| General Housekeeping | Form: (02A )
402589248
12/23/2022 | • Operator will strive to minimization and reduce waste.
• Recycling produced water for Caerus’s completions operations.
• Reduction of waste by use of closed loop drilling systems to reduce the volume of drill cuttings.
• Reduction of waste by using bulk containers rather than drums.
• Unused chemicals will be transported to the next drilling site or will be sent back to the chemical provider company.
• Communication with subcontractors on waste minimization practices.
• Implement good housekeeping measures to minimally impact the operating area and maintain a well-kept appearance at all company facilities.
• Waste will be segregated and stored according to its waste classification.
• A designated storage area will be established for waste storage.
• Operator will properly characterize and dispose of all waste (i.e. the specific landfill/waste disposal location allows for acceptance of the waste stream). |
| Wildlife | Form: (02A )
402589248
12/23/2022 | • Caerus will utilize the ELU G13-496 CDP as a remote frac location. Furthermore, directional drilling is planned to minimize habitat loss and fragmentation.
• Perform biological site surveys (on-site) for each new development, using the most recent data sets for wildlife and aquatic resources (the report format is based upon Federal on-site surveys).
• Perform pre-disturbance surveys when the on-site inspection and commencement of disturbance occur in different field seasons (e.g., new raptor nests), using the most recent data sets for wildlife and aquatic resources.
• Caerus will utilize the Wildlife Resources Matrix (within the approved North Parachute Ranch Wildlife Mitigation Plan) to identify and document potential impacts or concerns during the project planning phase for proposed drilling/completion operations and construction of roads, pads, and pipelines.
• Caerus will request a one-time Federal Timing Limitation Exception for the operational season after initial construction from the BLM. If granted, Caerus will consult with CPW and, with concurrence from CPW agreeing with the BLM's decision, will submit a Form 4 Sundry Notice requesting relief from the December 15 to July 15 timing limitation in order to drill and complete al 35 wells in one occupation. |
| Wildlife | Form: (02A )
402589248
12/23/2022 | Proposed by CPW in lieu of Rule 309.e.(5).D.ii.bb, for access road and pipeline occupation within Rule 1202.c.(1).S Sportfish HPH:
1. Temporary tanks for flowback and produced water will reside within a downgradient perimeter berm on the Location and will be underlain with an impervious synthetic or engineered liner. Temp tanks will be removed once the wells have been completed.
2. Caerus will not have any permanent tanks whatsoever on the Location.
3. All wells on this Location will use a SCADA system that will notify Caerus immediately if an issue arises. Personnel will respond and address the situation immediately. CPW recommends an inspection frequency of less than once per day to avoid unnecessary disturbances to terrestrial wildlife species in the area.
4. Spill response will be conducted as described in Caerus' Fluid Leak Detection Plan.
5. Caerus will not construct any pits on the Location. |
| Storm Water/Erosion Control | Form: (02A )
402589248
12/23/2022 | • BMPs will be implemented during, on and around the disturbances associated with the well pad, soil stockpiles, access road(s), and pipeline rights-of-way. With the proposed location being on top of a ridge line, there is little to no run-on for this disturbance. BMP sizing was based on the regional 25-year 24-hour storm event. BMP topics include spill prevention and response, material delivery and storage, waste management and disposal, vehicle use and tracking controls, BMPs for potential pollution sources, inspection and maintenance schedules, and well pad control measures.
Structural
• The well pad stormwater control system will be maintained. It consists of a 6-inch-diameter drain at the center of the well pad, which is piped to a trench and stormwater catchment basin.
• The well pad fill slopes will be controlled using the 2-foot-high earthen berms, compacted to 95 percent soil/moisture density.
• Tank area secondary containment will be maintained using a lined steel containment system sized to contain 150 percent of the largest tank.
• Temporary equipment and materials used during well drilling and completion will have liners and secondary containment.
• The access road will be maintained with blading, a borrow ditch on the upslope side of the road to divert stormwater, and culverts placed along the roadway to channel stormwater.
• The flowline trench will be bored under Beaver Creek. The trench will be excavated under the existing culverts within the roadway at other drainage and intermittent stream crossings.
• Straw wattles will be staked adjacent to the windrowed soil excavated from the flowline trench to prevent runoff from loose soils.
Non-Structural
• Ingress, egress, and parking will occur in designated areas on the well pad.
• Waste materials will be bagged or containerized to avoid blowing and contact with precipitation.
• Vehicles and equipment will be monitored for leaks during well development.
• The well pad will be inaccessible to the public to prevent unauthorized access and excessive wear on access roads.
• Spill response booms and absorbents will be containerized and available on site.
• During well development and production, stormwater monitoring will occur daily. Areas that require correction for stormwater control will be addressed or repaired promptly.
• During production, stormwater inspections will be performed at least every 14 days and every 30 days after interim reclamation. Inspections will occur more frequently after significant storm or snowmelt events, in accordance with CDPHE requirements. |
| Material Handling and Spill Prevention | Form: (02A )
402589248
12/23/2022 | • To minimize any leaks during drilling a closed loop system will be utilized and personnel are onsite during drilling and completions 24/7 to inspect and monitor all equipment.
• Drilling fluid tanks have pit volume sensors and are monitored through the electric drilling recorder
• Equipment, tanks, and lines are regularly checked and monitored as personnel are on-site walking equipment 24/7.
• BOPE is pressure tested every 30 days or when a seal is broken.
• Pressure relief valves are designed with discharge into tanks.
• The on-site equipment used will be above ground and any potential leaks will be identified quickly.
• During the completions phase equipment is monitored and tracked onsite utilizing Electric Diagnose Controls which have built-in shutdown parameters to catch and prevent failures, including Vibration Control Monitoring sensors on Frac Pumps / Iron.
• All equipment/tanks are occupied & operated and monitored by personnel to prevent and respond and shutdown due to any failures/leaks/abnormalities not caught by above mention controls
• Checking of all temperatures / fluid levels / Packing and normal equipment wear & tear)
• Pumps and Equipment are placed inside of spill containments and Catch pans / berms are in place, where appropriate
• Pressure Testing of all equipment / iron is conducted before each stage, at pressures above anticipated operating pressure
• Use of Safety Systems to prevent over-pressuring of Iron.
• Safety Iron Restraints are installed on all High-Pressure Iron.
• During the flowback stage, there are personnel on-site 24 hours per day. Additionally, wells are connected though a Supervisory Control and Data Acquisition (“SCADA”) monitoring technology which allows for real-time monitoring remotely.
• During production, Caerus employees are trained to look for signs of leaks and releases through AVO; including looking at equipment conditions on-site or along pipeline rights-of-way, regardless if such a location is within their tier of responsibility. All teams work together to identify concerns. In addition, route operators, facility operators and gas control operators are trained and required to monitor. Well pads with multiple wells are visited no less frequently than weekly and are inspected for any leaks.
• Pressure testing is completed at least annually on active pipelines within the system. Facility operators have checklists built to assess daily and weekly the appearance and condition of the facility in which they operate.
• To prevent any major uncontrolled leaks caused from overpressure of piping around the new well pad meter skids, pressure safety valves (“PSVs”) will be installed, both on the upstream high-pressure side between the well and meter skid, as well as the downstream lower-pressure side of the meter. If the meter is blocked and pressure is increasing in the piping from the producing well, the upstream PSV, along with other pressure alarms and controls, will protect the piping and prevent serious leaks. The downstream PSV is being installed to protect the lower pressure rated piping for the corresponding pipelines from overpressure when a blocked flow also occurs. Pipelines generally have low and or high pressure set point alarms, which will be checked when received. There are also emergency shut down (ESD) set points to shut down equipment before an overpressure event can even occur. Data from wells are also analyzed by operators looking for variations from the norm in pressures or, where applicable, volume – when there is a variation, it warrants a site visit.
• The on-location flowlines and dump lines become part of a regular pressure testing program, as addressed in the 1100 Series Rules. In addition, there are well operators, field coordinators and others in the field that are trained to look for concerns during regular site visits and audio/visual observations if they are in the area or on-location. |
| Dust control | Form: (02A )
402589248
12/23/2022 | • Fresh water will be periodically applied to disturbance areas during construction to minimize fugitive dust.
• The construction crew will monitor wind conditions during the site construction. When necessary, freshwater will be applied to dry soils during high wind events. Caerus will evaluate site conditions and may temporarily suspend ground disturbance activities to minimize fugitive dust.
• The Sprague Gulch Road is a road maintained graveled as deemed necessary by BLM. The proposed access road will have six inches of road surfacing materials applied once constructed.
• Caerus has implemented speed restrictions on all lease roads and requires all employees and contractors to adhere to all posted speed restrictions.
• During long-term production operations, Caerus will conduct annual inspections of the existing and proposed access roads and will perform maintenance as necessary to ensure road integrity and minimize fugitive dust. Road maintenance actions may include, but are not limited to spot graveling, storm water control maintenance and periodic watering of the road(s). Caerus prefers to utilize non-chemical-based dust suppressants wherever possible, but in instances where it becomes necessary due to high wind then Caerus may utilize magnesium chloride.
• Caerus will utilize telemetry equipment to minimize will site visitation to reduce fugitive dust from vehicles traveling on the graveled roads. |
| Construction | Form: (02A )
402589248
12/23/2022 | • The pad will be constructed as designed and shown on the Construction Layout Drawings. During construction only the minimum amount of vegetation necessary for the construction of roads and facilities will be removed. Topsoil will be set aside and preserved during excavation. Topsoil be re-used as cover on disturbed areas and perimeter berms. • • No construction or routine maintenance activities are performed during periods when the soil is too wet to adequately support construction equipment.
Any stockpile(s) for topsoil and excess cut material will be located in work areas surrounded by straw wattles.
• All new flowline/pipeline installations will be performed in accordance with new flowline guidance and requirements in the COGCC 1100 Series Rules. All new offsite pipelines will be registered. |
| Noise mitigation | Form: (02A )
402589248
12/23/2022 | • Any operations involving the use of a drilling rig, workover rig, or fracturing and any equipment used in the drilling, completion or production of a well are subject to and will comply with the Agricultural maximum permissible noise levels in Rule 423.a.(2).A. of 65 db(A) in the hours between 7:00 a.m. to 7:00 p.m. and 60 db(A) in the hours between 7:00 p.m. to 7:00 a.m.
• If a noise complaint is made to either Caerus directly, the COGCC, or the local government, and Caerus is notified of the complaint, noise levels will be measured within 48 hours of receipt of the complaint; Caerus will contact the concerned party (if contact information is available) to discuss the complaint and the results of the noise measurements. |
| Emissions mitigation | Form: (02A )
402589248
12/23/2022 | • Caerus will implement enhanced green completions best management practices by routing all natural gas, liquids and produced water to a centralized facility where production will be stored and processed. Caerus will not vent or flare production. Caerus will comply with all applicable air regulations implemented by the Air Quality Control Commission. |
| Drilling/Completion Operations | Form: (02A )
402589248
12/23/2022 | • DRILL CUTTINGS: Solids control equipment consisting of shale shakers, centrifuges, and flocculating units will be utilized to separate drill cutting solids from liquid(water). Drill cuttings maybe segregated between surface casing cuttings, and production zone cuttings and stockpiled on location. Cuttings samples will be collected every 1000 cubic yards and will be submitted for laboratory analysis of COGCC Table 915-1analytes. Drill cuttings will be managed pursuant to COGCC rule 905.e.until sampling and analytical data demonstrates them compliant with COGCC Table 915-1. Water based drill cuttings that exceed Table 915-1 for constituents listed under soil suitability for Reclamation will be managed per COGCC Rule 905.g.(2).and pursuant to Rule 915.b. If cuttings meet Table 915-1 standards, they will be managed under beneficial reuse on location. They could also be used under beneficial reuse, at another location, if approved by COGCC through a Sundry Form 4. Any excess cuttings may potentially be transported to an authorized waste facility. The moisture content of any cuttings shall be as low as practicable to prevent accumulation of liquids greater than de minimis amounts cuttings may be mixed with waste cement to act as a drying agent. In the event that a drill cuttings analytically demonstrate constituents above Table 915-1 standards, these cuttings will be remediated per COGCC rule 905.e(2). Pursuant to Rule 304.c.(11) cuttings management details can be found in the Waste Management Plan attached.
• FLOWBACK & STIMULATION/CONTAINMENT: Caerus will be completing the wells from a remote location, the ELU G13-496 CDP, which will serve as the support pad and central delivery point, therefore no permanent tanks will be situated on the ELU A18-495 well pad. As wells progress from the drilling stage to the completions stage temporary working tanks will be situated on the ELU A18-495 Well Pad. Completion operations will be conducted from the off-site ELU G13-496 CDP via a buried frac line that will have a riser near the wells to be completed.
• On the ELU A18-495 location, wireline trucks, data van and an estimated 15-20 500-bbl tanks will be on location for roughly 18-months as the wells progress from the drilling to completions stage during Sim-Ops. The contents of the tanks will contain produced water. The temporary tanks will be placed on a certain portion of the ELU A18-495 Well Pad and laid upon an impervious synthetic or engineered liner which would be underlaid by road base. The liners will be sufficient to hold up to 150% of the largest tank on the location. Note, the entire Oil and Gas Location for the ELU A18-495 will include a compacted earthen berm perimeter around the operational area for ELU A18-495 Well Pad. Once the working tanks are no longer necessary for operations both the tanks and the impervious liner will be removed. |
| Drilling/Completion Operations | Form: (02A )
402589248
12/23/2022 | Lighting
• Caerus will use low-glare or no-glare lighting and will conduct lighting inspections to confirm lighting fixtures are orientated correctly.
• Working areas within the working pad surface (WPS) will be adequately lit to aid in safe working conditions during all low-light working times (e.g., night-time, dusk, dawn, overcast). Lighting shall conform with all OSHA, IESNA, and ANSI standards. 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.
• For non-working or shut-down days where no personnel are on-site or in working areas, nonessential 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.
• Equipment shall be operated and/or orientated 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.
• Any lighting damaged and/or improperly directed or angled will be promptly fixed and/or corrected to conform to this lighting plan.
• For work-place safety concerns, no direct or reflected direct light shall shine towards the entrance of the WPS. |
| Interim Reclamation | Form: (02A )
402589248
12/23/2022 | • Timing - Interim reclamation will begin within 6 months after the last well is completed and the site is transitioned from well completions to production operations. Run-off and sediment control will be addressed when the soil is mostly dry and when seasonal and weather conditions are most favorable. Typically, road and location blading will occur after the winter and spring seasons.
• Waste Disposal - Caerus will properly characterize and dispose of waste in accordance with its Waste Management Plan.
• Recontouring - Disturbed areas will be recontoured to blend with the pre-disturbance surface and restore natural drainage patterns.
• Topsoil - Topsoil stored on the location will be restored on the reclaimed area. Salvaged topsoil will be replaced and contoured to maximize erosion control and soil stability.
• Erosion control - Erosion controls will be maintained to prevent stormwater run on, runoff, and erosion.
Stormwater controls during production are shown on the attached Facility Layout Drawing.
• Seedbed Preparation - Gravel or surface material will be removed or redistributed during interim reclamation.
Areas to be reclaimed will be cross ripped to an estimated depth of 18 inches unless restrictive features are
encountered at a shallower depth.
• Seed mix - Caerus will broadcast or hydroseed the U.S. Forest Service Native Plant Materials Program certified weed-free recommended seed mix.
• Weed control - The location will be monitored for the presence of invasive weeds. Invasive weeds will be treated to prevent them from establishing or spreading.
• Access - Unauthorized access will continue to be restricted by the locked gate to TPR at the northern end of the Tepee Park Ranch road.
• Monitoring - The location will be monitored for vegetative success. It will be reseeded where needed to establish 80 percent of pre-disturbance cover. |
| Final Reclamation | Form: (02A )
402589248
12/23/2022 | • The disturbed areas surrounding the well location, including the access road will be recontoured to blend as nearly possible with the natural topography. Final grading of backfilled and cut slopes will be done to prevent erosion and encourage establishment of vegetation. Previously existing drainages will be re-established.
• The long-term objective is to establish a self-perpetuating plant community that is compatible with and capable of supporting the identified land use. Noxious weeds will be treated in accordance with applicable COGCC rules and county weed management requirements. For more detailed information please review the Final Reclamation Plan attached. |
| Storm Water/Erosion Control | Form: (04 )
403532160
10/14/2024 | Caerus Piceance LLC (Caerus) wishes to replace the existing BMP #4 to state the following as a result of the new SWMP that is attached:
- Strive to minimize the area of disturbance.
- Caerus has created and provided the Stormwater Management Plan (Plan) as required by the Colorado Energy & Carbon Management Commission (ECMC) Rule 304.c.(15). This Plan, per Rules 1002.f.(2), describes the Best Management Practices (BMPs) that will be implemented to address the potential pollutant sources that may reasonably affect the quantity and/or quality of stormwater discharge at the proposed oil and gas facility. Caerus will maintain the site-specific BMPs until the facility is Final Reclaimed, per Rule 1004, and Bond Release has been received. The site-specific stormwater BMPs employed at the disturbance will comply with ECMC, Colorado Department of Public Health and Environment (CDPHE) and White River Field Office Bureau of Land Management (BLM) stormwater regulations. The disturbance will be incorporated into Caerus’ North Piceance field wide Stormwater Management Plan in compliance with CDPHE Water Quality Control Division (WQCD) General Permit No. COR4400646, will abide by ECMC’s stormwater Rule 1002.f., and follow BLM Gold Book expectations. Per COGCC Rule 1002.f.(3), Caerus has developed a field wide Post-Construction Stormwater Program. The Post-Construction Stormwater Management Plan (PC-SWMP) goes into effect when a disturbance meets final stabilization requirements set forth by CDPHE WQCD General Permit.
- Implement control measures to minimize the discharge of pollutants from potential pollutant sources at the site.
- Implement Controls Measure (CMs) for Temporary and/or Final Stabilization on our disturbances. Caerus is committed to installing Perimeter Controls until Temporary or Final Stabilization CMs can be implemented.
Minimize erosion during discharge.
- Stormwater runoff from all disturbed areas and soil storage areas must utilize or flow to one or more control measures to minimize erosion or sediment in the discharge.
- Structural and nonstructural vehicle tracking controls shall be implemented to minimize vehicle tracking of sediment from disturbed areas and may include tracking pads, minimizing site access, and downgradient sediment control measures. |
| Storm Water/Erosion Control | Form: (04 )
403532160
10/14/2024 | Caerus Piceance LLC (Caerus) requests to entirely remove Operator Proposed BMP #14 for stormwater inspections: Operator will conduct stormwater inspections immediately after storm event as a result of the new SWMP that was created for this location and attached. |
| | Form: (04 )
404133532
12/4/2025 | During the rig stack: The drilling contractor is keeping a watchman on location at all times day and night to ensure there are no unauthorized persons entering the location. This individual also is inspecting the location daily for any issues related to the fluids and equipment on location. QB has increased the frequency of stormwater inspections from bi-weekly to weekly. Stormwater inspections will also be conducted after a storm event. In addition, other QB personnel will frequently visit the location to ensure there are no issues with equipment and materials on site.
Frac operations are anticipated to continue throughout the next 90-days so work will be continuously conducted on site. This plan will remain in place until drilling activity resumes. |