| General Housekeeping | Form: (02A )
403444016
7/15/2024 | Inspections
For the purposes of this location, inspections will be conducted every 14 calendar days and within 24 hours after the end of any precipitation or snowmelt event that causes surface erosion for active construction sites and up to 72 hours after the end of any precipitation or snowmelt event that causes surface erosion for sites that may be temporarily idle, but prior to re-commencing construction activities. Provided the timing is appropriate, the post-storm inspections may be used to fulfill the 14-day routine inspection requirement. Sites that have been completed and are awaiting establishment of vegetation will be on a 30-day inspection schedule where post-storm event inspections are not required.
Reports and Record Keeping
The following record keeping procedures will be implemented in order to provide accurate and complete documentation of events associated with the stormwater management program. Routine inspections will include the 14-day, post precipitation event, and 30-day inspections. All stormwater related records will be filed and stored by GMT for a minimum of three years after each individual site has achieved final stabilization.
Employee Training
The Qualified Stormwater Managers are trained to understand the following as related to the scope of their job duties:
• The permit deadlines associated with installation, maintenance, and removal of storm water controls and with stabilization.
• The location of all storm water controls on the site required by the permit and how they are to be maintained.
• The proper procedures to follow with respect to the permit’s pollution prevention requirements.
• When and how to conduct inspections, record applicable findings, and make corrective action recommendations. |
| General Housekeeping | Form: (02A )
403444016
7/15/2024 | The following BMPs are the result of the CDPHE consultation:
• Operator will properly maintain vehicles and equipment
• Operator will use non-emitting pneumatic controllers
• Operator will use electric drilling rigs if available, and will demonstrate best-effort if
unable to utilize them
• Operator will use Tier IV or equivalent engines, such as NG Tier II w/ battery assist, (or
better) for hydraulic fracturing (dual-fuel engines are not considered equivalent)
• Operator will use electric equipment and devices (e.g. vapor recovery units or VRUs, fans,
etc.) to minimize combustion sources on site (if yes, operator will provide a list outlining
which equipment and devices will be electrified)
• Operator will use Tier IV or equivalent engines, such as NG Tier II w/ battery assist, (or
better) for nonroad construction equipment (dual-fuel engines are not considered equivalent)
• Operator will use pipelines to transport water used for hydraulic fracturing to location
• Operator will have adequate and committed pipeline takeaway capacity for all produced gas
and oil
• Operator will shut in the facility to reduce the need for flaring if the pipeline is unavailable
• Operator will incorporate options for recycling produced gas onsite during pipeline
downtime, such as: using the gas for gas lift systems, routing it to the facility fuel system, or
installing a natural gas liquid (NGL) skid to process the gas onsite
• Operator will use lease automatic custody transfer (LACT) system to remove/reduce the
need for truck loadout
• Operator will use OGP Group III drilling fluid
• Operator will cover trucks transporting drill cuttings
• Operator will use a squeegee or other device to remove drilling fluids from pipes as they
exit the wellbore
• Operator will ensure that all drilling fluid is removed from pipes before storage
• Ozone mitigation on forecasted high ozone days: operator will eliminate use of VOC paints
and solvents
• Ozone mitigation on forecasted high ozone days: operator will minimize vehicle and engine
idling
• Ozone mitigation on forecasted high ozone days: operator will reduce truck traffic and
worker traffic
• Ozone mitigation on forecasted high ozone days: operator will postpone the refueling of
vehicles
• Ozone mitigation on forecasted high ozone days: operator will suspend or delay the use of
non-essential fossil fuel powered ancillary equipment
• Ozone mitigation on forecasted high ozone days: operator will reschedule non-essential
operational activities such as pigging, well unloading and tank cleaning
• Ozone mitigation on forecasted high ozone days: Operator will postpone flowback if
emissions cannot be adequately captured with a vapor recovery unit (VRU)
• Operator will use Modular Large Volume Storage Tanks
• Secondary containment: Operator will install perimeter controls to control potential
sediment-laden runoff in the event of spill or release from Modular Large Volume Storage Tank
• Operator will not use fracturing fluids which contain PFAS compounds
• Operator will contribute to nearby fire district(s) to support transition away from
PFAS-containing foam through funding, buy-back program participation/promotion, etc.
• Operator will coordinate with nearby fire district(s) to evaluate whether PFAS-free foam can
provide the required performance for the specific hazard
• If PFAS-containing foam is used at a location: operator will properly characterize the site to
determine the level, nature and extent of contamination
• If PFAS-containing foam is used at a location: operator will perform appropriate soil and
water sampling to determine whether additional characterization is necessary and inform the
need for and extent of interim or permanent remedial actions
• If PFAS-containing foam is used at a location: operator will properly capture and dispose of
PFAS-contaminated soil and fire and flush water |
| Wildlife | Form: (02A )
403444016
7/15/2024 | • The operator agrees to establish company guidelines to minimize wildlife mortality from vehicle collisions on roadways. Slow speeds and increased awareness among employees and contractors is expected to reduce impacts to wildlife.
• All open-vent exhaust stacks on production equipment shall be designed to prevent entry by birds and bats and to discourage nesting or perching. All tanks and above ground facilities shall be equipped with structures or devices that discourage nesting of raptors and corvids.
• The Location will be fenced, if requested by the surface owner, with wildlife friendly barb wire to keep ungulates out of the Location. |
| Storm Water/Erosion Control | Form: (02A )
403444016
7/15/2024 | General
• During construction and development topsoil stockpiles should not exceed 3:1 (horizontal:vertical) to minimize erosion potential and facilitate interim stabilization.
• Seeding and mulching on the western portion of the location will occur during interim reclamation to minimize the disturbed area to protect the topsoil and negate additional soil erosion.
• A portion of the topsoil stockpile will be seeded and mulched and used in final reclamation.
• Gravel will be installed on the wellpad and access road. Any area not needed for production activities will be interim reclaimed.
• Topsoil stockpiled for more than six months will be seeded and mulched with a temporary grass cover or will be stabilized using structural and/or non-structural control measures.
Ditch
Four Diversion Ditches will be constructed during the drilling/completions (active construction) and production (interim reclamation) at low points/outfalls from the diversion ditch network. Diversion ditches will surround the construction area capturing sediment laden runoff channeling into the down-gradient sediment basin. It will be tied into the existing Phase 1 Diversion Ditch. Where the tributary disturbed area is less than 1 acre a sediment trap will be planned for the well site at the low point of the pad. It may be implemented at the downstream termination of the diversion ditches. The trap will contain silt from the upstream fill slopes around the pad. Periodic maintenance of traps may be necessary to remove accumulated silt and debris. Sediment traps shall be installed before site grading begins. The Diversion Ditch is to be removed once Final Stabilization has been reached. The northwest pad ditch-1 will be1,120’L with a depth of 24” min and 3:1 side slope with a 0.5% unlined minimum slope. The northwest off-site ditch-1 will be 1,300’L with a 24” depth and 4:1 side slope with 0.5% unlined minimum slope.The southwest pad ditch-2 will be 1,120’L with a 24” depth and 3:1 side slope with 0.5% unlined minimum slope. The southwest off-site ditch-2 will be 1,120’L with a 24” depth and 4:1 side slope with 0.5% unlined minimum slope.
Berms
Berms help contain and divert runoff. Berms may be used for the upslope of cut or fill slopes to contain or divert surface water. The purpose of a berm is to contain surface water with a permitter barrier or divert surface water when accompanied with a ditch. Berms will be placed on the along the exterior boundaries around the sediment. Berms and ditches will divert surface water to the on-pad sediment basin/detention basin. Berms will be 2’ high with 4:1 slopes and 2’ bench.
Culvert
This site will be constructed with two (2) culverts under the access road and an IPC for culvert protection. The culverts will be constructed on the west side of the pad at the access road entrance,both consisting of 24” x 56’ and 24” x 54’ CMP.
Sediment Basin (SB)/Detention Basin
The Sediment Basin will be constructed on the East side of the drill pad edge during the drilling/completions (active construction) and production (interim reclamation) at low points/outfalls from the diversion ditch network. Where the tributary disturbed area is greater than 1 acre, a sediment basin will be planned for the well site at the low point of the pad. It will be implemented at the downstream termination of the diversion ditches. The basin will contain silt from the upstream cut and fill slopes around the drill pad. Periodic maintenance of the sediment basin may be necessary to remove accumulated silt and debris. Sediment basins shall be installed before the site grading begins. Sediment Basin will be removed once Final Stabilization has been reached. The sediment basin 1 will be standard with a 4.3’ depth, bottom width 75’W x 150’L and the spillway crest length 5630.0’.
Outlet Protection (OP)
There will be two (2) OP at the exit points of the culverts at the access road entrance of the pad, both constructed on the south side and one on the outlet structure of the sediment basin.
Sediment Control Log (SCL)
The sediment control log will be placed along the exterior of the Limits of Disturbance during the pre-production and production phase.
Reinforced Rock Aprons (RRA)/Rip-Rap
During the drilling/completions (active construction) and production (Interim Reclamation) at the off-site diversion ditch and culvert outlets/outfalls, and within swales as check dam structures. The ripraps will be on the outfall at the southeast Sediment Basin’s outlet ditch and will be removed once final stabilization has been reached. Riprap shall be installed in the interim phase, following culvert or outfall installation.
Seeding and Mulching
Seeding and mulching will be done during the drilling/completions (active construction) and production (Interim reclamation) on all areas where construction activity has ceased for 14 or more calendar days which have not been temporarily stabilized, and areas of final reclamation. Seeding and mulching will be done on the areas within the southern, eastern, and western Limits of Construction (LOC) but not included within the Drill Pad area. Topsoil and spoils stockpiles to be spread over the reclaim area once pad reduction occurs. Cut and fill slopes adjacent to the pad and access road swales shall be stabilized with SM. It shall be applied after grading is complete in the final phase. If the seeding and mulching application does not provide adequate stabilization for the area where slopes exceed 4:1, then more robust BMPs shall be utilized. |
| Material Handling and Spill Prevention | Form: (02A )
403444016
7/15/2024 | Management
• All personnel, including contractors, will be informed of waste management protocols and
locations of waste receptacles prior to the start of any operations.
• Operator will conduct site inspections throughout all operational phases to ensure waste is
properly stored and receptacles are being emptied as needed.
Treatment
• All treated waste will be clearly labeled and properly stored.
• Operator will maintain records of all waste analysis and treatment.
Storage
• All waste storage will include compatible containers and be in compliance with regulations.
Containers will also be inspected regularly to ensure proper function.
• Waste levels will be monitored, and maximum storage limits will not be exceeded.
• Operator will maintain records of all waste storage.
Disposal
• On-site receptacles for waste will be clearly labeled, placed in designated locations, and emptied as needed, within compliance.
• Transported waste will only be disposed at permitted locations.
• Operator will maintain records of all waste disposal.
Transport
• All transport will be conducted via compatible containers and by licensed transporters.
• All transport vehicles will use the designated haul route to ingress and egress the locations.
• Operator will maintain records of all waste transport.
• Operator will perform informal daily AVO inspections and formal weekly inspections during all phases of activity.
Inspection of Production Equipment
• Operator will adhere to the inspection procedures for all production equipment as outlined and
detailed in this Fluid Leak Detection Plan.
Spill Prevention
• Operator will provide site specific training to all field employees on an annual basis. Training will include a review of past spills or failures. Training attendance logs and records of training sessions will be maintained by Operator for a minimum of 3 years.
Flowline Integrity Testing
• Aboveground flowlines will be visually inspected on a weekly basis and tested triennially for leaks. Underground lines will be pressure tested every 3 years. Pressure testing records will be maintained by operator for a minimum of 10 years.
Spill Response
• Spills are reported immediately to the Person Responsible and clean-up personnel upon discovery.
• Oil and impacted media are removed or remediated as soon as possible.
Drilling & Workover Procedures
• PVT alarms, automation and other sensory monitoring devices will be utilized to monitor active tank levels at all times. During any transfer operations, visual inspections from inlet and outlet vessels with radio communication will be implemented. Daily visual inspections will be performed on all equipment, hoses and valving to ensure integrity of fluid containment at all times.
Secondary Containment
• Berms and all 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.
• Drilling Operations: Continuous monitoring will be used to track fluid volumes and monitor for leaks. A closed loop system will be used. Fluid storage tanks on the location will be equipped with mechanical (visual) level indicators that are inspected by operation personnel. |
| Dust control | Form: (02A )
403444016
7/15/2024 | • GMT will gravel all working surfaces and perform interim reclamation within six months of
well drilling and completion.
• Utilize existing vegetation, trees slash or brush piles to cover disturbed areas not used for
vehicle traffic.
• Application of fresh water during dry season.
• Operations will be confined to the wellpad working surface.
• Continuous monitoring of disturbed areas to evaluate additional BMPs needed.
• Fresh water application to disturbed areas during construction.
• Fresh water or magnesium chloride application to graveled surfaced of the Location and
associated roads.
• Speed limit signs will be posted per surface owner agreement.
• Contractors will be notified of speed limits if no signs are posted.
• Regular road maintenance such as grading and adding additional gravel as needed. |
| Drilling/Completion Operations | Form: (02A )
403444016
7/15/2024 | MLVT BMP:
Operator will have an MLVT Design Package, certified and sealed by a licensed professional engineer, which is on file in their office and available upon request. The site shall be prepared in accordance with the specifications of the design package prior to tank installation; including ensuring that proper compaction requirements have been met.
The MLVT will be at least 75 feet from a wellhead, fired vessel, heater-treater, or a compressor with a rating of 200 horsepower or more. It will be placed at least 50 feet from a separator, well test unit, or other non-fired equipment.
All liner seams will be welded and tested in accordance with applicable ASTM international standards.
Operator will be present during initial filling of the MLVT and the contractor will supervise and inspect the MLVT for leaks during filling.
Operator will comply with the testing and re-inspection requirements and associated written standard operating procedures (SOP) listed on the design package.
Signs will be posted on the MLVT indicating that the contents are freshwater.
The MLVT will be operated with a minimum of 1 foot of freeboard at all times.
Access to the MLVT will be limited to operational personnel and authorized regulatory agency personnel.
Operator or contractor will conduct daily visual inspections of the exterior wall and surrounding area for integrity deficiencies.
Operator will have a contingency plan/emergency response plan associated with the MLVT and it is on file at their office.
A fabric reinforced liner will be utilized. In the event that a tank breach were to occur, the fabric reinforced liner will prevent a “zippering” failure from occurring. The liner will meet the specifications per the design package.
Operator acknowledges and will comply with the Colorado Oil & Gas Conservation Commission Policy on the Use of Modular Large Volume Tanks in Colorado dated June 13, 2014
|
| Interim Reclamation | Form: (02A )
403444016
7/15/2024 | Landscape Evaluation and Description
• The surface water flow direction is to the east and west.
• No pre-existing drainages are identified within the disturbance boundaries.
• The nearest receiving water is Coal Creek, located approximately 3.14 miles west. Coal creek is a tributary to the South Platte River.
• The land will be reclaimed back to cropland in consultation with the surface owner.
Erosion Control Measure Deployment
• Seeding and mulch application will be completed within 24 hours of seedbed preparation, weather permitting.
• The seed mix will be drill seeded throughout the interim reclamation area.
• All seed will be certified weed free and pure live seed (PLS) rated per federal, state, county, and municipal standards.
• Certified weed free grass or wheat origin straw mulch will be uniformly applied at a rate of 3,000 lbs. per acre to cover 100% of the seed bed.
• Mulch will be properly anchored to the soil surface using a commercial straw crimper with a final orientation north to south.
Soil Management and Placement
• Topsoil horizon depth will be identified based on changes in physical characteristics.
• Topsoil will be separated from the disturbance area to the depth of the topsoil horizon, determined by topsoil samples.
• Salvaged topsoil will be stockpiled, seeded, and the location marked or documented.
• All efforts will be taken to ensure topsoil will not be comingled with subsoil materials during recontouring and subsoil preparation operations.
Grading
• The grade of the interim reclamation area is between 0-2%.
• The surface elevation will be returned as close to the original relative position and contour as practicable during pad size reduction and grading operations.
Seeding Method
• Seed application will be completed within 24 hours of seedbed preparation, weather permitting. If land forming and earthwork is completed outside of a desirable seeding window, seedbed preparation and subsequent seeding operations should be held until a favorable window. The applicable seed mix as agreement upon with the surface owner will be drill seeded throughout the 8.774-acre interim reclamation area with a north to south orientation, along topographic contours, and semi-perpendicular to prevailing winds, to prevent loss of topsoil, assist in erosion prevention, and to match the surrounding established crop vegetation. Seed depth will be a minimum of 0.25 inches and maximum of 0.5 inches. Multiple passes will be completed along any narrow linear disturbances (access road, etc.) to reduce drill spacing and promote density. Seed and soil amendments will not be tilled into the soil profile.
Weed Management
• Certified weed free grass or wheat origin straw will be utilized for mulching operations.
• Mowing operations will be commenced when the height of weeds exceeds 6 inches or before seed development.
• Herbicide applications will be utilized as needed to treat prostrate, low growing, or perennial noxious weed species for which mowing methods are ineffective.
• Herbicide applications will be spot-specific.
Pre-Disturbance Landscape Assessment
• A landscape assessment will be conducted prior to ground disturbance to ensure, based on field collected topographic surveys, the recontoured reclamation surface matches pre-disturbance grade and topography.
• Any pre-existing drainage features will be reestablished during recontouring.
Site-Specific Seed Mix
• Reseeding will be completed with species consistent with the adjacent plant community.
• The proposed seed mix for this location is the western wheatgrass.
• GMT Exploration Company, LLC will consult with the surface owner regarding the future land use and acceptability of the proposed seed mix.
• Seeding will occur throughout the interim reclamation area.
Fence Installation
• A wildlife fence will be maintained to mitigate wildlife and/or livestock access to the interim
reclamation area. |