or modified closed-loop systems for drilling and completion operations in order to minimize or eliminate the need for earthen pits; however, notwithstanding the foregoing, where appropriate, and subject to prior County approval, the County generally supports: 1) the use of unlined drilling pits when bentonite or a similar clay additive is used during the drilling process, and 2) the use of lined single- or multi-well water storage pits in order to minimize the transport of water and promote recycling, subject to the requirements set forth in this subsection. Permitted modified closed-loop systems include oil and gas wells where air or fresh water is used to drill through the surface casing interval, defined as fifty (50) feet below the depth of the deepest aquifer, and a closed loop system is used for the remainder of the drilling and/or completion or recompletion procedures. Multi-well pits are defined as lined, engineered pits, constructed over an engineered base, with construction or liner specifications meeting or exceeding Commission pit lining rules, that will serve the functions of drilling, completion, and/or flowback pits for more than one well. |
| Storm Water/Erosion Control | Form: (02A )
402289797
6/12/2020 | Operator will install stormwater controls around the perimeter of the location prior to construction. Controls will include a ditch and berm system to divert water around the location and minimize the potential for runoff/runon and a stormwater detention pond. They will remain in place through final reclamation or until pad is stabilized.
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| Material Handling and Spill Prevention | Form: (02A )
402289797
6/12/2020 |
Secondary Containment
All facilities will be equipped with remote monitoring and remote shut down, which includes isolation at the well head. Engineered liner systems will be used in secondary steel containment systems for tank batteries. Pollution control containers (spill boxes) will be used on truck loading lines and placed within the limits of the secondary containment system. Automatic shutdown level devices will be installed on each tank with remote monitoring capabilities. Automatic shutdown level devices will be installed on all pressure vessels and liquid knockouts. Automatic shutdown pressure devices will be installed on flowlines from well heads to facilities with remote monitoring capabilities. Additionally, cathodic protection will be used on buried steel lines to mitigate corrosion. Automatic shutdown pressure devices will be installed on process vessels with remote monitoring capabilities. |
| Emissions mitigation | Form: (02A )
402289797
6/12/2020 | Emissions Controls
Combustors will be available at the Location during the entire production phase to eliminate fugitive emissions in the event of maintenance or emergency use. The device will be fired using natural gas and operate with a 98% or higher hydrocarbon destruction efficiency. The device will be designed and operated in a manner that will ensure no visible emissions during normal operation. Test separators and associated flow lines, sand traps and emission control systems shall be installed on-site to accommodate green 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, Operator shall not produce the wells without an approved variance per Rule 805.b.(3)C. |
| Traffic control | Form: (02A )
403001067
12/2/2022 | Traffic will be reduced during completion operations by using temporary above ground water lines to deliver water.
Haul routes were designated and developed in consultation with the County. A Road Maintenance agreement is in place with the County.
Commercial reasonable dust control measures will be used as needed following local requirements.
In order to establish a baseline condition and post construction condition of the Access Road prior to the initial and post construction of a Well Site, Crestone will provide video recording or photographs of the condition of the Access Road to ensure the roads remain safe for public use. If road damage has occurred, Crestone will either be responsible for repair or will pay the County for such repairs.
The County has the right to reasonably restrict the hours during which vehicles and equipment may be moved on the Roads covered by the Road Damage Agreement (see attached) for the protection of public health, safety and welfare. |
| General Housekeeping | Form: (02A )
403001067
12/2/2022 | 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.
All surface trash, debris and material not intrinsic to the operation of the oil and gas facility shall be removed stored in a roll off container or other trash bin and disposed of at a commercial solid waste disposal location.
Waste will be stored on location in compatible container or containment devices designed or engineered for the purposes for which they will be utilized. These containers will be inspected on a regular basis to ensure that no undue wear, structural issues, sever rust, other defects, which may impact their effectiveness.
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.
CPR 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. |
| Wildlife | Form: (02A )
403001067
12/2/2022 | If a trench is left open for more than 5 consecutive days during pipeline construction, CPR will install wildlife escape ramps at a minimum of one ramp per ¼ mile of trench.
CPR will use CPW-recommended seed mixes for interim and final reclamation when consistent with the Surface Owner’s approval and any local soil conservation district requirements.
CPR will use CPW-recommended fence designs with consistent with the Surface Owner’s approval and any Relevant Local Government requirements.
CPR will conduct all vegetation removal necessary for Oil and Gas Operations outside of the nesting season for migratory birds (April 1 to August 31). For any vegetation removal that must be scheduled between April 1 to August 31, CPR will implement appropriate hazing or other exclusion measures prior to April 1. If hazing or other exclusion measures are not implemented, CPR will assign a qualified contractor to conduct pre-construction nesting migratory bird surveys within the approved disturbance area prior to any vegetation removal during the nesting season. If active nest(s) are located, CPR will establish work zone buffers around active nests.
If operations will begin more than approximately six months past the field survey date and between March 15 and October 31, additional burrowing owl habitat surveys will be conducted by qualified biologists to ensure no new suitable habitat has been established. If new habitat is identified, burrowing owl surveys will be initiated and CPW will be consulted prior to the start of construction as needed.
If work begins between February 1 and August 15, raptor nesting surveys will be conducted by qualified biologists within approximately one week of the start of construction.
If work begins between April 1 and August 31, migratory bird nesting surveys will be conducted by qualified biologists within one week of the start of construction.
If operations will begin between February 1 and August 31, nesting surveys will be conducted by qualified biologists in accordance with agency-recommended protocols. If active nests are observed within applicable CPW-recommended species-specific buffers, CPW will be consulted and appropriate mitigation measures will be implemented as needed. |
| Storm Water/Erosion Control | Form: (02A )
403001067
12/2/2022 | Reinforced rock for culverts (RRCs) shall be utilized upstream and downstream of the culverts. Reinforced rock berms (RRBs) will also be placed intermittently along the flowline of the roadside ditches. The RRBs will be placed in the interim reclamation phase, while the RRCs will be placed during active construction, and maintained throughout interim reclamation.
The stabilized staging area shall be used for equipment storage, parking, a loading/unloading zone, portable toilets, construction trailer, waste collection, and material stockpile and storage. The stabilized staging area will essentially be the perimeter of the working surface during construction.
Where the tributary disturbed area is greater than 1 acre, a sediment basin will be planned for the well site at the low point of the pad. It will be implemented at the downstream termination of the diversion ditches. The basin will contain silt from the upstream cut and fill slopes around the drill pad. Periodic maintenance of the pond may be necessary to remove accumulated silt and debris. Sediment basins shall be installed before the site grading begins.
Where the tributary disturbed area is less than 1 acre a sediment trap will be planned for the well site at the low point of the pad. It may be implemented at the downstream termination of the diversion ditches. The trap will contain silt from the upstream fill slopes around the pad. Periodic maintenance of traps may be necessary to remove accumulated silt and debris. Sediment traps shall be installed before site grading begins.
Unlined diversion ditches will be constructed at the toe of the cut and fill slopes along the boundaries of the pad. These ditches will capture sediment laden runoff from the slopes and channel it into sediment basins and/or traps. In the fill slope application, the material excavated for the ditch shall be compacted and bermed on the downhill side for an additional layer of protection. Diversion ditches shall be installed before grading work begins on the fill slopes and as soon as the site grading is complete on the cut slopes.
Cut and fill slopes adjacent to the pad and access road swales shall be stabilized with SM. It shall be applied after grading is complete in the final phase. If the seeding and mulching application does not provide adequate stabilization for the area where slopes exceed 4:1, then more robust bmp's shall be utilized.
9" diameter sediment control logs shall be used on the downstream perimeter of the spoil and topsoil stockpiles per manufacturer specifications. Sediment control logs shall be installed in the interim phase once stockpiles have been created.
In lieu of a VTC, the contractor shall install an asphalt apron where a proposed access road intersects a paved public roadway. If the public roadway is gravel, a VTC is not necessary. VTC or asphalt apron shall be installed in the initial phase before the site grading begins.
Type-m riprap shall be installed downstream of all culverts for a width of 4 times the culvert diameter and a length of 4 times the culvert diameter. Riprap shall be installed in the interim phase, following culvert or outfall installation.
Steep slopes shall be protected with straw coconut blankets where indicated on the SWMP plan or where seeding and mulching application is not effective. Blanket shall be installed with seeding during the final phase. |
| Material Handling and Spill Prevention | Form: (02A )
403001067
12/2/2022 | 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.
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.
Inspections of all production equipment including temporary equipment.
Routine operational checks on the facility.
Documented weekly inspections.
Audio, Visual, Olfactory (AVO) inspections in accordance with COGCC Rule 609.d. and Air Quality Control Commission Regulation 7
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.
Response to all spills and release in accordance with COGCC 900 Series Rules including timely reporting, response, and investigation. |
| Dust control | Form: (02A )
403001067
12/2/2022 | 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. |
| Noise mitigation | Form: (02A )
403001067
12/2/2022 | At the time of this NMP, Patterson Rig 345 is scheduled to be utilized for the drilling of the Prosper Farms - Property Reserve location. Rigs have been designed and equipped with sound mitigating equipment including devices to minimize squeaking from the draw works brakes. The drill phase is scheduled to last, at this time, for approximately 75 days.
A quiet frac fleet will be used during the completion phase. The frac is scheduled, at this time, to last for approximately 75 days.
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. |
| Emissions mitigation | Form: (02A )
403001067
12/2/2022 | Crestone Peak will have both oil and gas pipelines in place prior to production of the 11 additional horizontal wells.
Crestone Peak will commit to using an electric drilling rig powered by grid power.
Crestone agrees to utilize Tier IV engines (or better) during hydraulic fracturing operations. |
| Odor mitigation | Form: (02A )
403001067
12/2/2022 | Drilling rig engine exhausts are pointed straight up so as not to be directed towards any occupied buildings.
To mitigate the effects of odor from Crestone's operations, Crestone employ only International Association of Oil & Gas Producers (IOGP) Group III drilling base fluids with <0.5 weight % aromatics and will not use drilling fluids based on diesel. These Group III drilling fluids are odorless and contain no BTEX.
Drilling mud chillers are used to keep drilling fluid temperatures low. Low drilling fluid temperatures reduce the volume of fluid vaporized into the air.
All drilling fluids will be routed through a closed loop system.
No open earthen pits to store fluids or drill cuttings.
Drill piping is wiped down each time the drilling operation “trips” out of the hole.
Drill cuttings are placed in metal bins and covered to minimize odors prior to being transported to the designated waste management facilities.
During the hydraulic fracturing process, diesel-fueled equipment is placed in away that exhausts are pointed straight up to not direct exhaust towards any occupied buildings.
Tier II or Tier IV diesel engines are used during hydraulic fracturing operations where available.
During operations, tanks are sealed with a thief hatch to prevent emissions.
Emission Control Devices (Combustors) will be used to combust any flash gas from tanks.
During oil loadout operations, a Truck Loadout Vapor Recovery (TLVR) system will be used to capture and direct odorous air contaminants and emissions to a combustor. |
| Drilling/Completion Operations | Form: (02A )
403001067
12/2/2022 | 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 2-head LED flood lights mounted to the 32-foot walls and 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.
Wall Panels (e.g., visual/sound walls) will be placed along the perimeter of the WPS and will be removed following Flowback Operations.
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. |
| Interim Reclamation | Form: (02A )
403001067
12/2/2022 | - 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 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 northwest to southeast on slopes less than 8% and on contour on greater slopes.
- Hydraulically applied tackifier/Ecomatrix BFM will be applied at a rate of 1,000 lbs./ per acre to sufficiently secure straw mulch through the first growing season on slopes greater than 8%, stabilize soils and increase moisture retention, promote seed germination and establishment, and assist in erosion prevention.
- 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.
- Salvaged topsoil will be stockpiled, seeded with cover crop grasses, and the location marked or documented.
- 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.
- A landscape assessment will be conducted prior to ground disturbance to ensure that the recontoured reclamation surface matches pre-disturbance grade and topography.
- Any preexisting drainage features will be reestablished during recontouring.
- Reseeding will be completed with species consistent with the adjacent plant community.
- The selected seed mix for this location is the Loamy Plains Seed Mix.
- Crestone will consult with the surface owner regarding the planned seed mix.
- Seeding will occur throughout the interim reclamation area and long-term soil stockpiles.
- A wildlife fence will be installed to mitigate wildlife access to the interim reclamation area.
- A preexisting privacy fence will be installed around the working surface site perimeters. |