| General Housekeeping | Form: (02A )
401255572
7/27/2017 | 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 stormwater 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 of trash and discarded materials will be conducted at the end of each work day. Cleanup will consist of patrolling the roadway, 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. |
| Wildlife | Form: (02A )
401255572
7/27/2017 | Burrowing owl habitat suitability survey was conducted on 02/22/2017. The nearest suitable habitat in prairie dog colony observed 180' south of the Y 16-27 Pad. |
| Storm Water/Erosion Control | Form: (02A )
401255572
7/27/2017 | Stormwater management plans (SWMP) are in place to address construction, drilling and operations associated with Oil & Gas development throughout the state of Colorado in accordance with Colorado Department of Public Health and Environment (CDPHE) and General Permit No. COR-038637. BMP’s will be constructed around the perimeter of the site prior to, or at the beginning of construction. BMP’s used will vary according to the location and will remain in place until the pad reaches final reclamation. |
| Material Handling and Spill Prevention | Form: (02A )
401255572
7/27/2017 | Spill Prevention Control and Countermeasures (SPCC) plans are in place to address any possible spill associated with Oil & Gas operations throughout the state of Colorado in accordance with CFR 112. |
| Planning | Form: (04 )
403090739
9/15/2022 | Construction, Flowback, Interim Reclamation
• Operator will conduct construction, flowback, and interim reclamation activities only during daylight hours to maximize the use of natural lighting.
• On occasion, the use of additional or alternative lighting sources may be required for site security or when field conditions experience a significant alteration. If such changes occur, light measurements may be conducted at the nearest RBU(s) to ensure compliance. If it is determined that the measured light level exceeds standards, additional BMPs will be implemented to the site lighting to achieve compliance. These changes may include removing or replacing light sources, repositioning equipment on location, or installing additional sound walls.
Drilling and Completions
• Operator will minimize lighting when not needed using timers or motion sensors.
• Operator will use full cut-off lighting to minimize light pollution and obtrusive lighting.
• Operator will use lighting colors that reduce light intensity, including using neutral white lights.
• Operator will use low-glare or no-glare lighting that utilizes high-mount/narrow-beam angle settings.
• Whenever feasible, Operator will schedule regular production activities during daylight hours to maximize the use of natural lighting. the nest or temporarily disable the lighting source until nest is abandoned.
• When present, Operator will locate all light sources inside and beneath the temporary sound walls bordering the location.
• Adjusting the lighting sources to point downward and towards the interior of location. |
| Planning | Form: (04 )
403090739
9/15/2022 | 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
Vehicle fueling: Operator will refuel vehicles only on impervious surfaces and never during storm events
Vehicle fueling: Operator will ensure that a fueling contractor is present during the entire fueling process to prevent overfilling, leaks and drips from improper connections
Dust suppression: Operator will not use produced water or other process fluids for dust suppression
Liners - A minimum 30-mil poly liner will be utilized under the drilling rig, mud tanks, shakers and drill cuttings bins. During completions, most equipment associated with hydraulic fracturing will be underlain by a minimum 30-mil poly liner with drive-over foam berms. Bulk liquids used during D&C activities, including chemical injection skids, acid and chlorine tanks, and fuel tanks will be containerized in appropriate sealed vessels and underlain by an impervious liner and/or secondary containment system capable of containing any spill or leak from that vessel.
Groundwater Sampling – Operator will comply with the sampling requirements in Rules 615.c and 907.b.(9) or request exceptions to the requirements in previous Rules 318.A.f and 609.d.(3). |
| Dust control | Form: (04 )
403090739
9/15/2022 | o Maintain a current Safety Data Sheet (SDS) in their company vehicle when using a dust suppressor containing chemicals, in accordance with OSHA Standard 29 CFR 1910.1200 (Hazard Communication) as well as local and State requirements.
o Ensure watering practices are not creating additional hazards on access roads (slick roads, muddy conditions, etc.)
• All soil piles created by construction activities will be managed utilizing Hydro-mulch, straw crimping, and/or tracking methods to prevent dust from exiting location and creating a hazard during pre-production activities. Soil piles will be graded and/or seeded to prevent erosion and the generation of dust post-production.
• Operator will minimize the amount of fugitive dust using speed restrictions. All vehicles will be subject to a speed limit of 20 MPH on all lease roads to minimize dust.
• Operator will avoid the creation of fugitive dust by restricting or limiting construction activity during high wind days.
• Operator will not use any of the following fluids for dust suppression:
o Produced water
o E&P waste or hazardous waste
o Crude oil or any oil specifically designed for road maintenance
o Chemical solvents
o Process fluids
• All secondary roads created for this project (non-public roadways) will be finished with ½” – ¾” crushed stone road base.
• Based on the currently anticipated construction schedule, there is a high likelihood of continued dry conditions and the potential for high winds during construction operations. As a result, Noble will ensure that additional storage of water and water dispersing equipment, such as water cannons or water trucks, are staged at the location to be immediately available to mitigate dust related to construction. As noted elsewhere in this plan, Noble will curtail construction activities during periods of high winds.
• Silica dust from handling sand used in hydraulic fracturing operations will be mitigated by utilization of the enclosed Sand Box delivery systems. As such, no pneumatic transportation of sand will be conducted on this location. |
| Noise mitigation | Form: (04 )
403090739
9/15/2022 | Mitigation measures will be completed prior to the commencement of the noise generating activity. Temporary sound walls will be installed during daylight hours within the disturbance area, as shown on the attached location figure, along the east and south sides of the location. The sound walls will remain in place for the duration of drilling and completion activities on the site. Sound walls will be 32’ tall at a minimum and will reduce cumulative noise levels on average 7-10 decibels. Wall height may be increased if it is determined additional height is necessary to control sound. Sound walls will be constructed with sound dampening material on the sides and double layer sound dampening material may be used if needed. Sound walls will be on the east and south of the working pad surface. The sound walls will remain in place until the applicable noise sources have been removed. Additional sound barriers may also be placed around equipment, such as frac pumps or generators, as needed.
Operator will take continuous sound measurements from each noise point of compliance during pre-production activities and ongoing operations lasting longer than 24 consecutive hours such as drilling, completion, recompletion, stimulation, and well maintenance, in areas zoned residential or within 2,000 feet of a Building Unit. If compliance is not confirmed, Operator will employ additional mitigation to ensure compliance with COGCC and Weld County rules, such as exhaust mufflers, hay bales, additional sound walls, or replacement of offending noisy equipment with quieter systems.
• In order to minimize potential impact on the identified RBUs, Noble Energy has/will take the following actions:
o Notify residential building owners of upcoming work and ensure all owner concerns are met prior to and during operations.
o Ensure service providers maintain equipment properly to minimize nuisance noise. This includes equipment with moving parts or noise-reducing modifications (compressors, pumps, etc.).
o Ensuring company and service provider vehicle traffic is maintained to a minimum, especially during nighttime hours. Service providers who operate heavy equipment will be reminded to keep vehicle speed to a minimum as well as avoid unnecessary engine braking.
o Company personnel will continuously sample sound levels throughout all phases of operations, ensuring adequate noise levels are maintained. If local, state, or federal noise levels are exceeded, Operations supervision will immediately be notified, and actions will be taken to minimize noise levels, up to and including stopping work.
o Operator will employ other measures as needed, to accommodate occupants of RBUs that may be experiencing potential impacts from noise from field activities.
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| Odor mitigation | Form: (04 )
403090739
9/15/2022 | While there is a precedent for using type III drilling fluids by a few operators in the basin, Noble has employed a different technology to achieve the same odor mitigation effect for Residential Building Unit occupants. Noble’s drilling operations employs D822 fluid that is a middle run distillate, defined as a strict class II fluid with minimal traces of BTEX. When comparing the data for D822 and the EDC (environmental drilling compound) base oils from group III fluids. Of note, the D822 is comparable with 0.05vol% BTEX vs an example EDC fluid containing 0.03vol% BTEX. The difference is that there are more general aromatics in D822 than in the EDC fluids, which is why it is still designated a Group II fluid as opposed to a Group III fluid. The total volume fraction of BTEX content is minimal and comparable to a Group III fluid. This fluid is paired with an odor neutralizer to reduce the odor impact to residences near our operations. This Best Management Practice has been approved and deployed in our Wells Ranch Mini Row Development, and to date we are unaware of drilling odor complaints.
Presently, Noble Energy utilizes Benzaco’s Odor Armor in low concentrations but is actively researching, and will most likely be adapting, new additives by the time construction activities commence at this location. Should a new additive be acquired, Noble Energy will provide the SDS and other pertinent information via Sundry prior to field deployment.
At least 1 wind direction indicator shall be always clearly visible from all principal working areas so that wind direction can be easily determined to evaluate the potential migration pathways of odors.
Operator will conduct regular odor surveillance downwind at the perimeter of the property during drilling, well completion, or rework, repair, or maintenance.
All locations onsite shall be subjected to an instrument-based leak detection and repair (LDAR) inspection at least monthly during drilling and completion and quarterly during production. Volumetric Testing Involves measurement of liquid volume which must be added or removed from system to maintain constant pressure; volume changes indicate either leaks or thermal expansion/contraction of liquid.
If odors are detected from removed drill piping, production tubing or sucker rods, operator will cover or enclose, or equivalent screening from wind or heat sources while storing such equipment for removal.
To reduce odors during drilling and completion, the rig will be washed of oily debris before moving in. Operator will utilize drying shakers to minimize residual oil on cuttings prior to transport and will promptly remove cuttings during drilling operations. Cuttings will not be stored on site.
Trucks will be prohibited from idling on location when not in use to prevent to accumulation of odors from exhaust. |
| Drilling/Completion Operations | Form: (04 )
403090739
9/15/2022 | Operator acknowledges and will comply with the Colorado Oil & Gas Conservation Commission Policy on the Use of Modular Large Volume Tanks in Colorado dated June 13,2014.
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