| Traffic control | Form: (02A )
403649068
10/11/2024 | Operator will utilize lay-flat water pipeline to source water for completion operations to reduce traffic associated with pre-production operations.
Operator will utilize an oil pipeline to transport oil from the location to reduce traffic associated with permanent production operations.
Operator will restrict all non-essential site trips during the commuter hours of 7:00 a.m. to 9:00 a.m. and 4:00 p.m. to 6:00 p.m.
Operator will develop a plan to warn motorists of heavy truck traffic during construction of the Site. |
| Wildlife | Form: (02A )
403649068
10/11/2024 | Ensure all personnel and contractors are aware of and adhere to applicable wildlife protection measures and BMPs;
Personnel and contractors will not harm any wildlife observed on site and will maintain recommended buffer distances related to wildlife;
Personnel and contractors will report any wildlife concerns, including the discovery of injured or orphaned wildlife, to on-site management and applicable EHSR personnel;
Inform and educate employees and contractors on wildlife conservation practices, including no harassment or feeding of wildlife. Crestone will use CPW-recommended fence designs;
Operator will conduct additional avian surveys prior to the commencement of construction to ensure no conflicts have developed since the prior survey(s). |
| Storm Water/Erosion Control | Form: (02A )
403649068
10/11/2024 | Four (4) diversion ditches will be constructed during the drilling/completions (active construction) and production (interim reclamation) at low points/outfalls from the diversion ditch network. Diversion ditches will surround the construction area capturing sediment laden runoff channeling into the down-gradient sediment basin. Two (2) of the diversion ditches will be reclaimed for the interim reclamation. All diversion ditches will have a depth of 24”, 4:1 side slopes, and a minimum slope of 0.5%.
Berms will be placed along the exterior boundary of the sediment basin. Berms and ditches will divert surface water to the on-pad sediment basin/detention basin. Berms will be 6’ high with 4:1 side slopes.
This site will be constructed with two (2) culverts under the access road.
The Sediment Basin will be constructed on the northeast corner of the drill pad edge during the drilling/completions (active construction) and production (interim reclamation) at low points/outfalls from the diversion ditch network. Where the tributary disturbed area is greater than 1 acre, a sediment basin will be planned for the well site at the low point of the pad. It will be implemented at the downstream termination of the diversion ditches. A sediment basin will be installed before the site grading begins. The sediment basin will be reclaimed for the interim reclamation.
During the production phase, a private extended detention basin will be constructed closer to the production pad surface in the northeast corner after the production pad surface has been downsized.
The sediment control log will be placed along the northern edge of the proposed access road and along the northern and eastern edges of the topsoil stockpile during the pre-production and production phase. SCL will be constructed along the north and east edges of the pad. SCL will be constructed along the north and east of the topsoil pile. SCL will be constructed along the north side of the road entrance.
Three (3) RRA will be constructed during the construction phase. One (1) on the northwest edge of the pad. One (1) on the northeast of the pad. One (1) on the east edge of the pad. These will be reclaimed during the production phase.
During the production phase, an RRA will be constructed on the north east edge of the pad for silt and debris from off-site ditch-2.
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 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.
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. |
| Material Handling and Spill Prevention | Form: (02A )
403649068
10/11/2024 | Consistent with good materials and waste management practices, Operator maintains records of material/waste source, transporter, and final disposition or disposal.
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.
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 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.
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.
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 )
403649068
10/11/2024 | 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. |
| Construction | Form: (02A )
403649068
10/11/2024 | Unnecessary sounds such as honking horns, revving engines, loud music, and unwarranted hammering/banging will be strictly prohibited.
Lighting will be angled in a downward manner to limit the halo effect off location.
Lights will be placed at reasonable heights to limit spillage off location.
Operator will not install permanent lighting. |
| Emissions mitigation | Form: (02A )
403649068
10/11/2024 | Operator will install an oil pipeline and gas pipeline to the location prior to first production.
Operator will utilize compressed air pneumatics for all pneumatic actuation on location.
Operator will utilize a pressurized maintenance vessel during maintenance operations.
Operator will electrify the permanent production facilities.
Lease Automated Custody Transfer (LACT) will be used to transfer fluids from the oil production tanks.
Wells, facilities, and equipment will be equipped to be shut-in remotely. |
| Odor mitigation | Form: (02A )
403649068
10/11/2024 | 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 III) 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 proposed facilities to utilize compressed air pneumatics.
8. Operator will upgrade the proposed facilities to utilize to a pressurized maintenance vessel system which minimizes the need for venting during maintenance operations.
9. Operator will upgrade the proposed facilities to be energized with utility power reducing odors associated with internal combustion engines. |
| Drilling/Completion Operations | Form: (02A )
403649068
10/11/2024 | 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.
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 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 flow back will be routed to a gas sales pipeline or combusted with a minimum of 98% destruction efficiency.
Any fluids encountered during flow back will be sent to the facility for processing until it is transferred via pipeline for disposal (e.g., water) or sale (e.g., oil).9.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.
Crestone will transport fresh water to the location with lay-flat pipeline. Reducing the amount of truck traffic during completion operations. |
| Interim Reclamation | Form: (02A )
403649068
10/11/2024 | Stockpile Management: Topsoil will be stockpiled along the eastern edge of the proposed pad. In order to mitigate topsoil loss and migration of soil offsite, 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. The stockpile will be regularly monitored for noxious weed growth. Re-seeding will occur as necessary, over the course of active construction in order to achieve widespread uniform vegetative cover.
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 will be monitored and re-applied as necessary, until vegetative growth is established. |