| Storm Water/Erosion Control | Form: (02A )
401963396
9/6/2019 | Conoco Philips will use engineered controls, constructed in a manner that is consistent with good engineering practices, to prevent offsite migration of sediment/contaminant. |
| Material Handling and Spill Prevention | Form: (02A )
401963396
9/6/2019 | Conoco Phillips shall use steel secondary containment structures to prevent the discharge of oil from crude oil storage tanks, produced water storage tanks, separator/production skids and portable storage containers.
All flowline and piping within the production facilities will be lined using a secondary liner. |
| Material Handling and Spill Prevention | Form: (02A )
401963396
9/6/2019 | Pollution control containers (spill boxes) will be used on truck loading lines and will be placed within the limits of the secondary containment system. |
| Material Handling and Spill Prevention | Form: (02A )
401963396
9/6/2019 | To minimize the potential for release from the facilities, all facilities will be capable of being remotely monitored and remotely shut down, which includes isolation at the well head.
In addition, Conoco Phillips will install automatic shutdown pressure devices on process vessels with remote monitoring capabilities and installed on flowlines from well heads to facilities with remote monitoring capabilities.
Automatic shutdown level devices will be installed on each tank with remote monitoring capabilities and will be installed on all pressure vessels and liquid knockouts. |
| Material Handling and Spill Prevention | Form: (02A )
401963396
9/6/2019 | Conoco Phillips will use cathodic protection on buried steel lines to mitigate corrosion and will install engineered liner systems within the secondary steel containment systems for the production facilities to prevent migration of contaminants into the underlying soils and groundwater. |
| Drilling/Completion Operations | Form: (02A )
401963396
9/6/2019 | Conoco Phillips shall operate in compliance with the Colorado Oil and Gas Conservation Commission Policy on the use of Modular Large Volume Tanks in Colorado, dated June 13, 2014. |
| Planning | Form: (02A )
403065585
1/9/2024 | Operator will not situate new staging, refueling, or chemical storage areas within 500 feet of the ordinary high water mark of any river, perennial, or intermittent stream, lake, pond, or wetland. |
| Planning | Form: (02A )
403065585
1/9/2024 | CDPHE BMPs provided in the CDPHE November 3, 2023 Consultation Letter:
• 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 hydraulic fracturing
• 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)
• For hydrocarbons, operator will implement a "hybrid production flowback method" or "modern production flowback method" (eliminates tanks by routing the oil, natural gas directly to permanent production equipment)
• Operator will use pipelines to transport water used for hydraulic fracturing to location
• Operator will have adequate and committed pipeline take away 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 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
• Secondary containment: Operator will install perimeter controls to control potential sediment-laden runoff in the event of spill or release from Modular Large Volume Storage Tank
• 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 |
| Wildlife | Form: (02A )
403065585
1/9/2024 | • A wildlife fence will be maintained to mitigate wildlife and/or livestock access to the interim reclamation area.
• CPR will ensure all personnel and contractors are aware of and adhere to all applicable wildlife mitigation measures and BMPs;
• CPR personnel and contractors will not harm any wildlife observed on site and will maintain recommended buffer distances related to wildlife;
• CPR personnel and contractors will report any wildlife concerns, including the discovery of injured or orphaned wildlife, to on-site management and applicable EHSR personnel;
• CPR will consult CPW and/or other applicable agencies upon the discovery of new wildlife constraints, as needed;
• CPR will use qualified third-party contractors for wildlife surveys, monitoring, and other consultation purposes; and
• CPR and/or its contractors will document any wildlife-related issues or changes.
• If work begins between March 15 and October 31, burrowing owl surveys will be conducted by qualified biologists and CPW will be consulted prior to the start of construction as needed.
• If work begins between February 1 and August 15, raptor nesting surveys will be conducted by qualified biologists within approximately one week of the start of construction.
• If work begins between April 1 and August 31, migratory bird nesting surveys will be conducted by qualified biologists within one week of the start of construction.
• If any swift fox activity or potential dens are identified prior to construction, game cameras will be deployed to determine if any dens are active with swift foxes. If a den is determined to be active, operator will consult with CPW to determine appropriate mitigation and protection measures. |
| Material Handling and Spill Prevention | Form: (02A )
403065585
1/9/2024 | 1. Consistent with good materials and waste management practices, CPR 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 CPR has active waste disposal profiles with. Depending on operational considerations, the type of waste in question, and approved disposal profiles, CPR may send waste to one or more approved facilities on a single, individual project.
2. CPR 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.
3. In the event of an unintended release of material by a contractor, CPR requires the contractor to report the release, and to remediate impacts in accordance with applicable cleanup standards. CPR 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.
4. 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.
5. 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.
6. Soils impacted with produced fluids may be either remediated onsite with COGCC, landowner, and, if required, local government approval, or transported offsite for disposal at a disposal facility permitted to receive E&P waste. All incidents are reported in accordance with COGCC 900-Series Rules.
7. 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.
8. 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.
9. Waste will be stored on location in compatible container or containment devices designed or engineered for the purposes for which they will be utilized. These containers will be inspected on a regular basis to ensure that no undue wear, structural issues, sever rust, other defects, which may impact their effectiveness.
10. Tank bottoms will be disposed of at licensed third-party solid waste disposal facilities.
11. Trucks will use the haul route approved under the Aurora Operator Agreement.
|
| Material Handling and Spill Prevention | Form: (02A )
403065585
1/9/2024 | Drilling and Completions Operations
• Frequent and thorough inspections throughout all stages of operations.
• Inspections occur twice a day on fluid equipment and logged into a data system Secondary containment is placed under equipment
• Portable containers are stored inside portable containment
• Procedures and training on equipment use in place to avoid and mitigate spills.
• Double-walled storage tanks will used where applicable.
• Continuous monitoring and third-party systems will be used to track fluid volumes and monitor for leaks.
• Rig will be placed on an impervious plastic liner including four-inch to six-inch high berm walls.
• Closed loop drilling systems will be utilized.
• Temporary portable containers (e.g., drums) are stored inside plastic lined or other impervious containment.
• General secondary containment (impervious liner) will be placed under equipment.
• Active drilling fluid tanks will be equipped with a third-party measurement and alarm system (Pason Pit Volume Totalizer) to track
tank volumes and changes during the drilling operation.
• Fluid storage tanks on the location will be equipped with mechanical (visual) level indicators that are inspected by operation personnel.
• Third-party continuous monitoring on integral systems in addition to routine inspections. In the event of an upset condition, Operators are
notified and respond immediately.
• Regular preventative maintenance schedules followed for equipment. |
| Material Handling and Spill Prevention | Form: (02A )
403065585
1/9/2024 | Facility Construction
• Qualified third-party inspectors will inspect equipment to evaluate compliance with COGCC Rules and Regulations and applicable technical
standards.
• Secondary containment will be installed with an impervious liner.
• Secondary containment will be sized to 150% of the largest storage tank.
• Production tanks will be lined where applicable.
• Pressure and Integrity testing prior to placing equipment into service.
• All equipment will be installed and tested in accordance with applicable American Society of Mechanical Engineers (ASME) and American
Petroleum Institute (API) standards.
• Underground piping on the facility will be electronically inspected prior to installation using coating deficiency detectors per COGCC 1102.I.(1).
• Flowlines will be inspected by a qualified third-party inspector who is trained in accordance with 1102.h prior to placing into service.
• Flowlines will be integrity tested per 1100 Series Rules.
• All production tanks are built in accordance with API 12F standards.
• Produced water production tanks at the facility utilize an internal liner.
• Test ports for integrity testing are installed on insulated tanks. |
| Material Handling and Spill Prevention | Form: (02A )
403065585
1/9/2024 | Spill Prevention and Material Handling
• Inspections of all production equipment including temporary equipment.
o Routine operational checks on the facility.
o Documented weekly inspections.
o Audio, Visual, Olfactory (AVO) inspections in accordance with COGCC Rule 609.d. and Air Quality Control Commission Regulation 7
o Annual Spill Prevention and Control Countermeasure Inspections.
• Periodic operator training on spill prevention best management practices and equipment operations.
• Fluid handling equipment will have valves and caps to mitigate leaks.
• Internal and External Tank integrity Inspections.
• Annual separator and flow through process equipment cleanouts and integrity evaluations.
• Pressure testing of all flowlines.
Spill Response
• Response to all spills and release in accordance with COGCC 900 Series Rules including timely reporting, response, and investigation. |
| Dust control | Form: (02A )
403065585
1/9/2024 | • Application of fresh water to disturbed areas during earth moving activities.
• Application of fresh water or magnesium chloride to graveled surfaces of the Site and associated roads.
• Use of high-quality construction materials such as crushed granite road base, which generates less dust than other aggregates.
• Limit disturbance of natural vegetation to only that area that is reasonably necessary for construction.
• Re-establishment of vegetation on disturbed areas not graveled.
• Covered storage containers to be used for sand, silica, proppant or similar material during hydraulic fracturing.
• Establish speed limit on all access roads of 20MPH or less. Personnel failing to comply will be subject to disciplinary action.
• Establish speed limit on the Site of 5MPH or less. Personnel failing to comply will be subject to disciplinary action.
• Curtail scope of work during high wind conditions (sustained winds 25MPH or greater).
• Regular road maintenance will include adding gravel and grading when needed.
• Additional management practices such as road surfacing, natural wind breaks and barriers, or automation of wells to reduce truck traffic may also be utilized to minimize fugitive dust emissions.
• Crestone will use a rock base tracking pad at the access point to help remove dirt and prevent debris from collecting on all access roads. As necessary, Crestone will sweep roads nearest the access point of dirt and debris to maintain a clean entrance.
• The access road will be constructed per CDOT road-base #6 specification. Construction materials may include but are not limited to: premixed road base material; 1 – 1.5” river rock, crushed granite or other aggregate with not less than 1” nominal size.
• Plan for Suppressing Fugitive Dust Caused by Wind: will curtail scope of work during high windconditions (sustained winds 25MPH or greater) |
| Noise mitigation | Form: (02A )
403065585
1/9/2024 | Avoidance:
1. Site selection - This site was selected to maximize distance to the nearest RBU which is over 2,500 feet from edge of working pad surface.
2. Equipment selection - Quiet-Fleet™ hydraulic fracturing technology will be utilized to decrease noise.
Minimization:
1. Bales will be used as sound barriers on the northern side of the pad excepting those openings required for pad access and emergency exits. Bales will also be deployed around the northern pad corners and small segments along the western and eastern sides of the pad.
2. Drilling rig engine exhausts are pointed straight up so as not to be directed towards any occupied buildings.
3. Crestone will install “quash” sound damping material in all permanent buildings that house noise sources if necessary.
4. The Operator shall provide a 24-hour contact number for noise complaints on the facility sign required in section 5-3.6.F.3.h of Arapahoe County Oil and Gas Regulations, as well as the COGCC’s complaint hotline number. |
| Emissions mitigation | Form: (02A )
403065585
1/9/2024 | 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 natural gas-powered engines with a battery backup, or if available, Tier IV engines. |
| Odor mitigation | Form: (02A )
403065585
1/9/2024 | 1. Operator will use a filtration system and additives to the drilling and fracturing fluids to minimize odors
2. Operator shall utilize a closed-loop, pit-less mud system for managing drilling fluids.
3. Operator shall employ the use of drilling fluids with low to negligible aromatic contact (IOGP Group II) during drilling operations after the surface casing is set and freshwater aquifers are protected.
4. Operator shall remove drill cuttings daily and as soon as waste containers are full.
5. Operator shall employ pipe cleaning procedures when removing the drill pipe from the hole; these procedures may include “wiping” the pipe before racking it in the derrick.
6. If a justified complaint is received, the Operator may utilize a mud-chiller to reduce odor breakout and increase the concentration of odor-mitigating additives in the mud system.
7. Operator will upgrade the existing facility and proposed facilities to utilize compressed air pneumatics.
8. Operator will utilize to a pressurized maintenance vessel system which minimizes the need for venting during maintenance operations.
9. Operator will upgrade the existing facility to be energized with utility power reducing odors associated with internal combustion engines. |
| Drilling/Completion Operations | Form: (02A )
403065585
1/9/2024 | Lighting Mitigation
1. During drilling and completions operations that 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.
2. During the Pad Construction Operations, no night-time work is anticipated. Daylight work will be performed during this work operation.
3. No permanent lighting is proposed for this project. All lighting shall conform to Federal, State, and Industry recognized standards for both on-site workplace safety and off-site public protection (OSHA, FAA, COGCC, 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 COGCC, county, municipal, and any applicable governing body’s standards.
4. Temporary lighting will be 4-head LED flood lights on mobile 25-foot telescoping towers (BUG Rating is B3-U3-G5). All lighting will be capable of adjustment and will be 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.
5. For workplace safety, no direct or reflected direct light shall shine towards the entrance of the WPS.
6. Operator will watch for and remove glare and reflection points during all work operations of the project from temporary or permanent structures, temporary lighting, vehicles, construction equipment, and clothing/PPE.
7. Any lighting damaged and/or improperly directed or angled will be promptly fixed and/or corrected to conform to the lighting plan.
8. Equipment shall be operated and/or orientated and/or shielded in such a manner that lights permanently affixed to equipment do not shine above the horizontal plane passing through the center point of the light source or shine beyond the boundary of the WPS.
9. For all work operations, once temporary lighting is in place, 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.
10. 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.
11. For non-working or shut-down days where no personnel are on-site or in working areas, non-essential temporary lighting will be turned off. If no personnel are on-site and essential temporary lighting is needed, the essential temporary lighting will be inspected every 24 hours.
12. All redundant, unused, or not-needed lights will be turned off. |
| Interim Reclamation | Form: (02A )
403065585
1/9/2024 | Erosion Control Measure Deployment
-Seeding and mulch application will be completed within 24 hours of seedbed preparation, weather permitting.
-The seed mix will be drill seeded throughout the interim reclamation area.
-All seed will be certified weed free and pure live seed (PLS) rated per federal, state, county, and municipal standards.
-Certified weed free grass or wheat origin straw mulch will be uniformly applied at rate of 3,000 lbs./ per acre to cover 100% of the seed bed.
-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
-Topsoil horizon depth will be identified based on changes in physical characteristics.
-Topsoil will be separated from the disturbance area to the depth of the topsoil horizon.
-Salvaged topsoil will be stockpiled, seeded, and the location marked or documented.
-Topsoil will NOT be comingled with subsoil materials during recontouring and subsoil preparation operations.
Grading
-The grade of the interim reclamation area is between 0-2%.
-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
-Seeding will be completed with range-type drill methods.
Weed Management
-Certified weed free grass or wheat origin straw will be utilized for mulching operations.
-Mowing operations will be commenced when the height of weeds exceeds 6 inches or before seed development.
-Herbicide applications will be utilized as needed to treat prostrate, low growing, or perennial noxious weed species for which mowing methods are ineffective.
-Herbicide applications will be spot-specific.
Pre-Disturbance Landscape Assessment
-A landscape assessment will be conducted prior to ground disturbance to ensure that the recontoured reclamation surface matches pre-disturbance grade and topography.
-Any preexisting drainage features will be reestablished during recontouring.
Site-Specific Seed Mix
-Reseeding will be completed with species consistent with the adjacent plant community.
-The selected seed mix for this location is the Loamy Plains Seed Mix (see Seed Mix Table above).
-Crestone will consult with the surface owner regarding the planned seed mix.
-Seeding will occur throughout the interim reclamation area. |