| Community Outreach and Notification | Form: (02A )
403096386
12/8/2023 | By planning single occupation drilling and completion phases, this will minimize the long-term traffic to the location as well as minimize the traffic, noise, and other potential nuisance factors for current and future residents in the area. |
| Traffic control | Form: (02A )
403096386
12/8/2023 | Revised CDPHE language: Pipelines: Operator will use pipelines to transport water for hydraulic fracturing to location. |
| General Housekeeping | Form: (02A )
403096386
12/8/2023 | Preproduction Phase: • Lights are angled away from surrounding off site buildings • Lighting for preproduction has been reduced to provide a minimum acceptable level for safe operation. • Lights are switched off when not required. • Lights are directed to task areas only. • Light masts are automatically switched on and off based on a lighting sensor.
Production Phase: Lighting levels do not exceed 10-foot candles. • Type H lights are specified with IDA Dark Sky approved fixture with visor. • Type H lights fixtures are mounted at a height of 12 feet above grade. • Lights are to be provided with a photocell sensor which automatically turns on when at dusk and turns off during daylight hours. |
| General Housekeeping | Form: (02A )
403096386
12/8/2023 | • Onsite E&P Waste Storage will be stored in compatible containers or engineered containment devices. The containers will be regularly inspected to ensure they are in good condition and free of excessive wear, structural issues, or other defects that may impact their effectiveness. MRG, LP CE Pad Waste Management Plan • Operator will not bury or burn trash or other waste materials at this location. • Trash receptacles will be designed, maintained, and operated to protect public safety and the environment from exposure to overflowing, leak prone, or insecure trash receptacles. |
| General Housekeeping | Form: (02A )
403096386
12/8/2023 | Lighting: All lights will be directed downward and inward such that no light shines above a horizontal plane passing through the center point light source.
Drilling Phase: • Lights are angled away from surrounding off site buildings • Lighting for preproduction has been reduced to provide a minimum acceptable level for safe operation. • Lights are switched off when not required. • Lights are directed to task areas only. • Light masts are automatically switched on and off based on a lighting sensor.
Production Phase: Lighting levels do not exceed 10-foot candles. • Type H lights are specified with IDA Dark Sky approved fixture with visor. • Type H lights fixtures are mounted at a height of 12 feet above grade. • Lights are to be provided with a photocell sensor which automatically turns on when at dusk and turns off during daylight hours. |
| Wildlife | Form: (02A )
403096386
12/8/2023 | • Install exclusionary devices to prevent bird and other wildlife access to equipment stacks, vents, and openings. • Install screening or other devices on the stacks and on other openings of heater treaters or fired vessels to prevent entry by migratory birds |
| Wildlife | Form: (02A )
403096386
12/8/2023 | If MRG plans to conduct any vegetation removal necessary for construction during the nesting season for migratory birds (April 1 to August 31), a preconstruction nesting migratory bird survey will be conducted within the approved disturbance area. |
| Storm Water/Erosion Control | Form: (02A )
403096386
12/8/2023 | MRG intends to locate sediment basins in the low elevation drainage areas (one ~140’ from the southwest corner of the pad at the end of the diversion ditch and one at the end of the diversion ditch at the southeast corner of the location to catch any runoff that may leave location.
MRG intends to locate sediment basins in the low elevation drainage areas (one ~140’ from the southwest corner of the pad at the end of the diversion ditch and one at the end of the diversion ditch at the southeast corner of the location to catch any runoff that may leave location.
The following erosions and sediment control measures are planned for the Drilling Phase of the CE pad: 1. Sediment control logs (i.e. straw wattles) 2. Seeding, mulching and crimping 3. Silt fence 4. Surface roughening MRG, LP. 5. Stilling Basin 6. Level Spreader 7. Vehicle Tracking Control 8. Concrete Washout Area 9. Temporary Sediment Basin 10. Riprap outlet (i.e. spillway) protection 11. Water application (dust control)
The following erosions and sediment control measures are planned for the Production Phase of the CE pad: 1. Sediment basin 2. Seeding, mulching and crimping 3. Stilling basin 4. Level spreader (i.e. flow spreader) 5. Riprap outlet (i.e. spillway) protection 6. Vegetated swales (i.e. grass-lined swales)
|
| Storm Water/Erosion Control | Form: (02A )
403096386
12/8/2023 | Topsoil: • Protection from Wind Erosion: surface roughening, applying hydro-seed/mulch, using soil tackifier, covering stockpiles with rolled erosion control products, etc. • Protection from Water Erosion: surface roughening, applying hydro-seed/mulch, using soil tackifier, covering stockpiles with rolled erosion control products, etc. • Weed Establishment Prevention: MRG will use Cultural, Mechanical, Biological, and Chemical controls to prevent the establishment of weeds. |
| Storm Water/Erosion Control | Form: (02A )
403096386
12/8/2023 | Revised CDPHE language: ECMC permit will incorporate other agency water quality protection plans by reference as applicable (e.g. stormwater management plan). |
| Material Handling and Spill Prevention | Form: (02A )
403096386
12/8/2023 | A closed loop drilling system will be used. The cuttings will be stored in an above ground container and hauled offsite for commercial disposal by a licensed third-party transportation company.
Completion fluids will be sent to tanks, separators, or other containment/filtering equipment before the fluids will be placed into any pipeline, storage vessel located on the well pad, or into tanker trucks for offsite disposal. Excess completion water from completion operations will be taken to a third-party commercial facility to be disposed
Flowback fluids will be collected in enclosed tanks onsite until they are removed to be disposed of at a third-party commercial facility.
Produced fluids will be stored on location in enclosed tanks located within lined, steel secondary containment. The location will also utilize earthen berms around the perimeter of the location as tertiary containment.
Trash and debris from clearing activities, construction materials, and workers will be mitigated by keeping sufficient trash containers on location and emptying them regularly |
| Material Handling and Spill Prevention | Form: (02A )
403096386
12/8/2023 | All loadlines shall be bull plugged or capped. Secondary containment areas for tanks shall be constructed of steel panels, designed and installed to prevent leakage and resist degradation from erosion or routine operation and shall be constructed with a synthetic or engineered liner that contains all primary containment vessels and flowlines and is mechanically connected to the steel ring to prevent leakage. Steel berms will be able to contain spills with capacity > 150% volume of the largest tank. Any spills will be immediately cleaned up and reported if volume exceeds reporting limit. |
| Material Handling and Spill Prevention | Form: (02A )
403096386
12/8/2023 | Prior to beginning drilling operations, flowlines will be pressure tested to identify any potential leaks. Once integrity has been confirmed, flowlines will be utilized for drilling operations.
All new produced fluid tanks will be installed within the steel secondary containment on an impervious liner.
Prior to being placed into production, manifold connections will be tested with freshwater to identify potential leaks. Once integrity is confirmed, the tanks will be turned over to production operations. |
| Material Handling and Spill Prevention | Form: (02A )
403096386
12/8/2023 | Pursuant to the ECMC Policy on the Use of Modular Large Volume Tanks (MLVT), MRG will provide certification to the ECMC that the installation and operations of MLVTs will comply with the Design Criteria, Site Preparation & Installation, and MLVT Operations and Contingency Planning outlined in the Policy. The MLVT design package, contractor installation records, records of inspections and associated action items and records of any repairs will be maintained and be available upon request. Daily visual inspections will be conducted per the ECMC MLVT Policy. MRG’s contingency/emergency response plan has been developed and is available upon request. |
| Dust control | Form: (02A )
403096386
12/8/2023 | MRG will utilize freshwater for dust suppression practices. Speed restrictions on the access roads will be utilized to minimize dust. An average of 25 mph is currently anticipated to be used for most vehicles. • Construction activities may be limited or deferred on high-wind days to restrict potential fugitive dust, specifically activities that involve moving dirt will be deferred on high wind days to prevent fugitive dust and soil loss. • Topsoil and stockpiled soils will be stabilized through either wheel packing, tackifiers, seeding practices, or erosion control blankets. • If County Road 3 is paved in the future, MRG will pave the first 100 feet of access road connecting to County Road 3. |
| Dust control | Form: (02A )
403096386
12/8/2023 | MRG will utilize freshwater for dust suppression practices.
• Speed restrictions on the access roads will be utilized to minimize dust. An average of 25 mph is currently anticipated to be used for most vehicles.
• Construction activities may be limited or deferred on high-wind days to restrict potential fugitive dust, specifically activities that involve moving dirt will be deferred on high wind days to prevent fugitive dust and soil loss.
• Topsoil and stockpiled soils will be stabilized through either wheel packing, tackifiers, seeding practices, or erosion control blankets.
• If County Road 3 is paved in the future, MRG will pave the first 100 feet of access road connecting to County Road 3. |
| Noise mitigation | Form: (02A )
403096386
12/8/2023 | Preproduction: Approximately 660 total linear feet of 32-foot-high, Sound Transmission Class (STC) 25 acoustical wall installed on the north and east perimeter of the site.
During production, MRG will utilize 220 linear feet of 20-foothigh acoustical perimeter sound wall to mitigate potential noise impacts. |
| Emissions mitigation | Form: (02A )
403096386
12/8/2023 | MRG will shut in the facility to reduce the need for flaring if the pipeline is unavailable. Telemetry will be installed on location to monitor the location remotely and minimize the truck traffic trips required to visit the well. The location will be connected to a third-party crude oil gathering pipeline to reduce truck traffic that would otherwise be required to haul produced hydrocarbon fluids from location.
During flowback operations, a closed tank system will be utilized, and any vapors will be controlled by an enclosed combustor.
MRG is proposing to utilize a temporary surface freshwater line to transport freshwater for completions to location to eliminate the truck traffic that would have been necessary if water hauling was utilized.
MRG will utilize an electric drilling rig to minimize noise generated by diesel engines. |
| Emissions mitigation | Form: (02A )
403096386
12/8/2023 | This location will be connected to a natural gas pipeline as well as a crude oil pipeline to minimize production equipment required onsite as well as heavy truck traffic to the location during the production phase. |
| Emissions mitigation | Form: (02A )
403096386
12/8/2023 | Revised CDPHE language: Operator will not store hydrocarbon liquids in storage tanks on the site (other than a maintenance tank possibly used for well unloading or other maintenance activities). |
| Emissions mitigation | Form: (02A )
403096386
12/8/2023 | Revised CDPHE language: Ozone mitigation on forecasted high ozone days: Operator will suspend or delay the use of fossil fuel powered ancillary equipment for non-emergency, routine activates. |
| Odor mitigation | Form: (02A )
403096386
12/8/2023 | Fresh water mud system will be utilized for surface hole. MRG will be using Group III Oil Based Mud for drilling of the production string. Due to the low VOC and BTEX counts of the Group III system, odor neutralizer is not anticipated, however filtration systems and/or additives to minimize, not mask, odors from drilling and fracturing fluids shall be utilized in the drilling and flowback processes. Oil based drilling fluid not being used in the active mud system shall be stored in closed, upright tanks. Upon tripping out of the hole, the drillpipe will be wiped to remove any residual mud. The storage of excess drilling fluid (fluid not being used in the active mud system) will be in closed, upright tanks. Oil-based mud (OBM) drill cuttings are circulated up the annulus and through the rig flowline to a mud-gas separator, where any gas entrained in the mud is separated and flows off the separator’s overhead to an internal combustion device; the drilling cuttings then flow with the drilling mud over two sets of drying shakers and then through a centrifuge to further dry the cuttings; the dried cuttings are placed into steel bins where they are temporarily stored on location prior to transport to offsite disposal; Enclosed shale shakers shall be utilized to contain fumes from exposed mud where safe and feasible. Odor neutralizer will be used in the active mud system for management of odors within 24 hours of receipt of a complaint. Drill cuttings will not remain in storage at the oil and gas location for long periods of time; disposal will occur regularly. Operator will cover trucks transporting drill cuttings. |
| Odor mitigation | Form: (02A )
403096386
12/8/2023 | Truck loadouts, well unloads, and swabbing will be controlled eliminating high pressure venting or flaring. MRG, LP CE Pad Odor Mitigation Plan o Hydrocarbon odors from production facilities will be minimized by keeping produced fluid hydrocarbons and natural gas contained within pipes, separators, tanks, and combustors; all tanks will be sealed with thief hatches and gaskets; tank vapors will be captured with properly sized piping and combustors. o Oil and gas facilities and equipment shall be operated in such a manner that odors and dust do not constitute a nuisance or hazard to public welfare. o All tanks will be sealed with thief hatches and gaskets. Tank vapors are captured with properly sized piping and combustors. |
| Interim Reclamation | Form: (02A )
403096386
12/8/2023 | Proper site preparation would be ensured by spreading of stored and salvaged topsoil or topsoil replacement to an adequate depth and by ripping, tilling, disking, harrowing, and dozer track imprinting where appropriate. |