| General Housekeeping | Form: (02A )
400512734
2/8/2014 | General housekeeping will consist of neat and orderly storage of materials and fluids. Wastes will be temporarily stored in sealed containers and regularly collected and disposed of at offsite, suitable facilities. If spills occur prompt cleanup is required to minimize any commingling of waste materials with storm water runoff. Routine maintenance will be limited to fueling and lubrication of equipment. Drip pans will be used during routine fueling and maintenance to contain spills or leaks. Any waste product from maintenance will be containerized and transported offsite for disposal or recycling. There will be no major equipment overhauls conducted onsite. Equipment will be transported offsite for major overhauls. Cleanup will consist of patrolling the roadways, access areas, and other work areas to pick up trash, scrap debris, other discarded materials, and any contaminated soil. These materials will be disposed of properly and promptly. |
| Storm Water/Erosion Control | Form: (02A )
400512734
2/8/2014 | Storm Water Management Plans (SWMP) are in place to address construction, drilling and operations associated with Oil and Gas development throughout the state of Colorado in accordance with Colorado Department of Public Health and Environment (CDPHE). BMP’s will be constructed around the perimeter of the site prior to, or at the beginning of construction. BMP’s used will vary according to the location, and will remain in place until the pad reaches final reclamation.
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| Material Handling and Spill Prevention | Form: (02A )
400512734
2/8/2014 | Spill Prevention Control and Countermeasures (SPCC) plans are in place to address any possible spills associated with Oil and Gas operations throughout the state of Colorado in accordance with CFR 112.
In accordance with COGCC Rule 1002.f.(2)A. & B., shall provide a designated storage area for dry bulk chemicals and miscellaneous fluids. The storage area shall be covered to prevent contact of precipitation with chemicals, shall be elevated above storm- or standing water, and shall provide sufficient containment to prevent release of spilled fluids or chemicals from impacting soil, surface water or groundwater and will prevent the co-mingling of spilled fluids or chemicals with other E & P Waste.
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| Noise mitigation | Form: (02A )
400512734
2/8/2014 | Noise levels will be maintained at levels not to exceed COGCC specifications currently in existence, measured at a point 350’ from the noise source, or as defined by current COGCC regulations. Where possible, drilling rig engine exhaust will be vented away from occupied buildings. Light sources will likewise be directed downwards, and away from occupied structures where possible. No special noise mitigation efforts should be required at this site. Once the drilling and completion rigs leave the site, there will be no permanently installed lighting on site. |
| Traffic control | Form: (02A )
400956015
8/18/2016 | Traffic Plan (Rule 604.c.(2)D.
GWOC works closely with all municipalities as appropriate to develop a mutually acceptable road traffic access plan addressing site specific traffic-related issues. These plans may address issues such as; routes, construction specification of access roads, maintenance, dust control, jake brake limits, traffic controls, enforcement, emergency response, etc. GWOC will work with municipalities, the County’s Planning Department and/or Road Department to address complaints related to traffic or dust issues as appropriate. Dust control measures may include surface stabilization, or dust control with appropriate chemical or water applications.
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| General Housekeeping | Form: (02A )
400956015
8/18/2016 | Housekeeping
General housekeeping will consist of neat and orderly storage of materials and fluids. Wastes will be temporarily stored in sealed containers and regularly collected and disposed of at offsite, suitable facilities. If spills occur prompt cleanup is required to minimize any commingling of waste materials with storm water runoff. Routine maintenance will be limited to fueling and lubrication of equipment. Drip pans will be used during routine fueling and maintenance to contain spills or leaks. Any waste product from maintenance will be containerized and transported offsite for disposal or recycling. There will be no major equipment overhauls conducted onsite. Equipment will be transported offsite for major overhauls. Cleanup will consist of patrolling the roadways, access areas, and other work areas to pick up trash, scrap debris, other discarded materials, and any contaminated soil. These materials will be disposed of properly and promptly.
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| Material Handling and Spill Prevention | Form: (02A )
400956015
8/18/2016 | ii. Fluid leak detection, repair, reporting, and record keeping for all above and below ground
on-site fluid handling, storage, and transportation equipment.
Leak Detection Plan (Rule 604.c(2)F.)
GWOC designs its new facilities to both avoid leaks or releases as well as to help
detect them in a timely manner to minimize potential impacts. Tanks and all
above-ground pipelines and valves etc. are inspected on a daily basis by company lease operators. In
addition, GWOC also conducts formal annual SPCC inspections,
and formal site specific and random audits, by third-party consultants to inspect for
general site conditions as well as condition of tanks, pipelines, and containment
structures. GWOG also complies with the required Flowline Integrity rules as appropriate. In
addition, our company lease operators and production staff review
production records, including volumes and pressures, looking for irregularities that may
indicate a problem with a tank or pipeline. If an irregularity is detected that may
indicate a potential release the suspect tank and/or pipeline(s) are removed from
service, isolated, and either pressure tested or visibly inspected for indications of a
potential leak. |
| Material Handling and Spill Prevention | Form: (02A )
400956015
8/18/2016 | v. Storage tank pressure and fluid management.
Load lines (Rule 604.c.(2)O)
Load line containment is part of GWOG’s secondary containment
system. In any designated setback zone all loadlines are capped or bullplugged or
locked shut to reduce the likelihood of a release occurring. In addition, GWOC places
all load line receivers/valves inside secondary containment areas or in a proper load
line containment device or both.
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| Material Handling and Spill Prevention | Form: (02A )
400956015
8/18/2016 | C. Site Specific Mitigation Measures.
ii. Ground and surface water protection;
GWOG has Spill Prevention Control and Countermeasures (SPCC) plans in place to address any possible spills
associated with all GWOG Oil and Gas operations throughout the state of Colorado in accordance with CFR 112.
In accordance with COGCC Rule 1002.f.(2)A. & B., shall provide a designated storage area for dry bulk chemicals
and miscellaneous fluids. The storage area shall be covered to prevent contact of precipitation with chemicals,
shall be elevated above storm- or standing water, and shall provide sufficient containment to prevent release of
spilled fluids or chemicals from impacting soil, surface water or groundwater and will prevent the co-mingling of
spilled fluids or chemicals with other E & P Waste.
Berm specifications are also addressed above. |
| Dust control | Form: (02A )
400956015
8/18/2016 | vi. Proppant dust control.
Appropriate proppant dust control is utilized by service companies when pneumatic transfer is employed.
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| Construction | Form: (02A )
400956015
8/18/2016 | Berm Construction:
i. Containment berms shall be constructed of steel rings, designed and installed to prevent leakage
and resist degradation from erosion or routine operation.
ii. Secondary containment areas for tanks 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.
iii. Not applicable
iv. Great Western has requested a variance to Rule 604.c.(3)B.iv. |
| Construction | Form: (02A )
400956015
8/18/2016 | i. Fire, explosion, chemical, and toxic emission hazards, including lightning strike hazards.
Control of Fire Hazards (Rule 604.c.(2)N)
GWOC constructs and operates our facilities to meet or exceed state and API codes, as appropriate,
including API RP 500 electrical classifications inside bermed areas. Any unused potentially
flammable materials are moved a minimum distance of 25-feet from wellhead, tanks, and separator
areas. GWOC implements a written Hot Work Permit Program for employees and contractors
doing any defined ‘Hot Work’ activities on GWOC locations. All oil tanks on location are lowprofile
(16’ height instead of standard 25’ tanks) to reduce the lightning strike hazard and all equipment is grounded. GWOC will provide a 125-150lb. dry-chem, ABC, wheeled fire extinguisher for onsite fire suppression during all
drilling/completions events as additional mitigation |
| Construction | Form: (02A )
400956015
8/18/2016 | iii. Automated well shut in control measures to prevent gas venting during emission control system failures
or other upset conditions will be utilized. |
| Construction | Form: (02A )
400956015
8/18/2016 | C. Site Specific Mitigation Measures.
iii. Visual impacts associated with placement of wells or production equipment; and
Due to the industrial setting in the pad area Great Western does not feel visual impacts will be a concern. |
| Noise mitigation | Form: (02A )
400956015
8/18/2016 | Noise (Rule 604.c.(2)A.
The subject Great Western Operating Company, L.L.C. (GWOC) location will operate in accordance with maximum permissible noise levels per COGCC Rule 604.c.(2)A. and 802, as applicable. GWOC will utilize reasonable and cost-effective best practices to endeavor to reduce noise levels below these limits in areas where occupied structures occur within a Designated Setback Zone. Where possible, drilling rig and completion equipment engine exhaust will be directed away from occupied buildings to assist with noise mitigation. No noise compliance issues are expected from the production area.
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| Noise mitigation | Form: (02A )
400956015
8/18/2016 | C. Site Specific Mitigation Measures.
i. Noise;
Noise (Rule 604.c.(2)A.)
The subject Great Western Operating Company, L.L.C. (GWOC) location will operate
in accordance with maximum permissible noise levels per COGCC Rule 604.c.(2)A.
and 802, as applicable. GWOC will utilize reasonable and cost-effective best practices
to endeavor to reduce noise levels below these limits in areas where occupied
structures occur within a Designated Setback Zone. Where possible, drilling rig and
completion equipment engine exhaust will be directed away from occupied buildings to
assist with noise mitigation. No noise compliance issues are expected from the
production area. |
| Emissions mitigation | Form: (02A )
400956015
8/18/2016 | Odors and Light Pollution Mitigation
Where possible, drilling rig and completion equipment engine exhaust will be directed away from occupied buildings to assist in mitigating potential odors. Light sources will be directed downwards, and away from occupied structures where possible. While GWOC does not anticipate any mitigation measures will be necessary for odors, sealed tanks with pressure relief valves and emissions controls will be utilized for the production phase. Once the drilling and completion rigs leave the site, there will be no permanently installed lighting on site.
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| Emissions mitigation | Form: (02A )
400956015
8/18/2016 | iv. GWOG will not flare or vent gas upon completion of flowback, excepting upset or emergency conditions,
or with prior written approval from the Director for necessary maintenance operations.
Green Completions (Rule 604.c.(2)C.)
• The quality (combustibility) of the gas is typically monitored directly at the high pressure
separator. When salable (combustible) quality gas is measured/detected the
gas stream is immediately diverted to the sales pipeline or the well is shut in or a form
42 for flaring will be submitted for approval. |
| Drilling/Completion Operations | Form: (02A )
400956015
8/18/2016 | Closed Loop Drilling Systems - Pit Restrictions (Rule 604.c.(2)B.
GWOC is utilizing a Closed Loop Drilling System on the subject facility. No open pit storage of water is foreseen for this facility. If open pit storage of fresh water is required, a Form 15 will be submitted and approved prior to use of such pit, and appropriate signage and escape provisions will be provided as required. Cuttings and drilling fluids will be removed from location and properly treated or disposed of according to applicable regulations.
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| Drilling/Completion Operations | Form: (02A )
400956015
8/18/2016 | Green Completions (Rule 604.c.(2)C.
As applicable, per COGCC Rule 805, GWOC will utilize all reasonable and cost-efficient best practices, including but not limited to those listed in Rule 805, to maximize resource recovery and mitigate releases to the environment.
• Initial frac and drillout effluent is routed through a sand catcher/trap and a junk/sand tank to remove sand and well frac debris.
• Once any hydrocarbons are detected but prior to encountering salable quality combustible gas or significant volumes of liquid hydrocarbons (condensate or oil) (greater than 10 barrels per day average) the effluent is routed through a high-pressure separator and closed-top tanks to minimize emissions to the environment. Hydrocarbon liquids, produced water, and sand are separated utilizing the high-pressure separator.
• The quality (combustibility) of the gas is typically monitored directly at the high-pressure separator. When salable (combustible) quality gas is measured/detected the gas stream is immediately diverted to the sales pipeline or the well is shut in or a from 42 for flaring will be submitted for approval.
• The separated produced water and hydrocarbon liquids (condensate/oil) are directed to specific tanks for storage until being unloaded and hauled to disposal or sales as appropriate.
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| Drilling/Completion Operations | Form: (02A )
400956015
8/18/2016 | Multi-well Pads (Rule 604.c.(2)E.
GWOC strives to utilize multi-well pads wherever technically and economically practicable to minimize potential impacts to neighbors and the environment. Multi-well pads are not always feasible due to numerous possible issues including but not limited to; landowner requirements, topographic constraints, well bore reaches, setback requirements, etc. This pad will be constructed in such a manner that noise mitigation may be installed and removed without disturbing the site or landscaping. The pad has all weather access roads to allow for operator and emergency response. This pad has been placed as far as possible from building units.
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| Drilling/Completion Operations | Form: (02A )
400956015
8/18/2016 | Leak Detection Plan (Rule 604.c(2)F.
GWOC designs its new facilities to both avoid leaks or releases as well as to help detect them in a time-efficient manner to minimize potential impacts. Tanks and all visible pipelines and valves etc. are inspected informally on a daily basis by company lease operators. In addition, GWOC also conducts formal annual SPCC inspections, and formal site specific and random audits, by third-party consultants to inspect for general site conditions as well as condition of tanks, pipelines, and containment structures. In addition, our company lease operators and Production staff review production records, including volumes and pressures, looking for irregularities that may indicate a problem with a tank or pipeline. If an irregularity is detected that may indicate a potential release the suspect tank and/or pipeline(s) are removed from service, isolated, and either pressure tested or visibly inspected for indications of a potential leak.
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| Drilling/Completion Operations | Form: (02A )
400956015
8/18/2016 | Berm Construction (Rule 604.c.(2)G.
A minimum containment capacity of 150% of the single largest storage vessel inside the containment will be constructed around any liquids storage area within a designated setback zone. For this location, steel containment with sealed liners will be utilized at all storage facilities on this location.
Tanks and all visible pipelines and valves etc. will be inspected informally on a daily basis by company lease operators. In addition, GWOC also conducts formal annual SPCC inspections, and formal site specific and random audits, by third-party consultants to inspect for general site conditions as well as condition of tanks, pipelines, and containment structures.
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| Drilling/Completion Operations | Form: (02A )
400956015
8/18/2016 | Pit level indicators (Rule 604.c.(2)K
GWOC does not typically utilize pits in any of its operations. If a pit was to be used proper pit Level indicators would be installed to indicate pit levels and compliance with pit volume rules.
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| Drilling/Completion Operations | Form: (02A )
400956015
8/18/2016 | Fencing requirements (Rule 604.c.(2)M
At a minimum GWOC installs appropriate fencing to restrict access by any unauthorized persons. This fencing may vary depending on site-specific situations. Fencing will be properly noted on facility layout diagrams for both drilling/completion and the production phases of operations.
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