| General Housekeeping | Form: (02A )
401959539
8/24/2019 | Light Mitigation: Light sources during all phases of operations will be directed downwards and away from occupied structures. Permanent lighting will be installed around the facility to allow both the operator and haulers to conduct safe operations at night. All lights will be directed down toward the location or shielded so no light pollution leaves the facility. Confluence will install an engineered sound wall surrounding the location during all drilling and completion operations in order to block light from the building units to the west, southwest and east. |
| Storm Water/Erosion Control | Form: (02A )
401959539
8/24/2019 | Berm Construction: A steel containment berm or structure will be erected around the oil and water storage tanks. The berm will enclose an area sufficient to contain and provide secondary containment for 150% of the largest single tank. The berm will be inspected at least every 14 calendar days while the site is under construction and within 24 hours of a precipitation event. Inspection records will be kept on file for a minimum of three (3) years These records will be made available to the regulatory agencies upon request.
Confluence will build an enhanced ditch and berm system on the north side of the pad that is both taller and wider than our normal ditch and berm to trap and direct away from surface water, any liquids that might escape our lined steel tank battery containment in the event of a spill. |
| Material Handling and Spill Prevention | Form: (02A )
401959539
8/24/2019 | Material Handling and Spill Prevention
Leak Detection Plan: Confluence DJ's lease operators conduct a daily AVO (audio, visual, olfactory) inspection of each producing location when they first arrive to pump the wells. This includes checking all surface equipment to make sure that there are no leaks, all tank thief hatches are closed, all pressure-relief valves are closed, and no emission-control devices are smoking. If they find that any of these items are out of order, they immediately work on fixing the issue.
Additionally, Confluence conducts and documents a monthly LDAR (leak detection and repair) inspection. This consists of an environmental scientist trained in surface oilfield equipment walking through each of our locations along with lease operators and an infrared camera to identify any smaller vapor leaks that may be invisible to the naked eye. These leaks are documented and usually repaired immediately onsite. Sometimes repairs take a couple days if new equipment needs to be procured to replace the faulty equipment. |
| Dust control | Form: (02A )
401959539
8/24/2019 | Dust mitigation measures shall include but are not limited to the use of speed restrictions, regular road maintenance, restrictions of construction activities during high wind days, and silica dust controls when handling sand used in hydraulic fracturing operations. The access road will be constructed with road base aggregate material. Additional management practices such as road surfacing, wind breaks and barriers may be used.
In terms of silica dust controls when handling sand used in hydraulic fracturing operations, Confluence's vendors will use an advanced Containerized Sand System for proppant delivery, storage on location and ultimately delivery to the blender and frac fluid system. The containers use gravity (not pneumatics) to drop sand into the blender's sand hopper that drastically reduces dust generation. This system also removes people and equipment from the proppant handling operations during fracturing treatments, considerably reducing exposures and EHS risks to individuals from dust and older sand handling equipment (like conveyor belts). Remote controls are used to open and close sand gates on the bins to further reduce silica dust exposure to workers and scales are used to weigh the boxes so people are not required to open boxes and visually inspect how much proppant is remaining. PPE is worn as required for each job/ task including respirators when exposure to silica dust require them.
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| Noise mitigation | Form: (02A )
401959539
8/24/2019 | Noise mitigation Confluence will install an engineered sound wall surrounding the location during all drilling and completion operations in order to block sound from the building units to the west, southwest and east. |
| Emissions mitigation | Form: (02A )
401959539
8/24/2019 | Emission Control: Green Completions -Test separators and associated flow lines, sand traps and emission control systems shall be installed on-site to accommodate green completions techniques. When commercial quantities of salable quality gas are achieved at each well, the gas shall be immediately directed to a sales line or shut in and conserved. If a sales line is unavailable or other conditions prevent placing the gas into a sales line, the operator shall not produce the wells without an approved variance per Rule 805.b.(3)C. |
| Emissions mitigation | Form: (02A )
401959539
8/24/2019 | Confluence's standard facility design incorporates tank level automation which is displayed at a facility monitor board. Lease operators and oil haulers use this monitor to document top and bottom gauges when loading out oil and water which removes the need for opening hatches and manually gauging tank levels.
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| Odor mitigation | Form: (02A )
401959539
8/24/2019 | Odor Mitigation: Confluence will comply with Rule 805 and 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. They will utilize an Emission Control Devices to reduce odor emissions during production. Confluence's primary form of OBM odor control will be a product called 'Odor Armor' that is mixed directly into the mud while drilling wells with OBM. Odor Armor is an enzyme that will help both treat and mask odors on location. Additionally, good housekeeping practices and inventory management will help to mitigate OBM odor. Promptly hauling off cuttings as they are generated will reduce the volume of cuttings on location. Disposal of other trash and rags that have been exposed to oil based mud will also prevent the odor from becoming a nuisance. We will also use solids controls equipment that efficiently handles our cuttings to minimize amount of OBM in our dried cuttings. |