| Planning | Form: (02A )
402590095
6/22/2022 | Bayswater shall connect the proposed facility to crude oil gathering systems and shall transport crude oil from this site via pipelines at first production which will significantly reduce the impacts associated with truck traffic. If a produced water pipeline becomes available to Bayswater during the production phase of the operation Bayswater will connect and transport that product through the produced water pipeline which will eliminate the need for trucking of produced water at this location, thus reducing impacts to traffic. |
| Planning | Form: (02A )
402590095
6/22/2022 | Per the Surface Use Agreement, Bayswater will install permanent gates at each point where the road intersects perimeter or cross fences, and will install screen and fencing around the well and its facilities. |
| Planning | Form: (02A )
402590095
6/22/2022 | Per the approved WOGLA, Bayswater shall have a company representative on location for all drilling and completion operations and will monitor every person entering the location for reason to be on the location. If it becomes necessary,
Bayswater will install gates or gate guards to restrict traffic on to the location. The installed sound walls will limit access paths on to the location and will aid in identifying those personnel that need to be on location. |
| Planning | Form: (02A )
402590095
6/22/2022 | Two years after the commencement of production operations Bayswater will evaluate the existing well production trends, oil tank capacity, and make a determination if it is operationally feasible to reduce the number of oil tanks on Location. Results of that evaluation and possible reduction in the number of oil tanks on Location will be submitted on a Form 4 Sundry to COGCC no later than 730 days (two years) after first oil production from the Pad. |
| Storm Water/Erosion Control | Form: (02A )
402590095
6/22/2022 | Operator shall install stormwater controls, constructed in a manner that is consistent with good engineering practices, that will prevent offsite migration of sediment/contaminant into the nearby bank of ditch parallel to Spring Creek. Stormwater controls shall be installed prior to construction activities. Gas, oil, and water gathering lines will be co-located to minimize potential of erosion associated with construction of any pipeline (s).
Stormwater Management is being coordinated with Weld County via Preliminary Drainage Report submitted as part of the 1041 WOGLA Application, and a Grading Permit and Final Drainage Report will be approved by Weld County Public Works prior to site construction.
Berm Construction: Tertiary containment will be installed at the Ruby 7-J Pad as required to protect the ditch parallel to Spring Creek which is less than 500’ and down gradient of the Location.
Per the approved WOGLA, Bayswater will comply with the Colorado Water Quality Control Commission regulations by following the active Stormwater Management Plan, which outlines the BMP’s, inspection processes and spill prevention that will be implemented during facility construction and post- construction activities for this location. The location will be covered under Bayswater’s fieldwide Stormwater permit, COR400369. |
| Storm Water/Erosion Control | Form: (02A )
402590095
6/22/2022 | • All areas compacted by drilling and subsequent oil and gas operations which are no longer needed following completion of such operations will be cross-ripped during interim reclamation prior to seeding. Compaction alleviation operations will be undertaken when the soil moisture at the time of ripping is below thirty-five percent (35%) of field capacity. Ripping will be undertaken to a depth of eighteen (18) inches unless bed rock is encountered at a shallower depth.
• All segregated soil horizons removed from crop lands will be replaced to their original relative positions and contour and will be tilled adequately to re-establish a proper seedbed and treated as needed for erosion control and invasive species prevention. Any perennial forage crops that were present before disturbance will be reestablished.
• Any areas reclaimed that will not be returned to farming operations will be planted with the recommended Weld County seed mix.
• Bayswater will install stormwater controls, constructed in a manner that is consistent with good engineering practices, that will prevent offsite migration of sediment/contaminant, into the nearby sensitive areas.
• Gas, oil, and water gathering lines will be co-located to minimize potential of erosion associated with construction of any pipeline(s).
• Operator shall install stormwater controls, constructed in a manner that is consistent with good engineering practices, that will prevent offsite migration of sediment/contaminant, into the nearby sensitive areas. Stormwater controls shall be installed prior to construction activities.
• Operator will be responsible for segregating the topsoil, backfilling, re-compacting any backfill, reseeding, and re-contouring the surface of any disturbed area so as not to interfere with Owner’s operations and will reclaim such area to be returned to preexisting conditions as best as possible with control of all weeds.
• Operator will stabilize the topsoil stockpiles utilizing vehicle tracking perpendicular to slope angle for short term stabilization and drill seed/crimped straw mulch application for longer term stabilization measures to suppress fugitive dust caused solely by wind.
• Stabilization and revegetation will be performed as part of interim reclamation.
• Stormwater controls shall be installed prior to construction activities.
• Stormwater inspection will be performed at least every 14 days from the start of construction through interim reclamation, every 30 days until interim reclamation has good growth, and then annually or semiannually through the producing life of the well.
• The stormwater system for the Ruby 7-J Pad includes one onsite swale, two offsite diversion berms and one pond with an outlet structure.
• Spill prevention and response are addressed in training of employees and contractor personnel on at least an annual basis. |
| Material Handling and Spill Prevention | Form: (02A )
402590095
6/22/2022 | As referenced in the approved WOGLA, the location will be automated to monitor all production operations remotely. In the event that the facility is not operating under normal conditions, the automation system will immediately notify the operator. The automation system also has the ability to remotely perform an emergency shut down if necessary. |
| Material Handling and Spill Prevention | Form: (02A )
402590095
6/22/2022 | Drilling Fluids Procedures and BMPs
• A closed–loop system will be used for drilling operations as required by Rule 408.a.
• All drilling fluid tanks, both active and storage, are inspected prior to use and daily while in use and replaced or repaired if needed.
• All drilling fluid transfers will be performed by two drilling crew members to assure transfer is completed, valves are closed following transfer and that no fluids are lost.
• During initial rig up on site, all hoses, lines and valves will be assembled and checked for proper connection, alignment and for leaks, and then inspected daily during drilling operations.
• All tanks will be properly labeled for contents of the tanks.
• A 40 ml poly liner with foam type berms will be utilized under the drilling rig, mud tanks, shakers, and drill cuttings bins to contain any leaks if they were to occur.
Completion Fluid Procedures and BMPs
• All completion fluid tanks are inspected prior to use and daily while in use and replaces or repaired if needed.
• All completion fluid transfers will be performed by two completion crew members to assure transfer is completed, valves are closed following transfer and that no fluids are lost.
• During initial rig up rig up on site, all hoses, lines and valves will be assembled and checked for proper connection, alignment and for leaks, and then inspected daily during completion operations.
• All tanks will be properly labeled for contents of the tanks.
• A 40 ml poly liner with foam type berms will be utilized under the frac spread layout to contain any leaks if they were to occur.
Production Fluid Procedures and BMPs
Monitoring & Detection
• Fluid Monitoring in tanks will be achieved through high level alarms installed in each tank with guided wave radar tank level gauges. These gauges report remotely tank volumes via telemetry. This telemetry allows pumpers to have real time access to information and review levels at any time. Pumpers also have the ability to Shut in the wells in the event of an emergency.
Inspection
• The tanks are visually inspected by the lease operators and weekly AVO inspections are performed and documented.
• Audio, Visual and Olfactory (AVO) inspections or Infrared surveys will be performed to identify any leaks coming from the flowlines on a monthly basis.
• Flowlines will be inspected per COGCC 1100 regulations.
• Periodic site inspections will be conducted by Bayswater personnel or 3rd party environmental contractors to look for any signs of leaks and or potential leaks.
• Tanks and tank berms will also be formally inspected quarterly under the Spill Prevention Control and Countermeasures (SPCC) plan unless specific COAs warrant more frequent inspections. Tanks are also inspected daily by the lease operator (pumper) and contract water haulers, who have been trained on identifying corrective actions on tanks/flowlines. |
| Dust control | Form: (02A )
402590095
6/22/2022 | Operator shall employ practices for control of fugitive dust caused by their operations. Such practices shall include but are not limited to the use of speed restrictions, automation of wells and production facilities, regular road maintenance, restriction of construction activity during high-wind days, and silica dust controls when handling sand used in hydraulic fracturing operations. Bayswater additionally has implemented the use of traffic signs when leaving the location to remind drivers of specific routes to utilize.
Operator will stabilize the topsoil stockpiles utilizing vehicle tracking perpendicular to slope angle for short term stabilization and drill seed/crimped straw mulch application for longer term stabilization measures to suppress fugitive dust caused solely by wind.
Operator will minimize the amount of fugitive dust through the use of speed restrictions. All vehicles will be subject to a speed limit of 15 MPH on all lease roads to minimize dust.
Operator will mitigate the creation of fugitive dust through regular road maintenance as coordinated through agreements with Relevant Local Governments or Agencies with road jurisdiction. The access road will be covered with a minimum of 2” of road base material for stabilization and to mitigate dust. Per the approved 1041WOGLA, water or magnesium chloride will be used to mitigate dust impacts during initial construction of the drill site and may be restricted or limited during high-wind days.
Operator will minimize fugitive dust caused by their operations, or dust originating from areas disturbed by their Oil and Gas Operations that becomes windborne.
Operators will not use any of the following fluids for dust suppression:
• Produced water
• E&P Waste or hazardous waste
• Crude oil or any oil not specifically designed for road maintenance
• Solvents
• Any process Fluids
Operator will use only fresh water (potable or non-potable) to conduct dust suppression activities within 300 feet of the ordinary high-water mark of any water body.
Access road will be watered or treated with a commercial dust suppressant if necessary.
Silica dust from handling sand used in hydraulic fracturing operations will be mitigated by utilization of the enclosed Sand Box type sand delivery method.
Operator will maintain safety data sheets (“SDS”) for any chemical-based dust suppressant and make the SDS available immediately upon request to the Director and to the Local Government. Operators will maintain SDS for any chemical-based dust suppressant until the site passes final site Reclamation and transfer the records upon transfer of property ownership. |
| Noise mitigation | Form: (02A )
402590095
6/22/2022 | • Bayswater has conducted a Noise Impact Assessment for each phase of operations (drilling, completions, and production) to assess operational noise levels against the maximum allowable dBA and dBC noise levels stated in the Regulation.
• Bayswater will utilize a Quiet Fleet for completions operations.
• Prior to commencement of any drilling and completion activities, a full perimeter sound wall of 2,620 linear feet (approximate) of 32-foot-tall, engineered sound wall rated at STC32 will be installed around the location.
• A pre-operational ambient sound level survey will be conducted at the two locations outlined in Figure 2 prior to the start of construction activities to quantify pre-existing A and C-weighted sound levels.
• If the completions fleet or either the drilling rigs is changed prior to commencement of operations, the mitigation measures will be equally or more protective. A Form 4 will be submitted per Rule 404.d to outline any changes.
• Bayswater will post contact information to receive and address noise complaints arising from pre-production operations around the clock, 24-hours, 7 days per week. Upon receipt of a complaint, either directly to Bayswater or from the COGCC, Bayswater will contact relative stakeholder within 48 hours of receipt. |
| Emissions mitigation | Form: (02A )
402590095
6/22/2022 | By connecting to a gas gathering system, delivering fresh water to the location via pipelines for completions operations, prohibiting trucks idling when not in use, and using electrical power at the site, Bayswater will be reducing impacts from their oil and gas operations to air resources and will perform baseline as well as continuous air quality monitoring to gauge and ensure the effectiveness of their emissions reduction measures. |
| Emissions mitigation | Form: (02A )
402590095
6/22/2022 | • By conducting LDAR inspections and weekly AVO inspections in accordance with written plan/procedures and by taking proactive measures as requested by CDPHE during designated Ozone Action Days, emissions impacts will be monitored and reduced to pose minimal change to existing conditions.
• Instrument air will be utilized to run pneumatic devices to reduce fugitive emissions.
• Per Rule 608.a.(10)C, all sealed Tanks will be designed for a minimum of 4 ounces of backpressure. Vent/back pressure valves, the combustor, lines to the combustor, and knockouts will be sized and maintained to safely accommodate any surge the system may encounter. Bayswater will properly maintain, and periodically test, Tank seals to ensure that they provide the required back pressure and prevent emissions.
• If a VOC action level is exceeded, an alert will be sent to the Bayswater operations team and a site investigation will be performed to assess the elevated readings as well as documenting the work activities that were being conducted on and around the site at the time the action level was detected.
• Any malfunction of operations not indicative of normal operations identified during the site investigation will be corrected while on location or as soon as practicable. |
| Odor mitigation | Form: (02A )
402590095
6/22/2022 | If an odor complaint is received, Operator will contact the affected building unit owner and investigate the odor levels within 24 hours, or less if possible, of the receipt of the complaint. Operator will begin investigation and, depending on the source of the odor, will determine the course of odor mitigation. The results of the investigation will determine how Operator proceeds with odor mitigation. Drilling operations will continue if odor can be mitigated concurrently. Operator will contact the affected building unit owner to address the complaint and discuss the investigative results and the additional mitigation efforts the Operator plans to put into place. Such mitigation measures may involve any of the following options as a result of the initial investigation but are not limited to these, depending on the source of the odor:
o Adding additional amounts of odor neutralizers to the mud system to reduce odors while still being used per the manufacturer’s recommended levels;
o Minimize the time of drill cuttings on location by hauling such cuttings to the commercial disposal facility on a more frequent basis while drilling with oil based mud;
o Wiping any drilling fluids from the drill pipe as it is racked into the derrick |
| Odor mitigation | Form: (02A )
402590095
6/22/2022 | •Water based mud will be used while drilling the surface hole and then switched to oil-based mud starting below surface casing to TD.
•Water-based mud is a gypsum/water clear fluid that typically carries the odor profile of fresh dirt and is not normally susceptible to odor-causing bacterial degradation.
•All odor-emitting substances are hauled off location as quickly as possible. Cuttings are hauled off daily when facility is open.
•Any stored mud additives are contained in sealed sacks or drums prior to removal or use.
•Oil based mud specifics are- Name: D822, Type: distillate, Group: II. |
| Drilling/Completion Operations | Form: (02A )
402590095
6/22/2022 | Per the approved WOGLA and the submitted Form 2B, Bayswater will source and deliver fresh water to the location for the completion operations via temporary pipelines which will significantly reduce the impacts associated with truck traffic. |
| Drilling/Completion Operations | Form: (02A )
402590095
6/22/2022 | Operator will use full cut-off lighting; to minimize light pollution and obtrusive lighting.
When operator has active operations involving personnel ongoing at an oil and gas location, Operator will provide sufficient on-site pre-production lighting to ensure the safety of all persons on or near the site.
Operator will locate lighting inside and beneath the sound walls and take precaution to ensure that lights do not shine outside of openings in the sound wall. |
| Interim Reclamation | Form: (02A )
402590095
6/22/2022 | Bayswater consulted with the surface owner to minimize the impact on agricultural operations associated with the property. The facilities were located such that they are on the edge of the farming operations and the least disruptive to the irrigation system as possible. Upon completion of all drilling and completion operations and in accordance with Weld County and COGCC rules and regulations, the disturbed area not needed for production operations will be reclaimed and returned to farming operations. |