| Traffic control | Form: (02A )
402968053
12/12/2022 | Traffic will be reduced during completion operations by using temporary above ground water lines to deliver water.
Haul routes were designated and developed in consultation with the County. A Road Maintenance agreement is in place with the County.
Commercial reasonable dust control measures will be used as needed following local requirements.
In order to establish a baseline condition and post construction condition of the Access Road prior to the initial and post construction of a Well Site, Crestone will provide video recording or photographs of the condition of the Access Road to ensure the roads remain safe for public use. If road damage has occurred, Crestone will either be responsible for repair or will pay the County for such repairs.
The County has the right to reasonably restrict the hours during which vehicles and equipment may be moved on the Roads covered by the Road Damage Agreement for the protection of public health, safety and welfare. |
| General Housekeeping | Form: (02A )
402968053
12/12/2022 | Consistent with good materials and waste management practices, CPR 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 upon request. See attached list of waste disposal facilities that CPR has active waste disposal profiles with. Depending on operational considerations, the type of waste in question, and approved disposal profiles, CPR may send waste to one or more approved facilities on a single, individual project.
CPR 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, CPR requires the contractor to report the release, and to remediate impacts in accordance with applicable cleanup standards. CPR 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 unanticipated hazardous waste streams 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.
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, sever rust, other defects, which may impact their effectiveness.
Tank bottoms will be disposed of at licensed third-party solid waste disposal facilities.
Trucks will use the haul route approved under the Arapahoe County Administrative Energy Use by Special Review Plan (local permit). |
| General Housekeeping | Form: (02A )
402968053
12/12/2022 | Most work operations will take place 7-days a week & 24-hour a day. Care will be taken to provide safe, well-lit working areas during night-time and other low-light conditions. Care will also be taken to prevent unintended light from leaving the site and becoming a hazard or nuisance to the public or surrounding wildlife habitat.
During the Pad Construction Operations, no night-time work is anticipated. Daylight work will be performed during this work operation.
All lighting shall conform to Federal, State, and Industry recognized standards for both on-site workplace safety and off-site public protection (OSHA, FAA, COGCC, IESNA, and ANSI). No direct light, except those governed by FAA standards, shall shine beyond the boundaries of the WPS, especially onto public roads, adjacent properties, and/or high priority habitats. All lighting shall conform with all COGCC, county, municipal, and any applicable governing body’s standards.
Temporary lighting will be 4-head LED flood lights on mobile 25-foot telescoping towers (BUG Rating is B3-U3-G5). All lighting will be capable of adjustment and will be directed inward and between 45-65° downward towards working areas on the WPS. No light will shine above the horizontal plane passing through the center point of the light source. Lights will be shielded with a photometric diffusion fabric or membrane tint to prevent direct or reflected direct light from leaving the site.
For workplace safety, no direct or reflected direct light shall shine towards the entrance of the WPS.
Watch for and remove glare and reflection points during all work operations of the project from temporary or permanent structures, temporary lighting, vehicles, construction equipment, and clothing/PPE.
Any lighting damaged and/or improperly directed or angled will be promptly fixed and/or corrected.
Equipment shall be operated and/or orientated and/or shielded in such a manner that lights affixed to equipment do not shine above the horizontal plane passing through the center point of the light source or shine beyond the boundary of the WPS.
For all work operations, once temporary lighting is in place, a lighting self-audit of the site will be performed to ensure that no unintended light will leave the site and become a hazard or a nuisance.
For any change to the lighting during any work operations, a lighting self-audit of the site will be performed to ensure that no unintended light will leave the site and become a hazard or a nuisance.
For non-working or shut-down days where no personnel are on-site or in working areas, non-essential temporary lighting will be turned off. If no personnel are on-site and essential temporary lighting is needed, the essential temporary lighting will be inspected every 24 hours.
All redundant, unused, or not-needed lights will be turned off. |
| Wildlife | Form: (02A )
402968053
12/12/2022 | If a trench is left open for more than 5 consecutive days during pipeline construction, CPR will install wildlife escape ramps at a minimum of one ramp per ¼ mile of trench. CPR will use CPW-recommended seed mixes for interim and final reclamation when consistent with the Surface Owner’s approval and any local soil conservation district requirements. CPR will use CPW-recommended fence designs with consistent with the Surface Owner’s approval and any Relevant Local Government requirements. CPR will conduct all vegetation removal necessary for Oil and Gas Operations outside of the nesting season for migratory birds (April 1 to August 31). For any vegetation removal that must be scheduled between April 1 to August 31, CPR will implement appropriate hazing or other exclusion measures prior to April 1. If hazing or other exclusion measures are not implemented, CPR will assign a qualified contractor to conduct pre-construction nesting migratory bird surveys within the approved disturbance area prior to any vegetation removal during the nesting season. If active nest(s) are located, CPR will establish work zone buffers around active nests. If operations will begin more than approximately six months past the field survey date and between March 15 and October 31, additional burrowing owl habitat surveys will be conducted by qualified biologists to ensure no new suitable habitat has been established. If new habitat is identified, burrowing owl surveys will be initiated and CPW will be consulted prior to the start of construction as needed.
If operations will begin between February 1 and August 31, nesting surveys will be conducted by qualified biologists in accordance with agency-recommended protocols. If active nests are observed within applicable CPW-recommended species-specific buffers, CPW will be consulted and appropriate mitigation measures will be implemented as needed.
If operations will begin between December 1 and October 31, burrowing owl surveys and/or raptor and migratory bird nesting surveys will be conducted by qualified biologists in accordance with agency-recommended protocols, as needed. If active nests are observed within applicable CPW-recommended species-specific buffers, CPW will be consulted and appropriate mitigation measures will be implemented as needed. |
| Material Handling and Spill Prevention | Form: (02A )
402968053
12/12/2022 | Double-walled storage tanks will used where applicable.
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.
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).
Produced water production tanks at the facility utilize an internal liner.
Test ports for integrity testing are installed on insulated tanks.
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. |
| Dust control | Form: (02A )
402968053
12/12/2022 | 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 )
402968053
12/12/2022 | Reinforced Rock Berms (RRB And RRC) will be implemented during Drilling / Completions (Active Construction) and Production (Interim Reclamation). They will be placed at the culvert inlet/outlets, and with swales as check dam structures. Reinforced rock for culverts (RRCs) shall be utilized upstream and downstream of the culverts. Reinforced rock berms (RRBs) will also be placed intermittently along the flowline of the roadside ditches. The RRBs will be placed in the interim reclamation phase, while the RRCs will be placed during active construction, and maintained throughout interim reclamation.
Stabilized Staging Area (SSA) will be implemented during Drilling / Completions (Active Construction) and Production (Interim Reclamation). It will be on the working pad surface. The stabilized staging area shall be used for equipment storage, parking, a loading/unloading zone, portable toilets, construction trailer, waste collection, and material stockpile and storage. The stabilized staging area will essentially be the perimeter of the working surface during construction.
Sediment Basin (SB) will be implemented during Drilling / Completions (Active Construction) and Production (Interim Reclamation). It will be constructed at low points/ outfalls from the diversion ditch network. 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. Periodic maintenance of the pond may be necessary to remove accumulated silt and debris. Sediment basins shall be installed before the site grading begins.
Sediment Trap (ST) will be implemented during Drilling / Completions (Active Construction) and Production (Interim Reclamation). It will be constructed at low points/ outfalls from the diversion ditch network. 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. Periodic maintenance of traps may be necessary to remove accumulated silt and debris. Sediment traps shall be installed before site grading begins.
Diversion Ditches (DD) will be implemented during Drilling / Completions (Active Construction) and Production (Interim Reclamation). It will be constructed surrounding the working pad surface. Unlined diversion ditches will be constructed at the toe of the cut and fill slopes along the boundaries of the pad. 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 site grading is complete on the cut slopes.
Seeding And Mulching (SM) will be implemented during Drilling / Completions (Active Construction) and Production (Interim Reclamation). It will be implemented in all areas where construction activity has ceased for 14 or more calendar days which have not been temporarily
stabilized, and areas of final reclamation. Cut and fill slopes adjacent to the pad and access road swales shall be stabilized with SM. 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.
Sediment Control Log (SCL) will be implemented during Drilling / Completions (Active Construction) and Production (Interim Reclamation) along the contour of cut and fill slopes and surrounding soil storage areas. 9" 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.
Vehicle Tracking Control (VTC) will be implemented during Drilling / Completions (Active Construction) and Production (Interim Reclamation). A temporary VTC may be used roadway access, prior to paving the asphalt apron. In lieu of a 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 site grading begins.
Riprap will be implemented during Drilling / Completions (Active Construction) and Production (Interim Reclamation) at the sediment basin and culvert outfalls. 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 or outfall installation.
Erosion Control Blanket (ECB) will be implemented during Drilling / Completions (Active Construction) and Production (Interim Reclamation) as necessary along eroded slopes. 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).
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. |
| Noise mitigation | Form: (02A )
402968053
12/12/2022 | Unnecessary Sounds – Unnecessary sounds such as honking the horn, revving vehicle engines, loud music, and unwarranted metal hammering/banging are all examples of sound that can create nuisance; failure to eliminate unnecessary sound from location will be subject to an internal compliance assessment if reported by a landowner.
Rigs are designed and equipped with sound mitigating equipment including devices to minimize squeaking from the draw works brakes.
Crestone will install “quash” sound damping material in all permanent buildings that house noise sources if necessary.
Crestone will conduct a background ambient noise survey between 30 and 90 days prior to start of construction and will submit those results to the COGCC. No action needed if the ambient noise survey does not change the allowable noise levels per Rule 423.d.
The Operator shall provide a 24-hour contact number for noise complaints on the facility sign. |
| Odor mitigation | Form: (02A )
402968053
12/12/2022 | Drilling rig engine exhausts will be pointed straight up so as not to be directed towards any occupied buildings.
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.
Drilling mud chillers are used to keep drilling fluid temperatures low. (Low drilling fluid temperatures reduce the volume of fluid vaporized into the air.)
All drilling fluids will be routed through a closed loop system.
No open earthen pits to store fluids or drill cuttings.
Drill piping is wiped down each time the drilling operation “trips” out of the hole.
Drill cuttings are placed in metal bins and covered to minimize odors prior to being transported to the designated waste management facilities.
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 IV or better diesel engines are used during hydraulic fracturing 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.
If an odor complaint is received, Crestone will respond and evaluate the location to determine if the source of the odor is related to operations. Crestone will respond and evaluate equipment and potential sources of odors to determine the root cause. If the odors are determined to be caused by Crestone’s oil and gas operations, Crestone will resolve the issue and remove odor causing equipment from service as soon as possible to ensure that all odors are minimized outside the boundaries of the oil and gas location. |
| Interim Reclamation | Form: (02A )
402968053
12/12/2022 | 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 grade of the interim reclamation area is between 0-3 percent.
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 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.
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 Clayey Plains Grazing Seed Mix
Crestone will consult with the surface owner regarding the planned seed mix.
Seeding will occur throughout the interim reclamation area, topsoil stockpile, 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. |
|