| General Housekeeping | Form: (02A )
401077706
2/9/2017 | 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 )
401077706
2/9/2017 | BMP’s will vary according to location and will remain in place until the pad reaches final reclamation. |
| Planning | Form: (02A )
403453598
1/3/2024 | During the consultation with CDPHE conducted on November 1, 2023 the following BMPs were agreed to by the Operator:
Operator will use electric drilling rigs if available, and will demonstrate best-effort if unable to utilize them
Operator will use Tier IV or equivalent engines, such as NG Tier II w/ battery assist, (or better) for hydraulic fracturing
Operator will use electric equipment and devices (e.g. vapor recovery units or VRUs, fans, etc.) to minimize combustion sources on site (if yes, operator will provide a list outlining which equipment and devices will be electrified)
Operator will use pipelines to transport water used for hydraulic fracturing to location
Operator will have adequate and committed pipeline take away capacity for all produced gas and oil
Operator will shut in the facility to reduce the need for flaring if the pipeline is unavailable
Operator will use lease automatic custody transfer (LACT) system to remove/reduce the need for truck loadout
Operator will cover trucks transporting drill cuttings
Ozone mitigation on forecasted high ozone days: operator will reduce truck traffic and worker traffic
Secondary containment: Operator will install perimeter controls to control potential sediment-laden runoff in the event of spill or release from Modular Large Volume Storage Tank
Operator will not use fracturing fluids which contain PFAS compounds
Operator will contribute to nearby fire district(s) to support transition away from
PFAS-containing foam through funding, buy-back program participation/promotion, etc.
If PFAS-containing foam is used at a location: operator will properly characterize the site to determine the level, nature and extent of contamination
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| Traffic control | Form: (02A )
403453598
1/3/2024 |
Transportation BMPs
Operator will utilize lay-flat water pipeline to source water for completion operations to reduce traffic associated with pre-production operations.
Operator will utilize an oil pipeline to transport oil from the location to reduce traffic associated with permanent production operations.
Operator will restrict all non-essential site trips during the commuter hours of 7:00 a.m. to 9:00 a.m. and 4:00 p.m. to 6:00 p.m.
Operator will develop a plan to warn motorists of heavy truck traffic during construction of the site.
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| General Housekeeping | Form: (02A )
403453598
1/3/2024 | Waste Management BMPs
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. See attached list of waste disposal facilities that Operator has active waste disposal profiles with. 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.
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.
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.
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.
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.
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 CECMC 900-Series Rules.
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.
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| General Housekeeping | Form: (02A )
403453598
1/3/2024 | Light BMPs
Nuisance: since the drilling and completions phases occur 24-hours per day, lighting is required by regulation for worker safety during nighttime hours; illuminating the location may cast halos or shadows that are perceptible from a distance; headlights on vehicles may also be visible during the overnight hours when vehicles enter/exit location.
Mitigation: lights will be angled in a downward manner to limit the ‘halo effect’ from impacting nearby receptors; only those lights necessary to maintain a safe working environment, and compliance with the applicable regulations, will be used. |
| Wildlife | Form: (02A )
403453598
1/3/2024 | Wildlife BMPs
If a trench is left open for more than 5 consecutive days during pipeline construction, Crestone will install wildlife escape ramps at a minimum of one ramp per ¼ mile of trench.
If construction or other earth-moving activities will begin within the recognized migratory bird breeding season between April 1 and August 31, migratory bird nesting surveys will be conducted prior to the start of construction. Should any nests be identified at that time, Crestone will provide work zone buffers around active nests.
Flowlines and utilities associated with the Site will not cross any perennial streams identified as aquatic High Priority Habitat.
The Site will not include Drilling Pits, Production Pits, or other Pits associated with Oil and Gas Operations.
If construction begins between February 1 and July 31, additional raptor nesting surveys are recommended. If active raptor nests are observed within CPW’s recommended species-specific buffers, consultation with CPW is recommended to determine appropriate mitigation measures.
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| Storm Water/Erosion Control | Form: (02A )
403453598
1/3/2024 | Topsoil BMPs
Topsoil will be stockpiled along the eastern edge and northern center of the proposed pad. In order to mitigate topsoil loss and migration of soil offsite, the stockpile will undergo surface roughening, seeding, and mulching.
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.
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.
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.
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| Storm Water/Erosion Control | Form: (02A )
403453598
1/3/2024 | Stormwater BMPs
Berms will be placed on the along the west and northwest corner, around the sediment basin to the north and the northeast edges along the top of pad fill sections. Berms and ditches will divert surface water to the on-pad sediment basin/detention basin. Berms will be 2’ high with 4:1 slopes and 2’ bench.
This site will have eight (8) diversion ditches. Two (2) on the northwest of the site, diverting water northeast into the sediment basin. They will be removed during the production phase. One (1) on the west of the site, diverting water north and east into the sediment basin. One of them will be constructed during the construction phase and the other during the production phase. Two (2) on the south and east of the site, diverting water north into the existing sediment basin. One (1) on the east side of the site, diverting water north into the sediment basin which will be removed during the production phase. During the production phase one (1) will be constructed to the north of the site, diverting water northeast to southeast into the detention basin.
This site will have one (1) sediment basin and one (1) detention basin. The Sediment Basin will be constructed during the preproduction phase to the north of the site and be removed for the production phase. The Detention Basin will be constructed during the production phase to the east of the site.
This site will have two (2) rip-raps. One is located at the sediment basin to the north during preproduction phase, and one is located at the detention basin to the east during the production phase.
Seeding and mulching will be done on the topsoil pile to the north of the pad, and on the pad cut and fill slopes along the perimeter of the pad.
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| Material Handling and Spill Prevention | Form: (02A )
403453598
1/3/2024 | Fluid Leak Detection BMPs
During drilling, completion, and production operations, regular Auditory, Visual, and Olfactory Monitoring (AVO) inspections are performed on equipment containing hydrocarbons, fluids, or associated chemicals. AVO inspections include taking the time to look, smell and listen for leaks.
Operator utilizes a polyethylene liner beneath the drilling rig during drilling operations and beneath the areas where completions equipment (including pump trucks and other heavy equipment) during completion operations to ensure there is an impermeable layer between the rig and the earth. The use of this liner prevents hydrocarbons and other fluids from reaching the soil in the unlikely event a leak does occur. The liner is inspected for integrity throughout drilling operations and maintenance/repair to the liner occurs as needed.
Routine SPCC inspections will be conducted and documented pursuant U.S. EPA requirements. The location will be equipped with a SCADA system that allows for remote monitoring and shut-in capabilities.
Operator has developed a robust Leak Detection and Repair (LDAR) program, which utilizes Forward Looking Infrared (FLIR®) cameras to identify and fix leaks. These inspections will begin during the drilling phase and continue throughout the life of the Oil & Gas Location.
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| Dust control | Form: (02A )
403453598
1/3/2024 | Dust suppression during initial construction will be accomplished by the application of freshwater to the access road(s) and exposed earthen surfaces to reduce the transportability of dust when atmospheric conditions are conducive to sustained winds and/or periodic gusts. All dust suppression efforts will consist of only freshwater unless otherwise requested and approved as applicable.
To minimize sand-related dust emissions, the Operator will be utilizing containerized box technology for sand transport, storage and use during the completions phase. These sand containers (or “sand boxes”) are sealed containers that protect the sand from exposure to wind and prevent dust generation.
Operator will post an access road speed limit not to exceed 20 miles per hour to minimize fugitive dust emissions from vehicle traffic traveling on the access road.
Operator will perform regular inspections and road maintenance to ensure the integrity of the access road and associated features is maintained throughout the life of this project. Maintenance consists of re-compacting the road base/recycled asphalt mix on an as-needed basis.
Operator will install and maintain vehicle tracking controls (i.e., coarse aggregate, a tracking pad, paved apron, or cattle guard) to further reduce and remove loose mud and dirt on construction equipment and vehicles servicing location. |
| Noise mitigation | Form: (02A )
403453598
1/3/2024 | Noise BMPs
Nuisance: relative to ambient levels, temporary increases in sound levels are expected during drilling and completion operations.
Mitigation: Crestone planned the pad so that it is greater than 3857’ from the nearest residential building unit. Additionally, Crestone will utilize a quiet completions fleet. |
| Odor mitigation | Form: (02A )
403453598
1/3/2024 | 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.
6. Operator will utilize compressed air pneumatics.
7. Operator will utilize a pressurized maintenance vessel system which minimizes the need for venting during maintenance operations.
8. Operator will energize the proposed facility with utility power reducing odors associated with internal combustion engines. |
| Drilling/Completion Operations | Form: (02A )
403453598
1/3/2024 | Light Mitigation
1. Drilling operations will take place 7-days a week & 24-hour a day. Care will be taken to keep lighting levels at the specified levels while providing safe, well-lit working areas during night-time and other low-light conditions.
2. 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.
3. No permanent lighting is proposed for this project and temporary 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).
4. No direct light shall shine beyond the boundaries of the Working Pad Surface (WPS), especially onto public roads, adjacent properties, and/or high priority habitats. All lighting shall conform with all ECMC, county, municipal, and any applicable
governing body’s standards.
5. All lighting will be capable of adjustment and will be directed inward and between 45-65° downward towards working areas on the WPS.
6. 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.
7. For workplace safety, no direct or reflected direct light shall shine towards the entrance of the WPS.
8. Any lighting damaged and/or improperly directed or angled will be promptly fixed and/or replaced.
9. 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. |
| Interim Reclamation | Form: (02A )
403453598
1/3/2024 |
Interim Reclamation BMPs
During the preproduction phase the berms will be constructed on the northwest side, to the north around the sediment basin, and northeast side. These will be removed during the production phase. During the preproduction phase the berms will consist of 2’ high with a 4:1 ratio side slope and a 2’ bench. Berm will be constructed from subsoil.
Following interim reclamation, the site will have one (1) detention basin, which will be constructed during the production phase on the east side of the pad where the existing sediment basin is located. Bottom dimensions consisting of 90’ x 135’, depth 4.4’, with a spillway, outlet culvert, rip-rap, and trickle channel.
Five (5) diversion ditches. Two (2) on the southwest of the site, diverting water northeast into the sediment basin. One of them will be constructed during the preproduction phase and the other during the production phase. Two (2) on the southeast of the site, diverting water northeast into the existing sediment basin.
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 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.
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.
Reseeding will be completed with species consistent with the adjacent plant community. The proposed seed mix for this location is the western wheatgrass. 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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