| Wildlife | Form: (02A )
401598341
2/13/2019 | Black Bear
• Initiate a food and waste/refuse management program that uses bear-proof food storage containers and trash receptacles.
• Initiate an education program that reduces bear conflicts.
• Establish policy to prohibit keeping food and trash in sleeping quarters.
• Establish policy to support enforcement of state prohibition on feeding of black bear.
• Report bear conflicts immediately to CPW. |
| Wildlife | Form: (02A )
401598341
2/13/2019 | Sensitive Wildlife Habitat: Greater Sage Grouse
• Identify seasonal habitats and migratory patterns of sage-grouse. Map all seasonal habitats using CPW habitat selection models as they become available.
• No surface occupancy within 0.6 mile of any known greater sage-grouse lek.
• After drilling and completions activities reduce visits to well-sites through remote monitoring (i.e. SCADA) and the use of multi-function contractors.
• Schedule, as best as possible, well site visitations to portions of the day between 9:00 a.m. and 4:00 p.m. during the lekking season (March 1 to May 15).
• Establish company guidelines to minimize wildlife mortality from vehicle collisions on roads.
• Phase and concentrate all development activities, so that large areas of undisturbed habitat for wildlife remain and thorough reclamation occurs immediately after development and before moving to new sites. Development should progress at a pace commensurate with reclamation success.
• Implement the species appropriate Infrastructure Layout and Drilling and Production Operations Wildlife Protection Measures found in Section II D. of the CPW Wildlife BMP document as follows:
• Section II D. DRILLING AND PRODUCTION OPERATIONS WILDLIFE PROTECTION MEASURES: The purpose of these measures is to reduce disturbance on the actual drill site and the surrounding area, to reduce direct conflict with wildlife and hunters, and to prevent wildlife access to equipment.
1. Use centralized hydraulic fracturing operations.
2. Transport water through centralized pipeline systems rather than by trucking.
3. Where possible, locate pipeline systems under existing roadways, or roadways that are planned for development.
4. Maximize use of state-of-the-art drilling technology (e.g., high efficiency rigs, coiled-tubing unit rigs, closed-loop or pitless drilling, etc.) to minimize disturbance.
5. Conduct well completions with drilling operations to limit the number of rig moves and traffic.
6. Install exclusionary devices to prevent bird and other wildlife access to equipment stacks, vents and openings.
7. During pipeline installations install trench plugs, earthen ramps, or other means as necessary to ensure that open pipeline trenches do not trap wildlife, and that pipe strings to not impair wildlife movements.
• Minimize surface disturbance and fragmentation of greater sage-grouse habitat through use of the smallest facility footprints possible, use of multiple well pads, clustering of roads and pipelines, and the widest possible spacing of surface facilities.
• Where applicable design tanks and other facilities with structures such that they do not provide perches or nest substrates for raptors, crows and ravens.
• Where needed, install raptor perch deterrents on equipment, fences, cross arms and pole tops in greater sage-grouse habitat.
• Remove all unnecessary infrastructure.
• Treat waste water pits and any associated pit containing water that provides a suitable medium for breeding mosquitoes with Bti (Bacillus thuringiensis v. israelensis) or take other effective action to control mosquito larvae that may spread West Nile Virus to wildlife, especially grouse.
• Implement the species appropriate reclamation guidelines found in Section II G. of the CPW Wildlife BMP document.
• Section II G. RESTORATION, RECLAMATION AND ABANDONMENT: The purpose of these measures is to restore disturbed sites to their pre-development conditions, using native vegetation that can be used by the indigenous wildlife. Develop a reclamation plan in consultation with CPW, NRCS, and the land owner or land management agency that incorporates wildlife species-specific goals and that defines reclamation performance standards, including the following components:
1. Seed
a. Use only certified weed-free native seed in seed mixes, unless use of non-native plant materials is recommended by CPW.
b. Use locally adapted seed whenever available, especially for species which have wide geographic ranges and much genetic variation (e.g., big sagebrush (Artemesia tridentata), antelope bitterbrush (Purshia tridentata), etc.).
c. Where more than one ecotype of a given species is available and potentially adapted to the site, include more than one ecotype per species in the seed mix.
d. Use appropriately diverse reclamation seed mixes that mirror an appropriate reference area for the site being reclaimed (see also species-specific recommendations).
e. Conduct seeding in a manner that ensures that seedbed preparation and planting techniques are targeted toward the varied needs of grasses, forbs and shrubs (e.g., seed forbs and shrubs separately from grasses, broadcast big sagebrush but drill grasses, etc.).
f. Emphasize bunchgrass over sod-forming grasses in seed mixes in order to provide more effective wildlife cover and to facilitate forb and shrub establishment.
g. Seed immediately after recontouring and spreading topsoil. Spread topsoil and conduct seeding during optimal periods for seed germination and establishment. Use of the same contractor for re-contouring land as used for seeding is often the most effective approach.
h. Do not include aggressive, non-native grasses (e.g., intermediate wheatgrass, pubescent wheatgrass, crested wheatgrass, smooth brome, etc.) in reclamation seed mixes. Site specific exceptions may be considered.
i. Distribute quick germinating site adapted native seed or sterile non-native seed for interim reclamation on cut and fill slopes and topsoil piles.
j. Plan for reclamation failure and be prepared to repeat seeding as necessary to meet vegetation cover, composition, and diversity standards.
2. Vegetative Cover Standard
a. Choose reference areas as goals for reclamation that have high wildlife value, with attributes such a diverse and productive understory of vegetation, productive and palatable shrubs, and a high prevalence of native species.
b. Establish vegetation with total perennial non-invasive plant cover of at least eighty (80) percent of pre-disturbance or reference area levels.
c. Establish vegetation with plant diversity of non-invasive species which is at least half that of pre-disturbance or reference area levels. Quantify diversity of vegetation using a metric that considers only species with at least 3 percent relative plant cover.
d. Observe and maintain a performance standard for reclamation success characterized by the establishment of a self-sustaining, vigorous, diverse, locally appropriate plant community on the site, with a density sufficient to control erosion and non-native plant invasion and diversity sufficient to allow for normal plant community development.
3. Timing
a. Use early and effective reclamation techniques, including interim reclamation to accelerate return of disturbed areas for use by wildlife.
b. Remove all unnecessary infrastructure.
c. Close and reclaim roads not necessary for development immediately, including removing all bridges and culverts and recontouring/reclaiming all stream crossings.
d. Reclaim reserve pits as quickly as possible after drilling and ensure that pit contents do not contaminate soil.
e. Remediate hydrocarbon spills on disturbed areas prior to reclamation.
f. Reclaim sites during optimum seasons (e.g. late fall/early winter or early spring).
g. Complete final reclamation activities so that seeding occurs during the first optimal season following plugging and abandonment of oil and gas wells.
BMPs continued in comments |
| Planning | Form: (02A )
402609499
3/11/2022 | • Prior to submittal of the Application for Permit to Drill (Federal APD), Laramie conducted onsites and meetings with the COGCC, Bureau of Land Management (BLM), Colorado Parks and Wildlife, and the associated private landowners. These onsites and meetings were held to discuss Laramie’s proposed development plan for the CC 0697-15-08 well pad and the Annex Cuttings Facility 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 CC 0697-15-08 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, which minimizes the surface area needed to conduct operations on the CC 0697-15-08 pad location.
• Existing infrastructure operated by Summit and Laramie will be utilized for transportation of natural gas and produced water to minimize the surface disturbance required for tying in gathering facilities.
• Laramie will implement ambient air quality monitoring on site during drilling, completion, and the first six (6) months of production operations.
• Laramie will properly maintain vehicles and equipment.
• Other than safety devices, Laramie will use non-emitting pneumatic controllers.
• Laramie will have adequate and committed pipeline take away capacity for all produced gas and oil. |
| General Housekeeping | Form: (02A )
402609499
3/11/2022 | • Operator will strive to minimization and reduce waste.
• Reduction of waste by use of closed drilling systems to reduce the volume of drilling waste.
• Reduction of waste by use using bulk containers rather than drums.
• Any chemicals used will be kept to a minimum; unused chemicals will be transported to another site or will be sent back to the chemical provider company.
• Proper Implement good housekeeping measures to minimally impact the operating area and maintain a well-kept appearance at all company facilities; all materials will be stored in a neat and orderly manner in their appropriate containers.
• A designated storage area will be established for waste storage; waste will be segregated and stored according to its waste classification; operator will properly characterize and dispose of all waste (i.e. the specific landfill/waste disposal location allows for acceptance of the waste stream).
• Ve icular 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 chemical or hydrocarbon spills will be cleaned up immediately in accordance with established company procedures.
• Laramie will follow manufacturers’ recommendations and company policies for proper use and disposal of products. |
| Wildlife | Form: (02A )
402609499
3/11/2022 | • Laramie will inform and educate all employees and contractors on wildlife conservation practices, including no harassment or feeding of wildlife.
• Laramie will minimized direct impact to wildlife habitat by using 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 )
402609499
3/11/2022 | • Stormwater control measures will be in place during all phases of development (construction, drilling, completions, interim reclamation, and production) 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 with a collection trench inside the Working Pad Surface along the eastern, southern, and western sides and around the cuttings management area along the northern (cut slope) edge of the WPS; The collection trench drains to a sediment trap with a 6-inch outlet pipe in the southwest corner of the WPS; there will be a system of exterior (outside the WPS) diversion ditches along the base of the fill slopes around the eastern, southern, and western sides of the disturbance area; these ditches will have rocked check dams and will tie into a sediment catchment system in the southwest corner; silt fencing will be placed along the western, southern, and eastern edges of the maximum area of disturbance; 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 roadbase materials for surfacing; the location is subject to State oversight from the COGCC.
• Topsoil will be stored within a stockpile along the northern and western edges of the location, outside of the Working Pad Surface, and will be segregated from all subsurface material; to minimize potential for loss of organic materials, waddles will be placed around the entire perimeter of the topsoil stockpile and a silt fence will be place along the inside of the pile on the west side.
• Excess spoils will be stored within a stockpile along the eastern edge of the location, outside of the Working Pad Surface and will be segregated from all subsurface material; waddles will be placed around the entire perimeter of the spoils stockpile.
• Outlet protection should be used when a conveyance discharges onto a disturbed area where there is potential for accelerated erosion due to concentrated flow.
• Laramie will conduct stormwater inspections immediately after storm event.
• Laramie will conduct weekly stormwater inspections during normal operations.
• 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 Laramie proposed produced water management system for disposal/treatment.
• Documentation / Stormwater Management Plan - if it is infeasible to install or repair a control measure immediately after discovering a deficiency, Laramie 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.
• After interim reclamation, wattles will be placed around the entire perimeter of the original area of disturbance; a diversion ditch will remain along the southern edge of the location leading to a sediment catchment system; a minimum 1.5-foot compacted earthen perimeter berm with a collection trench inside the final Production Pad Surface will be placed around the entire well pad and will be tied into a sediment catchment system at the southern edge of the pad surface. |
| Material Handling and Spill Prevention | Form: (02A )
402609499
3/11/2022 | 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; closed loop solids control system will be utilized with no reserve pits.
• 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.
• Temp 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.
• Pipelines (flowlines from wellheads to separators to tanks; and any temporary surface lines used for hydraulic stimulation and/or flowback operations) will be pressure test in accordance with the 1100-series rules prior to putting into initial service any temporary surface or permanent surface/buried pipelines 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.
• Laramie spill response procedures will be adhered to for any spills or releases; all spills will be managed in accordance with the COGCC 900 Series rules.
• A berm will be installed around the perimeter of the pad.
• Drilling mud will be fresh water bentonitic based.
• Drilling fluid products will be stored on location off the ground and in containment sheltered from the weather.
• Fuel storage tank will have secondary containment underneath fuel pump, fittings, and hose connections.
• Drill cutting storage will be stockpiled on the edge of location against the cut slope of a pad (if available) segregated from all topsoil and vegetation. Appropriate storm water drainage will be in place and the cuttings storage area will have a berm at the base to prevent any storm water run-off from exiting the pad or spreading to the rest of the pad outside of the designated area. • Closed loop solids control system will be utilized with no reserve pits.
• All wells located on the pads will be equipped with remote shut-in capabilities.
• The use of cathodic protection on buried steel lines to mitigate corrosion. |
| Material Handling and Spill Prevention | Form: (02A )
402609499
3/11/2022 | Fluid Leak Detection:
• Audio, Visual, and Olfactory (AVO) inspections: AVO inspections will be conducted monthly at the each of the locations (CC 0610-21-41 Well Pad, CC 0603-23-32 Well Pad, and CC 0697-15-08 Well Pad) throughout the life of the well pads.
• Routine inspection of all production equipment, wellheads, temporary equipment, etc.; As described above, routine inspections to be conducted at the well pad location will include: Routine physical inspections of production equipment (by Laramie production personnel); Air Compliance inspections and monitoring (by Laramie 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 Laramie production personnel).
• As part of our LDAR, STEM, OOOOa inspection / compliance programs, Laramie will adhere to the use of Approved Instrument Monitoring Methods (AIMM) for inspecting production equipment and facilities at the well pad.
• 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.
• Laramie spill response procedures will be adhered to for any spills or releases occurring at the well pad. All spills will be managed in accordance with the COGCC 900 Series rules.
• Leak Detection and Repair (LDAR) inspections are performed at all locations; however, the inspection frequency is tiered based upon the level of emission controls that are required / employed at each location.
• 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 per COGCC regulation; all records will be made available to the COGCC upon request.
• All loadlines will be bullplugged 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 Laramie’s office).
• Laramie will track and clean up all spills, including those that are not reportable.
• Laramie 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.
• 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 )
402609499
3/11/2022 | Per- and Polyfluoroalkyl Substances [PFAS]):
• If PFAS-containing foam is used at a location, Laramie 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, Laramie will properly capture and dispose of PFAS-contaminated soil and fire and flush water.
• If PFAS-containing foam is used at a location: Laramie will properly characterize the site to determine the level, nature and extent of contamination. |
| Dust control | Form: (02A )
402609499
3/11/2022 | • During Well Pad and Access Road Construction, freshwater will be applied to dry soils at all disturbance areas during construction to minimize fugitive dust.
• Laramie will not use produced water or other process fluids for dust suppression.
• During High Winds - Laramie will monitor wind conditions during site construction; during wind event in excess of 13 miles per hour, Laramie 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 wind event over 20 miles per hour, Laramie 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.
• Field employees will notify operations if dust is observed.
• Water trucks will be utilized to wet roadways, as needed, when natural moisture is insufficient to prevent airborne dust.
• Water trucks apply magnesium chloride or fresh water to roadways depending on location.
• Drop heights from excavators and loaders shall be minimized to a distance no more than 5 feet.
• Contractor shall conduct a visual inspection of the vehicle wheels and the wheels of the equipment loaded upon each vehicle to assess the presence of dirt.
• Road Surfacing of new Access Roads - The existing lease road will be spot graveled during site construction to ensure there is sufficient gravel on the road to minimize fugitive dust; six (6) inches of road surfacing materials will be applied to the proposed access road following construction.
• Speed Restrictions - Laramie has implemented speed restrictions on all lease roads and requires all Laramie employees and contractors to adhere to all posted speed restrictions; the speed limit for the existing access road and the proposed access road to the locations will be twenty-five (25) miles per hour.
• Road Maintenance - During long-term production operations, Laramie will conduct inspections of the existing and proposed access roads 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 - Laramie will utilize telemetry equipment to minimize well site visitation when possible to reduce fugitive dust from vehicles traveling the dirt / gravel roads.
• Completion operations will not use any proppant to eliminate possible fugitive sand dust emissions. |
| Noise mitigation | Form: (02A )
402609499
3/11/2022 | • 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 noise regulations set forth by COGCC Rule 423.
• Exhaust mufflers will be installed on engines to reduce noise impacts.
• Mufflers or vent tanks will be used for sound suppression when bypassing air injection on connections when drilling with aerated fluid.
• Major surface pipe handling operations will be limited to daylight hours as much as possible.
• Solids control equipment and shale shakers will be maintained to ensure proper function and noise mitigation.
• If a noise complaint is made to either Laramie directly, the COGCC, or the local government, and Laramie is notified of the complaint, noise levels will be measured within 48 hours of receipt of the complaint; Laramie 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 )
402609499
3/11/2022 | • Laramie’s proposed well pads and other surface locations in its Laramie 2021 Cascade Creek OGDP are located outside of, but near, High Priority Habitat. As an additional best management practice to avoid and/or mitigate adverse impacts to such High Priority Habitat, Laramie will collect data on both ambient noise levels and noise levels during drilling and completion operations within the nearest High Priority Habitat area nearest each well pad. The noise levels will be measured at a single location that is within the boundary of the nearest High Priority Habitat area and is at least 350 feet from the nearest area of disturbance. Laramie will submit noise survey data to COGCC via Form 4 Sundry at least once prior to construction, at least once during drilling operations, and at least once during completions operations, to demonstrate average ambient and operational noise levels. If noise levels regularly or significantly exceed the maximum Commercial/Agricultual cumulative noise levels set forth in Table 423-2, Laramie will assess what more it may do to further reduce noise levels during drilling and completion operations. The implementation of any additional noise mitigation measures undertaken by Laramie, and the method by which such noise mitigation measures are implemented, shall be in and according to Laramie’s discretion, and shall not create additional surface disturbance or other adverse cumulative impacts. Before implementing any additional noise mitigation measure, Laramie shall confer with Colorado Parks and Wildlife and COGCC staff. |
| Emissions mitigation | Form: (02A )
402609499
3/11/2022 | • Laramie 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.
• Venting/Flaring - Laramie will control bradenhead/casinghead venting.
• Venting/Flaring - Laramie 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. |
| Odor mitigation | Form: (02A )
402609499
3/11/2022 | • Drill cuttings will be run through a centrifugal dryer to minimize odor during temporary storage on location prior to transfer and placement into the Annex Cuttings Facility.
• If odor complaints are received and it is determined that they are caused by the drilling fluids, then an odor neutralizing agent or similar product will be added to the system to eliminate the odor.
• 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. |
| Drilling/Completion Operations | Form: (02A )
402609499
3/11/2022 | • Site lighting shall be shielded and directed downward and inward toward operations to avoid glare on nearby public roads.
• A closed loop system will be implemented during drilling.
• Laramie will use zero VOC (group III, low/negligible odor) drilling mud.
• All cuttings generated during drilling will be kept in a bermed portion of the well pad prior to disposition offsite.
• The moisture content of any water/bentonite-based drilling mud (WBM-) generated cuttings shall be as low as practicable to prevent accumulation of liquids greater than de minimis amounts; solids control equipment consisting of shale shakers, centrifuges, and flocculating unit may be utilized to separate WBM-generated cutting solids from liquids (water/bentonite drilling mud); drill cuttings will be segregated between surface casing cuttings and the intermediate / production zone cuttings; and stockpiled on location.
• Cuttings samples from each interval (surface casing, intermediate, and production) will be collected and will be submitted for laboratory analysis of COGCC Table 915-1 constituents; if cuttings meet Table 915-1 standards, they will be treated as non-oily waste and disposed of in the three-sided containment area at the Annex Cuttings Facility.
• In the event that a certain volume of drill cuttings analytically demonstrate constituents above Table 915-1 standards, the cuttings will be remediated during treatment and management at the Annex Cuttings Facility to levels below all applicable standards of Table 915-1.
• Laramie will cover trucks transporting drill cuttings to reduce dust and PM emissions during transport of WBM solids and cuttings materials from each well pad location.
• No offsite disposal of cuttings to another oil and gas location shall occur without prior approval of the Form 28 Centralized E&P Waste Management Facility. If cuttings are generated prior to aoproval of the Form 28, cuttings may be sent to a third party commercial disposal facility. An amended Waste Management Plan specifying disposal location and waste characterization method; commercial disposal of drill cuttings and drilling fluids will only require the operator to maintain documentation (manifests, bills of lading) of drill cuttings and drilling fluids disposal; the operator will implement measures (covers, misting) in trucks to reduce dust and PM emissions during transport of WBM solids and cuttings materials from the well pad location.
• Recycled produced water will be utilized for well completion operations minimizing the amount of fresh water required for development of the proposed wells on this location.
• Laramie will use pipelines to transport water for hydraulic fracturing to and from location.
• Laramie will recycle or beneficially reuse flowback and produced water for use downhole.
• Laramie will properly characterize and dispose of all waste at the appropriate specific landfill/waste disposal location that allows for acceptance of the particular waste stream. |
| Interim Reclamation | Form: (02A )
402609499
3/11/2022 | Topsoil Protection:
• 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 stabilizing stockpile surfaces 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 or other similar measures.
• Protection from Water Erosion - surface roughening, applying hydro-seed/mulch, using soil tackifier, covering stockpiles with rolled erosion control products or other similar measures.
• Weed Establishment Prevention - Laramie uses Cultural, Mechanical, Biological, and Chemical controls to prevent the establishment of weeds. |
| Interim Reclamation | Form: (02A )
402609499
3/11/2022 | • 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.
• Weed Establishment Prevention - Laramie uses Cultural, Mechanical, Biological, and Chemical controls to prevent the establishment of weeds. |
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