| Planning | Form: (02A ) 401687545 10/3/2018 | 603.g. Statewide equipment anchoring: Edge will anchor all equipment at drilling and production sites in geological hazard and floodplain areas to the extent necessary to resist flotation, collapse, lateral movement, or subsidence.
603.h All wells will be equipped with remote shut in capabilities accessible from Outside the floodplain in which the wellheads are located. Containment berms around all Tanks will be constructed of steel rings or another engineered technology that provides equivalent protection from floodwaters and debris. Edge is working with the county to what type of berm will best suit this location.
Edge will use water bars, and other measures to prevent erosion and non-source pollution. Implement and maintain BMPs to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, and site degradation. Co-locate gas and water gathering lines whenever feasible, and mitigate any erosion problems that arise due to the construction of any pipeline(s). |
| Drilling/Completion Operations | Form: (02A ) 401687545 10/3/2018 | Edge Energy II LLC. 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 ) 401687545 10/3/2018 | Edge Energy II, LLC. (Edge) 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) Edge 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. Edge follows manufacturer’s Standard Operating Procedures (SOPs) and will provide these SOPs upon request to the COGCC.
6) Edge will conduct daily, visual inspections of the exterior wall and general area for any integrity deficiencies before, during, and after filling the MLVTs. Edge 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.
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| Planning | Form: (04 ) 402089349 8/2/2019 | 603.g. Statewide equipment anchoring: Edge will anchor all equipment at drilling and production sites in geological hazard and floodplain areas to the extent necessary to resist flotation, collapse, lateral movement, or subsidence.
603.h All wells will be equipped with remote shut in capabilities accessible from outside the floodplain in which the wellheads are located. Containment berms around all Tanks will be constructed of steel rings or another engineered technology that provides equivalent protection from floodwaters and debris. Edge is working with the county to what type of berm will best suit this location.
Edge will use water bars, and other measures to prevent erosion and non-source pollution. Implement and maintain BMPs to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, and site degradation. Co-locate gas and water gathering lines whenever feasible, and mitigate any erosion problems that
arise due to the construction of any pipeline(s). |
| Drilling/Completion Operations | Form: (04 ) 402089349 8/2/2019 | Edge Energy II LLC. 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: (04 ) 402089349 8/2/2019 | Edge Energy II, LLC. (Edge) 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) Edge 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. Edge follows manufacturer’s Standard
Operating Procedures (SOPs) and will provide these SOPs upon request to the
COGCC.
6) Edge will conduct daily, visual inspections of the exterior wall and general area for
any integrity deficiencies before, during, and after filling the MLVTs. Edge 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 |
| Storm Water/Erosion Control | Form: (04 ) 402190139 10/7/2019 | Operator will make thorough stormwater inspections, in accordance with the requirements set forth by CDPHE Water Quality Division (WQD). The inspection schedule is as follows: while site is under construction, an inspection is required at least every 14 calendar days; post-construction, an inspection is required once a month; post-storm event inspections must be conducted within 24 hours after the end of any precipitation or snowmelt event that may cause surface erosion. Inspection records will be kept on file for a minimum of three (3) years from expiration or inactivation of permit coverage (or other). These records will be made available to regulatory agencies upon request. |
| Storm Water/Erosion Control | Form: (04 ) 402190139 10/7/2019 | Stormwater controls shall include the use of a ditch and berm system to keep potential floodwater from flowing onto the Location. An earthen berm, compacted to withstand erosional forces associated with flooding, shall be constructed around the entire pad perimeter except for access points. Drainage ditches will be constructed on all but the north side of the pad to route water around the Location. The location shall be graded and contoured to direct runoff toward a sediment trap/stormwater outfall placed strategically at the location's southeast corner, in line with the natural direction of surface flow at this Location. This sediment trap will accommodate water from the external ditch as well as catch any fluids flowing off the Location. Stormwater controls will remain in place until the pad is reclaimed. Fill sites, upon which structures will be constructed or placed, will be compacted to 95% of the maximum density obtainable with the Standard Proctor Test method or an acceptable equivalent method. |
| Material Handling and Spill Prevention | Form: (04 ) 402190139 10/7/2019 | Secondary containment shall be constructed around all tanks and separators to minimize transport of spilled liquids and provide protection from floodwaters and debris. This containment shall include a well-compacted earthen berm sized to contain 110% of the total volume of the largest tank, and will be fully lined with bentonitic clay liner to minimize any spills or releases penetrating into the soil. |
| Material Handling and Spill Prevention | Form: (04 ) 402190139 10/7/2019 | The location will be inspected daily for spills and releases. Should any spill or release occur, every reasonable step will be taken to quickly remediate the area disturbed. A post-spill report will be created documenting what happened, how the spill was remediated, and how to prevent such an instance from happening thereafter. Records will be kept indefinitely. |
| Material Handling and Spill Prevention | Form: (04 ) 402190139 10/7/2019 | Tanks shall be installed with remote tank valve shut off capabilities. |
| Material Handling and Spill Prevention | Form: (04 ) 402190139 10/7/2019 | All oil and gas production facilities including tank batteries shall be anchored to resist flotation, collapse or lateral movement. Oil and gas production facilities shall be elevated, flood proofed, or flood vented as appropriate. Typical anchoring systems include, but are not limited to, cables over the tanks that are tied to an anchor rod, bolting to a concrete pad, and/or pouring concrete into a tank to provide enough weight to prevent flotation. |
| Material Handling and Spill Prevention | Form: (04 ) 402190139 10/7/2019 | AVO (audio, visual, olfactory) inspections shall be conducted every time liquids are loaded out from storage tanks. Inspection includes ensuring proper operation and efficiency of all surface equipment; thief hatches and pressure-relief valves are closed and sealed, and emission control devices are working properly to minimize hydrocarbon venting. If any of these items are out of order, repairs will commence immediately. Additionally, Operator shall conduct and document a monthly LDAR inspection. Leaks shall be documented and repaired immediately; faulty equipment shall be repaired or replaced immediately or as soon as replacement equipment is available. |
| Wildlife | Form: (04 ) 403258793 12/13/2022 | If Drilling and Completions operations must occur between December 1 and April 30, Operator agrees to work daylight hours, beginning 2 hours after sunrise and concluding 2 hours before sunset. |
| Wildlife | Form: (04 ) 403258793 12/13/2022 | Well is in a CPW mapped Mule Deer Severe Winter Range High Priority Habitat. Although drilling and completions operations will be allowed, the Operator is strongly encouraged to avoid them between December 1 and April 30. |