| General Housekeeping | Form: (02A )
403161663
10/3/2023 | Light Mitigation BMPs, Construction Phase:
• During construction of all phases, KMOG will only conduct day light operation and there will be no nighttime operations that require lighting.
Drilling Phase:
• KMOG will utilize LED fixtures to reduce skyglow.
• KMOG will position all lights to point in a downward direction where vertical lighting is not required. Where it is required, lights are angled in a vertical direction to provide task lighting for safety and operations involving personnel.
• Derrick mast lighting in Section 6.1 is facing horizontally to provide adequate lighting for safe operation.
• Lighting is angled to mitigate the amount of light leaving the location boundary, and away from surrounding off site buildings.
• Lighting within the Drilling area has been reduced to provide a minimum acceptable value for safe operation.
• Light masts are automatically switched off/on based on lighting sensors.
• Lights are switched off when not required.
• Low power (63 W) LED lights are used for the drill rig.
• In the event of a lightning complaint, KMOG will address the complaint and work with all parties involved to ensure the complaint is resolved.
Completions and Flowback Phases:
• KMOG will utilize LED fixtures to reduce skyglow.
• KMOG will position all lights to point in a downward direction where vertical lighting is not required. Where it is required, lights are angled in a vertical direction to provide task lighting for safety and operations involving personnel.
• Lighting is angled to mitigate the amount of light leaving the location boundary, and away from surrounding off site buildings.
• Lighting within the Completion and Flowback areas have been reduced to provide a minimum acceptable value for safe operation.
• Light masts are automatically switched off/on based on lighting sensors.
• Lights are switched off when not required.
• Lights are directed to task areas only.
• A 170 ft. long, 32 ft. high sound barrier will be constructed on the East side of the well pad, which will limit the amount of light leaving the property to the East.
• In the event of a lightning complaint, KMOG will address the complaint and work with all parties involved to ensure the complaint is resolved.
Production Phase:
• KMOG will utilize LED fixtures to reduce skyglow.
• KMOG will position all lights to point in a downward direction, in order to mitigate light leaving the location boundary.
• Lighting within the Production areas have been reduced to provide a minimum acceptable value for safe operation.
• In the event of a lighting complaint, KMOG will address the complaint and work with all parties
Kerr McGee Oil & Gas Onshore LP Labrisa 11-35 HZ Lighting Mitigation Plan involved to ensure the complaint is resolved. |
| Wildlife | Form: (02A )
403161663
10/3/2023 | An environmental assessment will be conducted immediately prior to pad construction, drilling, and completion operations. |
| Wildlife | Form: (02A )
403161663
10/3/2023 | • . Inform and educate employees and contractors on wildlife conservation practices, including no hunting, harassment, or feeding of wildlife.
• Consolidate and centralize fluid collection and distribution facilities to minimize impact to 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.
• Share and consolidate new corridors for pipeline rights-of-way and roads to minimize surface disturbance.
• Engineer new pipelines to reduce field fitting and reduce excessive right-of-way widths and reclamation.
• Mow or brush hog vegetation where appropriate, leaving root structure intact, instead of scraping the surface, where allowed by the surface owner.
• Limit access to oil and gas access roads where approved by surface owners, surface managing agencies, or local government.
• Post speed limits and caution signs to the extent allowed by surface owners, Federal and state regulations, local government, and land-use policies.
• Use wildlife-appropriate fencing where acceptable to the surface owner.
• Use topographic features and vegetative screening to create seclusion areas, where acceptable to the surface owner.
• Use remote monitoring of well production.
• Reduce traffic associated with transporting drilling water and produced liquids through the use of pipelines, large tanks, or other measures.
• Install automated emergency response systems (e.g., high tank alarms, emergency shutdown systems. |
| Storm Water/Erosion Control | Form: (02A )
403161663
10/3/2023 | KMOG will properly test for and dispose of TENORM
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| Storm Water/Erosion Control | Form: (02A )
403161663
10/3/2023 | Stormwater will be managed during construction by a combination of site-specific erosion and sediment control measures including: delineation of limits of construction to establish a work space; a vehicle tracking control placed along the southeast portion of the access road to the well pad and the facility pad to mitigate off-site sediment migration from vehicle traffic onto Weld County Road 47, approximately 0.50 miles southeast of the location; a temporary diversion ditch & berm around the entire location to manage run-on and run-off; temporary spillways and outlet structure placed in the northern, northwestern, northeastern, southwestern, and southcentral portions of the disturbance area ditch and berm which will allow for settling of sediment from stormwater prior to discharge; ~2 permanent culverts with inlet and outlet protection will be installed in the primary location access points to direct stormwater to designated discharge points; seed & mulch to stabilize areas no longer needed for construction, as well as for topsoil stockpiles which will remain in place until interim and final reclamation. During active construction, daily inspections will be completed by on-site personnel. A contractor will conduct stormwater compliance inspections every 14-days and/or following a rain event which produces 0.25” of precipitation or equivalent snow melt which causes surface erosion. Inspections will review all control measures / BMPs implemented, their status, and whether repair or replacement is needed. Maintenance and repair will be completed as soon as practicable, immediately in most cases. |
| Storm Water/Erosion Control | Form: (02A )
403161663
10/3/2023 | Ditch and berm shall be installed around the perimeter of the location, and subsequently around all topsoil stockpiles, to intercept and divert stormwater run-on/run-off and sediment from precipitation and melt events.
Track packing all topsoil stockpiles will occur to prevent erosion from stormwater and wind, as well as provide temporary stabilization.
Seeding and crimped straw mulch will be applied to prevent erosion and soil loss from stormwater and wind.
Vegetation establishment through seeding efforts will promote soil health and maintain carbon exchange.
Weed control will occur seasonally and as needed to hinder the spread of weeds throughout the topsoil stockpile(s) and help native grass establishment.
Ditch and berm shall be installed around the perimeter of the location, and subsequently around all topsoil stockpiles, to intercept and divert stormwater run-on/run-off and sediment from precipitation and melt events.
Track packing all topsoil stockpiles will occur to prevent erosion from stormwater and wind, as well as provide temporary stabilization.
Seeding and crimped straw mulch will be applied to prevent erosion and soil loss from stormwater and wind.
Vegetation establishment through seeding efforts will promote soil health and maintain carbon exchange.
Weed control will occur seasonally and as needed to hinder the spread of weeds throughout the topsoil stockpile(s) and help native grass establishment.
Vegetation establishment through seeding efforts will promote soil health and maintain carbon exchange.
Weed control will occur seasonally and as needed to hinder the spread of weeds throughout the topsoil stockpile(s) and help native grass establishment. |
| Material Handling and Spill Prevention | Form: (02A )
403161663
10/3/2023 | All storage tanks used for active production rig drilling operations, used in lieu of pits, will contain pit level monitors with Electronic Drilling Recorders (EDR). KMG uses EDRs with pit level monitor(s) and alarm(s) for production rigs. Basic level gauges will be used on tanks associated with the surface rig. |
| Material Handling and Spill Prevention | Form: (02A )
403161663
10/3/2023 | KMOG will refuel vehicles only on impervious surfaces and never during storm events.
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| Material Handling and Spill Prevention | Form: (02A )
403161663
10/3/2023 | KMOG will ensure that a fueling contractor is present during the entire fueling process to prevent overfilling, leaks and drips from improper connections
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| Material Handling and Spill Prevention | Form: (02A )
403161663
10/3/2023 | KMOG will not use PFAS on location
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| Dust control | Form: (02A )
403161663
10/3/2023 | • KMOG will proactively deploy fresh water to suppress dust along access road to well pad/ facility during all phases of pre-production operations
• Speed limits will be reduced to 10 mph on access road and 5 mph once vehicles reach well pad/facility
• Access roads and Vehicle Tracking Control will receive maintenance as needed throughout operations
• In the event of high winds that generate dust that cannot be mitigated with an application of water, KMOG will shut down construction operations
• During the Completions phase, KMOG will utilize a fully enclosed sand containerized proppant delivery system that eliminates the use of pneumatic transfer on location. This methodology utilizes a gravity choke feed system that reduces dust significantly. The dust levels from this system are minimal and below Occupational Safety and Health Administration (OSHA) permissible exposure limit which eliminates the need for additional Personal Protective
Equipment (PPE) |
| Construction | Form: (02A )
403161663
10/3/2023 | KMOG will extend an existing access road off of N. Oak St to access the location for drilling, completions, and production operations, including maintenance of equipment. The road will be properly constructed and maintained to accommodate for emergency vehicle access. |
| Construction | Form: (02A )
403161663
10/3/2023 | The completed wellsite will be surrounded with a fence and gate with adequate lock to restrict access to authorized personnel only. KMOG personnel will monitor the wellsite upon completion of the wells. Authorized representatives and/or KMOG personnel shall be on-site during drilling and completions operations. |
| Construction | Form: (02A )
403161663
10/3/2023 | KMOG will only construct during day light and there will be no nighttime operations that require lighting. |
| Construction | Form: (02A )
403161663
10/3/2023 | Fluid Leak Detection BMPs:
Material Handling and Spill Prevention
The following site-specific best management practices will be used on location: The temporary produced water storage tanks will be staged on a geosynthetic liner and surrounded by an earthen berm. The berms will enclose an area sufficient to provide secondary containment for 150% of the volume of the largest single tank and will be sufficiently impervious to contain spilled or released material. Berms and the liner and all secondary containment devices will be inspected at the same time as stormwater inspections, with personnel on location, daily inspections will occur. During nonactive, but while under construction, site inspections will occur every 14 days. During the production phase, a geosynthetic liner will be laid under the permanent tanks on this location and a metal containment will be constructed. Secondary containment devices will be constructed around crude oil, condensate, and produced water storage tanks and will enclose an area sufficient to contain and provide secondary containment for 150% of the largest single tank. Secondary containment devices will be inspected at the same time as stormwater inspections, with personnel on location, daily inspections will occur. During non-active, but while under construction, site inspections will occur every 14 days. When construction is completed and the Location is on production, site inspections will occur every 28 days.
Drilling Operations
During drilling operations, the following site-specific best management practices will be used: Appropriate secondary containment will be utilized when equipment maintenance is conducted on location. KMOG will shut down transfer pump and close supply valve when transfer or circulation is completed. KMOG will ensure fluids cannot enter holding tank through gravity feedback. Pre-job inspection will be conducted prior to start up which include the visual inspection of hoses, lines, and valves to ensure proper connection and alignment. During operations, all fluid containing equipment is inspected daily.
Completions Operations
During completions operations, the following site-specific best management practices will be used: KMOG will monitor pressure responses and containment to identify potential leaks. Lines will also be walked continuously throughout operations (between stages) to identify potential leaks. In addition, there is a slam valve and control valve with Emergency Shut Down system in line to the external temp tanks to prevent overflowing tanks during the green flowback duration.
Production Operations
During production operations, the following site-specific best management practices will be used: Automation technology will be utilized at this facility. This technology includes the use of fluid level monitoring for the tanks and produced water sumps, high-level shut offs, and electronic sensors to monitor the interstitial space of double-walled produced water sumps. All automation is monitored by Kerr-McGee's Integrated Operations Center (IOC), which is manned 24 hours per day, 7 days per week. All personnel on location on behalf of KMOG are trained in AVO techniques. All personnel are empowered with ‘Stop Work Authority’ and to report any leaks immediately. |
| Noise mitigation | Form: (02A )
403161663
10/3/2023 | KMOG has conducted a Noise Impact Assessment for each phase of operations (drilling, completions, and production) to assess operational noise levels against the maximum allowable dBA and dBC noise levels stated in the ECMC Rule 423 noise regulation. Each phase of operation will comply with the maximum permissible noise levels as summarized in Table 3 of Section 2 of this document.
KMOG will utilize a modified drilling rig designed to reduce overall noise levels. This will include low noise level shale shakers and modifications to the generator house to reduce noise levels from the exhaust vents and radiator fans. Additional noise reduction modifications may also be implemented depending on the rig contractor utilized following a noise survey study.
Prior to commencement of completion operations, KMOG will install approximately 180 linear feet of 32-foot-tall, engineered sound wall rated at STC-32 on the east side of the pad.
KMOG will utilize a Low Noise Completions Fleet for completions operations.
If the drilling rig or completions fleet is changed prior to commencement of operations, the mitigation measures will be equally or more protective. A sundry form will be submitted to outline any changes per both codes as required.
A pre-operational ambient sound level survey was conducted at the four locations outlined in Figure 2 of Section 7 to quantify pre-existing A and C-weighted sound levels.
Throughout the duration of preproduction operations and any construction lasting longer than 24-hours, KMOG will conduct continuous noise monitoring at Monitoring Point 1 described in Figure 2 of section 7 of this document.
KMOG will post contact information to receive and address noise complaints arising from pre-production operations around the clock, 24-hours, 7 days per week. Upon receipt of a complaint, either directly to KMOG, from the ECMC, or from Weld County, a KMOG representative will contact the relative stakeholder within 48-hours of receipt. |
| Emissions mitigation | Form: (02A )
403161663
10/3/2023 | Temporary ECD(s) will be utilized to mitigate releases of emissions from temporary produced water storage tanks for the duration which the tanks are on location and being used. |
| Emissions mitigation | Form: (02A )
403161663
10/3/2023 | KMOG commits to monitoring ambient air quality during drilling and completion operations and for the first 6 months of production in accordance with Reg. 7 |
| Emissions mitigation | Form: (02A )
403161663
10/3/2023 | KMOG will properly maintain vehicles and equipment
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| Emissions mitigation | Form: (02A )
403161663
10/3/2023 | KMOG will use non-emitting pneumatic controllers
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| Emissions mitigation | Form: (02A )
403161663
10/3/2023 | KMOG will use a natural gas drilling rig
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| Emissions mitigation | Form: (02A )
403161663
10/3/2023 | KMOG will not ulitize tanks for oil storage, other than maintence tanks. KMOG will have adequate and committed pipeline take away capacity for all produced gas and oil. Produced water will be trucked off location.
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| Emissions mitigation | Form: (02A )
403161663
10/3/2023 | KMOG will not flare or vent gas during completion or flowback, except in upset or emergency conditions, or with prior written approval from the Director for necessary maintenance operations
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| Emissions mitigation | Form: (02A )
403161663
10/3/2023 | KMOG will control emergency flaring with an enclosed combustor with a destruction efficiency of 98% or better
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| Emissions mitigation | Form: (02A )
403161663
10/3/2023 | KMOG will control bradenhead/casinghead venting
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