| Traffic control | Form: (02A )
403694859
12/5/2024 | • Pre-production operations will utilize temporary lay-flat water pipeline to bring fresh water to the location for completion operations which will significantly reduce truck traffic.
• Production operations will utilize a permanent oil takeaway pipeline
• Operator will post an access road speed limit not to exceed 20 miles per hour from vehicle traffic traveling on the access road.
• Drivers will observe posted speed limits on unpaved roads to avoid or minimize fugitive dust.
• Drivers will cover and secure loads to prevent debris from entering roadways.
• Access road will be plated with 6 inches of Aggregate Road base.
• Regular road maintenance such as grading and adding aggregate road base as necessary. |
| General Housekeeping | Form: (02A )
403694859
12/5/2024 | • Consistent with good materials and waste management practices, Operator maintains records of material/waste source, transporter, and final disposition or disposal. These records are maintained under usual and customary practice and are made available upon request. See attached list of waste disposal facilities that Operator has active waste disposal profiles with. Depending on operational considerations, the type of waste in question, and approved disposal profiles, Operator may send waste to one or more approved facilities on a single, individual project.
• Operator minimizes the generation of waste by ensuring that material products are fully used for their intended purpose. If unused materials remain following an activity, contractors are required to take unused product with them for reuse at the next applicable project. Contractors are contractually required to comply with applicable material and waste management practices.
• In the event of an unintended release of material by a contractor, Operator requires the contractor to report the release, and to remediate impacts in accordance with applicable cleanup standards. Operator tracks all contractor releases to closure by requiring formal documentation, supported by laboratory analysis demonstrating cleanup of site impacts, any required waste characterization, waste disposal approval, and manifests or load tickets tracking waste from source, through transport, to final disposal.
• If there are unanticipated hazardous waste streams not listed in the attached Waste Streams Spreadsheet, the hazardous waste will be stored and disposed of in compliance with all rules and regulations applicable to that specific waste. Produced water with no commercial value or reuse potential is typically disposed of via underground injection. In all instances, produced water is disposed of at an offsite location(s) via properly permitted disposal facilities including but not limited to UIC wells intended specifically for produced water disposal.
• Soils impacted with produced fluids will be transported offsite for disposal at a disposal facility permitted to receive E&P waste. All incidents are reported in accordance with ECMC 900-Series Rules.
• All drill cuttings generated during drilling operations are transported offsite with proper manifesting for disposal at facilities properly permitted to receive E&P waste. Drilling fluids will be stored on-site and recycled for use in future drilling operations.
• All surface trash, debris and material not intrinsic to the operation of the oil and gas facility shall be removed stored in a roll off container or other trash bin and disposed of at a commercial solid waste disposal location.
• Most work operations will take place 7-days a week & 24-hour a day. Care will be taken to keep lighting levels at the specified levels on the lighting plans while providing safe, well-lit working areas during night-time and other low-light conditions. Care will also be taken to prevent unintended light from leaving the site and becoming a hazard or nuisance to the public or surrounding wildlife habitat.
• During the Pad Construction Operations, no night-time work is anticipated. Daylight work will be performed during this work operation.
• All lighting shall conform to Federal, State, and Industry recognized standards for both on-site workplace safety and off-site public protection (OSHA, FAA, ECMC, IESNA, and ANSI). No direct light, except those governed by FAA standards, shall shine beyond the boundaries of the WPS, especially onto public roads, adjacent properties, and/or high priority habitats. All lighting shall conform with all ECMC, county, municipal, and any applicable governing body’s standards.
• Temporary lighting will be 3-head LED flood lights on mobile 25-foot telescoping towers. All temporary lighting shall confirm to the lighting photometric plans and fixture specification sheets and BUG calculations in Appendix E. All lighting will be capable of adjustment and directed inward and between 45-65 downward towards working areas on the WPS. No light should shine above the horizontal plane passing through the center point of the light source. Lights will be shielded with a photometric diffusion fabric or membrane tint to prevent direct or reflected direct light from leaving the site.
• For workplace safety, neither the temporary 3-head LED flood light plants and the permanent LED flood lights will not be positioned in a manner that directs or reflects direct light towards the entrance of the WPS.
• Any lighting damaged and/or improperly directed or angled will be promptly fixed and/or corrected to conform to the lighting plan.
• For all work operations, once temporary lighting is in place and for any change to the lighting during any work operations, a lighting self-audit of the site will be performed to ensure that no unintended light will leave the site and become a hazard or a nuisance.
• For non-working or shut-down days where no personnel are on-site or in working areas, temporary lighting will be turned off. During Pre-production Operations (Drilling, Hydraulic Fracturing), it is expected that temporary lighting will be utilized during the entirety of operations. During the Drill out and Flowback phase of the Production Operations, it is expected that temporary lighting will be utilized during approximately 50% of the working hours during these operations while personnel are on-site and essential temporary lighting is needed. If no personnel are on-site and essential temporary lighting is needed, the essential temporary lighting will be inspected every 24 hours.
• Any additional light units used to address workplace safety concerns that are not shown on the lighting photometric plans will be verified by a lighting engineer to ensure that the modified lighting will remain within the required lighting standards stated in this report.
• Production Operations will not utilize permanent lighting.
• Equipment will be painted “desert tan” (or similar) to avoid creating a marked contrast with the surrounding landscape. |
| Wildlife | Form: (02A )
403694859
12/5/2024 | • Crestone will avoid construction of a new location and access road within CPW-identified Pronghorn Winter Concentration Area by using an existing location and existing access road. The majority of the new disturbance area overlaps the previously disturbed from initial development of this location.
• Crestone will utilize an 8-foot opaque privacy fence installed around the production pad. This fence design does not contain open gaps between railings that could trap wildlife. The fence will be installed around the working pad surface following interim reclamation to allow big game to graze on the reclaimed lands.
• Crestone will avoid installation of new electrical infrastructure by using existing infrastructure.
• Crestone will utilize a full-wrap 32’ sound wall during the development of this location, significantly minimizing noise and light impacts.
• Crestone will not install any permanent lighting at this location, significantly minimizing light impacts.
• Crestone will utilize utility power as a power source for the permanent production facilities, significantly minimizing noise impacts.
• Crestone will reclaim/restore big game habitats with native shrubs, grasses and forbs identified by CPW that contribute to optimal big game habitat and other wildlife appropriate to the ecological site.
• Crestone will plan to perform interim reclamation as early as reasonably possible following their active operations. Currently, interim reclamation is planned prior to the start of the pronghorn winter season.
• Crestone will preclude the use of CPW-identified aggressive non-native grasses and shrubs in big game habitat reclamation.
• Inform and educate employees and contractors on wildlife conservation practices, including no harassment or feeding of wildlife;
• Consolidate and centralize fluid collection and distribution facilities to minimize impact to wildlife;
• Adequately size infrastructure and facilities to accommodate both current and future gas production;
• Protect culvert inlets from erosion and sedimentation and install energy dissipation structures at outfalls;
• Implement fugitive dust control measures;
• Install screening or other devices on the stacks and on other openings of heater treaters or fired vessels to prevent entry by migratory birds;
• Minimize rig mobilization and demobilization by completing or re-completing all wells from a given well pad before moving rigs to a new location;
• To the extent practicable, share and consolidate new corridors for pipeline rights-of-way and roads to minimize surface disturbance;
• Engineer new pipelines to reduce field fitting and reduce excessive right-of-way widths and reclamation;
o Mow or brush hog vegetation where appropriate, leaving root structure intact, instead of scraping the surface, where allowed by the surface owner;
o Limit access to Oil and Gas access roads where approved by surface owners, surface managing agencies, or local government;
o Post speed limits and caution signs to the extent allowed by surface owners, Federal and state regulations, local government, and land use policies;
• Use wildlife-appropriate fencing where acceptable to the surface owner;
• Use topographic features and vegetative screening to create seclusion areas, where acceptable to the surface owner;
• Use remote monitoring of well production to the extent practicable;
• Reduce traffic associated with transporting drilling water and produced liquids through the use of pipelines, large tanks, or other measures. Crestone estimates approximately 20-23 passenger vehicle roundtrips per day and 11-14 multiple-unit truck roundtrips per day during the drilling phase and approximately 2 passenger vehicle roundtrips per day during the first pronghorn winter season following initial production. Initial flowback, during which the highest volume of trucked produced water will leave the site, is anticipated to occur outside the pronghorn winter season;
• Install automated emergency response systems (e.g., high tank alarms, emergency shutdown systems; and
• 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.
• Operator will conduct additional avian surveys prior to the commencement of construction to ensure no conflicts have developed since the prior survey(s). |
| Wildlife | Form: (02A )
403694859
12/5/2024 | BMPs from CPW consultation:
1.The operator agrees to reclaim/restore plains pronghorn antelope habitats with native shrubs, grasses, and forbs identified by CPW that contribute to optimal pronghorn antelope habitat and other wildlife appropriate to the ecological site, unless the surface owner requests otherwise.
2. A full-wrap sound wall will be used during the development of this location, significantly minimizing noise and light impacts.
3. This location will use gas and oil takeaway pipelines.
4. Operator will not utilize permanent lighting.
5. Operator will utilize utility power for permanent production facilities.
6. If approved by the surface owner / rancher, the existing full barbed wire fence surrounding the location will be replaced with fencing that contains smooth top and bottom wires to reduce potential impacts to wildlife.
7. The operator agrees to preclude new oil and gas operations within CPW-mapped pronghorn winter concentration areas from January 1 through April 30.
8. Crestone will plan future non-emergency maintenance activities outside the Pronghorn winter season. |
| Storm Water/Erosion Control | Form: (02A )
403694859
12/5/2024 | • Stockpiles will measure approximately 9 feet in height and be staged at a ratio of 3:1.
• Diversion Ditches: Four (4) existing diversion ditches will be removed and three (3) existing diversion ditches will be remaining. Eight (8) diversion ditches will be constructed during the drilling/completions (active construction) and some will be relocated during production (interim reclamation). Diversion ditches will surround the construction area capturing sediment laden runoff channeling into the down-gradient sediment basin and sediment traps. All offsite ditches, 3 and 5, constructed during the construction phase will be reclaimed. Each offsite ditches will be constructed with 12-inches minimum depth with 4.1:1 side slopes; onsite ditches will be constructed with 10-inches minimum depth with 3:1 side slopes.
o Offsite Ditch-3 during the construction phase, will be located on the north edge of the pad, directing silt and debris from the northeast corner of the pad to the west into sediment trap-#1, with dimensions of 800-feet in length. During the production phase, Offsite Ditch-3 will be relocated and renamed to Offsite Ditch-6.
o Offsite Ditch-4 will be located on the east edge of the pad, directing silt and debris from the northeast corner of the pad to the south and tie into the offsite ditch-5 with dimension of 716-feet in length.
o Offsite Ditch-5 will be located on the south edge of the pad, directing silt and debris from the east to the west into Sediment Trap #2, with dimensions of 333-feet in length.
o During the construction phase, Onsite Ditch-6 will be located on the north edge of the working pad surface, the dimensions will be 535-feet, which will direct water from the northeast corner of the pad to the west then south into the Sediment Basin, during production phase, it will be relocated and renamed to Onsite Ditch-7.
o Onsite Ditch-7, during the construction phase will be located on the west edge of the working pad surface, diverting water southwest and south into the Sediment Basin with dimensions of 95-feet in length and will be reclaimed during the production phase.
o Onsite Ditch-5, during the construction phase will be located on the northeast edge of the working pad surface, diverting water south and tying into an existing ditch, which diverts water south into the Sediment Basin with dimensions of 564-feet in length, during production phase this onsite ditch will be relocated and renamed to Onsite Ditch-8.
o During production phase, Offsite Ditch-6 will be located on the east edge of the pad, diverting silt and debris west and north into Sediment Trap #3 with dimensions of 805-feet in length.
o Onsite Ditch-7 will be located on the north edge of the working pad surface, diverting water west and will tie into an existing diversion ditch on the west side of the working pad surface with dimensions of 322-feet in length.
o Onsite Ditch-8 will be located on the east edge of the working pad surface with dimensions of 477-feet in length, diverting water from the northwest and will tie into an existing diversion ditch, which diverts water into the Sediment Basin.
• Berms: Berms help contain and divert runoff. Berms may be used for the upslope of cut or fill slopes to contain or divert surface water. The purpose of a berm is to contain surface water with a permitter barrier or divert surface water when accompanied with a ditch.
• Culvert: This site has three (3) existing culverts, one (1) which will remain and two (2) will be removed. One (1) culvert will be constructed at the entrance of the pad. Culvert-5 dimensions 18” x 48’.
• Sediment Basin (SB)/ Extended Detention Basin (EDB): There is an existing Sediment Basin on the southwest corner of the drill pad edge. It will be implemented at the downstream termination of the diversion ditches. The basin will contain silt from the upstream cut and fill slopes around the drill pad. Periodic maintenance of the sediment basin may be necessary to remove accumulated silt and debris. The sediment basin dimensions 38’W x 76’L x 4’D with 6” riser pipe with 1-1/8” holes and 5776.4’ bottom elevation. During production phase the Sediment Basin will remain and be maintained by the owner until oil & gas operations cease and the site undergoes final reclamation.
• Outlet Protection (OP)/Inlet Protection: There will be one (1) OP. Outlet Protection will be constructed at the entrance of the pads culvert.
• Sediment Control Log (SCL): The sediment control log will be placed around the spoils stockpile and around the west edge of the topsoil stockpile.
• Reinforced Rock Aprons (RRA)/Sediment Trap: During the drilling/completions (active construction) and production (Interim Reclamation) at the off-site diversion ditch and culvert outlets/outfalls, and within swales as check dam structures. There is one (1) existing RRA that will be removed. There are two (2) sediment traps that will be constructed. During the construction phase, Sediment Trap #1 will be constructed on the northwest side of the pad, with dimensions of 21’W x 42’L x 4’D and will be relocated and renamed as Sediment Trap #3 with the dimension of 28’W x 56’L x 4’D. Sediment Trap #2 will be constructed on the south side of the pad, dimension will be 16’W x 32’L x 4’D and will remain during the production phase. If during site inspections, any of the sediment traps are shown to not accommodate the offsite flow, a sediment basin with a permanent outlet structure will be required to replace the sediment trap.
• Seeding and Mulching: Seeding and mulching will be done during the drilling/completions (active construction) and production (Interim reclamation) on all areas where construction activity has ceased for 14 or more calendar days which have not been temporarily stabilized, and areas of final reclamation. Seeding and mulching will be done on the areas within the northern, eastern, and southern Limits of Construction (LOC) but not included within the Drill Pad area. Topsoil and spoils stockpiles to be spread over the reclaim area once pad reduction occurs. Cut and fill slopes adjacent to the pad and access road swales shall be stabilized with SM. It shall be applied after grading is complete in the final phase. If the seeding and mulching application does not provide adequate stabilization for the area where slopes exceed 4:1, then more robust BMPs shall be utilized.
• Covering Materials: Storage of any dry components (such as powdered clay or cement) for drill mud, drilling fluids (“mud”), piping solvents, hydraulic fluid/oil, diesel fuel, fertilizers, chemicals, etc. will occur on the pad site. The Chico 4-65 26-25 North Stormwater Management Plan May 30, 2024 17 stabilized (granular material) surface of the pad site will act as barrier between the stored material and the bare ground. Storage containers shall be covered and stored on pallets or other similar means so that direct contact with the ground is avoided. Containers shall be labeled with the contents. |
| Storm Water/Erosion Control | Form: (02A )
403694859
12/5/2024 | • Vehicle Tracking Controls: Vehicle Tracking Control (VTC) is a temporary control measure that consists of a stabilized layer of aggregate or a prefabricated structure that is used to minimize tracking of sediments from the construction site (exposed soil) to paved road surfaces. Aggregate based vehicle tracking pads are typically 12-feet wide and 70-feet long. Prefabricated vehicle tracking pads are typically 12-feet wide and 35-feet long. Ingress and egress vehicle access points onto disturbed areas shall be stabilized with Vehicle Tracking Control Pads (VTC) and shall be constructed with angular rock, 3” to 6” in size and to a depth of at least 9-inches. The use of recycled asphalt or concrete is not permitted. The VTC shall be installed over a liner of non-woven geotextile with a weight of at least 10 oz/yd2 and a grab tensile strength of at least 250 pounds. No dirt or other materials shall be placed on paved surfaces or curb flow lines to act as curb ramps. Only metal ramps or rock wattles may be used in the curb flow line.
• Site Inspections: A qualified stormwater manager, or their representative, will examine all disturbed areas, including the construction site perimeter, haul routes and vehicular exits, material and water storage locations and stormwater discharge points during each inspection. Temporary and permanent erosion and sediment control measures will be visually verified to ensure effective operational condition.
• Stockpile Management: Topsoil will be stockpiled in one location, on the southeast corner of the proposed pad. In order to mitigate topsoil loss and migration of soil off site, the stockpile will undergo surface roughening, seeding, and mulching.
• Surface Roughening: Once topsoil segregation and stockpiling are complete, the stockpile surface will undergo surface roughening. A tracked vehicle will drive over the surface in order to imprint horizontal ridges to encourage sediment entrapment, improve infiltration, and reduce runoff velocity.
• Seeding: Once topsoil segregation, stockpiling, and surface roughening are complete, the stockpile will be seeded to mitigate erosion. Establishing vegetative cover will help to stabilize the soil.
• Mulching: Post seeding, a layer of straw or hay mulch will be installed via crimping along the stockpile, in order to promote seed germination and further stabilization of the soil. Mulching helps to mitigate the impacts of rainfall and increase soil moisture retention. Mulching will be monitored and re-applied as necessary, until vegetative growth is established. |
| Material Handling and Spill Prevention | Form: (02A )
403694859
12/5/2024 | • Absorbent material contaminated with crude oil, condensate, or other exempt waste will be handled in a manner that prevents spillage. Contaminated material cannot be placed in the landfill. Soaked items will be stored in leak proof containers located on site in the waste storage area.
• Crestone Peak Resources, LLC will maintain equipment/facilities to prevent drips, leaks, spills, etc. Drip pans or other containment vessels will be used to collect drips, leaks, etc. Absorbent materials will be reused if possible. Absorbent pads, booms and other soaked material will be recycled through an approved recycler.
• Upon detection of any spill, the first action to be taken is to ensure personal safety. All possible ignition sources, including running engines, electrical equipment (including cellular telephones, etc.), or other hazards will be immediately turned off or removed from the area. The extend of the spill and the nature of the spilled material will be evaluated to determine if remedial actions could result in any health hazards, escalation of the spill, or further damage that would intensify the problem. If such conditions exist, a designated employee will oversee the area of the spill and the construction SWMP Administrator will be notified immediately. The source of the spill will be identified and if possible, the flow of pollutants stopped if it can be done safely. However, no one should attend to the source or begin cleanup of the spill until ALL emergency priorities (fire, injuries, etc.) have been addressed. Clean-up measures shall be conducted in accordance with Crestone Peak Resources, LLC’s Fieldwide Stormwater Management Plan.
• During drilling, completion, and production operations, regular Auditory, Visual, and Olfactory Monitoring (AVO) inspections are performed on equipment containing hydrocarbons, fluids, or associated chemicals. AVO inspections include taking the time to look, smell and listen for leaks.
• Operator utilizes a polyethylene liner beneath the drilling rig during drilling operations and beneath the areas where completions equipment (including pump trucks and other heavy equipment) during completion operations to ensure there is an impermeable layer between the rig and the earth. The use of this liner prevents hydrocarbons and other fluids from reaching the soil in the unlikely event a leak does occur. The liner is inspected for integrity throughout drilling operations and maintenance/repair to the liner occurs as needed.
• Routine SPCC inspections will be conducted and documented pursuant U.S. EPA requirements. The location will be equipped with a SCADA system that allows for remote monitoring and shut-in capabilities.
• Operator has developed a robust Leak Detection and Repair (LDAR) program, which utilizes Forward Looking Infrared (FLIR®) cameras to identify and fix leaks. These inspections will begin during the drilling phase and continue throughout the life of the Oil & Gas Location. |
| Dust control | Form: (02A )
403694859
12/5/2024 | • Dust suppression during initial construction will be accomplished by the application of freshwater to the access road(s) and exposed earthen surfaces to reduce the transportability of dust when atmospheric conditions are conducive to sustained winds and/or periodic gusts. All dust suppression efforts will consist of only freshwater unless otherwise requested and approved as applicable.
• To minimize sand-related dust emissions, the Operator will be utilizing containerized box technology for sand transport, storage and use during the completions phase. These sand containers (or “sand boxes”) are sealed containers that protect the sand from exposure to wind and prevent dust generation.
• Operator will post an access road speed limit not to exceed 20 miles per hour to minimize fugitive dust emissions from vehicle traffic traveling on the access road.
• Operator will perform regular inspections and road maintenance to ensure the integrity of the access road and associated features is maintained throughout the life of this project. Maintenance consists of re-compacting the road base/recycled asphalt mix on an as-needed basis.
• Operator will install and maintain vehicle tracking controls (i.e., coarse aggregate, a tracking pad, paved apron, or cattle guard) to further reduce and remove loose mud and dirt on construction equipment and vehicles servicing location. |
| Noise mitigation | Form: (02A )
403694859
12/5/2024 | • Idling Equipment – While idling engine/equipment, maintain at the lowest frequency possible, as well as, in a position/location that will prevent sound from carrying to nearby residents.
• Unnecessary Sounds – Unnecessary sounds such as honking the horn, revving vehicle engines, loud music, and unwarranted metal hammering/banging are all examples of sound that can create nuisance; failure to eliminate unnecessary sound from location will be subject to an internal compliance assessment if reported by a landowner.
• In accordance with ECMC regulations., continuous sound monitoring will be conducted, pending permissions, near the property line of the nearest occupied structure and in each direction of an RBU within 2000 ft.
• Following the completion of construction, a sound barrier (minimum rating of STC-30) will be installed on all sides of the pad site. This sound barrier will be 32-feet tall and remain onsite though Completions operations.
• At the time of this NMP, Patterson 345 which is equipped with natural gas and batteries, is scheduled to be utilized for the drilling of the Chico North location. Rigs have been designed and equipped with sound mitigating equipment including devices to minimize squeaking from the draw works brakes. The drill phase is scheduled to last, at this time, for approximately 4 weeks.
• A quiet frac fleet will be used during the completion phase. The completions phase is scheduled, at this time, to last for approximately 8 weeks.
• At the commencement of production, if sound levels exceed the allowables set forth above, Crestone will mitigate production equipment, as necessary, to maintain compliance on the Chico North location.
• The Operator shall follow the most recent and most appropriate BMPs to reduce noise related to drilling and completion.
• Unloading pipe. The Operator shall not unload pipe from delivery trucks between 8:00 p.m. and 7:00 a.m.
• Pre-Production Operations will utilize 32’ sound walls erected around the location; A “quiet completions fleet” will be used for hydraulic fracturing.
• Production Operations will utilize electrified facilities to minimize noises originating from location. |
| Emissions mitigation | Form: (02A )
403694859
12/5/2024 | • Operator will install oil and gas pipeline takeaway to the Pad prior to first production.
• Operator will utilize compressed air pneumatics for all pneumatic actuation on location. |
| Emissions mitigation | Form: (02A )
403694859
12/5/2024 | BMPs agreed to from CDPHE Consultation:
• Operator will properly maintain vehicles and equipment
• Operator will use non-emitting pneumatic controllers
• Operator will use Tier IV or equivalent engines, such as NG Tier II w/ battery assist, (or better) for drilling (dual-fuel engines are not considered equivalent)
• Operator will use Tier IV or equivalent engines, such as NG Tier II w/ battery assist, (or better) for hydraulic fracturing (dual-fuel engines are not considered equivalent)
• Operator will use electric equipment and devices (e.g. vapor recovery units or VRUs, fans, etc.) to minimize combustion sources on site (if yes, operator will provide a list outlining which equipment and devices will be electrified)
• Operator will use Tier IV or equivalent engines, such as NG Tier II w/ battery assist, (or better) for nonroad construction equipment (dual-fuel engines are not considered equivalent)
• Operator will not store hydrocarbon liquids in permanent storage tanks on site after the first 2 years of production (other than a maintenance tank possibly used for well unloading or other maintenance activities)
• Operator will use pipelines to transport water used for hydraulic fracturing to location
• Operator will have adequate and committed pipeline takeaway capacity for all produced gas
and oil
• Operator will shut in the facility to reduce the need for flaring if the pipeline is unavailable
• Operator will use lease automatic custody transfer (LACT) system to remove/reduce the need for truck loadout
• Operator will use OGP Group III drilling fluid
• Operator will cover trucks transporting drill cuttings
• Operator will use a squeegee or other device to remove drilling fluids from pipes as they exit the wellbore
• Operator will ensure that all drilling fluid is removed from pipes before storage
• Ozone mitigation on forecasted high ozone days: operator will eliminate use of VOC paints and solvents
• Ozone mitigation on forecasted high ozone days: operator will minimize vehicle and engine idling
• Ozone mitigation on forecasted high ozone days: operator will reduce truck traffic and worker traffic
• Ozone mitigation on forecasted high ozone days: operator will postpone the refueling of vehicles
• Ozone mitigation on forecasted high ozone days: operator will suspend or delay the use of non-essential fossil fuel powered ancillary equipment
• Ozone mitigation on forecasted high ozone days: operator will reschedule non-essential operational activities such as pigging, well unloading and tank cleaning
Ozone mitigation on forecasted high ozone days: Operator will postpone flowback if emissions cannot be adequately captured with a vapor recovery unit (VRU)
• Operator will use Modular Large Volume Storage Tanks
• Operator will not use fracturing fluids which contain PFAS compounds
• Operator will contribute to nearby fire district(s) to support transition away from PFAS-containing foam through funding, buy-back program participation/promotion, etc.
• Operator will coordinate with nearby fire district(s) to evaluate whether PFAS-free foam can provide the required performance for the specific hazard
• If PFAS-containing foam is used at a location: operator will properly characterize the site to determine the level, nature and extent of contamination
• If PFAS-containing foam is used at a location: operator 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: operator will properly capture and dispose of PFAS-contaminated soil and fire and flush water |
| Odor mitigation | Form: (02A )
403694859
12/5/2024 | • Operator will use a filtration system and additives in the drilling and fracturing fluids that minimize odors.
• Operator shall utilize a closed-loop, pit-less mud system for managing drilling fluids.
• Operator shall employ the use of drilling fluids with low to negligible aromatic content (IOGP Group III) during drilling operations after the surface casing is set and freshwater aquifers are protected.
• Operator shall remove drill cuttings daily and as soon as waste containers are full.
• Operator shall employ pipe cleaning procedures when removing drill pipe from the hole; these procedures may include “wiping” the pipe before racking it in the derrick.
• If a justified complaint is received, Operator may utilize a mud-chiller to reduce odor breakout and increase concentration of odor-mitigating additives in mud system.
• Operator will utilize a maintenance vessel system.
• Operator will utilize a pneumatic air system to actuate the facilities on location.
• Operator will utilize tank vapor recovery units (blowers) for production tanks on location.
• Pre-Production operations will utilize closed-loop systems to manage fluids wherever possible, minimizing emissions, IOGP Group III drilling fluids, formulated to reduce emissions compared to traditional drilling fluids; drill cuttings will be removed daily and whenever waste containers are full, limiting the chance of odors arising; proper procedures will be followed when removing drill pipe from the wellbore to minimize residual odors.
• Production operations will utilize utility powered production equipment, compressed air pneumatics, pressurized maintenance vessel, and three-phase takeaway. |
| Drilling/Completion Operations | Form: (02A )
403694859
12/5/2024 | • The drilling rig that will be utilized to drill the wells to total depth will be powered by on-site power generation that utilizes either Tier IV equivalent natural gas-powered engines with a battery backup, or if available, Tier IV engines.
• Crestone will employ pipe cleaning procedures when removing drill string from hole and remove drill cuttings daily.
• Crestone will utilize Group III drilling fluids.
• Utilize closed-loop, pit-less fluid management system.
• Crestone will install a polyethylene liner across portions of the location as an isolation barrier. The drilling rig and associated equipment (including fluid storage areas) are placed atop the liner.
• Crestone will utilize Tier IV or equivalent rated completion equipment. This helps to minimize the cumulative impacts to air resources that are associated with the use of internal combustion engines.
• A “quiet completions fleet” will be used for hydraulic fracturing operations.
• Operator will employ the practice of “block and isolate” whenever possible on equipment, piping, and/or tank connections.
• Use of sealed containers (e.g., sandboxes) for the storage and transportation of sand used in hydraulic fracturing.
• Any gas encountered during drill-out will be combusted with a minimum of 98% destruction efficiency.
• Any fluids encountered during drill-out will be sent to a controlled tank and stored until transferred for disposal (e.g., water) or sale (e.g., oil).
• Any gas encountered during flowback will be routed to a gas sales pipeline or combusted with a minimum of 98% destruction efficiency.
• Any fluids encountered during flowback will be sent to the permanent production separators for processing until it is transferred via pipeline for disposal (e.g., water) or sale (e.g., oil) on the Pad.
• Crestone will install a polyethylene liner across portions of the location as an isolation barrier. The completion fleet and associated equipment (including fluid storage areas) are placed atop the liner. |
| Interim Reclamation | Form: (02A )
403694859
12/5/2024 | • Erosion Control Measure Deployment:
o Seeding and mulch application will be completed within 24 hours of seedbed preparation, weather permitting
o The seed mix will be drill seeded throughout the interim reclamation area.
o All seed will be certified weed free and pure live seed (PLS) rated per federal, state, county, and municipal standards.
o Certified weed free grass or wheat origin straw mulch will be uniformly applied at a rate of 4,000 lbs. per acre to cover 100% of the seed bed.
o Mulch will be properly anchored to the soil surface using a commercial straw crimper with a final orientation north to south.
• Soil Management and Placement:
o Topsoil horizon depth will be identified based on changes in physical characteristics.
o Topsoil will be separated from the disturbance area to the depth of the topsoil horizon, determined by topsoil samples.
o Salvaged topsoil will be stockpiled, seeded, and the location marked or documented.
o All efforts will be taken to ensure topsoil will not be comingled with subsoil materials during recontouring and subsoil preparation operations.
• Grading:
o The grade of the interim reclamation area is between 0-2%.
o The surface elevation will be returned as close to the original relative position and contour as practicable during pad size reduction and grading operations.
• Seeding Method:
o Seeding will be completed with range-type drill methods.
• Weed Management:
o Certified weed free grass or wheat origin straw will be utilized for mulching operations.
o Mowing operations will be commenced when the height of weeds exceeds 6-inches or before seed development.
o Herbicide applications will be utilized as needed to treat prostrate, low growing, or perennial noxious weed species for which mowing methods are ineffective.
o Herbicide applications will be spot-specific.
• Pre-Disturbance Landscape Assessment:
o A landscape assessment will be conducted prior to ground disturbance to ensure, based on field collected topographic surveys, the recontoured reclamation surface matches pre-disturbance grade and topography.
o Any pre-existing drainage features will be reestablished during recontouring.
• Site-Specific Seed Mix:
o Reseeding will be completed with species consistent with the adjacent plant community.
o The proposed seed mix for this location is the Colorado Parks and Wildlife (CPW) recommended seed mix for pronghorn habitat. The Seed Mix is referenced in the Topsoil Protection Plan.
o Crestone Peak Resources, LLC will consult with the surface owner regarding the future land use and acceptability of the proposed seed mix.
o Seeding will occur throughout the interim reclamation area.
• Fence Installation:
o A wildlife fence will be maintained to mitigate wildlife and/or livestock access to the interim reclamation area. |
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