| Planning | Form: (02A )
402578943
9/1/2021 | Planning BMPs:
• Prior to submittal of the Application for Permit to Drill (BLM-APD/Form 2) and the Oil and Gas Location Assessment (Form 2A), TEP conducted onsites and meetings with the Bureau of Land Management (BLM), Colorado Parks and Wildlife, and the associated private landowners. These onsites and meetings were held to discuss TEP’s proposed development plan for the WMC 24-17 pad and associated support facilities. Changes were made to the proposed development plan based on feedback received from all stakeholders and included in the APD.
• The development plan for the WMC 24-17 pad was prepared to minimize surface impacts to the greatest extent possible through the development of multiple wells from one location by utilizing directional drilling technology and utilizing existing facilities and infrastructure where possible, which minimizes the surface area needed to conduct operations on the WMC 24-17 pad location.
• Existing infrastructure operated by Summit and TEP will be utilized for transportation of natural gas and produced water to minimize the surface disturbance required for tying in gathering facilities.
• Per APCD requirements, TEP will implement ambient air quality monitoring on site during drilling, completion, and the first six (6) months of production operations; an air monitoring plan will be submitted 60 days prior to start of drilling;
• TEP will properly maintain vehicles and equipment;
• Other than safety devices, TEP will use non-emitting pneumatic controllers; and
• TEP will have adequate and committed pipeline take away capacity for all produced gas and oil. |
| Pre-Construction | Form: (02A )
402578943
9/1/2021 | Pre-Construction Meeting:
• Prior to commencement of construction activities, TEP will hold a pre-construction meeting with contractors to review proposed site construction and installation of stormwater control measures. The site will be staked for construction prior to preconstruction meeting. Staking will identify the boundaries of the proposed site to protect existing vegetation in areas that should not be disturbed. |
| General Housekeeping | Form: (02A )
402578943
9/1/2021 | General Housekeeping BMPs:
• Vehicular traffic will be minimized as much as possible to reduce nuisance dust and prevent soil erosion;
• Any trash generated during the project will be disposed of properly at a commercial disposal facility;
• Any chemicals used will be kept to a minimum;
• Any chemical or hydrocarbon spills will be cleaned up immediately in accordance with established company procedures;
• All materials will be stored in a neat and orderly manner in their appropriate containers; and
• TEP will follow manufacturers’ recommendations and company policies for proper use and disposal of products. |
| Wildlife | Form: (02A )
402578943
9/1/2021 | Wildlife (Protection) BMPs:
• TEP will inform and educate all employees and contractors on wildlife conservation practices, including no harassment or feeding of wildlife;
• TEP will install a proposed water pipeline from the Oil and Gas Location to TEP’s existing water management system to minimize truck traffic to the location and minimizing potential impact to wildlife;
• TEP will minimized direct impact to wildlife habitat by utilized existing infrastructure and disturbance corridors whenever possible; and
• Well telemetry equipment will be installed to minimize site visitation through remote monitoring of production operations. |
| Storm Water/Erosion Control | Form: (02A )
402578943
9/1/2021 | Stormwater / Erosion Control (Measures) BMPs:
• Stormwater control measures will be in place during all phases of development (construction, drilling, completions, interim reclamation, and production) to control stormwater runoff in a manner that minimizes erosion, transportation of sediment offsite, and site degradation;
• Stormwater control measures will include perimeter controls and site degradation control measures; these will include a minimum 1.5-foot compacted earthen perimeter berm around the entire working pad surface and around the cuttings management areas in the southeast portion of the well pad; topsoil will be windrowed on the eastern portion of the location within the disturbance area; there will be a system of exterior diversion ditches around the entire disturbance area; these ditches will be lined or armored, and will have rocked check dams and will tie into three sediment catchment basins along the northern and northeastern edges of disturbance; the access road will have rocked check dams; site degradation control measures will include grading, slope stabilization (seeding, mulching, surface roughening of the topsoil stockpile), straw wattles along the toe of all fill slopes, and the use of gravel and roadbase materials for surfacing; the location is subject to both Federal oversight from the BLM and State oversight from the COGCC;
• Topsoil will be stored within a topsoil stockpile east of the proposed pad and will be segregated from all subsurface material; waddles will be placed around the entire perimeter of the topsoil stockpile to minimize potential for loss of organic materials;
• Outlet protection should be used when a conveyance discharges onto a disturbed area where there is potential for accelerated erosion due to concentrated flow;
• TEP will conduct stormwater inspections immediately after storm event;
• TEP will conduct weekly stormwater inspections during normal operations;
• Bi-weekly inspection of the pad and stormwater control measures (berms, ditches, sediment basins), and the cuttings trench (berms and precipitation buildup); when necessary, precipitation within the cuttings trench will be pumped out and sent into the TEP proposed produced water management system for disposal;
• Stream Crossing and Road Construction - TEP will ensure that control measures are designed, installed and adequately sized in accordance with good engineering, hydrologic, and pollution control practices; and
• Documentation / Stormwater Management Plan - if it is infeasible to install or repair a control measure immediately after discovering a deficiency, TEP will document and keep on record in the stormwater management plan: (a) a description of why it is infeasible to initiate the installation or repair immediately; and (b) a schedule for installing or repairing the control measure and returning it to an effective operating condition as soon as possible. |
| Material Handling and Spill Prevention | Form: (02A )
402578943
9/1/2021 | Material Handling and Spill Prevention (Water Resource Protection) BMPs:
• Informal inspections of all tanks and storage facilities will occur daily during drilling, completions, and production operations;
• A closed loop drilling system will be employed;
• The moisture content of drill cuttings managed onsite shall be kept as low as practicable to prevent accumulation of liquids greater than de minimis amounts;
• Temporary frac tanks placed on location will have proper secondary containment including a perimeter berm around the Working Pad Surface and containment under the frac tanks;
• Flowback and stimulation fluids will be sent to enclosed tanks, separators, or other containment/filtering equipment before the fluids are placed into any pipeline storage vessel, other open top containment located on the well pad; or into tanker trucks for offsite disposal; no open top tanks will be used for initial flowback fluids containment;
• Pipelines (flowlines from wellheads to separators to tanks; and any temporary surface lines used for hydraulic stimulation and/or flowback operations) will be pressure test in accordance with the 1100-series rules prior to putting into initial service any temporary surface or permanent surface/buried pipelines and following any reconfiguration of the pipeline network; all permanent flowlines from wellheads to separators and from the separators to the tank will also be pressure tested annually; Inspection and record retention of flowline testing will be in accordance per COGCC regulation; all records will be made available to the COGCC upon request;
• Tank batteries will be placed within engineered, steel secondary containment with an impervious liner system or other secondary containment systems;
• Pollution control containers (spill boxes) to be used on truck loading lines within the limits of the secondary containment systems;
• TEP will properly characterize and dispose of all waste streams at facilities approved for acceptance of each waste stream;
• All wells located on this pad will be equipped with remote shut-in capabilities; and
• The use of cathodic protection on buried steel lines to mitigate corrosion. |
| Material Handling and Spill Prevention | Form: (02A )
402578943
9/1/2021 | Material Handling and Spill Prevention (Fluid Leak Detection) BMPs:
• Audio, Visual, and Olfactory (AVO) inspections: AVO inspections will be conducted monthly at the WMC 24-17 location throughout the life of the WMC 24-17 well pad.
• Routine inspection of all production equipment, wellheads, temporary equipment, etc.; As described above, routine inspections to be conducted at the WMC 24-17 location will include: Routine physical inspections of production equipment (by TEP production personnel); Air Compliance inspections and monitoring (by TEP Air Compliance staff); SPCC Inspections (by 3rd party contractor), Storm Water Management inspections (by 3rd party contractor), and continuous, dedicated SCADA monitoring of fluid production rates and pressures, and fluid storage volumes (by TEP production personnel).
• As part of our LDAR, STEM, OOOOa inspection / compliance programs, TEP will adhere to the use of Approved Instrument Monitoring Methods (AIMM) for inspecting production equipment and facilities at the WMC 24-17 well pad.
• Spill prevention training is provided to all field employees on a monthly basis. The monthly training consists of reviewing past incidents, root causes of the incidents, and what specific actions (lessons-learned) could be taken to prevent the reoccurrence of such incidents in the future.
• TEP spill response procedures will be adhered to for any spills or releases occurring at the WMC 24-17 well pad and reported to COGCC as required based on volumes and location of the spill;
• Leak Detection and Repair (LDAR) inspections are performed at all locations; however, the inspection frequency is tiered based upon the level of emission controls that are required / employed at each location.
• Storage Tank Emission Monitoring (STEM) inspections are performed monthly at any location where emissions must be controlled (> 2 tpy).
• OOOOa inspections are performed semi-annually on any facility constructed after 2015.
• Flare Logs are completed daily for all locations where active flares and emissions controls are required.
• Any leaks or spills detected during monitoring will be reported within 24 hours in accordance with Rule 912.b;
• All loadlines will be bullplugged or capped;
• All on-location flowlines will be inspected and tested per Rule 1104;
• All equipment deficiencies will be corrected immediately or as soon as practical (all identified problems and corrections/repairs will be documented and records will be maintained in the TEP’s office);
• TEP will track and clean up all spills, including those that are not reportable;
• TEP will temporarily shut in all production wells on the pad in the event of any upset condition;
• All piping is pressure tested and inspected for leaks prior to flowback; and
• Automation technology will be utilized at this location; this technology includes the use of fluid level monitoring for the tanks and high-level shut offs. |
| Material Handling and Spill Prevention | Form: (02A )
402578943
9/1/2021 | Material Handling and Spill Prevention (Per- and Polyfluoroalkyl Substances [PFAS]) BMPs:
• If PFAS-containing foam is used at a location, TEP will perform appropriate soil and water sampling to determine whether additional characterization is necessary and inform the need for and extent of interim or permanent remedial actions;
• If PFAS-containing foam is used at a location, TEP will properly capture and dispose of PFAS-contaminated soil and fire and flush water; and
• If PFAS-containing foam is used at a location: TEP will properly characterize the site to determine the level, nature and extent of contamination. |
| Dust control | Form: (02A )
402578943
9/1/2021 | Dust Control BMPs:
• During Well Pad and Access Road Construction - freshwater will be applied to dry soils at all disturbance areas during construction to minimize fugitive dust;
• TEP will not use produced water or other process fluids for dust suppression;
• During High Winds - TEP will monitor wind conditions during site construction; during wind events in excess of 13 miles per hour, TEP construction contractors will apply freshwater from an approved source to the disturbance area of the pad, road, or pipeline corridor to minimize or mitigate propagation of fugitive dust; accessibility and worker safety will be considered prior to application; during periods of sustained high wind events over 20 miles per hour, if potential fugitive dust cannot be controlled, TEP construction contractors will temporarily suspend work to minimize potential for migration of fugitive dust, ensure worker safety, and to minimize impacts to public health, safety, welfare, the environment, and wildlife;
• Road Surfacing - The existing lease road will be spot graveled during site construction to ensure there is sufficient gravel on the road to minimize fugitive dust; six (6) inches of road surfacing materials will be applied to the proposed access road following construction;
• Speed Restrictions - TEP has implemented speed restrictions on all lease roads and requires all TEP employees and contractors to adhere to all posted speed restrictions; the speed limit for the existing access road and the proposed access road to the Federal WMC 24-17 pad is and will be twenty-five (25) miles per hour;
• Road Maintenance - During long-term production operations, TEP will conduct annual inspections of the existing and proposed access roads and will perform maintenance actions as necessary to ensure road integrity and minimize fugitive dust; road maintenance actions may include, but not limited to, regrading, spot graveling, storm water control maintenance, and application of magnesium chloride (MgCl2) and / or fresh water;
• Site Visitation - TEP will utilize telemetry equipment to minimize well site visitation when possible to reduce fugitive dust from vehicles traveling the dirt / gravel roads;
• Wildlife - BLM Site Specific COA for Cutthroat Trout Habitat: “If feasible, dust suppression in proximity to Beaver Creek shall utilize potable water from a nearby source instead of raw water to avoid the spread of disease organisms and aquatic nuisance species.”;
• Completion operations will utilize an enclosed sand storage and delivery system to eliminate possible fugitive sand dust emissions; and
• Topsoil and stockpiled soils will be stabilized through either tackifiers, seeding practices, or erosion control blankets. |
| Noise mitigation | Form: (02A )
402578943
9/1/2021 | Noise Mitigation BMPs:
• Any operations involving the use of a drilling rig, workover rig, or fracturing and any equipment used in the drilling, completion or production of a well are subject to and will comply with the Agricultural maximum permissible noise levels in Rule 423.b.(2).A. of 65 db(A) in the hours between 7:00 a.m. to 7:00 p.m. and 60 db(A) in the hours between 7:00 p.m. to 7:00 a.m.; and
• If a noise complaint is made to either TEP directly or the COGCC (who will notifyTEP immediately), noise levels will be measured within 48 hours of receipt of the complaint; TEP will contact the concerned party (if contact information is available) to discuss the complaint and the results of the noise measurements. |
| Emissions mitigation | Form: (02A )
402578943
9/1/2021 | Emissions Mitigation BMPs:
• TEP will install equipment designed specifically to aid in the mitigation of VOC emissions from this location; this equipment includes emission control devices (ECDs) and tank load out controls; if one of these pieces of equipment is not operational, facility controls will automatically shut-in the pad until the equipment is back on-line;
• Test separators and associated flowlines, sand traps, and emission control systems will be installed onsite to accommodate green completions techniques.
• Venting/Flaring - TEP will control bradenhead/casinghead venting; and
• Venting/Flaring - TEP will not flare or vent gas during completion or flowback, except in upset or emergency conditions, or with prior written approval from the Director for necessary maintenance operations. |
| Odor mitigation | Form: (02A )
402578943
9/1/2021 | Odor Mitigation BMPs:
• Water/bentonite-based mud (WBM) drill cuttings are circulated up the annulus and through the rig flowline to a mud-gas separator, where any gas entrained in the mud is separated and flows off the separator’s overhead to an internal combustion device; the drilling cuttings then flow with the drilling mud over two sets of drying shakers and then through a centrifuge to further dry the cuttings; the dried cuttings are placed into steel bins where they are temporarily stored on location prior to placement into the cuttings trench;
• If odor complaints are received and it is determined that they are caused by the drilling fluids, then an odor neutralizing agent or similar product will be added to the system to eliminate the odor; and
• Hydrocarbon odors from production facilities will be minimized by keeping produced fluid hydrocarbons and natural gas contained within pipes, separators, tanks, and combustors; all tanks will be sealed with thief hatches and gaskets; tank vapors will be captured with properly sized piping and combustors. |
| Drilling/Completion Operations | Form: (02A )
402578943
9/1/2021 | Drilling / Completion Operations BMPs:
• Site lighting shall be shielded and directed downward, inward, away from the nearby areas where wildlife may be present, and toward operations to avoid glare on nearby public roads or possible wildlife areas;
• A closed loop system will be implemented during drilling;
• TEP will use zero VOC (group III, low/negligible odor) drilling mud;
• All cuttings generated during drilling will be kept in a bermed portion of the well pad prior to disposition;
• The moisture content of any water/bentonite-based drilling mud (WBM-) generated cuttings shall be as low as practicable to prevent accumulation of liquids greater than de minimis amounts; solids control equipment consisting of shale shakers, centrifuges, and flocculating unit may be utilized to separate WBM-generated cutting solids from liquids (water/bentonite drilling mud); drill cuttings will be segregated between surface casing cuttings and the intermediate / production zone cuttings; and stockpiled on location;
• Cuttings samples from each interval (surface casing, intermediate, and production) will be collected and will be submitted for laboratory analysis of COGCC Table 915-1 constituents; if cuttings meet Table 915-1 standards, they will be treated as soil and beneficially reused on location (cuttings trench or utilized in onsite interim reclamation activities);
• In the event that a certain volume of drill cuttings analytically demonstrate constituents above Table 915-1 standards, the cuttings will be remediated during interim reclamation activities to levels below all applicable standards of Table 915-1; f) No liners (if used) are allowed to be disposed of with the drill cuttings;
• TEP will cover trucks transporting drill cuttings if transportation of drill cuttings is necessary;
• No offsite disposal of cuttings to another oil and gas location shall occur without prior approval of an amended Waste Management Plan specifying disposal location and waste characterization method; commercial disposal of drill cuttings and drilling fluids will only require the operator to maintain documentation (manifests, bills of lading) of drill cuttings and drilling fluids disposal; the operator will implement measures (covers, misting) in trucks to reduce dust and PM emissions during transport of WBM solids and cuttings materials from the well pad location;
• Recycled produced water will be utilized for well completion operations minimizing the amount of fresh water required for development of the proposed wells on this location;
• TEP will use pipelines to transport water for hydraulic fracturing to and from location;
• TEP will recycle or beneficially reuse flowback and produced water for use downhole; and
• TEP will properly characterize and dispose of all waste at the appropriate specific landfill/waste disposal location that allows for acceptance of the particular waste stream. |
| Interim Reclamation | Form: (02A )
402578943
9/1/2021 | Interim Reclamation (Topsoil Protection) BMPs:
• Protection from Contamination - based on changes in physical characteristics (e.g., organic content, color, texture, density, or consistency) soil horizons will be segregated and stockpiled separately; stockpiles of different soil types will be separated by compacted earthen berms, sediment control logs, straw bale barriers, etc.; and stabilizing stockpile surfaces to control for erosion and sedimentation;
• Protection from Compaction - topsoil stockpiles will be indicated on site with signage; stockpiles will be placed in areas away from vehicle and equipment traffic; and when stockpiling, compaction will be minimized by limiting the number of equipment passes, limiting stockpile height, and using vegetation;
• Protection from Wind Erosion - surface roughening, applying hydro-seed/mulch, using soil tackifier, covering stockpiles with rolled erosion control products or other similar measures;
• Protection from Water Erosion - surface roughening, applying hydro-seed/mulch, using soil tackifier, covering stockpiles with rolled erosion control products or other similar measures; and
• Weed Establishment Prevention - TEP uses Cultural, Mechanical, Biological, and Chemical controls to prevent the establishment of weeds. |
| Interim Reclamation | Form: (02A )
402578943
9/1/2021 | Interim Reclamation BMPs:
• Interim reclamation will occur within six (6) months following completion of well drilling and completion operations;
• The areas identified to be interim reclaimed will be re-contoured to blend as nearly as possible with the natural topography during site reclamation; all topsoil will be moved from the stockpile area and placed over the facility’s cut and fill slopes to a uniform depth to ensure long term topsoil health including protection from erosion, prevention of weed establishment, and maintaining soil microbial activity until final reclamation;
• The location will be reseeded by drill, broadcast, or hydroseed methods; drill seeding will be utilized wherever soil characteristics and slope allow for effective operation of a rangeland seed drill.;
• The seed bed will be prepared on all topsoiled areas to alleviate compaction and minimize the potential for erosion;
• Topsoiled areas will be planted with desirable species or a seed mixture provided by the Surface Owner for this particular location;
• Protection from Wind and Water Erosion - topsoiled areas will be covered with certified weed free mulch at an application rate specified by the product’s manufacturer, or a specification sheet that follows good engineering practices; and
• Weed Establishment Prevention - TEP uses Cultural, Mechanical, Biological, and Chemical controls to prevent the establishment of weeds. |