| Pre-Construction | Form: (02A )
403185555
4/25/2023 | • The Operator will receive an orientation and training for operation, monitoring, and maintenance specific to the location.
• Prior to operation, the DEO Principal will review site readiness with the Operator. Review will include equipment, well pad maintenance, access roads, flowlines, and site security. Potential for risk to public health, safety, welfare, or the environment will be discussed at that time. Discussion will identify whether adjustment is needed for resources, materials, or practices to minimize potential risks. Significant changes will be documented as part of change management for the location.
• Contractors and vendors working on the location will be supervised by the Operator when it is necessary to do so to maintain safe operations.
• The Operator will be responsible for recommendations to improve operation of the site to avoid impacts to public health, safety, welfare, and the environment. Significant changes will require approval from the DEO Principal.
• Vendor sheets and invoices will be attached to the Change Management Checklist where needed to describe changes at the location. Operations Safety Management Program Red Rocks 3 September 2022 Best Management Practice
• DEO’s standard health and safety practices will be used to supplement the information provided in this Plan. |
| General Housekeeping | Form: (02A )
403185555
4/25/2023 | • Trash will be kept bagged or covered and will be removed from the location for disposal as domestic solid waste at an approved waste disposal facility.
• Containers will be labeled according to requirements of Rule 605.h. • Waste streams will not be commingled such that they no longer qualify as solid waste or E&P exempt waste.
• Wastes will be stored in containers or on lined containment that are chosen for compatibility and checked for leaks or integrity problems. Examples of containment include but are not limited to lined berms, lined containment, plastic totes, drums, etc.
• Good housekeeping measures will be implemented in the operating area to ensure safety and environmental health.
• Unused material will be removed for reuse at another drilling site or returned to the vendor as a product and will not be stored on the location.
• Cement returns, excess cement, oily E&P waste from a spill or release, and any other E&P waste will not be disposed of in the drill cuttings trench.
• Red Rocks 1-16 drill cuttings will be disposed of in a 1-16 drill cuttings trench. |
| Wildlife | Form: (02A )
403185555
4/25/2023 | • The operator will install and utilize bear-proof dumpsters and trash receptacles for food-related trash at all facilities that generate trash, in accordance with Rule 1202.a.(1) for black bear habitat. |
| Storm Water/Erosion Control | Form: (02A )
403185555
4/25/2023 | Short-Term
• Vegetation removal and soil disturbance on the Oil and Gas Location will be minimized to the area sufficient to site and level the drill rig and equipment.
• The operator will salvage and segregate topsoil based on soil characteristics of texture, color, structure, and consistency.
• Salvaged topsoil will be mounded on the Oil and Gas Location to a maximum height of approximately 4 feet and a slope of approximately 2:1.
• Topsoil will be protected from contamination by stockpiling it in a location free from drilling, fuel storage, and parking.
• Soil removed during flowline trenching will be segregated based on changes in physical characteristics. The soil layers will be windrowed adjacent to the trench.
• Soils from the flowline trench will be replaced promptly in the order in which they were removed. Long-Term
• The topsoil stockpile will be protected from compaction by designating it with surveyor staking and flagging as topsoil for reclamation.
• The topsoil stockpile will be protected from wind degradation by mounding at an approximately 2:1 steepness to prevent loose soils while promoting continued microbial activity.
• The topsoil stockpile will be protected from erosion by ensuring that stormwater controls and diversions are installed, where needed, to divert stormwater away from the stockpile.
• Surface roughening, crimped straw mulching, or an erosion control blanket will be used if needed to contain loose soils, while maintaining soil microbial activity.
• Vegetation will be allowed to establish on the topsoil stockpile to stabilize it, outcompete weeds, and promote soil microbial activity.
• The topsoil stockpile will be monitored and managed for weeds during weed management monitoring conducted at the Oil and Gas Location by the site operator. |
| Dust control | Form: (02A )
403185555
4/25/2023 | • Drivers will be instructed to maintain a speed of 20 mph on the access road to minimize fugitive dust, road wear, and erosion. Regular Road Maintenance • Regular inspection will occur for the access road for evidence of inadequate drainage and formation of potholes.
• Grading, blading, and filling potholes will be performed to maintain the road surface and discourage vehicles from widening the roadway or contributing to erosion. Dust Mitigation Plan Red Rocks 3 October 2022 Activity Best Management Practices Restricting Construction Activity During High Wind Days
• The 1-day well pad construction will be scheduled to avoid high-wind warnings issued for Las Animas County. Dust Suppression
• Blowing soil and failure of the soil to stabilize and form a crust on the location during construction and after interim reclamation will indicate that a dust suppression BMP is needed. In that event, a water truck will be used to wet the pad surface. Interim Reclamation
• Area not needed for production will be reclaimed in accordance with Rule 1003. Topsoil Stockpile
• The stockpile will be mounded to prevent loose soils and promote vegetative growth.
• Wheel packing, a tackifier, seeding practices, or an erosion control blanket will be used to improve short term stabilization.
• Vegetation will be allowed to establish to stabilize the stockpile, outcompete weeds, and promote soil microbial activity. |
| Construction | Form: (02A )
403185555
4/25/2023 | Structural
• Wattles will be placed on the north and south portions of the location. They will be staked in place.
• Stormwater diversions will be created when there is evidence of ponding or erosion runnels.
• The fuel tank used during well development will be double walled for secondary containment. There will be no separate fueling on the location.
• The drill rig will have a liner under the motor to capture drips or leaks.
Non-Structural
• Personnel will receive training for how spills or releases will be investigated, controlled, and contained.
• During pre-production, inspection of equipment will occur daily during well development to detect staining, drips, or leaks that could result in spills.
• Vehicles will be monitored for leaks during well development.
• During well drilling and completion, absorbent pads and absorbents will be available to support cleanup of leaks or spills. A larger incident would be bermed, and the operator would use third-party support, as needed.
• Waste materials will be bagged or containerized to avoid contact with precipitation.
• Ingress, egress, and parking will occur in designated areas.
• The well pad will be inspected for excessive erosion. Diversions will be installed if there is evidence of runnels or ponding. • Stabilization and revegetation will be performed as part of interim reclamation during the first growing season and within 6 months after well development is complete.
• During production, an operator will be on site approximately twice weekly to oversee areas that require corrective action.
• The Oil and Gas Location and stormwater controls will be monitored daily during site preparation and well development. After well development, stormwater inspections will occur at a minimum of once every 7 days, Stormwater Management Plan Red Rocks 7 October 2022 consistent with stormwater requirements administered by CDPHE. The inspection frequency may be reduced to once every 30 days after ground disturbance is complete and the site is stabilized with interim reclamation.
• The location and access road will not be accessible to the public to prevent unauthorized access and excessive wear on access roads. |
| Final Reclamation | Form: (02A )
403185555
4/25/2023 | • Site personnel will be trained in spill prevention, response, and response equipment on at least an annual basis. Training will include how spills or releases will be investigated, controlled, and contained in accordance with Rule 912.a.
• Spills or releases will be investigated, controlled, or contained, in accordance with Rule 912.a.
• If a spill or release meets criteria in Rule 912.b, it will be reported as specified in the rule.
• If a catastrophic loss of freshwater occurs from the freshwater truck, soil on site will be used to berm and prevent downgradient runoff.
• Equipment and transfer lines will be monitored daily during well drilling and completion for signs of drips, leaks, or spills, which will be promptly corrected.
• Flowlines will be installed consistent with Rule 1102. In accordance with Rule 1104, before a flowline is put into service, it will be pressure tested to maximum pressure for AVO leak detection.
• The operator will maintain shutoff valves on helium gas flowlines in accordance with Rule 1103.a.
• Per Rule 1104, the operator will conduct a monthly AVO survey to detect failures or signs of leaks from the wellhead and flowline.
• The operator will conduct annual flowline integrity testing in accordance with Rule 1104.
• Site personnel will be instructed on procedures for documenting and recordkeeping inspections and testing. |
| Emissions mitigation | Form: (04 )
403689119
2/27/2024 | A permit for the gas compressor will be obtained from the CDPHE |