| Planning | Form: (02A )
401218498
5/18/2017 | 604c.(2).E. Multiwell Pads: This 2A application is for a 9-well pad. After working with the Surface Owner on multiple designs we decided to combine all operations to avoid any future negative impact for surrounding BU owners. The surface owners also advised that our final location would work best with regards to their future plans for a storage facility on the W2 of their property.
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| Planning | Form: (02A )
401218498
5/18/2017 | 604c.(2).V. Development From Existing Well Pads: An existing pad was not available to utilize to develop these wells.
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| Traffic control | Form: (02A )
401218498
5/18/2017 | 604c.(2).D. Traffic Plan: A traffic plan is not required by the Local Government.
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| General Housekeeping | Form: (02A )
401218498
5/18/2017 | 604c.(2).N. Control of Fire Hazards: PDC will ensure that any material that might be deemed a fire hazard will be will remain no less than twenty-five (25) feet from the wellhead(s), tanks and separator(s). PDC installs automation equipment for tank level and pressure monitoring inside the bermed area that complies with API RP 500 classifications and with the current national electrical code as adopted by the State of Colorado.
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| General Housekeeping | Form: (02A )
401218498
5/18/2017 | 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.
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| Storm Water/Erosion Control | Form: (02A )
401218498
5/18/2017 | 604c.(2).F. Leak Detection Plan: See attached.
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| Storm Water/Erosion Control | Form: (02A )
401218498
5/18/2017 | This Stormwater Management Plan contains required elements associated with PDC’s construction activities, as defined in the CDPS General Permit for Stormwater Discharges Associated with Construction Activity, Authorization to Discharge Under the Colorado Discharge Permit System (Permit No. COR-030000, re-issued and effective July 1, 2007).BMPs for sediment and erosion control will be accomplished through a combination of construction techniques, vegetation and re-vegetation, administrative controls, and structural features.
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| Dust control | Form: (02A )
401218498
5/18/2017 | 805.b(1)-(c) Odors and Dust: Oil and gas facilities and equipment (temporary and permanent) will operate in a manner that odors and dust do not constitute a nuisance or hazard to public welfare. Odors: Oil and gas operations will be in compliance with the Department of Public Health and Environment, Air Quality Control Commission, Regulation No. 2 Odor Emission, 5 C.C.R. 1001-4, Regulation No. 3 (5 C.C.R. 1001-5), and Regulation No. 7 Section XVII.B.1 (a-c) and Section XII.
Dust; PDC will employ practices for control of fugitive dust caused by operations, these include but are not limited to the use of speed restrictions, regular road maintenance, restriction of construction activity during high-wind days, and silica dust controls when handling sand used in hydraulic fracturing operations. When necessary, PDC coordinates dust mitigation with the county on gravel roads, places road base where allowed by surface owner around tanks and wellheads to minimize dust, and will water the roads and locations when dry. In addition, automation is used on all new wells to minimize truck traffic. During winter operations normal dust abatement is not provided unless requested by surrounding land owners. Fugitive dust control will be incorporated as needed during all other months of drilling and completion operations. |
| Construction | Form: (02A )
401218498
5/18/2017 | 604c.(2).G. Berm Construction for Temporary and Permanent Equipment: Containment berms shall be constructed of steel rings with a geosynthetic liner, designed and installed to prevent leakage and resist degradation from erosion or routine operation. Secondary containment devices shall be sufficiently impervious to contain any spilled or released material. Secondary containment at the production facility is typically inspected by PDC personnel on a daily basis. Production facilities are also inspected by a third party consultant on a 14 day or 30 day schedule as per Colorado Discharge Permit System (CDPS) General Permit requirements for Stormwater Discharges Associated with Construction Activity until the site has been sufficiently vegetated or stabilized. These sites may also be inspected by a third party consultant on a quarterly, semi-annual or annual frequency as part of the Post-Construction Stormwater Management Plan in accordance with COGCC Rule 1002.f. Additionally, tank batteries are inspected by a third party consultant on an annual basis for Spill Prevention, Control and Countermeasure (SPCC) Plan compliance. Any deficiencies are relayed to appropriate PDC staff and a work order is generated to schedule necessary repairs.
Due to a downgradient surface water body within 500’, tertiary containment (such as an earthen berm or the like), will be installed around Production Facilities. |
| Construction | Form: (02A )
401218498
5/18/2017 | 604c.(2).S. Access Roads: PDC will utilize an improved lease access road off of County Road 47 (paved) for all heavy truck traffic and rig moves along with drilling operations and maintenance equipment. The lease access road will be properly constructed and maintained to accommodate for local emergency vehicle access. Dust will be mitigated as necessary on lease access road. PDC will employ practices for control of fugitive dust caused by operations, these include but are not limited to the use of speed restrictions and regular road maintenance. |
| Construction | Form: (02A )
401218498
5/18/2017 | 604.c.(2).W. Site Specific Measures: Lights should be turned downward and away from building units within the 1,000 foot buffer area. Dust mitigation will be provided as necessary on lease access roads.
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| Construction | Form: (02A )
401218498
5/18/2017 | 804. Visual Impact: Production facilities, regardless of construction date, which are observable from any public highway will be painted with uniform, non-contrasting, non-reflective color tones (similar to the Munsell Soil Color Coding System), and with colors matched to but slightly darker than the surrounding landscape.
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| Construction | Form: (02A )
401218498
5/18/2017 | 604c.(2).M. Fencing Requirements: The completed wellsites will be surrounded with a fence and gate. PDC personnel will monitor the wellsites regularly upon completion of the wells. Authorized representatives and/or PDC personnel shall be on-site during drilling and completion operations.
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| Construction | Form: (02A )
401218498
5/18/2017 | 604c.(2).Q. Guy Line Anchors: Rig guy wires are anchored to the rig’s base beam that the rig stands on, temporary and permanent anchors will not be set on this location.
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| Construction | Form: (02A )
401218498
5/18/2017 | 604c.(2).R. Tank Specifications: Condensate storage tanks will be designed, constructed and maintained in accordance with National Fire Protection Association (NFPA) Code 30 (2008 version). PDC will maintain written records to verify proper design, construction and maintenance. All records will be available for inspection by the Director.
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| Construction | Form: (02A )
401218498
5/18/2017 | To prevent adverse impacts to shallow groundwater, buried produced water vault shall be installed above an impermeable synthetic or geosynthetic liner system which shall be tied back into the surface liner.
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| Construction | Form: (02A )
401218498
5/18/2017 | PDC Energy, Inc. (PDC) has developed Best Management Practices (BMPS) to prevent injuries, property damage or environmental impacts and a Contingency Plan for any Modular Large Volume Tank (MLVT) leak or catastrophic failure of the tank integrity and resulting loss of fluid. These BMPs include, but not limited, by the following:
1) PDC determines MLVT locations based on size of location, nearby surface waters, site visibility, surrounding land use, property lines, onsite traffic, site security, tear-away tank fill connections, topography (high, low, slope, direction), nearby building units, roads, access points, and surface owner requests.
2) Signs shall be posted on each MLVT to indicate that the contents are fresh water and that no E&P waste fluids are allowed. Location and additional signage shall conform to Rule 210.
3) MLVTs will be operated with a minimum of 1 foot freeboard at all times.
4) Access to the tanks shall be limited to operational personnel.
5) Construction and installation of the tank structure, liner and sub-grade shall meet or exceed the manufacturer specifications. PDC follows manufacturer’s Standard Operating Procedures (SOPs) and will provide these SOPs upon request to the COGCC.
6) PDC will conduct daily, visual inspections of the exterior wall and general area for any integrity deficiencies before, during, and after filling the MLVTs. PDC uses Construction Sign-Off, Site Preparation Sign-Off, Completion Sign-Off, Pre-Fill, and Site Visit checklists to maintain a written record of inspections. However, when the fluid level in the MLVTs is less than two (2) feet and there is no activity going on (i.e. during holidays or a small break between completions), only intermittent inspections will be conducted. Two feet is the safe volume of fluid level that is needed to hold the liner down and keep the MLVT stable.
7) Each location where MLVT’s are used will have its own set of unique site-specific characteristics and associated risks (e.g., rural vs. urban setting, grade of the location, etc.) to be considered in a worst case scenario. These characteristics must be identified and addressed prior to the MLVT construction phase and should be documented in the MLVT construction checklist. Ensuring the safety of our employees, contractors, and the public are a top priority. This can be addressed with the implementation of MLVT pre-construction risk assessment measures to address safety concerns, and minimize environmental impacts and property damage in the unlikely event of a MLVT release.
8) In the event of a catastrophic MLVT failure, the Operator shall notify the COGCC as soon as practicable but not more than 24 hours after discovery, submit a Form 22-Accident Report within 10 days after discovery, conduct a “root cause analysis”, and provide same to COGCC on a Form 4-Sundry Notice within 30 days of the failure.
9) The MLVT shall be constructed and operated in accordance with a design package certified and sealed by a Licensed Professional Engineer either in Colorado or the state where the MLVT was designed or manufactured.
10) COGCC Rules 605.a.(3,5,6,7, and 8), as applicable to tank setbacks at the time of installation shall apply to the siting of this MLVT.
11) All MLVT liner seams shall be welded and tested in accordance with applicable ASTM international standards. Any repairs to liners shall be made using acceptable practices and applicable standards.
12) PDC Energy Inc. hereby certifies to the Director that the Modular Large Volume Tanks, utilized for the afore mentioned location, will be designed and implemented consistent with the Colorado Oil and Gas Conservation Commission policy dated June 13, 2014.
MLVT Certification
PDC Energy Inc. hereby certifies to the Director that the Modular Large Volume Tanks, utilized for the afore mentioned location, will be designed and implemented consistent with the Colorado Oil and Gas Conservation Commission policy dated June 13, 2014.
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| Noise mitigation | Form: (02A )
401218498
5/18/2017 | 604c.(2).A. Noise: WELL PAD: PDC has conducted baseline noise surveys for all drilling rigs that are being contracted and has also conducted a baseline noise survey for hydraulic fracture stimulation operations on a representative horizontal well. These baseline surveys are utilized for site specific noise modeling to determine if any mitigation measures are warranted. A review was conducted to identify potential receptors within 1000 feet of the proposed pad site. There are three (3) building units of concern located SW, NE, S. Light and sound mitigation will be installed to the north, east and south of the proposed location. Methods of noise mitigation shall include but not be limited to hay bales, sound walls, or customized semi-trailers. PRODUCTION FACILITIES: It is not anticipated that noise mitigation will be necessary at the proposed tank battery location. After construction is completed, equipment installed and production begins, noise levels will be assessed to determine if mitigation measures will be required to be compliant with Rule 802. |
| Emissions mitigation | Form: (02A )
401218498
5/18/2017 | 604c.(2).C. Green Completions: Flowlines, 48” HLPs, sand traps all capable of supporting green completions as described in rule 805 shall be installed at any Oil and Gas location at which commercial quantities of gas and or oil are reasonable expected to be produced based on existing wells. All green flow back equipment will be able to handle more than 1.5 times the amount of any know volumes in the surrounding field. First sign of salable gas will be put into production equipment and turned down line.
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| Drilling/Completion Operations | Form: (02A )
401218498
5/18/2017 | 604c.(2).I. BOPE Testing for Drilling Operations: PDC's contractors will supply a double ram BOPE (Blinds and pipes). BOPE is always function tested and all seals and ram block rubbers are inspected. After installation of the BOPE, PDCE conducts a pressure test on the BOPE at a low pressure of (200-400 psi) and a high pressure test with a third party tester, all tests are digitally recorded and any failed equipment or seals are replaced and re-tested.
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| Drilling/Completion Operations | Form: (02A )
401218498
5/18/2017 | 604c.(2).J. BOPE for Well Servicing Operations: All valves will also be tested to maximum rating by a third party prior to being delivered to location. Whenever snubbing operations are being used the snubbing stack will be pressure tested at the same time the BOPE is being tested which consist of a single pipe ram and a annular bag.
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| Drilling/Completion Operations | Form: (02A )
401218498
5/18/2017 | 604c.(2).K. Pit Level Indicators: PDC uses an Electronic Drilling Recorder (EDR) with pit level monitor(s) and alarm(s) for production rigs. Basic level gages are used on steel pits utilized for the surface rig.
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| Drilling/Completion Operations | Form: (02A )
401218498
5/18/2017 | 604c.(2).L. Drill Stem Tests: PDC does not conduct drill stem tests, but will seek prior approval from the director if a drill stem test will be preformed.
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| Drilling/Completion Operations | Form: (02A )
401218498
5/18/2017 | 604c.(2).O. Loadlines: All loadlines shall be bullplugged or capped.
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| Drilling/Completion Operations | Form: (02A )
401218498
5/18/2017 | 604c.(2).T. 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.
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