| General Housekeeping | Form: (02A )
402779501
4/12/2022 | E&P wastes will be transported offsite via truck by a licensed transporter to a licensed third party solid waste disposal facility/landfill. Frequency of these operations will vary by site based on waste volumes but will be temporary in most cases.
Waste will be stored on location in compatible container or containment devices designed or engineered for the purposes for which they will be utilized. These containers will be inspected on a regular basis to ensure that no undue wear, structural issues, severe rust, other defects, which may impact their effectiveness.
Drilling fluids are recovered and will be separated from the cuttings at surface. At the end of its use on a particular well, the liquid synthetic mud will be reused for additional drilling operations, or it will be returned to then vendor who originally supplied the mud. Transportation will occur on a daily basis as required to facilitate on ongoing drilling operations in accordance with COGCC Rule 905d.
Drill cuttings will be separated from liquid mud onsite, and the cuttings will be temporarily stored onsite in steel bins. Accumulated cuttings will be transported for permanent disposal to a licensed solid waste disposal facility. The actual solid waste disposal facility that will be used will depend on geographic proximity to the well being drilled. Transportation will occur on a daily basis as required to facilitate ongoing drilling operations.
Any soils contaminated by E&P waste will be disposed of at a licensed third-party solid waste disposal facility/landfill.
Tank bottoms will be disposed of at licensed third-party solid waste disposal facilities.
Liquid wastes such as produced water will be disposed of at licensed third-party injection facilities such as those run by NGL Water Solutions. |
| Wildlife | Form: (02A )
402779501
4/12/2022 | 1. Inform and educate employees and contractors on wildlife conservation practices, including no harassment or feeding of wildlife;
2. Consolidate and centralize fluid collection and distribution facilities to minimize impact to wildlife;
3. Adequately size infrastructure and facilities to accommodate both current and future gas production;
4. Protect culvert inlets from erosion and sedimentation and install energy dissipation structures at outfalls;
5. Implement fugitive dust control measures;
6. Install screening or other devices on the stacks and on other openings of heater treaters or fired vessels to prevent entry by migratory birds;
7. Minimize rig mobilization and demobilization by completing or re-completing all wells from a given well pad before moving rigs to a new location;
8. To the extent practicable, share and consolidate new corridors for pipeline rights-of-way and roads to minimize surface disturbance;
9. Engineer new pipelines to reduce field fitting and reduce excessive right-of-way widths and reclamation;
10. Mow or brush hog vegetation where appropriate, leaving root structure intact, instead of scraping the surface, where allowed by the surface owner;
11. Limit access to oil and gas access roads where approved by surface owners, surface managing agencies, or local government;
12. Post speed limits and caution signs to the extent allowed by surface owners, Federal and state regulations, local government, and land use policies;
13. Use wildlife-appropriate fencing where acceptable to the surface owner;
14. Use topographic features and vegetative screening to create seclusion areas, where acceptable to the surface owner;
15. Use remote monitoring of well production to the extent practicable;
16. Reduce traffic associated with transporting drilling water and produced liquids through the use of pipelines, large tanks, or other measures; and
17. Install automated emergency response systems (e.g., high tank alarms, emergency shutdown systems). |
| Storm Water/Erosion Control | Form: (02A )
402779501
4/12/2022 | Reinforced rock berms (RRBs) shall be utilized immediately upstream of the culverts. Reinforced rock berms (RRBs) will also be placed intermittently along the flowline of the roadside ditches.
Where the tributary disturbed area is greater than 1 acre, a sediment basin will be planned for the well site at the low point of the pad. It will be implemented at the downstream termination of the diversion ditches. The basin will contain silt from the upstream cut and fill slopes around the drill pad site. Periodic maintenance of the pond may be necessary to
remove accumulated silt and debris. Sediment basins shall be installed before the pad site grading begins.
Where the tributary disturbed area is less than 1 acre a sediment trap will be planned for the well site at the low point of the pad. It may be implemented at the downstream termination of the diversion ditches. The trap will contain silt from the upstream fill slopes around the pad site. Periodic maintenance of traps may be necessary to remove accumulated silt and debris. Sediment traps shall be installed before the pad site grading begins.
Unlined diversion ditches will be constructed at the toe of the cut and fill slopes along the boundaries of the pad site. These ditches will capture sediment laden runoff from the slopes and channel it into sediment basins and/or traps. In the fill slope application, the material excavated for the ditch shall be compacted and bermed on the downhill side for an additional layer of protection. Diversion ditches shall be installed before grading work begins on the fill slopes and as soon as the pad site grading is complete on the cut slopes
Cut and fill slopes adjacent to the pad site and access road swales shall be stabilized with seeding and mulching. It shall be applied after grading is complete in the final phase. If the seeding and mulching application does not provide adequate stabilization for the area where slopes exceed 4:1, then more robust bmp's shall be utilized.
12" diameter sediment control logs shall be used on the downstream perimeter of the spoil and topsoil stockpiles per manufacturer specifications. Sediment control logs shall be installed in the interim phase once stockpiles have been created.
In lieu of a vehicle tracking control (VTC), the contractor shall install an asphalt apron where a proposed access road intersects a paved public roadway. If the public roadway is gravel, a VTC is not necessary. VTC or asphalt apron shall be installed in the initial phase before the pad site grading begins.
Type-m riprap shall be installed downstream of all culverts for a width of 4 times the culvert diameter and a length of 4 times the culvert diameter. Riprap shall be installed in the interim phase, following culvert installation.
Steep slopes shall be protected with straw coconut blankets where indicated on the SWMP plan or where seeding and mulching application is not effective. Blanket shall be installed with seeding during the final phase.
During construction, inspections shall be conducted every 14 days, and after a major precipitation or melt event, which has the potential to cause surface runoff.
For sites earthwork and construction is completed, but final stabilization is not achieved due to vegetative cover, inspections shall be conducted every 30 days and exclude precipitation or melt event response. Inspections will continue until all reclaimed areas have achieved a cover of 70% the pre-construction reference vegetation (i.e. final stabilization).
Post-construction stormwater inspections will be conducted in accordance with COGCC Rules 1002.f and 1003.e, to document the status of the location, maintenance needs, effectiveness of stormwater control measures, to evaluate pollution sources, and to document reclamation / final stabilization progress. Inspections will be managed by the Stormwater Manager and conducted by their designated representative(s).
Findings, inspection records and site maps are documented electronically and available within 24 hours of any inspection. All inspection records are stored for a minimum of three years after the location has achieved final stabilization.
Action and documentation towards completing repairs identified at the time of inspection shall be made within 24 hours of discovery.
For maintenance items during post-construction, items will be documented and coordinated with production crews.
Timeline for completion of maintenance items are a priority and will depend on scope; but in all cases, shall not be completed until field conditions allow for safe access, and utility clearance has been confirmed for actions requiring ground disturbance / earthwork. |
| Material Handling and Spill Prevention | Form: (02A )
402779501
4/12/2022 | Frequent and thorough inspections throughout all stages of operations.
Procedures and training on equipment use in place to avoid and mitigate spills.
Continuous monitoring and third-party systems will be used to track fluid volumes and monitor for leaks.
Rig will be placed on an impervious plastic liner including four-inch to six-inch high berm walls.
Closed loop drilling systems will be utilized.
Temporary portable containers (e.g., drums) are stored inside plastic lined or other impervious containment.
General secondary containment (impervious liner) will be placed under equipment.
Active drilling fluid tanks will be equipped with a third-party measurement and alarm system (Pason Pit Volume Totalizer) to track tank volumes and changes during the drilling operation.
Fluid storage tanks on the location will be equipped with mechanical (visual) level indicators that are inspected by operation personnel.
Third-party continuous monitoring on integral systems in addition to routine inspections. In the event of an upset condition, Operators are notified and respond immediately.
Regular preventative maintenance schedules followed for equipment.
Qualified third-party inspectors will inspect equipment to evaluate compliance with COGCC Rules and Regulations and applicable technical standards.
Secondary containment will be installed with an impervious liner.
Secondary containment will be sized to 150% of the largest storage tank.
Production tanks will be lined where applicable.
Pressure and Integrity testing prior to placing equipment into service.
All equipment will be installed and tested in accordance with applicable American Society of Mechanical Engineers (ASME) and American Petroleum Institute (API) standards.
Underground piping on the facility will be electronically inspected prior to installation using coating deficiency detectors per COGCC 1102.I.(1).
Flowlines will be inspected by a qualified third-party inspector who is trained in accordance with 1102.h prior to placing into service.
Flowlines will be integrity tested per 1100 Series Rules.
All production tanks are built in accordance with API 12F standards.
Produced water production tanks at the facility utilize an internal liner.
Test ports for integrity testing are installed on insulated tanks.
Inspections of all production equipment including temporary equipment.
Routine operational checks on the facility.
Documented weekly inspections.
Audio, Visual, Olfactory (AVO) inspections in accordance with COGCC Rule 609.d. and Air Quality Control Commission Regulation 7
Annual Spill Prevention and Control Countermeasure Inspections.
Periodic operator training on spill prevention best management practices and equipment operations.
Fluid handling equipment will have valves and caps to mitigate leaks.
Internal and External Tank integrity Inspections.
Annual separator and flow through process equipment cleanouts and integrity evaluations.
Pressure testing of all flowlines.
Response to all spills and release in accordance with COGCC 900 Series Rules including timely reporting, response, and investigation. |
| Dust control | Form: (02A )
402779501
4/12/2022 | • Application of fresh water to disturbed areas during earth moving activities.
• Application of fresh water or magnesium chloride to graveled surfaces of the Site and associated roads.
• Use of high-quality construction materials such as crushed granite road base, which generates less dust than other aggregates.
• Limit disturbance of natural vegetation to only that area that is reasonably necessary for construction.
• Re-establishment of vegetation on disturbed areas not graveled.
• Covered storage containers to be used for sand, silica, proppant or similar material during hydraulic fracturing.
• Establish speed limit on all access roads of 20MPH or less. Personnel failing to comply will be subject to disciplinary action.
• Establish speed limit on the Site of 5MPH or less. Personnel failing to comply will be subject to disciplinary action.
• Curtail scope of work during high wind conditions (sustained winds 25MPH or greater).
• Regular road maintenance will include adding gravel and grading when needed per the executed Road Maintenance Agreement between the Operator and City of Aurora.
• Additional management practices such as road surfacing, natural wind breaks and barriers, or automation of wells to reduce truck traffic may also be utilized to minimize fugitive dust emissions.
• Crestone will use a rock base tracking pad at the access point to help remove dirt and prevent debris from collecting on all access roads. As necessary, Crestone will sweep roads nearest the access point of dirt and debris to maintain a clean entrance.
• Vertically track the stockpile by heavy equipment to prevent wind and water erosion.
• During construction, salvaged topsoil will be seeded and monitored for erosion and the establishment of undesirable and noxious weeds routinely.
• Seeding and straw mulch application will occur on the long-term topsoil storage stockpile during interim reclamation. |
| Construction | Form: (02A )
402779501
4/12/2022 | LIGHT MITIGATION - No permanent lighting is proposed for this project. All temporary lights will be directed toward working areas on the pad surface inward and angled approximately 45-65° downward and/or shielded to prevent direct light from leaving the site. Lighting BMPs will be used to minimize light pollution, which may include but
is not limited to:
• Shielding sensitive areas with a temporary lighting barrier such as a sound/visual wall
• Using automation, timers, or motion sensors to control and minimize lighting when not needed
• Turning off or shielding redundant or un-needed light
• Using full cut-off lighting to better direct light
• Using lighting colors that reduce light intensity
• Using low-glare or no-glare lighting
• Watching for and removing glare points |
| Construction | Form: (02A )
402779501
4/12/2022 | • During drilling operations, current Crestone pad construction practice places Soilcrete® in a roughly 60 foot wide by 150 foot long rectangle to support the drilling rig loads, and in
the remainder of the pad, plastic/rubber and oak mats are placed under the drill rig substructure and other ancillary third party equipment.
• Provide adequate surface drainage in accordance with a SWMP to reduce ponding and infiltration of water into the surficial soils. The SWMP will identify surface grading and
completion, utilization of swales, spillways, diversion ditches, and retention ponds to channelize and contain stormwater.
• Following construction, Crestone will complete daily inspections at the Well Site to identify and document any changes in ground surface (e.g., erosion, depressions, pooling water, heaving, swelling) and implement corrective actions. |
| Noise mitigation | Form: (02A )
402779501
4/12/2022 | AVOIDANCE - This site was selected to maximize distance to the nearest RBU which is over 2,000 feet from edge of working pad surface. Quiet-Fleet™ hydraulic fracturing technology will be utilized to decrease noise.
MINIMIZATION - Eight foot visual berm will be installed on the south side of the Well Site. Drilling rig engine exhausts are pointed straight up. Crestone will install “quash” sound damping material in all permanent buildings that house noise sources. Crestone has completed an ambient sound level survey for this location. |
| Emissions mitigation | Form: (02A )
402779501
4/12/2022 | Per CDPHE Regulation 7, continuous emissions monitoring will be performed for baseline air quality and monitoring during all pre-production operations through six months of initial production. Conducting weekly forward looking infrared (“FLIR”) camera evaluation of completions operations to minimize leaks.
Using NeoFlo™ Drilling Fluid – a non-toxic and benzene, toluene, ethylbenzene, and xylenes (“BTEX”)-free fluid
Piping fugitive emissions during drilling to a combustor
Using Tier 4 dual fuel engines for completions
Utilizing electric line power (when available) to power drilling and pumping equipment
Fuel augmentation with compressed natural gas for the completion fleet
Construction of facility and pipeline takeaway prior to flowback operations
Enclosed flowback equipped with vapor recovery units piped into sales line
Production gas connected to pipeline during flowback (green completion) and production (no flaring of production gas during pipeline downtime)
Production oil connected to pipeline during production utilizing lease automated custody transfer (“LACT”) units
Use of instrument air driven pneumatic controllers and pumps. |
| Odor mitigation | Form: (02A )
402779501
4/12/2022 | 1. Drilling rig engine exhausts are pointed straight up so as not to be directed towards any occupied buildings.
2. To mitigate the effects of odor from Crestone's operations, Crestone employ only International Association of Oil & Gas Producers (IOGP) Group III drilling base fluids with <0.5 weight % aromatics and will not use drilling fluids based on diesel. These Group III drilling fluids are odorless and contain no BTEX.
3. Drilling mud chillers are used to keep drilling fluid temperatures low. Low drilling fluid temperatures reduce the volume of fluid vaporized into the air.
4. All drilling fluids will be routed through a closed loop system.
5. No open earthen pits to store fluids or drill cuttings.
6. Drill piping is wiped down each time the drilling operation “trips” out of the hole.
7. Drill cuttings are placed in metal bins and covered to minimize odors prior to being transported to the designated waste management facilities.
Completions Operations - During the hydraulic fracturing process, diesel-fueled equipment is placed in a way that exhausts are pointed straight up to not direct exhaust towards any occupied buildings. Tier II or Tier IV diesel engines are used during hydraulic fracturing operations where available.
Production Operations - During operations, tanks are sealed with a thief hatch to prevent emissions. Emission Control Devices (Combustors) will be used to combust any flash gas from tanks. During oil loadout operations, a Truck Loadout Vapor Recovery (TLVR) system will be used to capture and direct odorous air contaminants and emissions to a combustor. |
| Drilling/Completion Operations | Form: (02A )
402779501
4/12/2022 | Water for drilling operations for the Blue 3-65 33-32-31 Pad will be sourced from a water hydrant near the intersection of 6th Avenue and N. Haysmount Road.
Water used for completion operations will be transported by a temporary water line (“Layflat”). |
| Interim Reclamation | Form: (02A )
402779501
4/12/2022 | Topsoil will be monitored regularly by Crestone personnel and during routine stormwater inspections. During construction, drilling, and completions operations, stormwater inspections will occur on a 14-day frequency and within 24 hours after the end of any precipitation or snowmelt event that causes surface erosion.
Topsoil will be salvaged from the construction area to a depth of 6 inches or to the depth of the topsoil horizon, whichever is deeper.
The topsoil stockpile will be vertically tracked by heavy equipment to inhibit wind and water erosion during active construction.
Salvaged topsoil will be seeded with Quickguard sterile triticale hybrid grass, or a similar performing product, while stockpiled during drilling and well completions operations. Seeding will occur when earthwork operations are complete. During normal operations and stormwater inspections, the Crestone employees and contractors will monitor the stockpile for erosion and establishment of undesirable and noxious weeds. Weeds will be treated mechanically with a mower whenever plant height exceeds 6 inches or before seed development. Chemical treatment of weeds with broad-leaf herbicides will only occur in spot-specific situations where prostrate weed growth or other site conditions preventing mechanical treatment are encountered. Soil sterilant and non-selective herbicides will not be used.
A portion of topsoil will be used to construct a containment and visual screening berm along the southern perimeter of the pad. The berm will be maintained for long-term topsoil storage for use in final reclamation. During interim reclamation operations, the berm will be seeded with native perennial grasses and temporarily stabilized with crimped straw mulch. |
| Interim Reclamation | Form: (02A )
402779501
4/12/2022 | Seeding and mulch application will be completed within 24 hours of seedbed preparation, weather permitting.
The seed mix will be broadcasted and drill seeded throughout the interim reclamation area.
All seed will be certified weed free and pure live seed (PLS) rated per federal, state, county, and municipal standards.
Certified weed free grass or wheat origin straw mulch will be uniformly applied at rate of 2,000 lbs./ per acre to cover 100% of the seed bed.
Mulch will be properly anchored to the soil surface using a commercial straw crimper with a final orientation south to north on slopes less than 8% and on contour on greater slopes.
Hydraulically applied tackifier/Ecomatrix BFM will be applied at a rate of 1,000 lbs./ per acre to sufficiently secure straw mulch through the first growing season on slopes greater than 8%, stabilize soils and increase moisture retention, promote seed germination and establishment, and assist in erosion prevention.
Topsoil horizon depth will be identified based on changes in physical characteristics.
Topsoil will be separated from the disturbance area to the depth of the topsoil horizon.
Salvaged topsoil will be stockpiled, seeded with cover crop grasses, and the location marked or documented.
Topsoil will not be comingled with subsoil materials during recontouring and subsoil preparation operations.
The surface elevation will be returned as close to the original relative position and contour as practicable during pad size reduction and grading operations.
Seeding will be completed with broadcast and drill methods.
Certified weed free grass or wheat origin straw will be utilized for mulching operations.
Mowing operations will be commenced when the height of weeds exceeds 6 inches or before seed development.
Herbicide applications will be utilized as needed to treat prostrate, low growing, or perennial noxious weed species for which mowing methods are ineffective.
Herbicide applications will be spot-specific and only broadleaf herbicides will be deployed.
A landscape assessment will be conducted prior to ground disturbance to ensure that the recontoured reclamation surface matches pre-disturbance grade and topography.
Any preexisting drainage features will be reestablished during recontouring.
Reseeding will be completed with species consistent with the adjacent plant community.
The selected seed mix and rate for this location is the Loamy Plains Seed Mi.
Crestone will consult with the surface owner regarding the planned seed mix.
Seeding will occur throughout the interim reclamation area, the screening berms, and at least 5 feet into the adjacent landscape.
A 4-foot-tall wildlife fence will be installed to mitigate wildlife access to the interim reclamation area.
An 8-foot-tall privacy fence will be installed around the pad working surface to prevent the public and wildlife from entering the Location. |