| General Housekeeping | Form: (02A )
401779047
1/24/2020 | Flammable liquids shall not be stored within fifty (50) feet of the wellbore, except for
the fuel in the tanks of operating equipment or supply for injections pumps. Where
terrain and location configuration do not permit maintaining this distance, equivalent
safety measures should be taken. |
| Storm Water/Erosion Control | Form: (02A )
401779047
1/24/2020 | Crestone will utilize BMPs at the location to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, site degradation, and protects surface waters. This location will include a diversion ditch around the perimeter of the pad with sediment traps in the NE, SE, SW, and NW corners. The location will also include road base armoring of the location surface, grading, and vehicle tracking on the pad access.
Depending on the status of reclamation, the site will be inspected on either a 14-day, 30-day, annual, or rain triggered event. |
| Material Handling and Spill Prevention | Form: (02A )
401779047
1/24/2020 | Leak Detection Program
• Annual hydrostatic test on the oil dump line from the separator to the tank battery.
• Annual hydrostatic “static” tests on our oil tanks.
• Annual hydrostatic “static” tests on our produced water tank and water dump line from the separator to the produced water tank.
• Lease Operator inspections of all equipment not to exceed 48 hours.
• Monthly documented inspections (EU).
• Annual environmental inspections of all battery and well equipment and pads.
• UT inspections of the pressure vessels every five years and input into Crestone’s RIPL Predictive Integrity Maintenance Program. (HLP separators and fuel gas separators)
The Crestone lease operator inspections are done as a routine part of the lease operators job. The lease operator would typically visit each of their assigned locations daily. They conduct a visual inspection of the facility which includes all valves, fittings, wellhead, tanks, vapor control systems and all connections. The lease operator also checks our Cygnet automation system for system pressures and flows. Any valve or fitting that is found to be leaking is either repaired immediately by the lease operator or shut-in procedures are implemented.
The monthly documented inspection, referenced previously, is done using an electronic form that is recorded in the EU system. This inspection and documentation requires the lease operator to inspect ALL aspects of the site and then triggers work orders for any leaks, or housekeeping issues.
The Lease operators also conduct a weekly – Audible, Visual, and Olfactory (AVO) inspection, which focuses on the tanks and vapor control system.
In addition, the sites are inspected with optical gas imaging cameras on a routine schedule, annually for compliance purposes.
Integrity testing of flowlines is done during both the construction phase as well as during the operations phase. At the construction phase lines are tested with 100% x-ray and go through hydrotests. Pressure testing of the flowlines is conducted on an annual basis. |
| Material Handling and Spill Prevention | Form: (02A )
401779047
1/24/2020 | Protection of Shallow Groundwater: Crestone places RPE Liner with 10oz Geomembrane under all mud tanks, as well as the surface and production rig to catch any releases that may occur. In addition, we line our well cellars with a liner material. Conex containment is also used to house items. |
| Material Handling and Spill Prevention | Form: (02A )
401779047
1/24/2020 | Well effluent containing more than ten (10) barrels per day of condensate or within two
(2) hours after first encountering hydrocarbon gas of salable quality will be directed to
a combination of sand traps, separators, surge vessels, and tanks as needed to
ensure safe separation of sand, hydrocarbon liquids, water, and gas and to ensure
salable products are efficiently recovered for sale or conserved and that non-salable
products are disposed of in a safe and environmentally responsible manner. |
| Material Handling and Spill Prevention | Form: (02A )
401779047
1/24/2020 | Crestone utilizes 24” tall corrugated galvanized metal berm walls with a capacity in
excess of 150% of the largest tank contained within the wall. In addition, Crestone best
practices mandates the use of impervious liners that extends under each storage tank
and up the walls, permanently affixed to the top of the metal berm wall. Protrusions of
piping that come through the liner include a fully sealed “boot” to prevent leakage. Separators will be contained within 22" tall metal berms built on compacted roadbase. |
| Dust control | Form: (02A )
401779047
1/24/2020 | Crestone places road base, rock and recycled asphalt to assist with dust abatement. During construction, drilling, completions and reclamations phases, Crestone monitors each site and, if needed, we will run water trucks on the lease road and county road. |
| Construction | Form: (02A )
401779047
1/24/2020 | Operator will have an MLVT Design Package, certified and sealed by a licensed professional engineer, which is on file in their office and available upon request. The site shall be prepared in accordance with the specifications of the design package prior to tank installation; including ensuring that proper compaction requirements have been met. The MLVT will be at least 75 feet from a wellhead, fired vessel, heater-treater, or a compressor with a rating of 200 horsepower or more. It will be placed at least 50 feet from a separator, well test unit, or other non-fired equipment. All liner seams will be welded and tested in accordance with applicable ASTM international standards. Operator will be present during initial filling of the MLVT and the contractor will supervise and inspect the MLVT for leaks during filling. Operator will comply with the testing and re-inspection requirements and associated written standard operating procedures (SOP) listed on the design package. Signs will be posted on the MLVT indicating that the contents are freshwater. The MLVT will be operated with a minimum of 1 foot of freeboard at all times. Access to the MLVT will be limited to operational personnel and authorized regulatory agency personnel. Operator or contractor will conduct daily visual inspections of the exterior wall and surrounding area for integrity deficiencies. Operator will have a contingency plan/emergency response plan associated with the MLVT and it is on file at their office. A fabric reinforced liner will be utilized. In the event that a tank breach were to occur, the fabric reinforced liner will prevent a “zippering” failure from occurring. The liner will meet the specifications per the design package. Operator acknowledges and will comply with the Colorado Oil & Gas Conservation Commission Policy on the Use of Modular Large Volume Tanks in Colorado dated June 13, 2014.
|
| Noise mitigation | Form: (02A )
401779047
1/24/2020 | Crestone will perform a baseline noise survey prior to any operational activity.
Crestone will install temporary 32’ sound walls on all four sides of the well pad that will go up once the pad has been constructed and stay up during drilling and completions phases to minimize noise and light impacts.
Once the wells are on production, if needed as determined by any additional sound monitoring, Crestone will install more permanent noise mitigation at the facility location to meet all COGCC regulations. These are lower profile and removable sound walls, inside the facility, to mitigate any noise from the compression area. |
| Noise mitigation | Form: (02A )
401779047
1/24/2020 | Crestone Peak Resources will construct the subject location to allow potential future noise mitigation installation without disturbance. |
| Odor mitigation | Form: (02A )
401779047
1/24/2020 | Drilling rig and completion engine exhausts are pointed straight up so as not to be directed towards any occupied buildings. During the fracturing process, diesel-fueled fracturing equipment will be located in the southwest part of the pad in order to reduce proximity of emissions to nearby housing located to the east.
To mitigate the effects of odor from Crestone's operations, Crestone will employ only International Association of Oil & Gas Producers (IOGP) Group III drilling base fluids with <0.5 weight % aromatics and will not use drilling fluids based on diesel. We also employ the use of mud chillers.
Sealed tanks with pressure relief valves and emissions controls will be utilized for the production facilities. |
| Drilling/Completion Operations | Form: (02A )
401779047
1/24/2020 | Green Completions -Test separators and associated flow lines, sand traps and
emission control systems shall be installed on-site to accommodate green completions
techniques. When commercial quantities of salable quality gas are achieved at each
well, the gas shall be immediately directed to a sales line or shut in and conserved. If a
sales line is unavailable or other conditions prevent placing the gas into a sales line,
the operator shall not produce the wells without an approved variance per Rule 805.b.(3)C. |