| General Housekeeping | Form: (02A )
401433917
6/9/2018 | 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 pickup trash, scrap debris, other discarded materials, and any contaminated soil. These materials will be disposed of properly. |
| Storm Water/Erosion Control | Form: (02A )
401433917
6/9/2018 | 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) 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 and maintained until the pad reaches final reclamation. |
| Dust control | Form: (02A )
401433917
6/9/2018 | Speed limits will be enforced. The traffic plan and route will include mitigation of impacts from temporary operation by applying water or magnesium chloride as dust suppression within 1000' of occupied residences and on lease roads as necessary in cooperation with the county. |
| Odor mitigation | Form: (02A )
401433917
6/9/2018 | D822, which relative to diesel has fewer aromatic hydrocarbons, is less flammable, and contains less BTEX will be used as the base fluid for the oil based drilling fluid. |
| Planning | Form: (02A )
402110798
9/23/2019 | OBJECTIVE CRITERIA 5.c
COGCC Rule 604.c.(2)F. Leak Detection Plan.
Material Handling and Spill Prevention:
• Noble Energy Inc. designs well heads and supporting infrastructure on the well pad to avoid releases and to be compliant with all regulations specific to leak detection and control (i.e. SPCC 40CFR112). Daily, monthly and annual inspections are performed at each well pad to confirm operational integrity and regulatory compliance. Noble will perform maintenance if it is deemed necessary through any of the scheduled inspections. Automation technology is utilized to monitor any variations in pressures and fluid gauges which could indicate a leak at the well head or flow lines to the production facility. In addition, automation provides remote shut-in capabilities in the event of an emergency.
Type: Stormwater/Erosion Control
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.’s: COR403291; COR403292; COR403293; and COR403294. BMP’s will be constructed around the perimeter of the site prior to, or at the beginning of construction. Specific BMP’s used may include stockpile stabilization, grading, sediment traps, and perimeter barriers based on final construction design and will remain in place until the pad reaches final reclamation.
Type: Material Handling and Spill Prevention
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. |
| General Housekeeping | Form: (02A )
402110798
9/23/2019 | 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 pickup trash, scrap debris, other
discarded materials, and any contaminated soil. These materials will be disposed of
properly. |
| Storm Water/Erosion Control | Form: (02A )
402110798
9/23/2019 | Grading and drainage of the well pad will be engineered with structural controls to ensure any off-pad flows to the perimeter channel and into a sediment-trap structure. |
| Dust control | Form: (02A )
402110798
9/23/2019 | Speed limits will be enforced. The traffic plan and route will include mitigation of impacts from temporary operation by applying water or magnesium chloride as dust suppression within 1000' of occupied residences and on lease roads as necessary in cooperation with the county. |
| Odor mitigation | Form: (02A )
402110798
9/23/2019 | D822, which relative to diesel has fewer aromatic hydrocarbons, is less flammable, and contains less BTEX will be used as the base fluid for the oil based drilling fluid. |
| Drilling/Completion Operations | Form: (02A )
402110798
9/23/2019 | Noble 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. |
| Drilling/Completion Operations | Form: (02A )
402110798
9/23/2019 | Noble Energy Inc. (Noble) 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) Noble determines MLVT locations based on size of location, nearby surface waters, site visibility, surrounding land use, property lines, onsite traffic, site security, tearaway 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. Noble follows manufacturer’s Standard Operating Procedures (SOPs) and will provide these SOPs upon request to the COGCC.
6) Noble will conduct daily, visual inspections of the exterior wall and general area for any integrity deficiencies before, during, and after filling the MLVTs. Noble 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. |
| Drilling/Completion Operations | Form: (02A )
402110798
9/23/2019 | Noble’s surface casing program is designed to isolate and protect DJ Basin-specific groundwater aquifers including Quaternary Alluvial groundwater, the Laramie-Fox Hill Aquifer and the Upper Pierre Aquifer, generally observed to 1500’ below ground surface. Noble’s casing program includes the drilling and installation of 9-5/8” surface casing several hundred feet below the lower-most aquifer at a typical depth of 1850’ below ground surface. The casing is cemented to surface completely isolating and protecting sensitive aquifer groundwater quality. |
| Drilling/Completion Operations | Form: (02A )
402110798
9/23/2019 | All surficial activities performed by Noble during well drilling and completion activities will be protective of the environment. Bulk liquids used during D&C activities will be containerized in appropriate sealed vessels and underlain by an impervious liner and containment berm capable of containing any spill or leak from that vessel. Valves and temporary flow lines associated with D&C activities will be inspected daily for leaks while in service. |