| Planning | Form: (02A )
402958552
9/23/2022 | • The wells are commingled into a bulk and test facility design. This reduces the total number of separators on location on a per well basis which in turn allows KMOG to have a smaller facility footprint. Reducing the total number of separators per well also reduces the total noise and emissions from the separator burners.
• Ozone mitigation on forecasted high ozone days: operator will postpone the refueling of vehicles, as feasible, given the number of ozone action days, the operations ongoing at the time, and safety considerations.
• Ozone mitigation on forecasted high ozone days: operator will suspend or delay the use of fossil fuel powered ancillary equipment, as feasible, given the number of ozone action days, the operations ongoing at the time, and safety considerations.
• Ozone mitigation on forecasted high ozone days: operator will postpone construction activities, as feasible, given the number of ozone action days, the operations ongoing at the time, and safety considerations.
• Ozone mitigation on forecasted high ozone days: operator will reschedule non-essential operational activities such as pigging, well unloading and tank cleaning, as feasible, given the number of ozone action days, the operations ongoing at the time, and safety considerations. |
| Traffic control | Form: (02A )
402958552
9/23/2022 | Access Road: KMOG will utilize the existing Weld County Road (WCR) 17 to WCR 38 to the lease access road to the pad for drilling, completions, and production operations, including maintenance equipment. The road will be properly constructed and maintained to accommodate for emergency vehicle access. |
| General Housekeeping | Form: (02A )
402958552
9/23/2022 | • Removal of Surface Trash: A commercial size trash bin for removing debris will be located on site. This bin will be for use by all parties affiliated with the operation. Upon completion of operations, the commercial trash bin will be removed from the location and disposed of in an appropriate manner.
• Good housekeeping measures will be implemented to prevent sediment, trash and toxic or hazardous substances from entering surface waters or impacting soils. Housekeeping practices include routine inspections, regular cleaning, site and equipment organization and maintenance, and appropriate chemical storage.
• Materials stored on Swartz 2-4HZ well pad will be kept away from direct traffic to prevent accidents.
• Dumpsters and trash receptacles will be enclosed and/or covered to prevent dissemination of rubbish when not in use.
• Storage areas will be swept for trash / rubbish, and cleanup coordinated by construction personnel.
• Drums and chemical storage containers will be clearly labeled, and an appropriate SDS kept on file to be made available for on-site personnel as needed.
• Loadlines: All loadlines shall be bullplugged or capped. |
| General Housekeeping | Form: (02A )
402958552
9/23/2022 | • Wastes will be stored in containers or on lined containment that are chosen for compatibility and checked periodically for leaks or integrity problems. Examples of containment include but are not limited to 3-sided steel tanks, steel tanks, lined containment, plastic totes, drums, etc.
• All specific wastes in the attached site-specific Table will have a detailed Safety Data Sheet available which includes information such as the properties of the wastes; the physical, health, and environmental health hazards; protective measures; and safety precautions for handling, storing, and transporting the chemical.
• The proper personal protective equipment will always be worn when handling waste. Employees will refer to the Safety Data Sheet for additional information.
• Good housekeeping measures will be implemented in the operating area and to ensure safety and environmental well-being.
• Wastes will be segregated and stored according to its waste type.
• When feasible, wastes will be recycled, re-used, or treated onsite. Fluids are generally re-used from location to location if possible. No onsite treatment or recycling is planned onsite for this location. In the event, that onsite treatment or recycling is feasible, a written management plan will be submitted to the COGCC Director for approval on a Form 4. |
| Wildlife | Form: (02A )
402958552
9/23/2022 | AVOIDANCE MEASURES
• Pad construction and drilling will be scheduled to avoid the timing stipulations of bald eagle winter night roost (November 15th - March 15th).
MINIMIZATION MEASURES
• The gates surrounding the operations area will remain closed and locked at all times to prevent wildlife from entering the property.
• A sound barrier will be installed during pad construction for drilling and completion operations to reduce noise pollution.
• Light pollution will be minimized by directing rig lighting downward and away from the Saint Vrain Creek river corridor; this practice will minimize impacts to BEWNR.
• KMOG will use CPW-recommended seed mix based on present soil conditions for interim and final reclamation conducted pursuant to Rules 1003 and 1004 and when consistent with the Surface Owner’s approval and any local soil conservation district requirements. Location specific plan can be found in the reclamation plan. Seed mix information will be made available upon request.
• Openings greater than 2” on equipment not running 24 hours a day will have avian protection installed.
• Approximately two weeks prior to construction start, the approved location will be surveyed by 3rd party biological contractor for nests.
• A site-specific spill prevention, control, and countermeasure plan complaint with EPA rule 40 CFR 112 Subpart A, B, C will be created for this location.
• Automated emergency response systems and emergency shutdown systems will be installed.
• Remote monitoring systems will be utilized at this location.
• Vegetation will be controlled on the active location throughout the life of the project.
• A Water On Demand system and pipelines will be utilized to minimize truck traffic on location.
• Periodic inspections for nests and of avian protection will occur throughout the life of the project.
• Training is provided to employees and contractors on wildlife conservation practices, including no harassment, feeding of wildlife, or illegal hunting.
• Fluids will be consolidated and centralized for collection and distribution to minimize impact to wildlife.
• Infrastructure and facility are adequately sized to accommodate planned production.
• Employees and contractors visiting location will follow Kerr-McGee Oil & Gas Onshore LP rules for accessing location, including speed limits and access timing. |
| Storm Water/Erosion Control | Form: (02A )
402958552
9/23/2022 | Construction Phase
• Construction phasing and sequencing will be implemented at Swartz 2-4HZ Well Pad to minimize the amount of surface disturbance and exposed soils to the greatest extent practicable.
• Ditch and berm shall be installed around the perimeter of the location, and subsequently around all topsoil stockpiles, to intercept and divert stormwater run-on/run-off and sediment from precipitation and melt events.
• Track packing all topsoil stockpiles will occur to prevent erosion from stormwater and wind, as well as provide temporary stabilization.
• Seeding and crimped straw mulch will be applied to prevent erosion and soil loss from stormwater and wind.
• Vegetation establishment through seeding efforts will promote soil health and maintain carbon exchange.
• Weed control will occur seasonally and as needed to hinder the spread of weeds throughout the topsoil stockpile(s) and help native grass establishment.
• All waste from materials imported to Swartz 2-4HZ Well Pad will be placed in containment bins, and removed for disposal/recycling at an approved, licensed facility.
• Self-contained port-o-lets will be placed on both the facility and well pad at Swartz 2-4HZ Well Pad and maintained by a licensed contractor at a frequency appropriate based on daily use.
• No waste materials will be buried or dumped on Swartz 2-4HZ Well Pad.
• Pre-existing vegetation cover will only be removed where necessary for the operation of construction and development at Swartz 2-4HZ Well Pad. Trees will only be cut or trimmed to facilitate clearing, grading and safe installation of the location.
• Vegetative buffers will be preserved to the greatest extent practicable for construction and development.
Drilling Phase
• Ditch and berm shall be installed around the perimeter of the location, and subsequently around all topsoil stockpiles, to intercept and divert stormwater run-on/run-off and sediment from precipitation and melt events.
• Track packing all topsoil stockpiles will occur to prevent erosion from stormwater and wind, as well as provide temporary stabilization.
• Seeding and crimped straw mulch will be applied to prevent erosion and soil loss from stormwater and wind.
• Vegetation establishment through seeding efforts will promote soil health and maintain carbon exchange.
• Weed control will occur seasonally and as needed to hinder the spread of weeds throughout the topsoil stockpile(s) and help native grass establishment.
Production Phase
• Vegetation establishment through seeding efforts will promote soil health and maintain carbon exchange.
• Weed control will occur seasonally and as needed to hinder the spread of weeds throughout the topsoil stockpile(s) and help native grass establishment.
Training and Certification
• All personnel involved with construction and stormwater activities will be adequately trained and familiarized with the applicable CDPS stormwater permit, local/State regulations, requirements for the stormwater permit, and identification of potential pollutant sources.
• Training(s) will cover information and procedures identified in this SWMP, and will be conducted prior to the start of construction, and as needed.
• Training is considered initial and ongoing for all personnel involved with construction and development at Swartz 2-4HZ Well Pad.
Swartz 2-4HZ Well Pad |
| Material Handling and Spill Prevention | Form: (02A )
402958552
9/23/2022 | Drilling
• During drilling operations, the following site-specific best management practices will be used: Appropriate secondary containment will be utilized when equipment maintenance is conducted on location. KMOG will shut down transfer pump and close supply valve when transfer or circulation is completed. KMOG will ensure fluids cannot enter holding tank through gravity feedback. Pre-job inspection will be conducted prior to start up which include the visual inspection of hoses, lines, and valves to ensure proper connection and alignment. During operations, all fluid containing equipment is inspected daily.
• The temporary produced water storage tanks will be staged on a geosynthetic liner and surrounded by an earthen berm. The berms will enclose an area sufficient to provide secondary containment for 150% of the volume of the largest single tank and will be sufficiently impervious to contain spilled or released material. Berms and the liner and all Kerr-McGee Oil & Gas Onshore LP (KMOG) secondary containment devices will be inspected at the same time as stormwater inspections, with personnel on location, daily inspections will occur. During non-active, but while under construction, site inspections will occur every 14 days. When construction is completed and the Location is on production, site inspections will occur every 28 days.
• Pit Level Indicators: All storage tanks used for active drilling operations (used in lieu of pits) contain pit level monitors with Electronic Drilling Recorders (EDR). KMG uses EDRs with pit level monitor(s) and alarm(s) for production rigs. Basic level gauges are used on tanks utilized for the surface rig.
• Operator will not use PFAS on location. |
| Material Handling and Spill Prevention | Form: (02A )
402958552
9/23/2022 | Completions
• During completions operations, the following site-specific best management practices will be used: KMOG will monitor pressure responses and containment to identify potential leaks. Lines will also be walked continuously throughout operations (between stages) to identify potential leaks. In addition, there is a slam valve and control valve with Emergency Shut Down system in line to the external temp tanks to prevent overflowing tanks during the green flowback duration.
• Two completions crew members required and dedicated for all fluid transfers (no exceptions) from start to finish of the operation. Their sole focus is on the transfer. No fluid transfer will occur during crew change. Crew members conducting the fluid transfer will not leave the area until transfer operations completed.
• Tanks (along with auxiliary equipment installed in tanks) will be inspected prior to use and replaced/repaired if damaged. Kerr-McGee Oil & Gas Onshore LP (KMOG) Fluid Leak Detection Plan – Berry Farms Wells 8-8HZ 3
• Appropriate secondary containment will be utilized when equipment maintenance is conducted on location.
• Contractors will maintain an updated copy of their SPCC plan on location and its personnel will be trained accordingly.
• Tanks will be labeled (signs, magnets, etc.) indicating the contents of the tank.
• Verify tank capacity is capable of handling estimated volumes prior to operations start.
• Tanks will have hatches, valves and bull plugs secured prior to transfers.
• Shut down transfer pump and close supply valve when transfer or circulation is completed. Ensure fluids cannot enter holding tank through gravity feedback.
• Pre-job inspection will be conducted prior to start up which include the visual inspection of hoses, lines, and valves to ensure proper connection and alignment.
• During operations, all fluid containing equipment is inspected daily.
• Walk all lines and confirm valve alignment before starting the transfer.
• Walk the lines as soon as the transfer starts to confirm no leaks.
• Temporary produced water storage tanks will be designed, constructed, and maintained in accordance with the following portions of the National Fire Protection Association (NFPA) Code 30 (2008 version): 1) Tanks are built to engineering standards using noncombustible materials, with relief device sizing based on API 2000 standards. 2) Tanks are inspected and maintained while in use. 3) The only pipes within the containment are related to the temporary tanks (i.e. no external piping is co-located within the containment), and firefighting equipment is, likewise, not stored within the containment area.
• The temporary produced water storage tanks will be staged on a geosynthetic liner and surrounded by an earthen berm. The berms will enclose an area sufficient to provide secondary containment for 150% of the volume of the largest single tank and will be sufficiently impervious to contain spilled or released material. Berms and the liner and all secondary containment devices will be inspected at the same time as stormwater inspections, with personnel on location, daily inspections will occur. During non-active, but while under construction, site inspections will occur every 14 days. When construction is completed and the location is on production, site inspections will occur every 28 days at a minimum.
• Monitor pressure responses and containment to identify potential leaks. Lines will be walked continuously throughout operations (between stages) to identify potential leaks.
• There is a slam valve and control valve with Emergency Shut Down system in line to the external temp tanks to prevent overflowing tanks during the green flowback duration.
• Hourly walk-throughs and pressure measurements recorded during flowback operations for leak detection.
• During operations, all fluid containing equipment is inspected daily.
• All personnel on location on behalf of KMOG are trained in AVO techniques. All personnel are empowered with ‘Stop Work Authority’ and to report any leaks immediately. |
| Material Handling and Spill Prevention | Form: (02A )
402958552
9/23/2022 | Production
• Operator will utilize its tankless design for its facilities at the location; the term tankless has been used for the design to designate that we have no oil storage on site.
• During production operations, the following site-specific best management practices will be used: Automation technology will be utilized at this facility. This technology includes the use of fluid level monitoring for the tanks and produced water sumps, high-level shut offs, and electronic sensors to monitor the interstitial space of double-walled produced water sumps. All automation is monitored by Kerr-McGee's Integrated Operations Center (IOC), which is manned 24 hours per day, 7 days per week. All personnel on location on behalf of KMOG are trained in AVO techniques. All personnel are empowered with ‘Stop Work Authority’ and to report any leaks immediately.
• Field Inspections include the following: Onsite and Offsite Pipelines (flowlines, production piping, gathering lines), Field Drainage Systems (oil traps, sumps, or skimmers); and additional equipment used during transferring of produced fluids.
• All personnel on location on behalf of KMOG are trained in AVO techniques. All personnel are empowered with ‘Stop Work Authority’ and to report any leaks immediately. |
| Material Handling and Spill Prevention | Form: (02A )
402958552
9/23/2022 | Recording Keeping
• Inspections resulting in findings are reported to the IOC. These are entered into an internal management system. Corrective actions are automatically assigned when necessary. SPCC required inspection records are kept in accordance with US EPA requirements.
• Maintenance or repair records are managed through an internal management system. These are tracked from assignment through completion of the tasks.
• Leak records: All leaks are reported immediately to the IOC and logged in internal management systems. Leak reports are reviewed daily. Any additional investigation is conducted by trained personnel and records in the system. All leaks are tracked until final resolution. Records are retained per federal, state, and local guidelines.
• Training Records: KMOG retains AVO training records for all personnel with access to the location in an internal management system. Records are retained per federal, state, and local guidelines. |
| Dust control | Form: (02A )
402958552
9/23/2022 | • KMOG will proactively deploy fresh water to suppress dust along access road to well pad/ facility during all phases of pre-production operations
• Speed limits will be reduced to 10 mph on access road and 5 mph once vehicles reach well pad/ facility
• Access roads and Vehicle Tracking Control will receive maintenance as needed throughout operations
• In the event of high winds that generate dust that cannot be mitigated with an application of water, KMOG will shut down construction operations
• KMOG will proactively deploy fresh water on CR 36 from access road entrance east to CR 17 as needed.
• During the Completions phase, KMOG will utilize a fully enclosed Sand Containerized Proppant Delivery System that eliminates the use of pneumatic transfer on location. This methodology utilizes a gravity choke feed system that reduces dust significantly. The dust levels from this system are minimal and below Occupational Safety and Health Administration (OSHA) permissible exposure limit which eliminates the need for additional Personal Protective Equipment (PPE). |
| Construction | Form: (02A )
402958552
9/23/2022 | • Fencing Requirements: The completed wellsites will be surrounded with a fence and gate with adequate lock to restrict access to authorized personnel only. KMOG personnel will monitor the wellsites upon completion of the wells. Authorized representatives and/or KMOG personnel shall be on-site during drilling and completion operations.
• Construction: Operator will only conduct during day light and there will be no nighttime operations that require lighting. |
| Noise mitigation | Form: (02A )
402958552
9/23/2022 | • KMOG has conducted a Noise Impact Assessment for each phase of operations (drilling, completions, and production) to assess operational noise levels against the maximum allowable dBA and dBC noise levels stated in the Regulation.
• The operator will comply with maximum permissible noise levels adjusted based on the results of the ambient noise survey. The adjusted noise levels are outlined in the Noise Mitigation Plan at respective compliance points:
- Drilling and Completions: Compliance Points 1, 3, and 4 – 65 db(A) Day / 60 db(A) Night – 65 db(C) Day / 65 db(C) Night
- Drilling and Completions: Compliance Point 2 – 65 db(A) Day / 60 db(A) Night – 79 db(C) Day / 71 db(C) Night
- Production: Compliance Points 1, 3, and 4 – 60 db(A) Day / 55 db(A) Night – 60 db(C) Day / 60 db(C) Night
- Production: : Compliance Point 2 – 70 db(A) Day / 64 db(A) Night – 75 db(C) Day / 70 db(C) Night
• Prior to commencement of any drilling and completion activities, approximately 2,040 linear feet of 32 foot tall, engineered sound wall rated at STC 32 will be installed as proposed in the NIA in the Noise Mitigation Plan. This will include approximately 640 linear feet on the north side of the location, 360 linear feet on the East Side of the location, 640 linear feet on the South side of the location, and 400 linear feet on the West side of location.
• A Quiet Completions Fleet will be utilized for completions operations.
• At the Directors request, OXY agrees to acquire an additional ambient at all four noise points of compliance 30 to 90 days prior to the commencement of operations. If the new ambient noise levels change any components of this Noise Mitigation Plan, a Form 4 sundry will be submitted to update the plan accordingly. • Continuous monitoring will be employed for all drilling and completions and any operations that lasts longer than 24 continuous hours. Monitor locations will coincide with the four noise points of compliance outlined in Figure 2 in Section 5 of this document.
• If the drilling rig or completions fleet is changed prior to commencement of operations, the mitigation measures will be equally or more protective. A Form 4 will be submitted per Rule 404.d to outline any changes.
• OXY will post contact information to receive and address noise complaints arising from preproduction operations around the clock, 24-hours, 7 days per week. Upon receipt of a complaint, either directly to OXY or from the COGCC, OXY will contact relative stakeholder within 24 hours of receipt. |
| Emissions mitigation | Form: (02A )
402958552
9/23/2022 | • Temporary ECD(s) will be utilized to mitigate releases of emissions from temporary produced water storage tanks for the duration which the tanks are on location and being used.
• Operator uses pipelines to transport hydrocarbons (oil & gas) from the production facility eliminating odors that could occur during truck loading.
• Operator will implement ambient air quality monitoring on site.
• Operator will use non-emitting pneumatic controllers.
• Test separators and associated flow lines, sand traps and emission control systems shall be installed on-site to accommodate 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, KMOG shall not produce the wells.
• Ozone Action Days ±KMOG will comply with the follow mitigation measures, as feasible, on forecasted Ozone Action Days:
a. Operator will minimize vehicle and engine idling
b. Operator will reduce truck traffic and worker traffic
c. Operator will postpone the refueling of vehicles
d. Operator will postpone construction activities
e. Operator will reschedule non-essential operational activities such as pigging, well unloading and tank cleaning
f. Operator will postpone flowback if emissions cannot be adequately captured with an ECD. |
| Odor mitigation | Form: (02A )
402958552
9/23/2022 | • All oil based drilling fluids will be built using a Group III base oil with negligible aromatic content and PAH less than 0.001% so that it does not emit odor during all production drilling operations.
• The Group III base oil will be utilized in a closed loop drilling fluid system and eliminate odor at the shakers, transfer tank, active/reserve tanks, and cuttings in collection tanks and during transport.
• All drill cuttings are processed through centrifugal dryers to remove residual oil-based drilling fluid not removed by shale shakers.
• All tubulars pulled out of the hole will be wiped prior to being racked in the derrick or laid down.
• Cuttings storage time on location will be minimized prior to transport to local landfills.
• New drilling fluid will be built using transfer line outlets located below tank fluid level to minimize splashing/agitation. New fluid will only be built using Group III base oils.
• KMOG will use a mud chiller with the intent to lower the drilling fluid temperature as fluids are redeployed downhole. Mud chillers will be installed downstream of the shale shakers.
• KMOG uses pipelines to transport hydrocarbons (oil & gas) from the production facility eliminating odors that could occur during truck loading. |
| Drilling/Completion Operations | Form: (02A )
402958552
9/23/2022 | • Guy line anchors will not be used. Base Beams will be used to stabilize the rig and removed after drilling.
Construction Phase:
• KMOG will only conduct day light operation and there will be no nighttime operations that require lighting.
Drilling Phase:
• KMOG will utilize LED fixtures to reduce sky glow.
• KMOG will position all lights to point in a downward direction where vertical lighting is not required. Where it is required, lights are angled in a vertical direction to provide task lighting for safety and operations involving personnel.
• Derrick mast is facing horizontally to provide adequate lighting for safe operation.
• Lighting is angled away from surrounding off site buildings.
• Lighting within the Drilling area has been reduced to provide a minimum acceptable value for safe operation.
• Light masts are automatically switched off/on based on lighting sensors.
• Lights are switched off when not required.
• Low power (63 W) LED lights are used for the drill rig.
• Sound barriers be partially placed on the northeast and southeast sides of the location and will significantly reduce lighting trespass to surrounding off-site buildings.
• In the event of a lightning complaint, KMOG will address the complaint and work with all parties involved to ensure the complaint is resolved.
Completions and Flowback Phases:
• KMOG will utilize LED fixtures to reduce sky glow.
• KMOG will position all lights to point in a downward direction where vertical lighting is not required. Where it is required, lights are angled in a vertical direction to provide task lighting for safety and operations involving personnel.
• Lighting is angled away from surrounding off site buildings.
• Lighting within the Completion and Flowback areas have been reduced to provide a minimum acceptable value for safe operation.
• Light masts are automatically switched off/on based on lighting sensors.
• Lights are switched off when not required.
• Lights are directed to task areas only.
• Sound barriers be partially placed on the northeast and southeast sides of the location and will significantly reduce lighting trespass to surrounding off-site buildings. • In the event of a lightning complaint, KMOG will address the complaint and work with all parties involved to ensure the complaint is resolved.
Production Phase
• KMOW will utilize LED fixtures to reduce sky glow.
• KMOG will position all lights in a downward direction.
• Lighting within the Production areas have been reduced to provide a minimum acceptable value for safe operation.
• In the event of a lightning complaint, KMOG will address the complaint and work with all parties involved to ensure the complaint is resolved. |
| Interim Reclamation | Form: (02A )
402958552
9/23/2022 | • Interim reclamation will commence within twelve months from first date of production for all disturbed areas affected by construction and drilling operations which are no longer in use or needed for production. Interim reclaimed areas will be returned to their original condition as practicable, or their final land use as designated by the surface owner.
• Seed and mulch are utilized in disturbed areas to establish stabilization through vegetative cover.
• Seeding will take place once surface disturbing activities are complete. Topsoil stockpiles will be stabilized with seed and mulch no longer than 14-days after completion of stockpiling efforts unless weather or ground conditions are not suitable to properly create a seedbed and promote successful germination.
• Seed & mulch will be installed on all disturbed areas no longer utilized for construction, and on all topsoil stockpiles which will remain on Swartz 2-4HZ for use during final reclamation. Anticipated topsoil stockpiles will be situated along the southern perimeter of the well pad.
• Seeding will remain in place until re-disturbed during final reclamation efforts.
• In areas to be returned to crop, the seed bed will be prepared and left for surface owner to plant during next agricultural season.
• Cropland Per rule 1003.b., “All segregated soil horizons removed from crop lands shall be replaced to their original relative positions and contour and shall be tilled adequately to re-establish a proper seedbed. Any perennial forage crops that were present before disturbance shall be re-established”. All cropland locations will be reclaimed within three months from completion final ground disturbing activities. |
| Final Reclamation | Form: (02A )
402958552
9/23/2022 | • Well Site Cleared: The wellsite will be cleared of all non-essential equipment within ninety (90) days after all wells associated with the pad have been plugged and abandoned.
• Identification of Plugged and Abandoned Wells: Once the well has been plugged and abandoned, KMOG will identify the location of the wellbore with a permanent monument that will detail the well name and date of plugging. |
| Drilling/Completion Operations | Form: (04 )
403554060
1/19/2024 | KMOG commits to using International Association of Oil and Gas Producers (IOGP) Group III drilling fluid during drilling operations. |
| Emissions mitigation | Form: (04 )
403773349
6/6/2024 | Water to be trucked onto the Swartz location will be stabilized produced water and
therefore will have minimal emissions.
The truck mileage to haul produced water from nearby pads to the Swartz site will be
at least 25% less than the mileage needed to haul produced water to the closest
disposal site, resulting in a significant reduction in truck mileage and the associated air
emissions.` |
| Drilling/Completion Operations | Form: (04 )
403773349
6/6/2024 | The MLVT will be in compliance with the following Energy & Carbon Management
Commission (ECMC) safety setbacks. 1) Seventy-five (75) feet from a wellhead, fired
vessel, heater-treater, or a compressor with a rating of 200 horsepower or more; 2)
Fifty (50) feet from a separator, well test unit, or other non-fired equipment.
Signs shall be posted on each MLVT to indicate that the contents are fresh water and
that no E&P waste fluids are allowed. Location and additional signage shall conform
to Rule 210.
MLVT will be operated with a minimum of 1 foot freeboard at all times. Access to the
tanks shall be limited to operational personnel. Construction and installation of the
tank structure, liner and sub-grade shall meet or exceed the manufacturer
specifications. KMOG follows manufacturers Standard Operating Procedures (SOPs)
and will provide these SOPs upon request to the ECMC.
KMOG will conduct daily, visual inspections of the exterior wall and general area for
any integrity deficiencies before, during, and after filling the MLVTs. if deficiencies are
noted, KMOG will repair them as soon as practicable. Records of repairs will be
maintained per Rule 205.
KMOG will follow pre-construction risk assessment measures to address safety
concerns and minimize environmental impacts and property damage in the unlikely
event of a MLVT release.
In the event of a catastrophic MLVT failure, KMOG shall notify the ECMC as soon as
practicable but not more than 24 hours after discovery, submit a Form 22 - Accident
Report within 10 days after discovery, conduct a root cause analysis and provide same
to ECMC on a Form 4-Sundry Notice within 30 days of the failure.
All MLVT liner seams shall be welded and tested in accordance with applicable ASTM
international standards. Any repairs to liners shall be made using acceptable practices
and applicable standards.
The MLVT shall be constructed and operated in accordance with a design package
certified and sealed by a Licensed Professional Engineer either in Colorado or the
state when the MLVT was designed or manufactured.
The MLVT well be designed and implemented consistent with ECMC's MLVT policy |
| Drilling/Completion Operations | Form: (04 )
403773349
6/6/2024 | BMP from Reuse and Recycling Plan - All incoming water and outgoing waste will be documented with the following:
1. The date of the transport.
2. The identity of the waste/water generator.
3. The identity of the waste/water transporter.
4. The location of the waste pickup site.
5. Volume of water/waste.
6. The name and location of the treatment or disposal site.
When treated water is used as hydraulic fracturing feed water, the information will be provided to the Colorado Energy and Carbon Management Commission on a Form 5A Completed Interval Report. |
| Drilling/Completion Operations | Form: (04 )
403773349
6/6/2024 | BMP from Reuse and Recycling Plan - for above ground piping carrying treated water to the hydraulic fracturing operations. Piping will be above ground where it can be easily evaluated for leaks.
Additionally, fused high density polyethylene pipe will be utilized to carry treated water as this is considered to be best industry practice for minimizing leaks around joints.
The untreated water storage tanks will be placed within a lined secondary containment.
All tanks and vessels will be inspected daily, and the facility will have operators 24/7.
KMOG will maintain waste tracking for the mobile recycling system. |
| Drilling/Completion Operations | Form: (04 )
403773349
6/6/2024 | BMP from Reuse and Recycling Plan -
Produced water and treated water will be stored in closed top frac tanks with emissions controls. Produced water and treated water will not be stored in pits or modular large volume storage tanks.
The untreated water storage tanks will be placed within a lined secondary containment.
All tanks and vessels will be inspected daily, and the facility will have operators 24/7. |
| Drilling/Completion Operations | Form: (04 )
403773349
6/6/2024 | BMP from Reuse and Recycling Plan -
The sludge generated from the treatment will be collected in tanks and transported offsite for disposal at a permitted landfill or KMOG's Aggregate Recycle Facility. The resulting water from the dewatering process will be recirculated back through the mobile recycling system. |