| OGLA | Form: (02A)
400336416
11/12/2012 | SITE SPECIFIC COAs
Notify the COGCC 48 hours prior to start of pad construction, rig mobilization, spud, and start of hydraulic stimulation operations using Form 42 (the appropriate COGCC individuals will automatically be email notified, including the LGD for hydraulic stimulation operations).
Operator must implement best management practices to contain any unintentional release of fluids, including any fluids conveyed via temporary surface or buried pipelines.
Operator must ensure secondary containment for any volume of fluids contained at well site during drilling and completion operations (as shown on the Proposed BMPs attachment); including, but not limited to, construction of a berm or diversion dike, diversion/collection trenches within and/or outside of berms/dikes, site grading, or other comparable measures (i.e., best management practices (BMPs) associated with stormwater management) sufficiently protective of nearby surface water. Any berm constructed at the well pad location will be stabilized, inspected at regular intervals (at least every 14 days), and maintained in good condition.
The moisture content of any cuttings in a cuttings pit, trench, or pile shall be as low as practicable to prevent accumulation of liquids greater than de minimis amounts. At the time of closure, if the drill cuttings are to be left onsite, they must also meet the applicable standards of table 910-1.
Flowback and stimulation fluids must be sent to tanks, separators, or other containment/filtering equipment before the fluids can be placed into any pipeline, storage vessel, or lined pit (only if an amended Form 2A has been submitted/approved and a Form 15 Earthen Pit Permitted has been submitted/approved) located on the well pad; or into tanker trucks for offsite disposal. The flowback and stimulation fluid tanks, separators, or other containment/filtering equipment must be placed on the well pad in an area with additional downgradient perimeter berming. The area where flowback fluids will be stored/reused must be constructed to be sufficiently impervious to contain any spilled or released material.
Berms or other containment devices shall be constructed to be sufficiently impervious (preferably corrugated steel with poly liner) to contain any spilled or released material around crude oil, condensate, and produced water storage tanks. |
| OGLA | Form: (02A)
400336416
11/12/2012 | TEMPORARY SURFACE PIPELINE COAs:
Operator must implement best management practices to contain any unintentional release of fluids along all portions of the surface pipeline route where temporary pumps and other necessary equipment are located.
Operator must routinely inspect the entire length of the surface pipeline to ensure integrity.
Operator must ensure 110 percent secondary containment for any potential volume of fluids that may be released from the surface pipeline at all stream, intermittent stream, ditch, and drainage crossings.
Operator will utilize, to the extent practical, all existing access and other public roads, and/or existing pipeline right-of-ways, when placing/routing the surface pipelines. This will reduce surface disturbance and fragmentation of wildlife habitat in the area. |
| OGLA | Form: (02A)
400390561
04/10/2013 | FIELD CONSTRUCTED STEEL TANK COAs:
Notify the COGCC 48 hours prior to start of water storage tank pad construction, tank construction, start of hydrostatic test, pipeline testing, and start of hydraulic stimulation operations using Form 42 (the appropriate COGCC individuals will automatically be email notified, including the LGD for hydraulic stimulation operations).
Operator must ensure secondary containment for any volume of fluids contained at the well pad location, as well as the large volume field constructed steel tank pad site during operations (as described in the tank documents and shown on the Construction Layout Drawings attachments); including, but not limited to, construction of a berm or diversion dike, diversion/collection trenches within and/or outside of berms/dikes, site grading, or other comparable measures (i.e., best management practices (BMPs) associated with stormwater management) sufficiently protective of nearby surface water. Any berm constructed at the large volume field constructed tank site and well pad location will be stabilized, inspected at regular intervals (at least every 14 days), and maintained in good condition.
No portion of any field constructed steel tank that will be used to hold liquids shall be constructed on fill material, unless the tank and fill portion of the pad area are designed and certified by a professional engineer, subject to review and approval by the director prior to construction of the tank. The construction of the tank shall be supervised by a professional engineer or their agent.
Operator shall stabilize exposed soils and slopes as an interim measure during operation of the field constructed steel tank.
Operator shall install, use, operate, and maintain the field constructed steel tank in accordance with manufacturer specifications and requirements, as provided and referenced in data submitted with and subsequent to this Form 2A.
The nearby downgradient hillsides below the LVAST must be periodically monitored for any day-lighting of fluids throughout tank operations.
Additional containment shall be required where temporary or permanent pumps and other necessary equipment or chemicals are located.
Operator will use adequately sized containment devices for all chemicals and/or hazardous materials stored or used on location and the facility shall comply with the operators SPCC Plan.
Operator will use adequately sized containment devices for all chemicals and/or hazardous materials stored or used on location and the facility shall comply with the operators SPCC Plan.
Strategically apply fugitive dust control measures, including enforcing established speed limits on private roads, to reduce fugitive dust and coating of vegetation and deposition in water sources.
Prior to operating any field constructed steel tank, a hydrostatic step test shall be conducted by filling the field constructed steel tank incrementally at 3-foot intervals (3-foot, 6-foot, and 9-foot), not to exceed 2-foot freeboard requirement on tanks constructed with no lid or with a floating top. The operator shall monitor the tank for leaks for a period of 12 hours for each step, prior to either draining the tank for repairs or commencing operations. Operator shall notify the COGCC Oil and Gas Location Assessment (OGLA) Specialist for Western Colorado (Dave Kubeczko; email dave.kubeczko@state.co.us) 48 hours prior to start of the hydrotest. Hydrotest monitoring results must be maintained by the operator for the life of the tank and provided to COGCC prior to using the tank (via Form 4 Sundry to Dave Kubeczko; email dave.kubeczko@state.co.us).
Operator will implement measures to ensure that adequate separation of hydrocarbons from the influent occurs to prevent accumulation of oil on the surface of stored completions fluids. Operator shall also employ a method for monitoring buildup of phase-separated hydrocarbons on the surface of stored fluids.
No oil is permitted on the surface of completions fluids.
The operator shall submit, and receive approval of, a reuse and recycling plan per Rule 907.a.(3), prior to any offsite reuse/recycling of tank fluids.
This field constructed steel tank shall be used for a period of no more than three (3) years for storage, recycling, reuse, treatment, or disposal of E&P waste or fresh water. Should the operation of this field constructed steel tank continue more than three years, a Form 28 shall be submitted and approved prior to the expiration of the Form 2A.
The operator shall submit, and receive approval of, a reuse and recycling plan, prior to any offsite reuse/recycling of pit fluids.
Submit additional disposal facilities (wells, pits, etc.), for tank liquid contents to COGCC via a Form 4 Sundry prior to disposal.
At the time of tank closure, operator must submit disposal information for solids, if necessary, via a Form 4 Sundry Notice to the COGCC Location Specialist for Western Colorado (Dave Kubeczko; email dave.kubeczko@state.co.us). The disposal method will need to be approved prior to operator starting tank closure. |
|
| PROPOSED BMPs | Form: (07 )
0
1/23/2012 | RU 23 -5
In addition to compliance with General Operating Requirements required under COGCC rule 1203 to be applied in Sensitive Wildlife Habitat and Restricted Surface Occupancy areas or COGCC 1204 to be applied statewide or in areas noted in the Rule, Williams will employ the following BMPs either field wide or at the specific location for which this Form 2A is being submitted.
Field Wide BMPs:
General
• Prepare plans and studies to support wildlife conservation and protection
• Contribute to and participate in wildlife studies and research efforts related to oil and gas activity's relationship to wildlife
• Treat /control noxious weeds /plants including Tamarisk
• Assist CDOW in obtaining access to private lands for wildlife research and conservation
• Focus BMPs on critical wildlife seclusion and "crucial habitats'
• Contribute to organizations that acquire /manage habitat
• Continue to Support Operation Game Thief
• Continue to support CDOW sportsman's programs
• Participate in wildlife seminars and conferences (e.g. AFWA)
• Focus Ranch and Property Management (Williams' owned /managed properties) on wildlife resources
• Identify conservation easement opportunities on Williams- owned /managed properties
• Acquire water rights and irrigate key habitat areas
• Restrict and /or manage grazing to benefit wildlife
• Fence and restrict activities in locations that provide high value habitat
• Construct habitat improvement projects as practical
• Enforce policies to protect wildlife (e.g., no poaching, no firearms, no dogs on location, no feeding of wildlife, etc.).
• Inventory, monitor and remove obsolete, degraded, or hazardous fencing on Williams owned property
• Support research to test the effectiveness of specific Best Management Practices
Planning
• Conduct wildlife surveys to determine presence of game /non -game species/habitat
• Identify and Protect "crucial habitats"
• Site access roads, pads and facilities in locations that minimize habitat impacts
• Identify private and Federal land seclusion areas where drilling will be voluntarily deferred in critical seasonal habitats
• Identify and protect migration corridors
• Minimize well pad density to the extent possible
• Minimize the number, size and distribution of well pads and locate pads a existing roads where possible.
• Cluster well pads in the least environmentally sensitive areas.
• Plan pipelines routes ahead of time to avoid field fitting and reduce excessive ROW widths and reclamation.
• Adequately size infrastructure and facilities to accommodate both current and future gas production.
Construction
• Schedule necessary construction in stream courses to avoid critical spawning times.
• Surface roads to ensure that the anticipated volume of traffic and the weight and speed of vehicles using the road do not cause environmental damage, including generation of fugitive dust and contribution of sediment to downstream areas.
• Protect culvert inlets from erosion and sedimentation and install energy dissipation structures at outfalls
• Use the minimum right -of -way width and vegetation mats where pipelines cross riparian areas and streams wherever possible
• Construct fluid pit fences and nets that are capable of withstanding animal pressure and environmental conditions and that are appropriately sized for the wildlife encountered.
• Install impermeable barriers beneath fluid pits to protect groundwater, riparian areas and wetlands.
• Salvage topsoil from all road construction and other rights -of -way and re -apply during interim and final reclamation.
• Strip and segregate topsoil prior to construction. Appropriately configure topsoil piles and immediately seed to control erosion, prevent weed establishment and maintain soil microbial activity
Drilling/Completions
• Continue application of BMPs to prevent wildlife from entering pits including fencing and netting where appropriate
• Limit days/hours operations where practical to minimize disturbance and traffic
• Promptly report spills that affect wildlife to the CDOW.
• Store and stage emergency spill response equipment at strategic locations so that it is available to expedite effective spill response.
• Limit parking to already disturbed areas that have not yet been reclaimed
• Screen water suction hoses to exclude fish.
• Reduce noise by using effective sound dampening devices or techniques (e.g., hospital -grade mufflers, equipment housing, insulation, installation of sound barriers, earthen berms, vegetative buffers, etc.).
Production/Reclamation
|
| PROPOSED BMPs | Form: (07 )
0
1/23/2012 | • Gate access roads where necessary to minimize /control access to "crucial habitats"
• Install automated emergency response systems (e.g., high tank alarms, emergency shut- down systems, etc.).
• Implement fugitive dust control program
• Avoid direct discharge of pipeline hydrostatic test water to any reservoir, lake,wetland, or natural perennial or seasonally flowing stream or river.
• Locate above -ground facilities to minimize the visual effect (e.g., low profile equipment, appropriate paint color, vegetation screening in wooded areas, etc.).
• Skim and eliminate oil from produced water ponds and fluid pits at a rate sufficient to prevent oiling of birds or other wildlife that could gain access to the pit.
• Apply an aggressive, integrated, noxious and invasive weed management plan. Utilize an adaptive management strategy that permits effective responses to monitored findings and reflects local site and geologic conditions
• Map the occurrence of existing weed infestations prior to development to effectively monitor and target areas that will likely become issues after development.
• Evaluate the utility of soil amendment application or consider importing topsoil to achieve effective reclamation.
• Use locally adapted seed whenever available and approved by landowner.
• Use appropriately diverse reclamation seed mixes that mirror an appropriate reference area for the site being reclaimed where approved by landowner.
• 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.)
• Emphasize bunchgrass over sod - forming grasses in seed mixes in order to provide more effective wildlife cover and to facilitate forb and shrub establishment.
• Seed during appropriate season to increase likelihood of reclamation success
• Do not include aggressive, non - native grasses in reclamation seed mixes
• 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.
• Establish vegetation with total perennial non - invasive plant cover of at least eighty (80) percent of pre - disturbance or reference area levels.
• 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.
• Establish permanent and monumented photo points and vegetation measurement plots or transects; monitor at least annually until plant cover, composition, and diversity standards have been met.
• 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 or normal plant community development.
• Use early and effective reclamation techniques, including interim reclamation to accelerate return of disturbed areas for use by wildlife
• Remove all unnecessary infrastructure during the production phase.
• Reclaim reserve pits as quickly as practical after drilling and ensure that pit contents do not contaminate soil.
• Remediate hydrocarbon spills on disturbed areas prior to reclamation.
• Complete final reclamation activities so that seeding occurs during the first optimal season following plugging and abandonment of oil and gas wells.
• Perform interim reclamation to final reclamation species composition and establishment standards.
• Perform interim reclamation on all disturbed areas not needed for active support of production operations
• Remove and properly dispose of degraded silt fencing and erosion control materials after their utility has expired
• Remove and properly dispose of pit contents where contamination of surface water, groundwater, or soil by pit contents cannot be effectively prevented
• Apply certified weed free mulch and crimp or tacify to remain in place to reclaim areas for seed preservation and moisture retention
• Control weeds in areas surrounding reclamation areas in order to reduce weed competition
• Educate employees and contractors about weed issues
• Where possible, fence livestock and /or wildlife out of newly reclaimed areas until reclamation standards have been met and plants are capable of sustaining herbivory
• Conduct necessary reclamation and invasive plant monitoring.
• Census and assess the utilization of the reclaimed areas by the target species
• Maintain pre and post development site inspection records and monitor operations for compliance
• Utilize GIS technologies to assess the extent of disturbance and document the reclamation progression and the footprint of disturbances
• Identify native species for which commercial seed sources are not available. Provide support to contractors for developing cultivation and seed production techniques for needed species
• Conduct reclamation field trials to match seed mixes, soil preparation techniques, and planting methods to local conditions.
Site Specific BMPs:
Planning
Share /consolidate corridors for pipeline ROWs to the maximum extent possible. Maximize the utility of surface facilities by developing multiple wells from a single pad (directional drilling), and by co- locating multipurpose facilities (for
|
| PROPOSED BMPs | Form: (07 )
0
1/23/2012 | example, well pads and compressors) to avoid unnecessary habitat fragmentation and disturbance of additional geographic areas.
• Minimize newly planned activities and operations within 300 feet of the ordinary high water mark of any reservoir, lake, wetland, or natural perennial or seasonally flowing stream or river.
• Locate roads outside of drainages where possible and outside of riparian habitat.
• Avoid constructing any road segment in the channel of an intermittent or perennial stream.
• Avoid new surface disturbance and placing new facilities in key wildlife habitats in consultation with CDOW.
• Minimize the number, length, and footprint of oil and gas development roads;
• Use existing roads where possible
• Combine utility infrastructure (gas, electric, and water) planning with roadway planning to avoid separate utility corridors
• Combine and share roads to minimize habitat fragmentation
• Where possible, consolidate pipeline and existing roadways, or roadways that are planned for development
• Place roads to avoid obstructions to migratory routes for wildlife, and to avoid displacement of wildlife from public to private lands.
• Design roads with visual and auditory buffers or screens (e.g., topographic barriers, vegetation, and distance).
• Accelerate development under a "clustered- development concept' on a site - specific basis where Williams has a 100% mineral interest or control of mineral development
• Maximize the use of directional drilling to minimize habitat loss /fragmentation
• Maximize use of long -term centralized tank batteries to minimize traffic
• Maximize use of remote completion/frac operations to minimize traffic
• Maximize use of remote telemetry for well monitoring to minimize traffic
• Phase and concentrate development activities, so that large areas of undisturbed habitat for wildlife remain.
• Maintain undeveloped areas within development boundaries sufficient to allow wildlife to persist within development boundaries during all phases of construction, drilling, and production.
• Minimize the duration of development and avoid repeated or chronic disturbance of developed areas. Complete all anticipated drilling within a phased,concentrated, development area during a single, uninterrupted time period.
• Restrict oil and gas activities as practical during critical seasonal periods
• Implement self imposed timing limitations to protect species and /or habitat Construction
• Close and reclaim roads not necessary for development,including removing all bridges and culverts and recontouring/reclaiming all stream crossings.
• Structures for perennial or intermittent stream channel crossings should be constructed using appropriately sized bridges or culverts
•Design road crossings of streams to allow fish passage at all flows and to minimize the generation of sediment.
•Design road crossings of streams at right angles to all riparian corridors an streams to minimize the area of disturbance to the extent possible.
•Construct retention basins and ponds that benefit wildlife
Drilling/Completions
•Install and maintain adequate measures to exclude all types of wildlife (e.g., big game, birds, and small rodents) from all fluid pits (e.g., fencing, netting, and other appropriate exclusion measures).
•Conduct well completions with drilling operations to limit the number of rig moves and traffic.
Production/Reclamation
• Utilize staked soil retention blankets for erosion control and reclamation of large surface areas with 3:1 or steeper slopes. Avoid use of plastic blanket materials.
• Restore both form and function of impacted wetlands and riparian areas and mitigate erosion.
• Remove well pad and road surface materials that are incompatible with post -production land use and re- vegetation requirements
• Use only certified weed -free native seed in seed mixes, except for non - native plants that benefit wildlife
• Install exclusionary devices to prevent bird and other wildlife access to equipment stacks, vents and openings.
• Reduce visits to well -sites through remote monitoring (i.e. SCADA) and the use of multi - function contractors.
• 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 where possible.
• Bore pipelines that cross perennial streams
• Install and use locked gates or other means to prevent unauthorized vehicular travel on roads and facility rights -of -way.
|
| Planning | Form: (02A )
400336416
11/26/2012 | Planning
• Conduct wildlife surveys to determine presence of game/non-game species/habitat
• Identify and Protect “crucial habitats”
• Site access roads, pads and facilities in locations that minimize habitat impacts
• Identify private and Federal land seclusion areas where drilling will be voluntarily deferred in critical seasonal habitats
• Identify and protect migration corridors
• Minimize well pad density to the extent possible
• Minimize the number, size and distribution of well pads and locate pads along existing roads where possible.
• Cluster well pads in the least environmentally sensitive areas.
• Plan pipelines routes ahead of time to avoid field fitting and reduce excessive ROW widths and reclamation.
• Adequately size infrastructure and facilities to accommodate both current and future gas production.
|
| Interim Reclamation | Form: (02A )
400336416
11/26/2012 | Production/Reclamation
• Gate access roads where necessary to minimize/control access to “crucial habitats”
• Install automated emergency response systems (e.g., high tank alarms, emergency shut- down systems, etc.).
• Implement fugitive dust control program
• Avoid direct discharge of pipeline hydrostatic test water to any reservoir, lake, wetland, or natural perennial or seasonally flowing stream or river.
• Locate above-ground facilities to minimize the visual effect (e.g., low profile equipment, appropriate paint color, vegetation screening in wooded areas, etc.).
• Skim and eliminate oil from produced water ponds and fluid pits at a rate sufficient to prevent oiling of birds or other wildlife that could gain access to the pit.
• Apply an aggressive, integrated, noxious and invasive weed management plan. Utilize an adaptive management strategy that permits effective responses to monitored findings and reflects local site and geologic conditions
• Map the occurrence of existing weed infestations prior to development to effectively monitor and target areas that will likely become issues after development.
• Evaluate the utility of soil amendment application or consider importing topsoil to achieve effective reclamation.
• Use locally adapted seed whenever available and approved by landowner.
• Use appropriately diverse reclamation seed mixes that mirror an appropriate reference area for the site being reclaimed where approved by landowner.
• 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.)
• Emphasize bunchgrass over sod-forming grasses in seed mixes in order to provide more effective wildlife cover and to facilitate forb and shrub establishment.
• Seed during appropriate season to increase likelihood of reclamation success
• Do not include aggressive, non-native grasses in reclamation seed mixes
• 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.
• Establish vegetation with total perennial non-invasive plant cover of at least eighty (80) percent of pre-disturbance or reference area levels.
• 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.
• Establish permanent and monumented photo points and vegetation measurement plots or transects; monitor at least annually until plant cover, composition, and diversity standards have been met.
• 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.
• Use early and effective reclamation techniques, including interim reclamation to accelerate return of disturbed areas for use by wildlife
• Remove all unnecessary infrastructure during the production phase.
• Reclaim reserve pits as quickly as practical after drilling and ensure that pit contents do not contaminate soil.
• Remediate hydrocarbon spills on disturbed areas prior to reclamation.
• Complete final reclamation activities so that seeding occurs during the first optimal season following plugging and abandonment of oil and gas wells.
• Perform interim reclamation to final reclamation species composition and establishment standards.
• Perform interim reclamation on all disturbed areas not needed for active support of production operations
• Remove and properly dispose of degraded silt fencing and erosion control materials after their utility has expired
• Remove and properly dispose of pit contents where contamination of surface water, groundwater, or soil by pit contents cannot be effectively prevented
• Apply certified weed free mulch and crimp or tacify to remain in place to reclaim areas for seed preservation and moisture retention
• Control weeds in areas surrounding reclamation areas in order to reduce weed competition
• Educate employees and contractors about weed issues
• Where possible, fence livestock and/or wildlife out of newly reclaimed areas until reclamation standards have been met and plants are capable of sustaining herbivory
• Conduct necessary reclamation and invasive plant monitoring.
• Census and assess the utilization of the reclaimed areas by the target species
• Maintain pre and post development site inspection records and monitor operations for compliance
• Utilize GIS technologies to assess the extent of disturbance and document the reclamation progression and the footprint of disturbances
• Identify native species for which commercial seed sources are not available. Provide support to contractors for developing cultivation and seed production techniques for needed species
• Conduct reclamation field trials to match seed mixes, soil preparation techniques, and planting methods to local conditions.
|
| Construction | Form: (02A )
400336416
11/26/2012 | Construction
• Schedule necessary construction in stream courses to avoid critical spawning times.
• Surface roads to ensure that the anticipated volume of traffic and the weight and speed of vehicles using the road do not cause environmental damage, including generation of fugitive dust and contribution of sediment to downstream areas.
• Protect culvert inlets from erosion and sedimentation and install energy dissipation structures at outfalls
• Use the minimum right-of-way width and vegetation mats where pipelines cross riparian areas and streams wherever possible
• Construct fluid pit fences and nets that are capable of withstanding animal pressure and environmental conditions and that are appropriately sized for the wildlife encountered.
• Install impermeable barriers beneath fluid pits to protect groundwater, riparian areas and wetlands.
• Salvage topsoil from all road construction and other rights-of-way and re-apply during interim and final reclamation.
• Strip and segregate topsoil prior to construction. Appropriately configure topsoil piles and immediately seed to control erosion, prevent weed establishment and maintain soil microbial activity
|
| Planning | Form: (02A )
400336416
11/26/2012 | General
• Prepare plans and studies to support wildlife conservation and protection
• Contribute to and participate in wildlife studies and research efforts related to oil and gas activity’s relationship to wildlife
• Treat/control noxious weeds/plants including Tamarisk
• Assist CDOW in obtaining access to private lands for wildlife research and conservation
• Focus BMPs on critical wildlife seclusion and “crucial habitats’
• Contribute to organizations that acquire/manage habitat
• Continue to Support Operation Game Thief
• Continue to support CDOW sportsman’s programs
• Participate in wildlife seminars and conferences (e.g. AFWA)
• Focus Ranch and Property Management (Williams’ owned/managed properties) on wildlife resources
• Identify conservation easement opportunities on Williams-owned/managed properties
• Acquire water rights and irrigate key habitat areas
• Restrict and/or manage grazing to benefit wildlife
• Fence and restrict activities in locations that provide high value habitat
• Construct habitat improvement projects as practical
• Enforce policies to protect wildlife (e.g., no poaching, no firearms, no dogs on location, no feeding of wildlife, etc.).
• Inventory, monitor and remove obsolete, degraded, or hazardous fencing on Williams owned property
• Support research to test the effectiveness of specific Best Management Practices
|
| Site Specific | Form: (02A )
400336416
11/26/2012 | Site Specific BMPs:
Planning
• Share/consolidate corridors for pipeline ROWs to the maximum extent possible.
• Maximize the utility of surface facilities by developing multiple wells from a single pad (directional drilling), and by co-locating multipurpose facilities (for example, well pads and compressors) to avoid unnecessary habitat fragmentation and disturbance of additional geographic areas.
• Minimize newly planned activities and operations within 300 feet of the ordinary high water mark of any reservoir, lake, wetland, or natural perennial or seasonally flowing stream or river.
• Locate roads outside of drainages where possible and outside of riparian habitat.
• Avoid constructing any road segment in the channel of an intermittent or perennial stream.
• Avoid new surface disturbance and placing new facilities in key wildlife habitats in consultation with CDOW.
• Minimize the number, length, and footprint of oil and gas development roads;
• Use existing roads where possible
• Combine utility infrastructure (gas, electric, and water) planning with roadway planning to avoid separate utility corridors
• Combine and share roads to minimize habitat fragmentation
• Where possible, consolidate pipeline and existing roadways, or roadways that are planned for development
• Place roads to avoid obstructions to migratory routes for wildlife, and to avoid displacement of wildlife from public to private lands.
• Design roads with visual and auditory buffers or screens (e.g., topographic barriers, vegetation, and distance).
• Accelerate development under a “clustered-development concept” on a site-specific basis where Williams has a 100% mineral interest or control of mineral development
• Maximize the use of directional drilling to minimize habitat loss/fragmentation
• Maximize use of long-term centralized tank batteries to minimize traffic
• Maximize use of remote completion/frac operations to minimize traffic
• Maximize use of remote telemetry for well monitoring to minimize traffic
• Phase and concentrate development activities, so that large areas of undisturbed habitat for wildlife remain.
• Maintain undeveloped areas within development boundaries sufficient to allow wildlife to persist within development boundaries during all phases of construction, drilling, and production.
• Minimize the duration of development and avoid repeated or chronic disturbance of developed areas. Complete all anticipated drilling within a phased, concentrated, development area during a single, uninterrupted time period.
• Restrict oil and gas activities as practical during critical seasonal periods
• Implement self imposed timing limitations to protect species and/or habitat
Construction
• Close and reclaim roads not necessary for development, including removing all bridges and culverts and recontouring/reclaiming all stream crossings.
• Structures for perennial or intermittent stream channel crossings should be constructed using appropriately sized bridges or culverts
• Design road crossings of streams to allow fish passage at all flows and to minimize the generation of sediment.
• Design road crossings of streams at right angles to all riparian corridors and streams to minimize the area of disturbance to the extent possible.
• Construct retention basins and ponds that benefit wildlife
Drilling/Completions
• Install and maintain adequate measures to exclude all types of wildlife (e.g., big game, birds, and small rodents) from all fluid pits (e.g., fencing, netting, and other appropriate exclusion measures).
• Conduct well completions with drilling operations to limit the number of rig moves and traffic.
Production/Reclamation
• Utilize staked soil retention blankets for erosion control and reclamation of large surface areas with 3:1 or steeper slopes. Avoid use of plastic blanket materials.
• Restore both form and function of impacted wetlands and riparian areas and mitigate erosion.
• Remove well pad and road surface materials that are incompatible with post-production land use and re-vegetation require¬ments
• Use only certified weed-free native seed in seed mixes, except for non-native plants that benefit wildlife
• Install exclusionary devices to prevent bird and other wildlife access to equipment stacks, vents and openings.
• Reduce visits to well-sites through remote monitoring (i.e. SCADA) and the use of multi-function contractors.
• 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 where possible.
• Bore pipelines that cross perennial streams
• Install and use locked gates or other means to prevent unauthorized vehicular travel on roads and facility rights-of-way.
|
| Drilling/Completion Operations | Form: (02A )
400336416
11/26/2012 | Drilling/Completions
• Continue application of BMPs to prevent wildlife from entering pits including fencing and netting where appropriate
• Limit days/hours operations where practical to minimize disturbance and traffic
• Promptly report spills that affect wildlife to the CDOW.
• Store and stage emergency spill response equipment at strategic locations so that it is available to expedite effective spill response.
• Limit parking to already disturbed areas that have not yet been reclaimed
• Screen water suction hoses to exclude fish.
• Reduce noise by using effective sound dampening devices or techniques (e.g., hospital-grade mufflers, equipment housing, insulation, installation of sound barriers, earthen berms, vegetative buffers, etc.).
|
| Construction | Form: (02A )
400390561
5/28/2013 | Construction
• Schedule necessary construction in stream courses to avoid critical spawning times.
• Surface roads to ensure that the anticipated volume of traffic and the weight and speed of vehicles using the road do not cause environmental damage, including generation of fugitive dust and contribution of sediment to downstream areas.
• Protect culvert inlets from erosion and sedimentation and install energy dissipation structures at outfalls
• Use the minimum right-of-way width and vegetation mats where pipelines cross riparian areas and streams wherever possible
• Construct fluid pit fences and nets that are capable of withstanding animal pressure and environmental conditions and that are appropriately sized for the wildlife encountered.
• Install impermeable barriers beneath fluid pits to protect groundwater, riparian areas and wetlands.
• Salvage topsoil from all road construction and other rights-of-way and re-apply during interim and final reclamation.
• Strip and segregate topsoil prior to construction. Appropriately configure topsoil piles and immediately seed to control erosion, prevent weed establishment and maintain soil microbial activity
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| Interim Reclamation | Form: (02A )
400390561
5/28/2013 | Production/Reclamation
• Install automated emergency response systems (e.g., high tank alarms, emergency shut- down systems, etc.).
• Apply an aggressive, integrated, noxious and invasive weed management plan. Utilize an adaptive management strategy that permits effective responses to monitored findings and reflects local site and geologic conditions
• Map the occurrence of existing weed infestations prior to development to effectively monitor and target areas that will likely become issues after development.
• Evaluate the utility of soil amendment application or consider importing topsoil to achieve effective reclamation.
• Use locally adapted seed whenever available and approved by landowner.
• Use appropriately diverse reclamation seed mixes that mirror an appropriate reference area for the site being reclaimed where approved by landowner.
• 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.)
• Emphasize bunchgrass over sod-forming grasses in seed mixes in order to provide more effective wildlife cover and to facilitate forb and shrub establishment.
• Seed during appropriate season to increase likelihood of reclamation success
• Do not include aggressive, non-native grasses in reclamation seed mixes
• 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.
• Establish vegetation with total perennial non-invasive plant cover of at least eighty (80) percent of pre-disturbance or reference area levels.
• 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.
• Establish permanent and monumented photo points and vegetation measurement plots or transects; monitor at least annually until plant cover, composition, and diversity standards have been met.
• 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.
• Use early and effective reclamation techniques, including interim reclamation to accelerate return of disturbed areas for use by wildlife
• Remediate hydrocarbon spills on disturbed areas prior to reclamation.
• Complete final reclamation activities so that seeding occurs during the first optimal season following plugging and abandonment of oil and gas wells.
• Perform interim reclamation to final reclamation species composition and establishment standards.
• Perform interim reclamation on all disturbed areas not needed for active support of production operations
• Apply certified weed free mulch and crimp or tacify to remain in place to reclaim areas for seed preservation and moisture retention
• Control weeds in areas surrounding reclamation areas in order to reduce weed competition
• Educate employees and contractors about weed issues
• Where possible, fence livestock and/or wildlife out of newly reclaimed areas until reclamation standards have been met and plants are capable of sustaining herbivory
• Conduct necessary reclamation and invasive plant monitoring.
• Census and assess the utilization of the reclaimed areas by the target species
• Maintain pre and post development site inspection records and monitor operations for compliance
• Utilize GIS technologies to assess the extent of disturbance and document the reclamation progression and the footprint of disturbances
• Identify native species for which commercial seed sources are not available. Provide support to contractors for developing cultivation and seed production techniques for needed species
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| Site Specific | Form: (02A )
400390561
5/28/2013 | Site Specific BMPs:
Planning
• Use existing roads where possible
• Combine and share roads to minimize habitat fragmentation
• Implement self imposed timing limitations to protect species and/or habitat
Construction
• Close and reclaim roads not necessary for development, including removing all bridges and culverts and recontouring/reclaiming all stream crossings.
• Structures for perennial or intermittent stream channel crossings should be constructed using appropriately sized bridges or culverts
• Design road crossings of streams to allow fish passage at all flows and to minimize the generation of sediment.
• Design road crossings of streams at right angles to all riparian corridors and streams to minimize the area of disturbance to the extent possible.
• Construct retention basins and ponds that benefit wildlife
Drilling/Completions
• Install and maintain adequate measures to exclude all types of wildlife (e.g., big game, birds, and small rodents) from all fluid pits (e.g., fencing, netting, and other appropriate exclusion measures).
Production/Reclamation
• Utilize staked soil retention blankets for erosion control and reclamation of large surface areas with 3:1 or steeper slopes. Avoid use of plastic blanket materials.
• Restore both form and function of impacted wetlands and riparian areas and mitigate erosion.
• Remove well pad and road surface materials that are incompatible with post-production land use and re-vegetation require¬ments
• Use only certified weed-free native seed in seed mixes, except for non-native plants that benefit wildlife
• Install exclusionary devices to prevent bird and other wildlife access to equipment stacks, vents and openings.
• Reduce visits to well-sites through remote monitoring (i.e. SCADA) and the use of multi-function contractors.
• 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 where possible.
• Bore pipelines that cross perennial streams
• Install and use locked gates or other means to prevent unauthorized vehicular travel on roads and facility rights-of-way.
The attached Sensitive Area Determination concludes that the location is not within a sensitive area due to the low potential for impacts to surface water in the case of a facility release. However, in order to satisfy COGCC guidance requiring that all locations within 500 ft. of mapped surface water incorporate BMPs to protect that surface water, Williams will employ the following BMPs at this location:
• WPX will ensure 110 percent secondary containment for any volume of fluids contained at well site during drilling and completion operations.
• WPX will implement best management practices to contain any unintentional release of fluids.
• Either a lined drilling pit or closed loop system will be implemented.
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| General Housekeeping | Form: (02A )
400390561
5/28/2013 | General
• Treat/control noxious weeds/plants including Tamarisk
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| Drilling/Completion Operations | Form: (02A )
400390561
5/28/2013 | Drilling/Completions
• Continue application of BMPs to prevent wildlife from entering pits including fencing and netting where appropriate
• Promptly report spills that affect wildlife to the CPW.
• Store and stage emergency spill response equipment at strategic locations so that it is available to expedite effective spill response.
• Limit parking to already disturbed areas that have not yet been reclaimed
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