| Planning | Form: (02A )
401331839
12/20/2018 | Multi-well Pads - Rule 604.c.(2)E.
This is a multi-well pad. GWOC utilizes multi-well pads wherever technically and economically practicable to minimize potential impacts to neighbors and the environment. The pad has all weather access roads to allow for operator and emergency response.
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| Planning | Form: (02A )
401331839
12/20/2018 | Berm Construction - Rule 604.c.(2)G.
A minimum containment capacity of 150% of the single largest storage vessel inside the containment will be constructed around any liquids storage area within a designated setback zone. For this location, steel containment with sealed liners will be utilized at all storage facilities on this location.
Tanks and all visible pipelines and valves etc. will be inspected informally on a daily basis by company lease operators. In addition, GWOC also conducts formal annual SPCC inspections, and formal site specific and random audits, by third-party consultants to inspect for general site conditions as well as condition of tanks, pipelines, and containment structures.
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| Planning | Form: (02A )
401331839
12/20/2018 | Fencing requirements - Rule 604.c.(2)M
At a minimum GWOC installs appropriate fencing to restrict access by any unauthorized persons. This fencing may vary depending on site-specific situations, such as reasonable security, local government or surface owner concerns. Fencing will be properly noted on facility layout diagrams for both drilling/completion and the production phases of operations.
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| Planning | Form: (02A )
401331839
12/20/2018 | Control of Fire Hazards - Rule 604.c.(2)N
GWOC constructs and operates our facilities to meet state and API codes, as appropriate, including API RP 500 electrical classifications inside bermed areas. Any unused potentially flammable materials are moved a minimum distance of 25-feet from wellhead, tanks, and separator areas. In addition, GWOC implements a Hot Work Permit Program for employees and contractors doing any defined ‘Hot Work’ activities on GWOC locations.
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| Planning | Form: (02A )
401331839
12/20/2018 | Load lines - Rule 604.c.(2)O
In any designated setback zone all load lines are capped or bull-plugged or locked shut to reduce the likelihood of a release occurring. In addition, GWOC places all load line receivers/valves inside secondary containment areas or in a proper load line containment device or both.
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| Planning | Form: (02A )
401331839
12/20/2018 | Identification of P&A wells - Rule 604.c.(2)U
GWOC shall identify the location of the P&A wellbore with a permanent monument as specified in Rule 319.a.(5). The operator shall also inscribe or imbed the well number and date of plugging upon the permanent monument. P&A wellbores shall be cutoff well below ground surface in agricultural areas to provide for landowners to safely farm the reclaimed well area.
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| Planning | Form: (02A )
401331839
12/20/2018 | Development from existing well pads - Rule 604.c.(2)V
GWOC shall provide for the development of multiple reservoirs by drilling on existing pads. GWOC strives to utilize multi-well pads wherever technically and economically practical to minimize potential impacts to neighbors and the environment. Multi-well pads are not always feasible due to numerous possible issues including but not limited to: landowner requirements, topographic constraints, wellbore reaches, setback requirements, etc.
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| Traffic control | Form: (02A )
401331839
12/20/2018 | Traffic Plan - Rule 604.c.(2)D.
An access route from the highway or county road to the proposed oil and gas location has been prearranged. Required access road permits will be obtained before construction begins and any special requirements outlined by the municipality will be followed. Emergency routes will be chosen prior to the commencement of operations and will be clearly marked and maintained throughout drilling, completion and production activities.
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| General Housekeeping | Form: (02A )
401331839
12/20/2018 | General Housekeeping:
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 cleanup will be implemented within 24-48 hours, as appropriate, to minimize any commingling of waste materials with storm water 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 will consist of patrolling the roadways, 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.
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| General Housekeeping | Form: (02A )
401331839
12/20/2018 | Removal of Surface Trash - Rule 604.c.(2)P
All surface debris, trash, unusable scrap, or solid waste from the facility will be properly temporarily stored on location in a secure container and ultimately removed and disposed of in a legal manner.
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| Storm Water/Erosion Control | Form: (02A )
401331839
12/20/2018 | Storm Water Management Plans (SWMP)
Storm water controls will be constructed around the perimeter of the site prior to construction. Typically, GWOC utilizes a ditch and berm system of storm water control at its sites. BMP’s used are determined just prior to construction by a third party storm water contractor and may vary according to the location. Storm water controls will remain in place until the pad is stabilized or reaches final reclamation. |
| Material Handling and Spill Prevention | Form: (02A )
401331839
12/20/2018 | MLVT Certification Statement:
Great Western Operating Company certifies that the MLVTs on this location will be designed and implemented consistent with the COGCC Policy on the use of MLVTs in the state of Colorado.
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| Material Handling and Spill Prevention | Form: (02A )
401331839
12/20/2018 | Material Handling and Spill Prevention
Spill Prevention Control and Countermeasures (SPCC) plans in place to address any possible spills associated with Oil and Gas operations throughout the state of Colorado in accordance with CFR 112.
In accordance with COGCC Rule 1002.f.(2)A. & B., shall provide a designated storage area for dry bulk chemicals and miscellaneous fluids. The dry chemicals in the storage area shall be adequately protected to prevent contact with precipitation, shall be elevated above storm- or standing water, and shall provide sufficient containment for liquid chemical storage to prevent release of spilled fluids from impacting soil, surface water or groundwater and will prevent the co-mingling of spilled fluids or chemicals with other E&P Waste.
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| Material Handling and Spill Prevention | Form: (02A )
401331839
12/20/2018 | Leak Detection Plan - Rule 604.c.(2)F.
GWOC designs its new facilities to both avoid leaks or releases as well as to help detect them in a time-efficient manner to minimize potential impacts. Tanks and all visible pipelines and valves etc. are inspected informally on a daily basis by company lease operators. In addition, GWOC also conducts formal annual SPCC inspections, and formal site specific and random audits, by third-party consultants to inspect for general site conditions as well as condition of tanks, pipelines, and containment structures. In addition, our company lease operators and Production staff review production records, including volumes and pressures, looking for irregularities that may indicate a problem with a tank or pipeline. If an irregularity is detected that may indicate a potential release the suspect tank and/or pipeline(s) are removed from service, isolated, and either pressure tested or visibly inspected for indications of a potential leak.
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| Material Handling and Spill Prevention | Form: (02A )
401331839
12/20/2018 | Pit level indicators - Rule 604.c.(2)K
GWOC does not typically utilize pits in any of its operations. No pits will be used for this facility.
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| Material Handling and Spill Prevention | Form: (02A )
401331839
12/20/2018 | Tank specifications - Rule 604.c.(2)R
All newly installed or replaced crude oil and condensate storage tanks shall be designed, constructed, and maintained in accordance with National Fire Protection Association (NFPA) Code 30 (2008 version). GWOC shall maintain written records verifying proper design, construction, and maintenance, and shall make these records available for inspection by the Director. Only the 2008 version of NFPA Code 30 applies to this rule.
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| Dust control | Form: (02A )
401331839
12/20/2018 | Dust Control
Dust control measures may include surface stabilization, or dust control with appropriate chemical or later applications.
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| Construction | Form: (02A )
401331839
12/20/2018 | Access Roads - Rule 604.c.(2)S
All access roads are designed, constructed, and maintained such that heavy equipment, including emergency response vehicles, can readily access and exit the location. The pad has all weather access roads to allow for operator and emergency response. In addition, GWOC will implement manual mud mitigation measures (eg. tracking control rock aprons) at location exits onto paved roads as necessary and in conjunction with county requirements.
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| Construction | Form: (02A )
401331839
12/20/2018 | Well site cleared - Rule 604.c.(2)T
Within ninety (90) days after a well is plugged and abandoned, the well site shall be cleared of all non-essential equipment, trash, and debris.
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| Noise mitigation | Form: (02A )
401331839
12/20/2018 | During the drilling and completions phase, Great Western plans to construct sound/visual walls that will be placed along the edges of the pad, where applicable. This will also assist to block out any lighting from nearby occupied structures. This pad will be constructed in such a manner that noise mitigation may be installed and removed without disturbing the site or landscaping.
Light sources will be directed downwards, and away from occupied structures. Once the drilling and completion rigs leave the site, there will be no permanently installed lighting on site. |
| Noise mitigation | Form: (02A )
401331839
12/20/2018 | Noise - Rule 604.c.(2)A.
Great Western Operating Company, L.L.C. (GWOC) will operate in accordance with permissible noise levels per COGCC Rule 604.c.(2)A. and 802, as applicable. Drilling rig and completion equipment engine exhaust will be directed away from occupied buildings to assist with noise mitigation. These practices will be implanted upon initiation of drilling and production.
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| Odor mitigation | Form: (02A )
401331839
12/20/2018 | Odors Mitigation:
When practical, drilling rig and completion equipment engine exhaust will be directed away from occupied buildings to assist in mitigating potential odors. Sealed tanks with pressure relief valves and emissions controls will be utilized for the production phase. Great Western will use an invert based drilling fluid with diesel or a similar fluid for the base oil. If odor complaints are received and it is determined that they are caused by the invert drilling fluid, then Benzaco Scientific’s Odor Armor odor neutralizing agent or similar product will be added to the mud system to eliminate the odor. This product and other similar products have been used by other operators in the DJ Basin and have been successful in eliminating odor attributed to invert drilling fluids. |
| Drilling/Completion Operations | Form: (02A )
401331839
12/20/2018 | Guy line anchors - Rule 604.c.(2)Q
Guy line anchors left buried for future use shall be identified by a brightly colored marker at least 4-feet in height and within 1-foot to the east of the anchor.
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| Drilling/Completion Operations | Form: (02A )
401331839
12/20/2018 | Green Completions (Rule 604.c.(2)C.
As applicable, per COGCC Rule 805, GWOC will utilize all reasonable and costefficient best practices, including but not limited to those listed in Rule 805, to maximize resource recovery and mitigate releases to the environment. • Initial frac and drillout effluent is routed through a sand catcher/trap and a junk/sand tank to remove sand and well frac debris. • Once any hydrocarbons are detected but prior to encountering salable quality combustible gas or significant volumes of liquid hydrocarbons (condensate or oil) (greater than 10 barrels per day average) the effluent is routed through a highpressure separator and closed-top tanks to minimize emissions to the environment. Hydrocarbon liquids, produced water, and sand are separated utilizing the highpressure separator. • The quality (combustibility) of the gas is typically monitored directly at the highpressure separator. When salable (combustible) quality gas is measured/detected the gas stream is immediately diverted to the sales pipeline or the well is shut in or a from 42 for flaring will be submitted for approval. • The separated produced water and hydrocarbon liquids (condensate/oil) are directed to specific tanks for storage until being unloaded and hauled to disposal or sales as appropriate. |
| Drilling/Completion Operations | Form: (02A )
401331839
12/20/2018 | Operator shall comply with the following reqyuirements of Order 1-189: Brighton PWS Buffer Zone.
(1) Pitless drilling systems;
(2) Flowback and stimulation fluids shall be contained within tanks that are placed on a well pad or in an area with downgradient perimeter berming;
(3) Berms or other containment devices shall be constructed around crude oil, condensate, and produced water storage tanks as follows:
a. Secondary containment shall be sized to contain a minimum of 150% of the volume of the largest primary containment vessel within the secondary containment area.
b. Containment berms shall be constructed of steel rings, designed and installed to prevent leakage and resist degradation from erosion or routine operation.
c. Secondary containment areas for tanks shall be constructed with a synthetic or engineered liner that contains all primary containment vessels and flowlines and is mechanically connected to the steel ring to prevent leakage.
d. Tertiary containment, such as an earthen site berm, is required around the downgradient and side-gradient portions of Production Facilities, including process vessels.
(4) Production Facilities will be installed with automated fluid level monitoring, capable of alerting the Operator if a sudden change in fluid level or upset condition occurs. Additionally, wells will be equipped with remote shut-in capability.
(5) All loadlines shall be bullplugged or capped.
(6) Notification to the Brighton Public Works Department prior to commencement of new surface disturbing activities at the site; and
(7) An emergency spill response program that includes employee training, safety, and maintenance provisions and current contact information for Brighton. The emergency response plan shall specify when notifications to Brighton shall be made and must be prepared in consultation with Brighton.
In the event of a spill or release, the Operator shall immediately implement the emergency response procedures in the above-described emergency response program.
If a spill or release results in significant adverse impacts or threatens such impacts to a portion of the Brighton PWS, the Operator shall notify Brighton immediately following discovery of the release in addition to reporting in accordance with Rule 906.b. |