| Material Handling and Spill Prevention | Form: (02A )
402226219
4/3/2020 | All facilities are capable of being remotely monitored and remotely shut down, which includes isolation at the well head. Engineered liner systems are used in secondary steel containment systems for tank batteries. Pollution control containers (spill boxes) are used on truck loading lines and are placed within the limits of the secondary containment system. Automatic shutdown level devices are installed on each tank with remote monitoring capabilities. Automatic shutdown level devices are installed on all pressure vessels and liquid knockouts. Automatic shutdown pressure devices are installed on flowlines from well heads to facilities with remote monitoring capabilities. Additionally, cathodic protection is used on buried steel lines to mitigate corrosion. Automatic shutdown pressure devices are installed on process vessels with remote monitoring capabilities.
Operator will use a RPE Liner with 10oz Geomembrane for containment under the drilling rigs. |
| Material Handling and Spill Prevention | Form: (02A )
402226219
4/3/2020 | Liquid Level High Kills: These kills prevent liquids from exiting a given vessel via a gas stream. If liquids enter a gas stream then the potential to experience small spills increases due to improper equipment for the process medium in the pipe. For example, if level high kills were not in place, liquid could be sent to an atmospheric combustor intended solely for the use of burning excess, or waste, gas in upset situations.
Liquid Level Low Kills: Liquid level low kills can be considered a more generic kill that gives indication of one of potentially numerous process upsets. The most likely culprit resulting in a LSL kill is a hung dump valve (minor process upset), however these kills can also capture leaks to atmosphere. If a significant leak occurs on location, predetermined vessel level setpoints will no longer be valid and the affected vessel will then shut-down on a liquid level low kill.
Pressure High Kills: Pressure high kills are somewhat self-explanatory, however the main reason we incorporate high pressure kills is not necessarily to protect vessels. We have PSV’s installed on every vessel that prevent the vessels from over-pressuring, but we prefer to never pop a PSV as this is both a process safety risk as well as an environmental incident. We set our Pressure High kills to shut-down the site at approximately 80% of max allowable working pressure of each vessel, which shuts down the site before PSVs relieve to the atmosphere.
Pressure Low Kills: Very similar to the Liquid Level Low kills, the low pressure shut-down alarm is a fairly generic indication of a process upset. Pressure low site shut-downs typically prevent gas or vapor spills, however they can also catch and prevent liquid spills.
2-Phase vessel: On our current 2-Phase vessels we incorporate the following kills: liquid level high, pressure high, and pressure low. Future 2-Phase vessels are planned to be outfitted with liquid level low switches as well.
3-Phase vessel: Our current and future 3-Phase vessels (heater treater) will be outfitted with all (4) site ESD kills.
Along with automated shut-downs we have preventative maintenance and best practices in place to prevent leaks from vessels. These include:
• Yearly shut-downs and visual inspections of each 2-phase and 3-phase vessel on site
• Yearly NDT (Non-Destructive Testing) of each 2-Phase and 3-Phase vessel shell and head on site
o Vessels that fail this test are removed from service
• Conservative corrosion allowances
• Internal coating to prevent corrosion
• Semi-Annual PSV testing
• Weekly environmental checks by operations personnel (weekly at a minimum, usually every 1-2 days per site)
• NDT of all water piping to prevent leaks due to corrosion
• NDT spot checking of various flowlines to monitor for thin walled piping due to erosion or corrosion
• Yearly test of all devices that shut down the facility (including the 4 shut-down devices listed above)
• The above best management practices are similar to those utilized by PSM facilities |
| Material Handling and Spill Prevention | Form: (02A )
402226219
4/3/2020 | A containment system capable of containing one and one-half times (150%) the capacity of the largest vessel, plus sufficient freeboard to prevent overflow will be constructed around all permanent tanks at the Eastern Hills South Well Site. The containment system will be constructed of a steel-rim berm and lined with a synthetic or engineered liner, mechanically connected to the steel-rim which will surround all primary containment vessels. When used, temporary vessels will have secondary containment constructed from lined earthen berms or pre-engineered, duck-pond style containment systems. All berms and containment devices will be inspected quarterly.
All flowlines (the pipeline connecting the wellhead to the production facility) are contained entirely within the boundary of the well pad. No off-location flowlines as defined and set forth in COGCC Rule 1101, will be utilized.
All tanks installed on the well site will be no taller than sixteen feet (16’). |
| Dust control | Form: (02A )
402226219
4/3/2020 | Dust associated with Site activities and traffic on roads will be minimized throughout all phases such that there are no visible dust emissions from sites or roads to the maximum extent practicable given wind conditions. Numerous mitigation measures are in place to minimize dust emissions including (but not limited to): application of fresh water to roads and ground during earth moving activities, curtailment of work during windy conditions and re-establishment of vegetation on disturbed areas that are not graveled. |
| Noise mitigation | Form: (02A )
402226219
4/3/2020 | Operator will use noise mitigation (sound walls) during the drilling and completion phases for the Eastern Hills South well site. Based upon modeled receptor locations, the Eastern Hills South wellsite is predicted to comply with the A-weighted and C-weighted COGCC noise limits. |
| Emissions mitigation | Form: (02A )
402226219
4/3/2020 | 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 will 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, Crestone shall not produce the wells without an approved variance per Rule 805.b.(3)C. |
| Odor mitigation | Form: (02A )
402226219
4/3/2020 | Operator will mitigate odors by routing to closed loop systems to the maximum extent practicable. If Operator receives complaints from a Residential Building, Operator will take measures to mitigate the odor within 24 hours, based on the specific circumstances. |
| Drilling/Completion Operations | Form: (02A )
402226219
4/3/2020 | Lighting is only used during the Drilling and Completion Phases of operations. No permanent lighting will be installed. All lighting used will be situated so that is downcast and does not shine beyond the boundary of the oil and gas operations area. |
| Interim Reclamation | Form: (02A )
402226219
4/3/2020 | Secure, opaque fencing will be installed at the Eastern Hills South Well Site after interim reclamation has been completed. Fencing will be 8' in height. |