| Planning | Form: (02A ) 402376823 1/13/2021 | Access Roads: KMG will utilize a new access road off of CR 46 for construction development and production operations, including maintenance operations. KMG has submitted a Weld County access permit application with the WOGLA application. The access road will be properly maintained to accommodate for local emergency vehicle access. |
| Planning | Form: (02A ) 402376823 1/13/2021 | KMG holds Surface Impact Planning (SIP) meetings for each planned location. These meetings are attended by KMG internal teams. This is a multi-disciplinary team including construction, operations, facilities, EHS, stakeholder relations, regulatory, surface land and mitigation. The team reviews potential impacts to surrounding residents, identifies and plans for necessary mitigations, and identifies BMPs that should be included in the pad development moving forward. The team reviews noise, odor, lights, traffic, haul routes, rig orientation and visual mitigation and any input we have received from surrounding communities either from response line calls or community meetings, relative to our operations. The purpose of the meeting is to proactively identify potential concerns, exhaust possible options and provide best in class solutions in order to have compatible operations.
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| Community Outreach and Notification | Form: (02A ) 402376823 1/13/2021 | Courtesy Notifications will be sent to stakeholders within one mile of the proposed location prior to construciton, drilling / completions operations, providing contact information for the Occidental's Colorado Response Line and online resources.
A COGCC health study fact sheet was mailed to the residential building units within 2000 feet of the location during COGCC review of the Form 2A. |
| Traffic control | Form: (02A ) 402376823 1/13/2021 | Traffic Plan: Prior to the commencement of operations, the operator will obtain access permits per Weld County regulations and use haul routes approved in the WOGLA permit. |
| General Housekeeping | Form: (02A ) 402376823 1/13/2021 | Loadlines: All loadlines shall be bullplugged or capped. |
| General Housekeeping | Form: (02A ) 402376823 1/13/2021 | Removal of Surface Trash: A commercial size trash bin for removing debris will be located on site. This bin will be for use by all parties affiliated with the operation. Upon completion of operations, the commercial trash bin will be removed from the location and disposed of in an appropriate manner.
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| General Housekeeping | Form: (02A ) 402376823 1/13/2021 | Lighting: Site lighting shall be shielded and directed downward and inward toward operations to avoid glare on public roads and nearby Building Units. A 32-foot tall wall will also be erected along the north, east and partially along the west and south sides of the drilling pad to minimize the impact of light glare. |
| Storm Water/Erosion Control | Form: (02A ) 402376823 1/13/2021 | KMG will create tertiary containment around the well pad and facility by constructing a berm/ditch around the oil & gas location with sediment traps to further protect adjacent water features.
A culvert is proposed at the access road for ditch 0' to the northwest. The natural grade at this proposed location slopes gently from north to south.
Once graded the well pad will be sloped 0.5% to the southwest and northeast from approximately the center of the well pad. The ditch/berm will be engineered to contain and divert runoff around the pad. The ditch/berm will direct flow from north to south through two sediment catch basins. |
| Storm Water/Erosion Control | Form: (02A ) 402376823 1/13/2021 | Site-Specific Measures: During active construction, drilling, and completions, with personnel on location, daily inspections will occur. During non-active, but while under construction, site inspections will occur every 14 days or after major rain events.
When construction is completed and the location is on production, site inspections will occur every 28 days with additional inspections after major rain events. During construction, stormwater features will be checked more frequently (up to daily, depending on the intensity of construction activity). These construction checks will not be formally documented, since they occur as part of construction oversight, and minor issues will be corrected with no further documentation. If and when larger issues are noted in these construction checks, the associated corrective actions would be documented. |
| Material Handling and Spill Prevention | Form: (02A ) 402376823 1/13/2021 | Berm Construction: A geosynthetic liner will be laid under the long-term tanks on this location and a metal containment will be constructed. Secondary containment devices will be constructed around crude oil, condensate, and produced water storage tanks and shall enclose an area sufficient to contain and provide secondary containment for 150% of the largest single tank.
Secondary containment devices shall be inspected at the same time as stormwater inspections, with personnel on location, daily inspections will occur. During non-active, but while under construction, site inspections will occur every 14 days. When construction is completed and the Location is on production, site inspections will occur every 28 days. |
| Material Handling and Spill Prevention | Form: (02A ) 402376823 1/13/2021 | Temporary produced water storage tanks shall be designed, constructed, and maintained in accordance with the following portions of the National Fire Protection Association (NFPA) Code 30 (2008 version):
1) Tanks are built to engineering standards using noncombustible materials, with relief devise sizing based on API 2000 standards.
2) Tanks are inspected and maintained while in use.
3) The only pipes within the containment are related to the temporary tanks (i.e. no external piping is colocated within the containment), and firefighting equipment is likewise not stored within the containment area.
4)Drill cuttings will not remain in storage at the oil and gas location for more than a 24 hours period. Disposal will occur before the end of the 24 hours period. |
| Material Handling and Spill Prevention | Form: (02A ) 402376823 1/13/2021 | Leak Detection Plan: Automation technology will be utilized at this facility. This technology includes the use of fluid level monitoring for the tanks and produced water sumps, high-level shut offs, and electronic sensors to monitor the interstitial space of double-walled produced water sumps. All automation is monitored by KMG's Integrated Operations Center (IOC), which is manned 24 hours per day, 7 days per week.
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| Material Handling and Spill Prevention | Form: (02A ) 402376823 1/13/2021 | Berm Construction: The temporary produced water storage tanks will be staged on a geosynthetic liner and surrounded by an earthen berm. The berms shall enclose an area sufficient to provide secondary containment for 150% of the volume of the largest single tank and shall be sufficiently impervious to contain spilled or released material. Berms and the liner shall be inspected at the same time as stormwater inspections, with personnel on location, daily inspections will occur. During non-active, but while under construction, site inspections will occur every 14 days. When construction is completed and the location is on production, site inspections will occur every 28 days. |
| Material Handling and Spill Prevention | Form: (02A ) 402376823 1/13/2021 | Pit Level Indicators: All storage tanks used for active drilling operations (used in lieu of pits) contain pit level monitors with Electronic Drilling Recorders (EDR). KMG uses EDRs with pit level monitor(s) and alarm(s) for production rigs. Basic level gauges are used on tanks utilized for the surface rig |
| Material Handling and Spill Prevention | Form: (02A ) 402376823 1/13/2021 | Berm Construction - Separators: All separators will have secondary containment in the form of a 22-inch steel berm will be constructed and buried 13-inches with the remaining 9-inches exposed above grade. The seams and penetrations of the berm are sealed. This shall be inspected at the same time as stormwater inspections, with personnel on location, daily inspections will occur. During non-active, but while under construction, site inspections will occur every 14 days.
When construction is completed and the Location is on production, site inspections will occur every 28 days. |
| Material Handling and Spill Prevention | Form: (02A ) 402376823 1/13/2021 | All piping is pressure tested and inspected for leaks prior beginning flowback. During the entirety of flowback piping is visually inspected for fluid leaks throughout the 24 hour operation. Once the wells have been turned over to production
(oil, gas and water through the facility) produced water will be diverted to the temporary tanks south of the production facility until the tanks are no longer needed.
The pipelines connecting to the temporary 500 bbl tanks will be buried. Prior to produced water being transported through the pipe pressure tests will confirm pipe integrity. |
| Dust control | Form: (02A ) 402376823 1/13/2021 | Dust: Water will be placed on unpaved roads to mitigate dust.
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| Construction | Form: (02A ) 402376823 1/13/2021 | Fencing Requirements: The completed wellsites will be surrounded with a fence and gate with adequate lock to restrict access to authorized personnel only. KMG personnel will monitor the wellsites regularly upon completion of the wells. Authorized representatives and/or KMG personnel shall be on-site during drilling and completion operations.
At the request of the Front Range Fire Rescue the gate and fence surrounding the completed wellsite and production facility will be secured with a Knox Padlock that is keyed to the Front Range Fire Rescue system. |
| Noise mitigation | Form: (02A ) 402376823 1/13/2021 | Noise: Sound walls will be placed along the north, east and partially along the west and south sides of the drilling pad prior to drilling and completions operations to dampen noise and minimize impact to the nearby residences during drilling and completions.
Quiet completions fleet will be used for completions operations.
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| Emissions mitigation | Form: (02A ) 402376823 1/13/2021 | Temporary ECD(s) will be utilized to mitigate releases of emissions from temporary produced water storage tanks for the duration which the tanks are on location and being used. |
| Emissions mitigation | Form: (02A ) 402376823 1/13/2021 | Kerr-McGee will conduct air monitoring consisting of continuous VOC analyzers, carbon sorbent tubes and Summa cannisters at the subject location. Monitoring will be conducted during pre-production operations. Kerr-McGee will provide air monitoring results to COGCC upon request. |
| Emissions mitigation | Form: (02A ) 402376823 1/13/2021 | Operator will provide air emissions monitoring to detect fugitive emissions at the production facility based upon a plan approved by the Director which will contain, at a minimum, the following conditions. A two-week baseline test will be conducted prior to the start of drilling. The monitors will be placed in proximity of the production facility and will remain in place from the beginning of drilling through production. One month following the initial thirty-day period after drilling commenced, a data summary report will be provided to the COGCC, which will include the first 30 days from the start of drilling, as well as the two-weeks of baseline data. Thereafter, monthly reports will be provided and submitted to the COGCC on a monthly basis for a duration of no less than one year, at which point, Operator may suspend further monitoring, upon approval of the Director and a finding by the Director that such monitoring is no longer necessary to protect public health, safety, welfare, the environment and wildlife resources. The air emissions monitoring will be performed by a third party. |
| Odor mitigation | Form: (02A ) 402376823 1/13/2021 | 805.b. Odor Mitigation. Additional BMPs for this location are:
1) Storage of excess drilling fluid (e.g., fluid not being used in the active mud system) in closed, upright tanks.
2) Drill cutting will be run through a centrifugal dryer to minimize odor during temporary time on location and during transport to disposal.
3) Odor neutralizer will be used in the active mud system for management of odors within 24 hours of receipt of a
stakeholder grievance.
4)Drill cuttings will not remain in storage at the oil and gas location for more than a 24 hours period. Disposal will occur before the end of the 24 hour period. |
| Drilling/Completion Operations | Form: (02A ) 402376823 1/13/2021 | KMG currently plans to use the water-on-demand system on this location which is a network of over 180 miles of underground pipeline that stretches the length of the 20-mile by 30-mile field to source and transport water to completions crews. This system eliminates more than 2,000 truck trips per day field-wide, while also reducing associated concerns of
traffic, noise, emissions and dust.
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| Drilling/Completion Operations | Form: (02A ) 402376823 1/13/2021 | Green Completions: Test separators and associated equipment shall be installed on-site to accommodate green completion techniques. When commercial quantities of salable 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, KMG shall not produce the wells without an approved variance per Rule 805.b.(3)C. |