| Planning | Form: (02A )
403690775
8/16/2024 | 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. |
| General Housekeeping | Form: (02A )
403690775
8/16/2024 | 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.
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.
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. |
| General Housekeeping | Form: (02A )
403690775
8/16/2024 | Commit to connecting to a gas gathering system by the commencement of production operations.
Schedule well pad construction to avoid high-wind warnings issued for Las Animas County.
Develop conventional vertical wells without hydraulic fracturing and proppant.
Water the well pad when indicated by loose soils to stabilize the soil and form a crust.
Minimize vegetation removal and soil disturbance to the area sufficient to site and level equipment.
Mound the soil stockpile with a slope of approximately 3:1 to prevent loose soils.
Reclaim the areas not needed to support production during the first growing season and within 6 months on non-cropland.
Place aggregate as needed at the apron where the access road ties into the public road.
Maintain and periodically test wellhead and flowline valves.
Perform well development over a short duration of approximately 5 days for well drilling and 5 days for completion at each location.
Provide for drilling equipment with a synthetic liner under the motor to capture drips or leaks and a double-walled fuel tank.
Use on-site soil, if necessary, to berm and prevent downgradient runoff if a potential catastrophic loss of freshwater occurs at the water truck.
Place wattles to prevent stormwater and sediment runoff from the locations.
Drill wells with air.
Source minimal groundwater for cementing and dust suppression from a permitted groundwater well.
Either conduct all vegetation removal necessary for oil and gas operations outside of the nesting season for migratory birds (April 1 to August 31) or conduct a pre-construction nesting migratory bird survey within the approved disturbance areas prior to any vegetation removal during the nesting season.
Downsize each location during interim reclamation to a 0.20-acre production pad.
Reclaim the remaining 0.90 acres at each location to pre-construction habitat.
Reclaim the flowline corridors to return them to pre-construction habitat.
Till the reclaimed area to re-establish a seedbed. In cooperation with the surface owner, DEO will identify appropriate soil amendments to promote vegetative growth.
Use the appropriate revegetation seed mix identified in the Interim Reclamation Plan.
Bury the flowlines in trenches approximately 2 feet wide to minimize soil disturbance. |
| Wildlife | Form: (02A )
403690775
8/16/2024 | The locations are in black bear habitat. The operator will install and utilize bear-proof
dumpsters and trash receptacles for food-related trash at all facilities that generate trash.
The operator will not withdraw from or discharge into surface waters.
The operator will not situate new staging, refueling, or chemical storage areas within 500
feet upgradient of the ordinary high water mark of any river, perennial or intermittent stream,
lake, pond, or wetland.
The Oil and Gas Location will have no drilling, production, or other fluid pits.
Trenches left open for more than 5 consecutive days during construction of flowlines regulated under the 1100 Series Rules will have wildlife escape ramps at a minimum of one
ramp per ¼ mile of trench.
When conducting interim and final reclamation pursuant to Rules 1003 and 1004, the
operator will use CPW-recommended seed mixes for reclamation when consistent with any
local soil conservation district requirements.
The operator will use CPW-recommended fence designs when consistent with any relevant
local government requirements.
The operator will conduct all vegetation removal necessary for oil and gas operations outside
of the nesting season for migratory birds (April 1 to August 31). For any vegetation removal
that must be scheduled between April 1 to August 31, the operator will implement appropriate
hazing or other exclusion measures prior to April 1 to avoid take of migratory birds. If hazing
or other exclusion measures are not implemented, the operator will conduct pre-construction
nesting migratory bird surveys within the approved disturbance areas prior to any vegetation removal during the nesting season. If active nests are located, the operator will provide work zone buffers around active nests.
Inform and educate employees and contractors on wildlife conservation practices, including no harassment or feeding of wildlife.
Where applicable, 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.
Implement fugitive dust control measures.
Minimize rig mobilization and demobilization by completing or re-completing all wells from a given well pad before moving rigs to a new location.
To the extent practicable, share and consolidate new corridors for pipeline rights-of-way 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 to the extent practicable.
Reduce traffic associated with transporting water through the use of large tanks or other measures.
Store and stage emergency spill response equipment at strategic locations so that it is available to expedite effective spill response.
Install emergency shutdown systems.
Avoid dust suppression activities within 300 feet of the ordinary high water mark of any reservoir, lake, wetland, or natural perennial or seasonally flowing stream or river.
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| Storm Water/Erosion Control | Form: (02A )
403690775
8/16/2024 | Vegetation removal and soil disturbance on the Oil and Gas Location will be minimized to the area sufficient to site and level equipment.
The operator will segregate and salvage topsoil based on soil characteristics of color, texture, structure, and consistency.
Salvaged topsoil will be mounded on the Oil and Gas Location to minimize loose soils.
The topsoil stockpile will be seeded within 6 months of completion of well development for non-cropland.
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.
The topsoil stockpile will be protected from compaction by designating it with surveyor staking as topsoil for reclamation.
The topsoil stockpile will be protected from wind degradation by mounding 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, seeding, and an erosion control blanket or crimped straw mulch, if needed, will be used 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. |
| Storm Water/Erosion Control | Form: (02A )
403690775
8/16/2024 | Wattles will be placed where shown on the Form 2A, Layout Drawings. 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.
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, 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. |
| Material Handling and Spill Prevention | Form: (02A )
403690775
8/16/2024 | 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. |
| Dust control | Form: (02A )
403690775
8/16/2024 | Drivers will be instructed to maintain a speed of 20 mph on the access road to minimize fugitive dust, road wear, and erosion.
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.
The 2-day well pad construction will be scheduled to avoid high-wind warnings issued for Las Animas County.
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.
Proppant will not be used.
Area not needed for production will be reclaimed in accordance with Rule 1003.
Aggregate will be placed as needed at the apron where the access road ties into the public road. The aggregate will serve as a wheel shaker and erosion control at the tie in.
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. |
| Interim Reclamation | Form: (02A )
403690775
8/16/2024 | Topsoil - Topsoil will be stockpiled on each location and 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 installed and maintained at each location to prevent stormwater run on, runoff, and erosion. Erosion controls are shown on the Facility Layout Drawings.
Weed control – The locations will be monitored for the presence of invasive weeds. Invasive weeds will be treated to prevent them from establishing or spreading.
Seed mix – The operator will use the certified weed-free seed mix identified in this plan and in coordination with the surface owner.
Seeding method and Timing – Drill seeding or other method to promote vegetative success will be conducted during the first growing season and within 6 months of completion of well development.
Fencing – Fencing will be installed to restrict unauthorized access and discourage unnecessary surface disturbance.
Recontouring - Disturbed areas will be recontoured to blend with the pre-disturbance surface and restore natural drainage patterns.
Monitoring – Locations will be monitored for vegetative success. Locations will be reseeded where needed to establish 80 percent of pre-disturbance cover. |