| Planning | Form: (02A )
402966313
12/15/2022 | Upon surface owner authorization and per COGCC Rule 615, Verdad will collect baseline water quality samples from an appropriate set of water wells within the vicinity of the oil and gas location. Baseline samples will be collected prior to drilling (setting of conductor casing)
operations for the initial site well. |
| General Housekeeping | Form: (02A )
402966313
12/15/2022 | Operator will not bury or burn trash or other waste materials at an oil and gas location.
Trash receptacles will be designed, maintained, and operated to exclude wildlife, and to protect public safety, the environment, and wildlife from exposure to overflowing, leak prone, or insecure trash receptacles.
When wastes are handled on site from generation, to storage, to transportation and disposal, practices (solidification of liquids and placement of storage) and equipment (secondary containment and liners) are used maintain full control of the waste and to prevent waste from impacting the working surface. |
| Wildlife | Form: (02A )
402966313
12/15/2022 | Inform and educate employees and contractors on wildlife conservation practices, including no harassment or feeding of wildlife;
Adequately size infrastructure and facilities to accommodate both current and future gas production;
Protect culvert inlets from erosion and sedimentation and install energy dissipation structures at outfalls;
Implement fugitive dust control measures;
Install screening or other devices on the stacks and on other openings of heater treaters or fired vessels to prevent entry by migratory birds;
Minimize rig mobilization and demobilization by completing or re-completing all wells from a given well pad before moving rigs to a new location;
Post speed limits and caution signs to the extent allowed by surface owners, Federal and state regulations, local government, and land use policies;
Install automated emergency response systems (e.g., high tank alarms, emergency shutdown systems.
Operator will install screening or other devices on the stacks and on other openings of heater treaters or fired vessels to prevent entry by migratory birds.
Operator will install screening or other devices portable tank secondary containment.
|
| Storm Water/Erosion Control | Form: (02A )
402966313
12/15/2022 | This location will use a diversion ditch and berm to surround the entire disturbance area. The ditch and berm will divert water from running on to the pad and manage water that precipitates onto the disturbance area.
Sediment traps will be placed at the southwest and northwest corners of the disturbance area. Outlet structure and outlet protection will also be placed in the northwest corner of the pad.
All stormwater runoff from the disturbance area will be directed to the sediment traps to allow any sediment transported in the water to settle out.
Erosion control measures will include rock socks in the ditch around the disturbance area to control the speed of water moving through the ditch and filtering sediment in the water as it passes.
Seeding and crimping straw mulch into cut/fill slopes and the topsoil pile will prevent erosion on those slopes.
Prior to seeding, soil roughening will be used to control the speed of water on slopes.
During interim reclamation the north border of the disturbance will be moved south to the new edge of the pad and the stormwater controls will be moved to the new edge of disturbance.
Operator shall install stormwater controls, constructed in a manner that is consistent with good engineering practices, that will prevent offsite migration of sediment/contaminant. Stormwater controls shall be installed prior to construction activities.
Gas, oil, and water flowlines will be co-located to minimize potential of erosion associated with construction of any flowline.
Operator will grade the topsoil stockpile to ensure that all surfaces can be stabilized safely and effectively.
Operator will stabilize and maintain areas needed for production operations or for subsequent drilling operations to minimize dust and erosion to the extent possible.
Vehicle tracking pads will be placed at the access road to prevent sediment transport from the facility by vehicles leaving the site.
Storage tanks and production equipment will be inside of containment to prevent any produced fluids from leaving the site with stormwater.
All chemicals on site will be in containment and/or protected from precipitation to prevent any chemical pollution from leaving the site with stormwater.
All Stormwater control measures will be inspected at the following frequencies:
o Storm water controls are inspected every 14 days during construction, drilling, and
completions.
o Once per month after that, until interim reclamation is completely established
(approximately 2 years).
o Once per year after that until facility abandoned.
Operator will manage potential pollutants located onsite by sealing, wrapping, covering, or having containment/protection while not actively being used in order to eliminate/minimize contact with stormwater runoff, and prevent discharges of chemicals or other materials from the site.
Operator will practice proper storage, safe-handling, good housekeeping and spill prevention practices and procedures to prevent pollutants or contaminants from leaving the site.
Energy dissipaters such as coconut blankets, straw mulch, rock socks, or straw waddles will be installed during construction and will be left in place and maintained for the life of the project or until disturbed slopes have been revegetated and stabilized. Locations for these BMPs will be dictated by the Site Specific SWMP. |
| Material Handling and Spill Prevention | Form: (02A )
402966313
12/15/2022 | AVO (Audio, Visual, Olfactory) inspections of pipe and connections will be performed daily on production equipment to detect leaks which will be immediately corrected, repaired and reported to COGCC as required. AVO inspections will include all production equipment, wellheads and flowlines on site.
Separators are encompassed by steel berms lined with an impervious poly or spray in liner and on top of road base that is approximately 1-2 feet to greatly minimize impact to the soil from any potential leak or drip from the separators. Sites are visited and inspected daily so a spill would be detected and cleaned up before any significant infiltration could occur. The berms would contain a spill from leaving the area around the separators.
Tank secondary containment will be lined with an impervious poly or spray in liner. Steel berms are able to contain spills with capacity > 150% volume of the largest tank. Pad will also have tertiary containment of ditch and berm to prevent any spills from leaving site. Any spills will be immediately cleaned up and reported if volume exceeds reporting limit.
Operator’s wells have remote monitoring and shut-in capabilities to mitigate spills and safety issues. Remote shut-in will allow Operator to immediately shut a well in the event of a reported problem on location or in the event of a potential threat such as a grass fire or flood.
Operator’s wells have remote monitoring and shut-in capabilities to mitigate spills and safety issues. Remote shut-in will allow Operator to immediately shut a well in the event of a reported problem on location or in the event of a potential threat such as a grass fire or flood.
All pressure piping and facilities are pressure tested and inspected according to Verdad’s Flowline Installation, Inspection and Repair SOP and in compliance with flowline integrity testing per 1100 Series Rules.
Annual SPCC inspections ensure fluid storage, processing, transport and handling equipment and
containment integrity and operation.
All fluid handling employees are trained annually on spill prevention and response.
Verdad has developed a robust Leak Detection and Repair (LDAR) program, which utilizes Infrared cameras to identify and fix leaks. The infrared gas detection camera is an Approved Instrument Monitoring Method (AIMM). These inspections will begin during the drilling phase and continue throughout the life of the Oil & Gas Location. These AIMM inspections will be conducted on a monthly frequency.
To minimize potential impacts to soil, containment will be used during fueling of equipment to contain spills and leaks during all phases of operations.
The fluid transfer system used during completion operations is monitored from the on-site mobile command center for changes in pressure, volume, or rate which are used as indicators for leak detection.
Operator utilizes polyethylene liners beneath the areas where completions equipment (including pump trucks and other heavy equipment) is placed on the pad to ensure there is an impermeable layer between the equipment and the ground.
A polyethylene liner beneath the drilling rig during drilling operations to ensure there is an impermeable layer between the rig and the ground to detect and capture leaking fluids. |
| Dust control | Form: (02A )
402966313
12/15/2022 | Operator will reduce traffic and dust associated with transporting completions water and produced liquids through the use of pipelines, large tanks, and other measures.
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 by wind.
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. To control dust, we will reduce speed on unpaved public roads. If there is any additional dust after the above measures have been taken, we will employ water trucks to mitigate dust. Dust control on unpaved county roads will be conducted in coordination with Public Works.
Restriction of construction activity during high-wind days. On windy days or days when dust becomes fugitive (leaves or threatens to leave the site) construction or activities will be halted until either fresh water can suppress dust or dust is no longer visible.
Use of a gravity fed box proppant delivery system that meets OSHA standards, rather than the historic pneumatic trailer proppant transfer system that blows sand out of the trailer into frac sand silos on the location; a method that required supplemental dust control to meet OSHA requirements. With a gravity fed proppant delivery system, the delivery container is also a well pad storage container, eliminating the need for frac sand silos on location. Storing frac sand in containers reduces sand dust during fracing operations by dropping sand directly from the container into the blender sand hopper.
To prevent dust from becoming a nuisance to the public, Mag Chloride will be utilized before construction on access road. To control dust, we will reduce speed on unpaved public roads. If there is any additional dust after the above measures have been taken, we will employ water trucks to mitigate dust. Dust control on unpaved county roads will be conducted in coordination with Public Works
Operator will be utilizing centralized storage facilities for fresh water, allowing us to limit the number of truck trips on and off location. During drilling operations all continuous operations personnel live on location. During completions operations a Operator supervisor lives on location, a majority of the frac crews travel via bus. All of the above will substantially reduce truck traffic. In addition, logistical traffic management will be
conducted in a manner that loads will be minimized as the opportunity allows.
Maximum speed on all roads constructed and maintained by the operator will not exceed 25 mph. |
| Noise mitigation | Form: (02A )
402966313
12/15/2022 | 1. Operator will comply with the maximum permissible noise levels specified in Rule 423.b.(1).
2. Operator will install temporary sounds walls to comply with COGCC and Relevant Local Government requirements. Sound walls will be installed for the duration of drilling and completion activities and will be placed a on all sides of the perimeter on the pad as indicated below to reduce impacts to nearby receptors.
3. The utilization and placement of these sound walls is driven by a forecasted Noise Impact Assessment that incorporates the applicable drilling rig and frac fleet noise signatures which are placed on to the topography of the site location. The sound model and assessment will provide mitigation methods that can be applied to bring an operation into compliance if needed. Verdad plans to utilize a “quiet” frac fleet.
4. The direction of prevailing winds is considered when planning the location in order to mitigate odor and noise from being a nuisance to the surrounding residents and occupied structures. In order to minimize sound levels during drilling operations at nearby residences, rig generators will be located as far as possible from the residence by rig orientation.
5. A topsoil pile will be located on the North side of the proposed location. This soil pile will further help to reduce impacts of noise to the nearest Building Unit Owner located to the North of the location.
|
| Emissions mitigation | Form: (02A )
402966313
12/15/2022 | Operator will not flare produced gas during normal operations.
Flowback fluid emissions will be captured in vapor tight tanks with emissions controlled at the combustor.
Operator will use supervisory control and data acquisition (SCADA) systems to monitor well operations, which will reduce emissions from vehicle traffic due to the reduced number of vehicle trips to the site.
Operator has an 24/7 SCADA System Monitoring that allows for continuous monitoring operating conditions when personnel are not on-site in order to identify and correct any improper operations as soon as possible.
Operator has a sophisticated Directed Inspection/Preventative Maintenance (DI/PM) program that contributes to the decrease in fugitive emissions and spills related to non-functioning or aging equipment. Operator completes daily audio/visual/olfactory observations at every active location which provides early detection of equipment malfunctions thereby minimizing emissions from leaks.
Operator will capture produced water storage tank emissions and route them to an emission control device with at least 95 percent design destruction efficiency.
Operator will use non-emitting pneumatic controllers at both the well heads and the production facilities.
Operator will utilize Lease Automatic Custody Transfer (LACT) to transfer the condensate product directly into a pipeline, eliminating truck traffic for condensate oil transport.
Operator will have a gathering line for gas transmission. Operator is working on an agreement with Taproot and plan to also have a crude gathering line by the time we are on location.
Operator will employ perimeter air quality equipment to continuously monitor the air around the site during pre-production and for the first six months of production.
Tanks and Vapor Control Systems will also be designed and constructed in accordance with Air Quality Control Commission Regulation Number 7.
Operator will implement a Leak Detection and Repair program (LDAR). The LDAR would involve monthly inspections using infrared (e.g., FLIR) cameras.
Operator will employ perimeter air quality monitors.
Operator will use temporary lay flat lines and an MLVT to reduce traffic associated with transporting drilling and completions water. Operator will utilize a tank-lite facility design which includes an oil line to transport oil production, reducing truck traffic and tank emissions;
• Operator will minimize vehicle and engine idling
• Operator will reduce truck traffic and worker traffic
• Operator will postpone the refueling of vehicles
• Operator will consider postponing the initiation construction activities
• Operator will reschedule non-essential operational activities such as pigging, well unloading and tank cleaning
• Operator will postpone flowback if emissions cannot be adequately captured with a vapor recovery unit
• Operator will eliminate use of VOC paints and solvents
• Operator will suspend or delay the use of non-essential fossil fuel powered ancillary equipment |
| Odor mitigation | Form: (02A )
402966313
12/15/2022 | Identify Sources
Verdad will identify all potential sources of odors and emission points and conduct emission or leak monitoring for
all tanks, compressors, knockout, and oil/water separation vessels. This is including any pressure relief devices or
vacuum devices attached to the vessels, and keep records of any releases from such devices. |
| Odor mitigation | Form: (02A )
402966313
12/15/2022 | Development Phase
Verdad will comply with the requirements of COGCC Rule 426 during development through the mitigation
methods outlined below. Verdad will make all attempts to prevent odors from emanating from the Oil and Gas
Location by proactively addressing known sources of odor.
Operator shall wash the rig of oily debris before moving in.
Operator shall utilize a gas buster on the closed loop drilling system to control any gas while drilling.
Operator shall utilize drilling fluids with low aromatic content, D822 which is a distillate, and has shown to have
lower odor than a traditional oil-based mud.
Operator shall utilize drying shakers or vertical dryers which will minimize residual oil on cuttings prior to
transport.
Operator will promptly remove 4-5 loads of drill cuttings per day during drilling operations.
Trucks will be prohibited from idling on location when not in use to prevent accumulation of odors from exhaust.
Operator shall utilize fully green completions with full vapor recovery and control including controlled flowback
tanks, wells turned over to facility once saleable quantities are produced to eliminate prolonged flowback flaring. |
| Odor mitigation | Form: (02A )
402966313
12/15/2022 | Production Phase
This location will utilize oil tankless production to an oil pipeline, eliminating the largest source of emissions, oil
tanks.
Operator shall utilize auto gauging to eliminate thief hatch openings during produced water loadouts.
A robust Leak Detection and Repair (LDAR) program with an audio, visual, olfactory program is planned for this
location as part of an overall leak and spill detection plan. |
| Drilling/Completion Operations | Form: (02A )
402966313
12/15/2022 | • Most work operations will take place 7-days a week & 24-hour a day. Care will be taken to keep lighting levels at the specified levels on the lighting plans while providing 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.
• No permanent lighting is proposed for this project. 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 3-head and 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 should 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.
• Wall Panels (e.g., visual/sound walls) will be placed along the edges of the WPS and will be removed following Flowback Operations.
• 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 to conform to the lighting plan.
• Equipment shall be operated and/or orientated and/or shielded in such a manner that lights permanently 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.
• Any additional light units used to address workplace safety concerns that are not shown on the lighting photometric plans will be verified by a lighting engineer to ensure that the modified lighting will remain within the required lighting standards stated in this report.
• Where safely applicable, the following are suggestions to aid in controlling and minimizing the site's lighting levels:
o Using automation, timers, or motion sensors
o Using or changing fixtures to full cut-off lighting fixtures to shield and direct light
o Using or changing to lighting colors that reduce light intensity
o Using or changing low-glare or no-glare lighting
o Adjusting or adding additional light shields such as photometric diffusion fabric or tinted membranes
o Adjusting or adding additional temporary wall panels (e.g., visual/sound walls) |
| Drilling/Completion Operations | Form: (02A )
402966313
12/15/2022 | MLVT Size is 120’DX14’H and the volume is 25,000 BBLS. Vendor/Manufacture will be Select Energy Services. It will be on location for 45 days during completion operations. Operator will follow the COGCC guidance policy dated June 13, 2014 on the use of MLVTs. |
| Drilling/Completion Operations | Form: (02A )
402966313
12/15/2022 | Operator will use temporary lay flat lines to transport water during completion operations. |
| Interim Reclamation | Form: (02A )
402966313
12/15/2022 | During initial pad construction, the topsoil will be stripped from the disturbance area and stored onsite for future use during pad pull-back and interim reclamation. All stockpiled topsoil will be protected from degradation due to contamination, compaction, and, to the extent practicable, from wind and water erosion. This will be achieved initially by applying cat-tracking/soil roughening to the topsoil pile and employing additional BMPs if and when needed (e.g., the addition of organic matter).
Verdad maintains a weed mitigation maintenance program to prevent the establishment of weeds on the topsoil pile and location.
The site will be inspected bi-weekly for BMP integrity and current installation. Any deficiencies noted will be addressed in a timely manner.
Verdad will grade the topsoil stockpile no steeper than 3:1 to ensure that all surfaces can be stabilized safely and effectively.
Verdad will stabilize and maintain areas needed for production operations or for subsequent drilling operations to minimize dust and erosion to the extent possible.
Verdad will implement a Spill Prevention, Control, and Countermeasure plan to protect soil from potential spills. |
| Interim Reclamation | Form: (02A )
402966313
12/15/2022 | The Location has shallow topsoil. The top 6 inches will be removed from the pad disturbance area surface and located on the north side of the pad. Any subsoil removed will be placed to the north of the topsoil pile and will be replaced underneath the topsoil when replaced during interim and final reclamation.
Erosion will be controlled by covering the pad surface with compacted road base, placing rock socks into drainage ditches, seeding disturbed areas not covered in road base and keeping slopes at 3:1 or less.
Weeds will be controlled with bare ground spraying, mowing and a local weed control company may be contracted for the removal of any weed infestations that cannot be controlled by mowing.
Interim reclamation will take place on disturbed areas affected by drilling and subsequent operations no later than 3 months after they are no longer in use.
The surrounding landscape is cropland. The downgradient direction is to the south. De Remer Lake of Banner Lakes is 610’ south of the location. The lake will be protected by the stormwater and drainage structures. |