| Planning | Form: (02A )
400564652
5/22/2014 | BACKGROUND
• Surface ownership for this location is under the jurisdiction of the Bureau and Land Management (BLM) and is therefore subject to Federal regulations related to surface protection and mitigation in accordance with the BLM Resource Management Plan and site-specific NEPA documents.
• This location is constructed and producing gas and is subject to the BMPs and COAs in the previously approved Form 2A.
• No new additional surface disturbance will occur. The addition of wells to the Facility Layout Diagram is therefore the focus of the BMPs described herein.
• The need for BLM meetings and site visits prior to approval of the Federal location/pad and well permits are subject to BLM discretion under their regulations.
|
| Planning | Form: (02A )
400564652
5/22/2014 | GENERAL – PLANNING
• Prior to initiation of the COGCC Form 2A and BLM permitting processes, Ursa held internal meetings and/or onsites are held to determine the feasibility of the location, and topographic constraints, proximity to building units, potential public and environmental concerns including surface waters, traffic/haul routes, 317B applicability, wildlife RSOs and SWH areas, noise potential, soil stability, and environmentally sensitive areas, plants, and wildlife. All information that may affect the location is documented as appropriate in Ursa’s “Site Assessment Checklist / Map. A copy of these internal practices was provided to the COGCC at the Setback Training on August 30, 2013 held in Grand Junction.
• Upon approval of the Form 2A, Ursa will hold Pre-Construction, Pre-Spud, Pre-Completions and Pre-Production meetings with contractors performing work at the location, as applicable to the proposed activity. As a BMP, Ursa has developed checklists for these meetings to review COAs, NTOs and related issues.
• Traffic and Public Safety – Ursa developed a site-specific Emergency Response Plan and Haul Route Map which is communicated to local emergency response agencies and stakeholders, as well as contractors performing work at the location.
|
| Community Outreach and Notification | Form: (02A )
400564652
5/22/2014 | GENERAL - COMMUNITY OUTREACH AND NOTIFICATIONS
• Ursa has notified the BLM of intended plans as the surface ownership is under Federal jurisdiction. BLM has waived all COGCC notifications to include Pre-application notifications, statutory notifications, MIRU notifications and construction, drilling and completions notifications related to Federal surface, as they are intimately involved in with all phases of permitting the location and associated wells.
• Ursa routinely communicates proposed plans and operations schedules to stakeholders to through Community Counts, the GARCO Energy Advisory Board, and others. In addition, periodic stakeholder meetings are held with landowners and affected parties.
• Communication with Kirby Wynn and municipal LGDs are also held routinely in addition to communication required by COGCC regulations.
|
| General Housekeeping | Form: (02A )
400564652
5/22/2014 | ENVIRONMENTAL STEWARDSHIP AND COMPLIANCE
OPERATIONS (GENERAL/ALL OPERATIONS PHASES)
• AGENCY INSPECTIONS AND CORRECTIVE ACTIONS – Ursa will implement corrective actions necessary in response to all agency inspections in a timely manner. Inspections resulting in the potential for immediate or significant environmental impacts will be addressed immediately, subject to safety and weather considerations.
• AIR PERMITTING AND COMPLIANCE – Ursa will comply with CDPHE regulations regarding air permitting, compliance monitoring and inspections and reporting. All air sources will be assigned AIRS ID numbers and tracked for compliance and reporting purposes. In addition, Ursa is required to track, monitor and report Greenhouse Gas (GHG) emissions to EPA.
• CHEMICAL & MATERIAL HANDLING – All materials and chemicals will be managed to minimize environmental contamination in accordance with MSDS sheets and EPA, COGCC and CDPHE regulations. Materials and chemicals that are not a waste may be reused or recycled.
• NOXIOUS WEEDS – Weeds will be managed in accordance with Ursa’s Noxious Weed plan; to include up to three treatments per year depending upon the species being managed and mapping as needed, throughout the life cycle of the location (construction – final reclamation).
• SPILLS / INCIDENTS – Spill prevention and response are addressed in Ursa’s Spill Prevention and Management Plan. This includes training of employees and contractors personnel on at least an annual basis. Spills response includes notifications, reporting, response actions, remediation and corrective actions. The spill criteria in Ursa’s plan requires that waste be properly classified as E&P or non-E&P wastes. For E&P waste, all spills greater than 1 barrel the COGCC will be reported to the COGCC using a Form 19. Should remediation be required, a Form 27 will be submitted as well. Spills related to non-E&P waste will be managed in accordance with CDPHE and EPA regulations depending on the volume spilled.
• WASTE - The location will be managed in accordance with Ursa’s Waste Management Plan as summarized in Attachment J (1) of this application. Ursa’s Waste Management Plan complies with and incorporates COGCC 900 rules regarding E&P waste, and CDPHE rules regarding hazardous wastes. The plan minimizes the potential for any exploration and production wastes, chemicals, fluids, etc. from leaving the location, including berms, barriers, and use of spill control materials.
• WILDLIFE - A Wildlife Mitigation Plan (March 24, 2010) is in place that was agreed to by Ursa (previously Antero). The plan allows for 90+ well pads. Currently, Ursa has 62 well pads. Ursa is current on all obligations under the plan.
CONSTRUCTION OPERATIONS
• DUST CONTROL - The pad and access road will be graveled to reduce fugitive dust and maintained as required by COGCC rules. In addition, water and other dust suppressants are used as required, dependent upon the level of activity, moisture conditions, etc. throughout all phases of operations
• RECLAMATION (Temporary and Interim) - The site will stabilized using seed mixes and materials compatible with soil types, moisture, and local climate conditions as specified by the appropriate agency and/or in landowner surface use agreements, or locally acceptable industry practices. Temporary seeding / stabilizations will be completed during optimum conditions to achieve best results for plant growth. Once all wells at the location are drilled, Ursa will complete interim reclamation in accordance with COGCC 1000 rules; and stabilize/seed the location as soon as practical subject to seasonal/weather constraints.
• STORMWATER - The location will be constructed in accordance with the CDPHE AND COGCC stormwater regulations as implemented by Ursa’s Stormwater Management Plan, so as to control sediment run-off. Stormwater BMPs will also serve as secondary or tertiary containment in the event of a spill. Site specific plans (i.e. diagrams) will be developed and inspected against at the frequency required by CDPHE regulations, to include 14 day, 30 day, and major storm event inspections until 70% reclamation is achieved. Corrective actions will be tracked and implemented. COGCC inspections will be conducted through 80% interim reclamation and annually thereafter. These inspections are also tracked and corrective actions implemented. Native soils will be used whenever available to construct stormwater BMPs, supplemented by non-native materials based on site-specific conditions.
• WATER WELL SAMPLING (COGCC Rule 609) – No water wells exist within ½ mile of the locations under this Form 2A.
DRILLING OPERATIONS
• WATER SAMPLING (Public Water Supply) – the location is not located within a COGCC 317B designated area.
COMPLETIONS OPERATIONS
• AIR & ODORS - Well completions will utilize flowback completion technologies and/or flares to reduce odors from plug drillout, and venting of salable and non-salable gas
• CHEMICAL USE – All chemicals used will be tracked and reported in accordance with COGCC rules and submitted through FracFocus within 120 days of initiating well stimulation.
• WASTE MANAGEMENT OF WATER – Flowback water used for well completions will be recycled and treated to the maximum extent practical at the location. Water that can’t be recycled will be injected through the use of wells approved by COGCC and Garfield County, or transported via truck or pipeline to the COGCC and Garfield County approved Wasatch E&P Facility.
• WATER LINES – Buried water pipeline infrastructure will be used to transport flowback water where water lines exist in close proximity to the well pad ad described above.
• WASTE - No stimulation or flowback pits will be constructed.
PRODUCTION OPERATIONS
• AIR & ODORS - Combustor controls will be used to mitigate odors from production tanks. Ursa will perform inspections on at least a monthly basis to ensure potential emissions sources are properly managed. In addition, Ursa’s pumper crew inspects each location on a daily basis.
• REMOTE MONITORING - Remote monitoring will be used to reduce truck traffic, fugitive dust to the extent practical.
• VISUAL IMPACTS - Above-ground facilities (e.g. production tanks) will be managed to minimize visual effects (e.g. painted to blend with environment)
• WILDLIFE – All separators/dehydrators and heater –treater equipment are outfitted with bird cones.
• WATER RECYCLING – Produced water used for well completions will be recycled and treated to the maximum extent practical. Water that can’t be recycled will be injected through the use of wells approved by COGCC and Garfield County, or transported via truck or pipeline to the COGCC and Garfield County approved Wasatch E&P Facility.
|
| Construction | Form: (02A )
400564652
5/22/2014 | CONSTRUCTION AND SITE STABILIZATION
• The location is already constructed and there will be no further surface disturbance. Use of the existing location will eliminate the need for an additional well pad and access roads; hence a reduction in surface disturbance, traffic, and impacts to the environment and wildlife habitat.
• The BMPs entitled “Environmental Stewardship and Compliance” provided more detailed information regarding environmental protection applicable to construction and site stabilization activities.
• For safety purposes, the location and site layout has been designed to accommodate all operations within the limits of disturbance while meeting Federal and state safety regulations, including required buffers and distances between operating components and combustion sources.
|
| Drilling/Completion Operations | Form: (02A )
400564652
5/22/2014 | DRILLING
• Directional / horizontal drilling will be implemented to avoid the need for additional well pads; reducing potential environmental impacts to include habitat loss and fragmentation, noise, traffic concerns, and related impacts to air, land and water.
• The CSF Compressor Station and CSF T would be used as support locations, but would not host temporary tank batteries, and would be used only for parking and rig moves.
• The BMPs entitled “Environmental Stewardship and Compliance” provided more detailed information regarding environmental protection applicable to drilling activities.
|
| Drilling/Completion Operations | Form: (02A )
400564652
5/22/2014 | COMPLETIONS
• Completions at the location will be supported by staging a temporary tank battery / water pumping station at an adjacent existing location also on BLM surface managed property. The pad locations selected are permitted by both the COGCC and BLM as oil and gas locations.
• For the Castle Springs E completions, it is anticipated that the Castle Springs CSF B, D and W locations may be used for temporary tank batteries. This will eliminate the need for additional surface disturbance. Water will be transferred between the locations via buried waterline. If needed, a temporary surface line may also be used.
• The BMPs entitled “Environmental Stewardship and Compliance” provided more detailed information regarding environmental protection applicable to completion activities.
|
| Drilling/Completion Operations | Form: (02A )
400564652
5/22/2014 | PRODUCTION
• All production equipment to include separators and tanks will be placed onsite in accordance with the Facility Layout Diagram and appropriate secondary containment.
• The BMPs entitled “Environmental Stewardship and Compliance” provided more detailed information regarding environmental protection applicable to production activities.
|