| Planning | Form: (02A )
402794601
10/6/2022 | Operator will conduct additional avian surveys prior to the commencement of construction to ensure no conflicts have developed since the prior survey(s). |
| Wildlife | Form: (02A )
402794601
10/6/2022 | Access Road Construction – Operator will not construct the western most portion of the access road, from the intersection with Picadilly Road to a point approximately 565 feet east of said intersection, during the Bald Eagle nesting season which begins on December 1st and ends on July 31st.
Eagles – Operator will conduct surveys for eagle nesting activity one week prior to the scheduled well pad construction start date, if the planned start date is between October 15 and July 31.
Raptors – Operator will conduct surveys for raptor nesting activity one week prior to the start of operations on the well pad if the planned start date is between February 1st and July 31st.
Western Burrowing Owls – Operator will conduct presence/absence surveys two weeks prior to the start of operations on the well pad if the planned start date is between March 15th and October 31st.
Migratory Birds – Operator will conduct presence/absence surveys for non-raptor ground nesting migratory birds prior to ground disturbing activities if well pad construction will begin between April 15th and August 31st.
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| Material Handling and Spill Prevention | Form: (02A )
402794601
10/6/2022 | During drilling, completion, and production operations, regular Auditory, Visual, and Olfactory Monitoring (AVO) inspections are performed on equipment containing hydrocarbons, fluids, or associated chemicals. AVO inspections include taking the time to look, smell and listen for leaks.
Operator utilizes a polyethylene liner beneath the drilling rig during drilling operations and beneath the areas where completions equipment (including pump trucks and other heavy equipment) during completion operations to ensure there is an impermeable layer between the rig and the earth. The use of this liner prevents hydrocarbons and other fluids from reaching the soil in the unlikely event a leak does occur. The liner is inspected for integrity throughout drilling operations and maintenance/repair to the liner occurs as needed.
Tanks will be designed, constructed, and maintained in accordance with NFPA Code 30 (2008 version). Inspection and record retention of tank inspections will be in accordance per SPCC regulation. All records will be made available to the COGCC upon request.
Operator will install an engineered containment system around and beneath the tank battery. The containment system is constructed of a perimeter of walls that are post driven into the ground around a flexible geotextile base. All components including the underlayment are sprayed with a polyurea liner technology. This liner technology maintains impermeability and puncture resistance under exposure to UV rays, weather extremes, and chemicals commonly encountered in oil and natural gas production, and provides seamless protection.
During truck loadout, additional inspection protocols include the inspection of loading equipment including the hoses, couplings, and valves to ensure no dripping, leaking, or other liquid or vapor loss occurs during liquid loadout events.
Routine SPCC inspections will be conducted and documented pursuant U.S. EPA requirements. The location will be equipped with a SCADA system that allows for remote monitoring and shut-in capabilities.
Operator has developed a robust Leak Detection and Repair (LDAR) program, which utilizes Forward Looking Infrared (FLIR®) cameras to identify and fix leaks. These inspections will begin during the drilling phase and continue throughout the life of the Oil & Gas Location.
Wells, facilities, and equipment will be equipped to be shut-in remotely.
Consistent with good materials and waste management practices, XOG maintains records of material/waste source, transporter, and final disposition or disposal. These records are maintained under usual and customary practice and are made available as necessary. See attached list of waste disposal facilities that XOG has active waste disposal profiles with. Depending on operational considerations, the type of waste in question, and approved disposal profiles, XOG may send waste to one or more of these facilities on a single, individual project.
XOG minimizes the generation of waste by ensuring that material products are fully used for their intended purpose. If unused materials remain following an activity, contractors are required to take unused product with them for reuse at the next applicable project. Contractors are contractually required to comply with applicable material and waste management practices.
In the event of an unintended release of material by a contractor, XOG requires the contractor to report the release, and to remediate impacts in accordance with applicable cleanup standards. XOG tracks all contractor releases to closure by requiring formal documentation, supported by laboratory analysis demonstrating cleanup of site impacts, any required waste characterization, waste disposal approval, and manifests or load tickets tracking waste from source, through transport, to final disposal.
If there are unforeseen hazardous wastes not listed in the attached Waste Streams Spreadsheet, the hazardous waste will be stored and disposed of in compliance with all rules and regulations applicable to that specific waste.
Produced water with no commercial value or reuse potential is typically disposed of via underground injection. In all instances, produced water is disposed of at an offsite location(s) via properly permitted disposal facilities including but not limited to UIC wells intended specifically for produced water disposal.
Soils impacted with produced fluids may be either remediated onsite with COGCC, landowner, and, if required, local government approval, or transported offsite for disposal at a disposal facility permitted to receive E&P waste. All incidents are reported in accordance with COGCC 900-Series Rules.
All drill cuttings generated during drilling operations are transported offsite with proper manifesting for disposal at facilities properly permitted to receive E&P waste. Drilling fluids will be stored on-site and recycled for use in future drilling operations.
All surface trash, debris and material not intrinsic to the operation of the oil and gas facility shall be removed stored in a roll off container or other trash bin and disposed of at a commercial solid waste disposal location. |
| Dust control | Form: (02A )
402794601
10/6/2022 | Dust suppression during initial construction will be accomplished by the application of freshwater to the access road(s) and exposed earthen surfaces to reduce the transportability of dust when atmospheric conditions are conducive to sustained winds and/or periodic gusts. All dust suppression efforts will consist of only freshwater unless otherwise requested and approved as applicable.
To minimize sand-related dust emissions, the Operator will be utilizing containerized box technology for sand transport, storage and use during the completions phase. These sand containers (or “sand boxes”) are sealed containers that protect the sand from exposure to wind and prevent dust generation.
Operator will post an access road speed limit not to exceed 20 miles per hour to minimize fugitive dust emissions from vehicle traffic traveling on the access road.
Operator will perform regular inspections and road maintenance to ensure the integrity of the access road and associated features is maintained throughout the life of this project. Maintenance consists of re-compacting the road base/recycled asphalt mix on an as-needed basis.
Operator will install and maintain vehicle tracking controls (i.e., coarse aggregate, a tracking pad, paved apron, or cattle guard) to further reduce and remove loose mud and dirt on construction equipment and vehicles servicing location.
A hard-surface apron will be installed at the entrance of the access the road to prevent mud-tracking and associated dust emissions on the public roadway. |
| Construction | Form: (02A )
402794601
10/6/2022 | Extraction will salvage and stockpile available topsoil resources based on recommended topsoil salvage depths. Topsoil will be stockpiled in multiple piles within the designated area boundaries to manage topsoil volumes on the location. Stockpiles will be maintained at minimal heights to reduce the potential for anaerobic conditions, which can impact soil microbial activity in the center of the stockpile. Topsoil stockpiles will be graded with slopes no greater than 3:1 to ensure that all surfaces can be seeded safely and effectively. Extraction will drill seed the topsoil stockpile with a native, perennial grass and forb seed mix containing species with deep-reaching roots (i.e., switchgrass - Panicum virgatum).
Lighting will be angled in a downward manner to limit the halo effect off location.
Lights will be placed at reasonable heights to limit spillage off location.
Equipment will be painted “desert tan” (or similar) to avoid creating a marked contrast with the surrounding landscape.
During Production, all site lighting will be photocell and occupancy sensor. These sensors will be affixed with a timer to automatically turn off lighting fixtures after a minimum of 15 minutes, preferably 1 hour, without activity to minimize the on/off flashing that stakeholders routinely mention. The sensors from each fixture will be tied in together so that a single sensor will reset the timer, again to minimize the on/off flashing of the fixtures. |
| Noise mitigation | Form: (02A )
402794601
10/6/2022 | Continuous noise monitoring will be conducted during the required stages to ensure that noise levels are maintained in compliance with COGCC Rule 423. One (1) continuous noise monitoring terminals will be placed proximal to residential building units to monitor sound levels. Allowables for the Warbler Pad monitoring location will be finalized after the ambient monitoring is conducted.
A sound barrier (Minimum rating of STC-30) will be installed along the western side of the pad site. This sound barrier will be a minimum of 32 ft high and will remain onsite for the required stages of the project.
While idling, engines/equipment maintain the lowest frequency possible and in a position/location that will prevent noise from carrying to nearby residents
Unnecessary noises such as honking the horn, revving vehicle engines, loud music, and unwarranted metal hammering/banging are all examples of noise that can create nuisance; failure to eliminate unnecessary noises from location will be subject to an internal compliance assessment if reported by a landowner.
To mitigate noise impacts from engines, sound barriers made out of steel and sound-absorbing insulation (i.e., NOT styrofoam) may be used.
Some engines can operate at a constant number of revolutions per minute (RPM), which reduces the often annoying, fluctuating noise caused by engines that speed up and slow down. Mufflers, like those used for automobile engines, can be used to minimize engine noise. In noise sensitive situations, a series of hospital-grade mufflers would be more effective at reducing noise from engines.
A “quiet completions fleet” will be used for hydraulic fracturing operations.
Production Facilities will be powered by electricity sourced from the regional power grid. |
| Noise mitigation | Form: (02A )
402794601
10/6/2022 | Any gas encountered during flowback will be routed to a gas sales pipeline or combusted with a minimum of 98% destruction efficiency. |
| Emissions mitigation | Form: (02A )
402794601
10/6/2022 | Employ the practice of “block and isolate” whenever possible on equipment, piping, and/or tank connections.
Operator will utilize a maintenance vessel system which eliminates venting from the location.
Operator will utilize a pneumatic air system to power the facilities on location which will eliminate the small amount of venting that would normally occur during production operations.
Any gas encountered during drill-out will be combusted with a minimum of 98% destruction efficiency.
Any fluids encountered during flowback will be sent to a controlled tank and stored until transferred for disposal (e.g., water) or sale (e.g., oil).
Lease Automated Custody Transfer (LACT) will be used to transfer fluids from the oil production tanks.
Instrument air skids will be used to generate compressed air for all pneumatic actuation.
Vapor Recovery Towers (VRT) will be used for separation of the production stream. |
| Odor mitigation | Form: (02A )
402794601
10/6/2022 | Operator will use a filtration system and additives to the drilling and fracturing fluids to minimize odors. Use of fragrance to mask odors is prohibited.
Operator shall utilize a closed-loop, pit-less mud system for managing drilling fluids.
Operator shall employ the use of drilling fluids with low to negligible aromatic contact (IOGP Group II) during drilling operations after the surface casing is set and freshwater aquifers are protected.
Operator shall remove drill cuttings daily and as soon as waste containers are full.
Operator shall employ pipe cleaning procedures when removing drill pipe from the hole; these procedures may include “wiping” the pipe before racking it in the derrick.
If a justified complaint is received, Operator may utilize a mud-chiller to reduce odor breakout and increase concentration of odor-mitigating additives in mud system. |
| Drilling/Completion Operations | Form: (02A )
402794601
10/6/2022 | At rig setup and regularly during Drilling and Completion phases, Operator will walk around the outside of the sound wall to confirm that it is preventing obtrusive lighting from leaving the site.
If there are comments from neighbors regarding lighting, the Operator is committed to adjusting light fixtures or installing shielding on light fixtures, and will work with the stakeholder to minimize lighting impacts.
During the Completions phase, additional lighting will be installed on the inside of the sound wall below the top. This site will have a complete wrap of sound wall. Therefore, the lighting installed on the inside of the sound wall should not impact the surrounding stakeholders.
In the event the sound wall requires repair, the Operator will take care during repairs to avoid shining any light (temporary or permanent) toward the opening in the sound wall to minimize impact to the neighborhood without reducing safety of the workers. Breaks in the wall for access will remain open for safety. |
| Drilling/Completion Operations | Form: (02A )
402794601
10/6/2022 | An electric rig powered by utility power will be utilized to drill the proposed wells. |
| Interim Reclamation | Form: (02A )
402794601
10/6/2022 | Extraction will utilize a temporary above-ground irrigation system to promote seed germination, if needed, during periods of dry and drought conditions. A temporary fresh water tank will be located within the pad and utilized for the temporary irrigation system until germination and seed growth is established. Extraction will use a professional landscape maintenance company to maintain the site.
Interim reclamation will also include the control of soil lost from wind and water erosion using best management practices (BMPs). BMPs are selected based on Site-specific conditions and include, but are not limited to, revegetation of disturbed areas, continuous berms, surface roughening, silt fences, sediment basins, straw bale dikes, or any other comparable measures. Interim reclamation helps to ensure the protection of the soil from erosion, to meet diverse needs of wildlife, thermal cover, predatory cover, overall diversity, and to help limit the visual impacts of the pad construction.
Determination of soil amendments and fertilizers and their respective amounts are based on the soil analyses results. Various types of soil amendments and fertilizers that may be utilized include, but are not limited to, compost, biosolids, the fertilizer Biosol, elemental sulfur, mycorrhizae, and inorganic fertilizers.
Compost, biosolids, and Biosol all provide macronutrients to aid in plant growth of the incoming seed and organic matter which helps with soil aggregation. Elemental sulfur can be used to reduce soil pH and mycorrhizae can aid in plant health and resilience.
Inorganic fertilizers including, but not limited to, nitrogen, phosphorous, and potassium will be determined by the results of the soil analyses and will be applied to the soil following or concurrent with seeding operations.
As part of interim reclamation, topsoil from the stockpile(s) will be spread throughout the reclamation site to a minimum depth of 4 inches. Following the distribution of topsoil, soil sampling and analyses will be conducted by a qualified soil scientist to determine the current health of the topsoil by examining chemical and physical attributes. Poor soil conditions may include one or more of the following: low nutrient/organic matter content, high pH values, high sodium absorption ratio (SAR), and high electrical conductivity (EC).
Any imported topsoil not used from the topsoil stockpile is required to have accompanying analytical reports. The fertilizers, other amendment quantities, and application rates applied to seeding area will be typical for grass and forb reclamation. It is expected that amendments and amendment quantities will be specified by the subcontractor for any topsoil that is imported.
Interim reclamation areas shall be free of all undesirable plant species designated to be noxious weeds, as practicable, and weed control shall be conducted in compliance with the Colorado Noxious Weed Act (C.R.S. §35-5.5-115). Additional reseeding shall be necessary if vegetation requirements are not successful. |
| Final Reclamation | Form: (02A )
402794601
10/6/2022 | Final reclamation includes plugging and abandoning wells and the backfilling of all pits. Within three months of the well plug and abandonment, removal of all debris and surface equipment and abandoned gathering and flow line risers will be completed. Access roads will be closed, graded, and re-contoured, in addition to the removal of any culverts and/or other obstructions that were installed. Following the request for facility closure, a pending remediation site investigation will be conducted. All reclamation work will be completed within three months on cropland or twelve months on non-cropland following the plug and abandon. An extension for final reclamation may be granted if unusual circumstances are encountered and every reasonable effort has been made to complete reclamation before the start of the next growing season (COGCC 2009).
If the Site will not return to cropland and will be reseeded with the seed mix specified in Table 1 or a mixture specified by Adams County, Extraction will utilize a temporary above-ground irrigation system to promote seed germination, including during periods of dry and drought conditions. A temporary fresh water tank will be located within the pad and utilized for the temporary irrigation system until germination and seed growth is established. Extraction will use a professional landscape maintenance company to maintain the site. The total plant cover of the disturbed areas should be at least 80% of a prescribed target cover, and noxious weeds should be absent (COGCC 2009).
Pipelines, gathering lines and flowlines shall be removed after one year of non-use when last well utilizing lines are plugged and abandoned unless this requirement is waived in writing by Adams County.
Temporary access roads associated with oil and gas operations at the Well Sites shall be reclaimed and revegetated to the original state within a reasonable amount of time, taking into account planting seasons, or as directed by the landowner in a Surface Use Agreement and subject to applicable COGCC variances. Operator must control erosion while access roads are in use.
Any imported topsoil not used from the topsoil stockpile are required to have accompanying analytical reports, when applicable. The fertilizers, other amendment quantities, and application rates applied to seeding area will be typical for grass and forb reclamation. It is expected that amendments and amendment quantities will be specified by the subcontractor for any topsoil that will be imported.
Final reclamation areas shall be free of all undesirable plant species designated to be noxious weeds as practicable and weed control shall be conducted in compliance with the Colorado Noxious Weed Act (C.R.S. §35-5.5-115). Additional reseeding shall be necessary if vegetation requirements are not successful. |