| Planning | Form: (02A )
403135970
9/11/2023 | Prior to submittal of the Application for Permit to Drill (BLM-APD/Form 2) and the Oil and Gas Location Assessment (Form 2A), TEP conducted onsite reviews and meetings with the Bureau of Land Management (BLM), Colorado Parks and Wildlife, and the associated private landowners. These onsite reviews and meetings were held to discuss TEP’s proposed development plan for the Arco Deep 1-27 pad and associated support facilities. Changes were made to the proposed development plan based on feedback received from all stakeholders and included in the APD.
The development plan for the Arco Deep 1-27 pad was prepared to minimize surface impacts to the greatest extent possible through the development of multiple wells from one location by utilizing directional drilling technology and utilizing existing facilities and infrastructure where possible. This ultimately minimizes the surface area needed to conduct operations on the Arco Deep 1-27 pad.
Existing infrastructure operated by Summit and TEP will be utilized for transportation of natural gas and produced water to minimize the surface disturbance required for tying in gathering facilities. |
| Planning | Form: (02A )
403135970
9/11/2023 | Air Monitoring BMPs:
Per APCD requirements, TEP will implement ambient air quality monitoring on site during drilling, completion, and the first six (6) months of production operations; an air monitoring plan will be submitted 60 days prior to start of drilling;
TEP will properly maintain vehicles and equipment;
Other than safety devices, TEP will use non-emitting pneumatic controllers; and
TEP will have adequate and committed pipeline take away capacity for all produced gas and oil. |
| Planning | Form: (02A )
403135970
9/11/2023 | Pre-Construction:
Prior to commencement of construction activities, TEP will hold a pre-construction meeting with contractors to review proposed site construction and installation of stormwater control measures.
The site will be staked for construction prior to preconstruction meeting. Staking will identify the boundaries of the proposed site to protect existing vegetation in areas that should not be disturbed. |
| General Housekeeping | Form: (02A )
403135970
9/11/2023 | General Housekeeping BMPs:
Vehicular traffic will be minimized as much as possible to reduce nuisance dust and prevent soil erosion;
Any trash generated during the project will be disposed of properly at a commercial disposal facility;
Any chemicals used will be kept to a minimum;
Any chemical or hydrocarbon spills will be cleaned up immediately in accordance with established company procedures;
All materials will be stored in a neat and orderly manner in their appropriate containers; and
TEP will follow manufacturers’ recommendations and company policies for proper use and disposal of products. |
| General Housekeeping | Form: (02A )
403135970
9/11/2023 | Site lighting shall be shielded and directed downward, inward, away from the nearby areas where wildlife may be present, and toward operations to avoid glare on nearby roads or wildlife areas. |
| Wildlife | Form: (02A )
403135970
9/11/2023 | TEP will inform and educate all employees and contractors on wildlife conservation practices, including no harassment or feeding of wildlife.
TEP will install a proposed water pipeline from the Oil and Gas Location to TEP’s existing water management system to minimize truck traffic to the location and minimize the potential impacts to wildlife.
TEP will minimize direct impact to wildlife habitat by utilizing existing infrastructure and disturbance corridors whenever possible.
Well telemetry equipment will be installed to minimize site visitation through remote monitoring of production operations. |
| Storm Water/Erosion Control | Form: (02A )
403135970
9/11/2023 | Stormwater control measures will be in place during all phases of development to control stormwater runoff in a manner that minimizes erosion, transportation of sediment offsite, and site degradation.
Stormwater control measures will include perimeter controls such as sediment traps, diversion diches, check dams, wattles, and other control measures necessary to control stormwater run-on and run-off and minimize offsite movement of sediment. Control measures will also include site degradation control measure such as grading, slope stabilization methods (i.e., seeding, mulching, surface roughening), perimeter berms, surfacing materials (i.e., gravel), and other necessary controls to minimize site degradation.
Topsoil will be stored within a topsoil stockpile south of the proposed pad and will be segregated from all subsurface material. Wattles will be placed around the entire perimeter of the topsoil stockpile to minimize potential for loss of organic materials.
Bi-weekly inspection of the pad and stormwater control measures (berms, ditches, sediment basins), and the cuttings trench (berms and precipitation buildup). When necessary, precipitation within the cuttings trench will be pumped out and sent into the TEP proposed produced water management system for disposal. |
| Storm Water/Erosion Control | Form: (02A )
403135970
9/11/2023 | All containers will be clearly labeled.
Dry materials will be stored on pallets and covered when not in use to avoid contact with precipitation, stormwater, and wind.
Potentially hazardous liquid materials in buckets, drums or tanks will be stored within secondary containment, such as soil berms, steel containers or bermed visqueen, to capture accidental spills or leaks. Drums will be kept off the ground within secondary containment and stored under cover, if needed. The berms shall be constructed such that they are sufficiently impervious to prevent the material from being released beyond the confines of the containment system.
Fuel tanks will be stored within secondary containment.
Container lids will be securely fastened.
In the event of a spill, procedures outlined in TEP’s SPRP will be followed. Persons trained in handling spills will be available.
Spill clean-up and containment materials (absorbent, shovels, etc.) will be readily accessible. Spills will be immediately cleaned up and contaminated materials will be properly stored on site until they can be disposed of in accordance with applicable regulations.
Storage areas and containers will be monitored for leaks and repaired or replaced as necessary. Storage areas will be inspected regularly, and any minor spills or leaks will be cleaned up immediately.
As necessary, covers and stormwater diversion structures will be utilized to minimize contact of precipitation and stormwater runoff with materials and wastes with potential to result in discharges causing pollution of surface waters.
TEP’s SPRP will be readily available at the field office as a reference to assist in responding to spills at locations where materials are stored or handled.
Material Safety Data Sheets (MSDS) and product labels will be available as per TEP’s Hazard Communications (HazCom) program.
Employees will have proper training in materials handling, spill prevention and response.
Stormwater control measures will be in place during all phases of development to control stormwater runoff in a manner that minimizes erosion, transportation of sediment offsite, and site degradation.
Stormwater control measures will include perimeter controls and site degradation control measures; these will include a minimum 1.5-foot compacted earthen perimeter berm around the entire working pad surface and around the cuttings trench near the north side of the well pad; topsoil will be stockpiled near the north end of the location within the disturbance area and segregated from all subsurface material; there will be a system of exterior diversion ditches around the entire oil and gas location; these diversion ditches will be fitted with rocked check dams and will tie into three (3) sediment catchment basins along the west and south side of oil and gas location; site degradation control measures will include grading, slope stabilization (seeding, mulching, surface roughening of the topsoil stockpile), straw wattles along the toe of all fill slopes, and the use of gravel and road base materials for surfacing; wattles will be placed around the entire perimeter of the topsoil stockpile to minimize potential for loss of organic materials.
Outlet protection should be used when a conveyance discharges onto a disturbed area where there is potential for accelerated erosion due to concentrated flow;
TEP will conduct stormwater inspections immediately after storm events;
Bi-weekly inspection of the pad and stormwater control measures (berms, ditches, sediment basins), and the cuttings trench (berms and precipitation buildup). When necessary, precipitation within the cuttings trench will be pumped out and sent into the TEP proposed produced water management system for disposal.
Documentation / Stormwater Management Plan – if it is infeasible to install or repair a control measure immediately after discovering a deficiency, TEP will document and keep on record in the stormwater management plan: (a) a description of why it is infeasible to initiate the installation or repair immediately; and (b) a schedule for installing or repairing the control measure and returning it to an effective operating condition as soon as possible.
A post-construction stormwater program will be developed for the facility as required per Rule 1002.f.(3). Stormwater control is also addressed under a field-wide Stormwater Management Plan. |
| Material Handling and Spill Prevention | Form: (02A )
403135970
9/11/2023 | Material Handling and Spill Prevention - Water Resource Protection:
Informal inspections of all tanks and storage facilities will occur daily during drilling, completions, and production operations;
A closed loop drilling system will be employed;
The moisture content of drill cuttings managed onsite shall be kept as low as practicable to prevent accumulation of liquids greater than de minimis amounts;
Temporary frac tanks placed on location will have proper secondary containment including a perimeter berm around the Working Pad Surface and containment under the frac tanks;
Flowback and stimulation fluids will be sent to enclosed tanks, separators, or other containment/filtering equipment before the fluids are placed into any pipeline storage vessel, other open top containment located on the well pad; or into tanker trucks for offsite disposal; no open top tanks will be used for initial flowback fluids containment;
Any temporary surface or permanent surface/buried pipelines (flowlines from wellheads to separators to tanks; and any temporary surface lines used for hydraulic stimulation and/or flowback operations) will be pressure tested in accordance with the 1100-series rules prior to being placed into initial service and following any reconfiguration of the pipeline network; all permanent flowlines from wellheads to separators and from the separators to the tank will also be pressure tested annually;
Tank batteries will be placed within engineered, steel secondary containment with an impervious liner system or other secondary containment systems;
Pollution control containers (spill boxes) to be used on truck loading lines within the limits of the secondary containment systems;
TEP will properly characterize and dispose of all waste streams at facilities approved for acceptance of each waste stream;
All wells located on this pad will be equipped with remote shut-in capabilities; and
The use of cathodic protection on buried steel lines to mitigate corrosion.
If contaminated soils are discovered during the removal and replacement of the existing tank battery, TEP will report, if required, and remediate any contaminated soils per the Waste Management Plan attached to the Form 2A. |
| Material Handling and Spill Prevention | Form: (02A )
403135970
9/11/2023 | Material Handling and Spill Prevention Fluid Leak Detection:
Audio, Visual, and Olfactory (AVO) inspections: AVO inspections will be conducted monthly at the oil and gas location throughout the life of the well pad.
Routine inspection of all production equipment, wellheads, temporary equipment, etc.; As described above, routine inspections to be conducted at the oil and gas location will include: Routine physical inspections of production equipment (by TEP production personnel); Air Compliance inspections and monitoring (by TEP Air Compliance staff); SPCC Inspections (by 3rd party contractor), Storm Water Management inspections (by 3rd party contractor), and continuous, dedicated SCADA monitoring of fluid production rates and pressures, and fluid storage volumes (by TEP production personnel).
As part of our LDAR, STEM, ooooa inspection / compliance programs, TEP will adhere to the use of Approved Instrument Monitoring Methods (AIMM) for inspecting production equipment and facilities at the oil and gas location.
Spill prevention training is provided to all field employees on a monthly basis. The monthly training consists of reviewing past incidents, root causes of the incidents, and what specific actions (lessons-learned) could be taken to prevent the reoccurrence of such incidents in the future.
Flowlines will be integrity-tested per the 1100 Series rules.
TEP spill response procedures will be adhered to for any spills or releases occurring at the oil and gas location. All spills will be managed in accordance with the COGCC 900 Series rules.
Storage Tank Emission Monitoring (STEM) inspections are performed monthly at any location where emissions must be controlled (> 2 tpy).
OOOOa inspections are performed semi-annually on any facility constructed after 2015.
Flare Logs are completed daily for all locations where active flares and emissions controls are required.
Spill prevention training will be provided to all field employees on an annual basis;
Any leaks or spills detected during monitoring will be reported within 24 hours in accordance with Rule 912.b;
Annual flowline testing will also occur according to COGCC rules 1101 and 1102. Inspection and record retention of flowline testing will be in accordance with COGCC regulation; all records will be made available to the COGCC upon request;
All load lines will be bull plugged or capped;
All on-location flowlines will be inspected and tested per Rule 1104;
All equipment deficiencies will be corrected immediately or as soon as practical (all identified problems and corrections/repairs will be documented and records will be maintained in the TEP’s office);
TEP will track and clean up all spills, including those that are not reportable;
TEP will temporarily shut in all production wells on the pad in the event of any upset condition;
All piping is pressure tested and inspected for leaks prior to flowback; and
Automation technology will be utilized at this location; this technology includes the use of fluid level monitoring for the tanks and high-level shut offs. |
| Material Handling and Spill Prevention | Form: (02A )
403135970
9/11/2023 | Material Handling and Spill Prevention - Per- and Polyfluoroalkyl Substances [PFAS]:
If PFAS-containing foam is used at a location, TEP 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, TEP will properly capture and dispose of PFAS contaminated soil and fire and flush water; and
If PFAS-containing foam is used at a location: TEP will properly characterize the site to determine the level, nature and extent of contamination. |
| Material Handling and Spill Prevention | Form: (02A )
403135970
9/11/2023 | Drill Cuttings Management and Sampling Protocols:
All cuttings generated during drilling will be kept in a bermed portion of the well pad prior to disposition;
The moisture content of any water/bentonite-based drilling mud (WBM) generated cuttings will be minimized through good engineering practices and mechanical processes to prevent the accumulation of liquids greater than de minimis amounts;
Solids control and separation equipment will be utilized to separate WBM-generated cuttings solids from liquids (water/bentonite drilling mud);
In the event that drill cuttings analytically demonstrate constituents above Table 915-1 standards, the cuttings will be remediated prior to interim reclamation activities to levels below all applicable standards of Table 915-1;
No liners will be used or disposed of in the cuttings trench;
No offsite disposal of water-based bentonite drilling cuttings to another oil and gas location or third party commercial disposal facilities shall occur without prior approval of an amended Waste Management Plan specifying disposal location and waste characterization method;
Contingency Sampling of the water/bentonite based drill cuttings will occur regardless of whether the original "background" or "baseline" samples collected from each well drilled are compliant with Table 915-1. The 6-point composite from each well may be used for preliminary analysis and waste profiling; however, discrete sample results will be required for confirmation sampling. The operator will need to close out the cuttings trench with a Form 27. The operator will propose the number of discrete samples, the locations, and depth intervals for the confirmation samples. The depth intervals will be selected to provide sufficient coverage between 0 and 19 feet below the final top surface of the cuttings within the trench. Upon approval of the Form 27, TEP will collect the proposed samples and analyze them for the Table 915-1 constituents. |
| Dust control | Form: (02A )
403135970
9/11/2023 | Pad / Road Construction: Fresh water will be periodically applied to disturbance areas during construction to minimize fugitive dust.
Fresh water will be used to minimize fugitive dust during construction, drilling, completion, and production operations. TEP will not use produced water or other process fluids for dust suppression.
Construction During High Wind: Contractor will monitor wind conditions during site construction. During wind events in excess of 13 miles per hour, TEP construction contractors will apply freshwater from an approved source to the disturbance area of the pad, road, or pipeline corridor to minimize or mitigate propagation of fugitive dust. Accessibility and worker safety will be considered prior to application. During periods of sustained high winds over 20 miles per hour, TEP construction contractors may temporarily suspend work to minimize potential for migration of fugitive dust, ensure worker safety, and to minimize impacts to public health, safety, welfare, the environment, and wildlife.
Road Surfacing: The existing lease road will be spot graveled during site construction to ensure there is sufficient gravel on the road to minimize fugitive dust.
Speed Restrictions: TEP has implemented speed restrictions on all lease roads and requires all TEP employees and contractors to adhere to all posted speed restrictions. The speed limit for the existing access road is, and will be, twenty (20) miles per hour.
Road Maintenance: During long-term production operations, TEP will conduct annual inspections of the existing road and will perform maintenance actions as necessary to ensure road integrity and minimize fugitive dust. Road maintenance actions may include, but not limited to, regrading, spot graveling, storm water control maintenance, and application of magnesium chloride (MgCl2) and / or fresh water.
Site Visitation: TEP will utilize telemetry equipment to minimize well site visitation, when possible, to reduce fugitive dust from vehicles traveling the dirt / gravel roads.
Soil Management: Topsoil and stockpiled soils will be stabilized through either tackifiers, seeding practices, or erosion control blankets. |
| Noise mitigation | Form: (02A )
403135970
9/11/2023 | Any operations involving the use of a drilling rig, workover rig, or fracturing and any equipment used in the drilling, completion or production of a well are subject to and will comply with the Agricultural maximum permissible noise levels in Rule 423.a.(2).A. of 65 db(A) in the hours between 7:00 a.m. to 7:00 p.m. and 60 db(A) in the hours between 7:00 p.m. to 7:00 a.m.; and If a noise complaint is made to either TEP directly, the COGCC, or the local government, and
TEP is notified of the complaint, noise levels will be measured within 48 hours of receipt of the complaint; TEP will contact the concerned party (if contact information is available) to discuss the complaint and the results of the noise measurements. |
| Noise mitigation | Form: (02A )
403135970
9/11/2023 | Any operations involving the use of a drilling rig, workover rig, or fracturing and any equipment used in the drilling, completion, or production of a well are subject to and will comply with the Agricultural maximum permissible noise levels in Rule 423.a.(2).A. of 65 db(A) in the hours between 7:00 a.m. to 7:00 p.m. and 60 db(A) in the hours between 7:00 p.m. to 7:00 a.m.; and
If a noise complaint is made to either TEP directly, the COGCC, or the local government, and TEP is notified of the complaint, noise levels will be measured within 48 hours of receipt of the complaint; TEP will contact the concerned party (if contact information is available) to discuss the complaint and the results of the noise measurements.
|
| Emissions mitigation | Form: (02A )
403135970
9/11/2023 | TEP will install equipment designed specifically to aid in the mitigation of VOC emissions from this location; this equipment includes emission control devices (ECDs) and tank load out controls; if one of these pieces of equipment is not operational, facility controls will automatically shut-in the pad until the equipment is back on-line;
Test separators and associated flowlines, sand traps, and emission control systems will be installed onsite to accommodate green completions techniques; and
Venting/Flaring - TEP 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. |
| Drilling/Completion Operations | Form: (02A )
403135970
9/11/2023 | Drilling Operations
Oil and gas operations will be in compliance with applicable BLM regulations, the Department of Public Health and Environment, Air Quality Control Commission, Regulation No. 2 Odor Emission, 5 C.C.R. 1001-4, Regulation No. 3 (5 C.C.R. 1001-5), and Regulation No. 7 Section XVII.B.1 (a-c) and Section XII.
Fresh water mud system will be utilized for drilling all proposed wells.
Upon tripping out of the hole, the drill pipe will be wiped to remove any residual mud.
A catch pan will be mounted around the BOP to catch any mud that falls through the rotary table preventing any spillage and source of odor.
The storage of excess drilling fluids (fluids not being used in the active mud system) will be in enclosed, upright tanks.
Odor neutralizer will be used in the active mud system for management of odors within 24 hours of receipt of a complaint.
A closed loop drilling system will be employed. |
| Drilling/Completion Operations | Form: (02A )
403135970
9/11/2023 | Completions Operations
Completion operations will be conducted remotely from the MV 1-23 Pad (Location ID: 322524). The MV 1-23 pad is located in a remote area of Garfield County, Colorado, more than 1- mile from the nearest Residential Building.
Produced water used for frac water will be treated with Sodium Hypochlorite. Sodium Hypochlorite (NaOCL), commonly referred to as biocide or bleach, will be used for bacterial and microbial control, as well as odor prevention and neutralization. TEP will utilize alternative chemicals if needed to effectively treat various microbials that can develop in produced water. |
| Drilling/Completion Operations | Form: (02A )
403135970
9/11/2023 | Flowback Operations
All hydrocarbons and produced water recovered will be contained within piping, 4-phase separators, and sealed tanks ensuring all odors are contained. Separated gas will be sent to a gas sales line or high efficiency combustor.
In compliance with the Air Pollution Control Division Regulation No. 7, flowback tanks containing hydrocarbon vapors will be fully enclosed with hatches sealed. All vapor present in tanks will be routed to a high efficiency combustor with at least a 98% design destruction efficiency. All produced water from enclosed flowback tanks will be pumped off-location into a pipeline.
Odor neutralizer will be added to produced water during flowback for management of odors within 24 hours of receipt of a complaint. |
| Drilling/Completion Operations | Form: (02A )
403135970
9/11/2023 | Production Operations
Produced water will be transported via pipeline from the proposed produced water pump on the Arco Deep 1-27 pad to the existing water pipeline tie-in point.
Hydrocarbon odors from production facilities will be minimized by keeping produced fluid hydrocarbons and natural gas contained within pipes, separators, tanks, and combustors; 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.
All tanks will be sealed with thief hatches and gaskets. Tank vapors are controlled with properly sized piping and combustors. |
| Interim Reclamation | Form: (02A )
403135970
9/11/2023 | The Oil and Gas Location will be re-contoured to blend as nearly as possible with the natural topography during site reclamation. All subsoil and topsoil separated and segregated during site construction will be replaced to a uniform depth during reclamation recontouring operations.
The Oil and Gas Location will be reseeded by drill, broadcast, or hydroseed methods. Drill seeding will be utilized wherever soil characteristics and slope allow for effective operation of a rangeland seed drill.
TEP will use a seed mix approved by the surface owner.
Erosion control will be implemented per the Stormwater Management Plan included in the Form 2A for this location and will be inspected and maintained as required by Federal, State, and Local regulations.
Noxious weeds which may be introduced due to soil disturbance during reclamation would be treated in accordance will applicable Federal, State, and local regulations.
Site reclamation will occur within six (6) months following well completion operations.
The areas identified to be interim reclaimed will be re-contoured to blend as nearly as possible with the natural topography during site reclamation; all topsoil will be moved from the stockpile area and placed over the facility’s cut and fill slopes to a uniform depth to ensure long term topsoil health including protection from erosion, prevention of weed establishment, and maintaining soil microbial activity until final reclamation.
The seed bed will be prepared on all topsoiled areas to alleviate compaction and minimize the potential for erosion.
Topsoiled areas will be planted with desirable species or a seed mixture provided by the Surface Owner for this particular location. |
| Interim Reclamation | Form: (02A )
403135970
9/11/2023 | Interim Reclamation:
Interim reclamation will occur within six (6) months following completion of well drilling and completion operations;
The areas identified to be interim reclaimed will be re-contoured to blend as nearly as possible with the natural topography during site reclamation; all topsoil will be moved from the stockpile area and placed over the facility’s cut and fill slopes to a uniform depth to ensure long term topsoil health including protection from erosion, prevention of weed establishment, and maintaining soil microbial activity until final reclamation;
The location will be reseeded by drill, broadcast, or hydroseed methods; drill seeding will be utilized wherever soil characteristics and slope allow for effective operation of a rangeland seed drill;
The seed bed will be prepared on all topsoiled areas to alleviate compaction and minimize the potential for erosion;
Topsoiled areas will be planted with desirable species or a seed mixture provided by the Surface Owner for this particular location;
Protection from Wind and Water Erosion - topsoiled areas will be covered with certified weed free mulch at an application rate specified by the product’s manufacturer, or a specification sheet that follows good engineering practices; and
Weed Establishment Prevention - TEP uses Cultural, Mechanical, Biological, and Chemical controls to prevent the establishment of weeds. |
| Interim Reclamation | Form: (02A )
403135970
9/11/2023 | Protection from Contamination: based on changes in physical characteristics (e.g., organic content, color, texture, density, or consistency), soil horizons will be segregated and stockpiled separately; stockpiles of different soil types will be separated by compacted earthen berms, sediment control logs, straw bale barriers, etc.; and stockpile surfaces will be stabilized to control for erosion and sedimentation.
Protection from Compaction: topsoil stockpiles will be indicated on site with signage; stockpiles will be placed in areas away from vehicle and equipment traffic; and when stockpiling, compaction will be minimized by limiting the number of equipment passes, limiting stockpile height, and using vegetation.
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: TEP uses cultural, mechanical, biological, and chemical controls to prevent the establishment of weeds. TEP’s complete Weed Control plan is included in Requirement 12 below.
The seed bed will be prepared on all topsoiled areas to alleviate compaction and minimize the potential for erosion.
Topsoiled areas will be planted with desirable species or a seed mixture provided by the Surface Owner for this particular location.
Protection from Wind and Water Erosion: topsoiled areas will be covered with certified weed free mulch at an application rate specified by the product’s manufacturer, or a specification sheet that follows good engineering practices. |