| Planning | Form: (02A )
402147964
1/23/2020 | Visual mitigation will include the use of low profile tanks (maximum height of 16 feet). Upon completion of interim reclamation, Operator will install an opaque, visual mitigation lansdcape wall constructed to a height of 8 feet. |
| Material Handling and Spill Prevention | Form: (02A )
402147964
1/23/2020 | 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.
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| Material Handling and Spill Prevention | Form: (02A )
402147964
1/23/2020 | Operator will install Liquid Level High Kills to prevent liquids from exiting a given vessel via a gas stream due to improper equipment for the process medium in the pipe.
Operator will set the Pressure High kills to shut-down the site at approximately 80% of max allowable working pressure of each vessel, which shuts down the site before PSVs relieve to the atmosphere.
Operator will use pressure low site shut-downs to prevent gas or vapor spills and prevent liquid spills.
Along with automated shut-downs we have preventative maintenance and best practices in place to prevent leaks from vessels. These include:
• Yearly shut-downs and visual inspections of each 2-phase and 3-phase vessel on site
• Yearly NDT (Non-Destructive Testing) of each 2-Phase and 3-Phase vessel shell and head on site
o Vessels that fail this test are removed from service
• Conservative corrosion allowances
• Internal coating to prevent corrosion
• Semi-Annual PSV testing
• Weekly environmental checks by operations personnel (weekly at a minimum, usually every 1-2 days per site)
• NDT of all water piping to prevent leaks due to corrosion
• NDT spot checking of various flowlines to monitor for thin walled piping due to erosion or corrosion
• Yearly test of all devices that shut down the facility (including the 4 shut-down devices listed above)
• The above best management practices are similar to those utilized by PSM facilities |
| Material Handling and Spill Prevention | Form: (02A )
402147964
1/23/2020 | A containment system capable of containing one and one-half times (150%) the capacity of the largest vessel, plus sufficient freeboard to prevent overflow will be constructed around all permanent tanks at the Location. The containment system will be constructed of a steel-rim berm and lined with a synthetic or engineered liner, mechanically connected to the steel-rim which will surround all primary containment vessels. When used, temporary vessels will have secondary containment constructed from lined earthen berms or pre-engineered, duck-pond style containment systems. All berms and containment devices will be inspected quarterly. |
| Dust control | Form: (02A )
402147964
1/23/2020 | Disturbed soil will be wetted using fresh water and/or tackifers. Construction operations will not occur during windy weather conditions. The Location will be downsized with disturbed areas reclaimed, re-seeded, and vegetated and the active footprint of the pad will be compacted and covered with gravel to prevent dust. |
| Noise mitigation | Form: (02A )
402147964
1/23/2020 | Operator will use noise mitigation sound walls during the drilling and completion phases for the Location. |
| Emissions mitigation | Form: (02A )
402147964
1/23/2020 | 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. |
| Emissions mitigation | Form: (02A )
402147964
1/23/2020 | 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. |
| Odor mitigation | Form: (02A )
402147964
1/23/2020 | Odor: Closed loop systems will be used. Operator will repsond to complaints from BU within 1,500 feet in 24-hours to mitigate odor based on specific circumstances. |
| Drilling/Completion Operations | Form: (02A )
402147964
1/23/2020 | Lighting: Operator will use lighting during Drilling/Completion phases only. All lighting will be capable of being directed inward to the Location and downcast to prevent light shining beyond the Location boundary. Permanent lighting will not be installed at the Location. |