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HomeMy WebLinkAbout1.13 COGCC Form 2BCPX Piceance Holdings, LLC 34 S. Wynden Drive, Suite 240 Limited Impact Review Garfield County, Colorado Houston, TX 77056 TPR Well Pad 36A Article 9 Oil and Gas Permit Application Appendix O: COGCC Form 2B State of Colorado Oil and Gas Conservation Commission 1120 Lincoln Street, Suite 801, Denver, Colorado 80203 Phone: (303) 894-2100 Fax: (303) 894 -2109 CUMULATIVE IMPACTS DATA IDENTIFICATION FORM 2B Rev 03/21 Document Number: Date Received: 403218178 Per Rule 303, this form and all required components and attachments will be submitted for any Oil and Gas Development Plan. OGCC Operator Number: City: Name of Operator: Address: 10639 CPX PICEANCE HOLDINGS LLC 34 S WYNDEN DR STE 240 HOUSTON Zip:State:77056 TX Phone: Name: Contact Name and Telephone: Nicholas Kurtenbach (713) 554-9031 Email:nick@cpxpiceance.com OPERATOR INFORMATION Oil & Gas Development Plan Name:TPR Pad 36A OGDP This OGDP is included in a Comprehensive Area Plan. CAP ID #: OIL & GAS DEVELOPMENT PLAN INFORMATION Oil & Gas Development Plan ID #: OGDP ID Number 482255 Oil & Gas Development Plan Docket #: Docket Number 220300066 OGDPXForm Type:Partial 2B - Rule 803.b.(2).A UIC Conversion OIL & GAS LOCATION DATA OIL & GAS LOCATION INFORMATION Oil & Gas Location Name:1 Number:Status:Active, builtTPR Well Pad 36A Provide a qualitative evaluation of the incremental adverse noise impacts to the surrounding receptors during the pre-production activities at this Oil & Gas Location. There are no residential building units within 2,000', or within 1 mile, of the Oil and Gas Location. The existing well pad is constructed. Noise from drilling and completions is not expected to be perceptible because of the significant distance to the nearest RBU and densely forested vegetation between the well pad and RBU. The Oil and Gas Location is not within high priority habitat except for aquatic habitat. Mapped elk habitat is greater than 1 mile east. It is separated from the location by a ridgeline and a drop of approximately 400' into the next drainage. Noise is not expected to affect wildlife because of the significant distance, intervening topography, and dense vegetation. Noise Impacts Loc ID#:334460 Total number of wells planned:32 Oil & Gas Location:QTRQTR:SWNE Sec:36 Twp:7S Rng:94W Meridian:6 Form 2A Doc#:403218159 Operations Duration Estimated total number of weeks to construct this Oil & Gas Location:4 Estimated total number of weeks to drill all planned wells for this Oil & Gas Location:32 Number of planned drilling occupations to drill all planned wells for this Oil & Gas Location:1 Estimated total number of weeks to complete all planned wells for this Oil & Gas Location:32 Estimated total number of months the Oil & Gas Location will be active, prior to abandonment and reclamation:360 Will there be simultaneous drilling and completions operations occurring at this Oil & Gas Location?Yes Number of planned completions occupations to complete all planned wells for this Oil & Gas Location:1 Page 1 of 11Date Run: 12/23/2022 Doc [#403218178] Provide a qualitative evaluation of the incremental adverse noise impacts to the surrounding receptors during the production stage of this Oil & Gas Location. During production, the location will contain the existing well pad, operating wells, separators, and storage tanks. Maintenance will be performed by an operator in a light-duty pickup truck. There will be no adverse incremental noise impacts during production to the nearest RBU or mapped elk habitat, which are greater than 1 mile away. Provide a qualitative evaluation of the incremental adverse light impacts to the surrounding receptors during the pre-production activities at this Oil & Gas Location. There are no RBUs within 2,000', or within 1 mile, of the Oil and Gas Location. The nearest RBU is separated from the location by densely forested vegetation. Light used on the well pad will be cast downward during drilling and completions. Light is not expected to be perceptible because of the significant distance to the RBU and screening from the intervening more than 1 mile of forest. The Oil and Gas Location is not within HPH except for aquatic habitat. Mapped elk habitat is greater than 1 mile east. It is separated from the location by a ridgeline and a drop of approximately 400' into the next drainage. Light is not expected to be perceptible to wildlife resources because of the distance, intervening topography, and screening from vegetation. Provide a qualitative evaluation of the incremental adverse light impacts to the surrounding receptors during the production stage of this Oil & Gas Location. The location will be unlit during production. Light Impacts Provide a qualitative evaluation of the incremental adverse odor impacts to the surrounding receptors during the pre-production activities at this Oil & Gas Location. There are no RBUs within 2,000', or within 1 mile, of the Oil and Gas Location. CPX proposes to use a water-based drilling mud. Odor is not expected to be perceptible because of the significant distance to the nearest RBU and low VOCs associated with the water-based mud. Provide a qualitative evaluation of the incremental adverse odor impacts to the surrounding receptors during the production stage of this Oil & Gas Location. Production will consist of natural gas wells, enclosed tanks, and associated equipment. Odor is not expected to be perceptible to the nearest RBU, which is greater than 1 mile away. Odor Impacts This Oil & Gas Location is listed as a sensitive area for water resources. 60 WATER RESOURCES X X This Oil & Gas Location is within 2,640 feet of a surface Water of the State. Estimated depth to groundwater: Estimated total planned on-location storage capacity of the Oil & Gas Location for: Oil 0 Number of Tanks Total Volume (bbls) 0 Condensate 2 800 Produced Water 2 1500 Other volumes of stored fluids, hydrocarbons, chemicals, or E&P Waste Fluids 8 96 List, with volumes, the “Other” fluids planned to be stored on the Oil & Gas Location, including, but not limited to: hydrocarbons, chemicals, or E&P Waste fluids. 8 x 12-bbl chemical storage tanks for injection pumps Potential Impacted Surface Water Resources Provide the distance and direction of the contaminant migration pathway from the Oil & Gas Location to the nearest downstream riparian corridors, wetlands, and surface Waters of the State. Also provide an evaluation of the baseline condition of the nearest downstream riparian corridors, wetlands, and surface Waters of the State. Enter 2,640 for distances greater than 1/2-mile. Distances are measured along the migration pathway, not a straight line from the edge of the Oil & Gas Location. Distance Evaluation of Baseline ConditionDirection Page 2 of 11Date Run: 12/23/2022 Doc [#403218178] Riparian Corridor 130 Surveyed perennial stream Wetland 190 Mapped NWI forested/shrub wetland Surface Waters of the State 130 Surveyed perennial stream W NW W Potential Impacts to Public Water Resources Provide the distance, direction, and evaluation of potential impacts to the nearest Public Water System Intake. Enter 5,280 for distances greater than 1-mile. Public Water System Intake 5280 NE None Distance Direction Evaluation of Baseline Condition Estimated Water Usage Provide the estimated total volumes of the following that are anticipated to be used during the drilling and completions stage of the Oil & Gas Location activity. Water Source Surface Water 55250 Volume (bbls) Ground Water 0 Recycled Water (Produced Water)160000 0 Volume (bbls) Recycled Water (non-Produced Water) 0 Volume (bbls) 0 165525 0 Unspecified Source Total Water Usage Percentage Recycled Water 97 % If an unspecified water source is planned to be used, provide a description of the source. Evaluate the measures being taken to reduce freshwater use, including reusing and recycling produced water. Freshwater will be limited to approximately 3% of water needs by using predominantly recycled produced water sourced from a third-party operator. ECOSYSTEM & WILDLIFE RESOURCES List High Priority Habitats (HPH) that occur within one mile of the Oil & Gas Location and list the distance from working pad surface. If the location is partially or entirely within a HPH list the distance as ‘0’ and provide the estimated acreage disturbance of that HPH by the location construction. High Priority Habitat (HPH) Name:Distance Estimated Acreage Disturbed Rule 1202.c.(1).R Cutthroat Trout Habitat 0 5.45 List total size of disturbed acreage and disturbed High Priority Habitat (HPH) area (in acres) during the Oil & Gas Location construction and after interim reclamation. Post-interim Reclamation Construction 1.34 5.45 Total Acreage (acres) 1.34 5.45 Total HPH Acreage (acres) Provide any further information regarding the location’s HPH disturbance. CPX obtained a Rule 309.e.(5).D.i written waiver and Rule 309.e.(5).E variance recommendation from Colorado Parks & Wildlife on June 18, 2021 for the location in mapped aquatic high priority habitat under Rule 1202.c.(1).R. CPW renewed the waiver and variance recommendation on July 13, 2022. Provide the acreage of the existing land use types that occur within one mile of the Oil & Gas Location. Note: a circle with a one mile radius is approximately 2010 acres. Existing Acreage Crop Land: Non-Crop Land: Subdivided: Irrigated Rangeland Industrial 600 Existing Acreage Non-Irrigated Forestry Commercial Existing Acreage Conservation Reserve Program(CRP) Recreation Residential 1410 Existing Acreage Other If any land use is industrial, provide a description of the use or operation of the industrial facilities. If any land use is “Other”, provide a description of the land use. Oil and gas exploration and production If any portion of the land use for the proposed oil and gas location includes Rangeland, Forestry, or Recreation, provide a list of the plant community or communities and estimated acreage disturbed for each: Page 3 of 11Date Run: 12/23/2022 Doc [#403218178] Estimated Disturbed Acreage Disturbed Grassland Native Grassland Estimated Disturbed Acreage Shrub Land Plains Riparian 0 Estimated Disturbed Acreage Mountain Riparian Forest Land Estimated Disturbed Acreage Wetland Aquatic Alpine Provide a qualitative evaluation of incremental adverse impacts to ecosystems, including any plant communities, as a result of Oil and Gas Operations associated with the proposed Oil & Gas Location. The Oil and Gas Location was previously constructed in 2008. Plant communities and the acreage was disturbed at that time. There will be no additional plant communities disturbed for use of the existing location. Soil Resources List all soil map units that occur within the Oil & Gas Location and list the estimated total area (in acres) disturbance of each soil map unit. NRCS Map Unit Name: Estimated Disturbed Acreage 104A: Haplocryolis-Cryaquolls 5.01 331C: Woodrock-Angostura 0.44 PUBLIC WELFARE This Oil & Gas Location lies within a Disproportionately Impacted Community as defined in the 100-series rules. Building Units within 1-mile Total number of ResidentialBuilding Units:0 0'-2,000'2,001'-5,280' 0 Total Number of non-school AND non child care center High Occupancy Building Units:0 0 Total number of School Facilities:0 0 Total number of Child Care Centers:0 0 List all State Parks, State Trust Lands, or State Wildlife Area within 1-mile of the Oil & Gas Location. None List all Designated Outdoor Activity Areas within 1-mile of the Oil & Gas Location. None List all mapped trails that support any of the following recreational activities within 1-mile of the Oil & Gas Location: Hiking, Biking, Horseback Riding, Motorcycle Riding, ATV Riding, OHV, Nordic Skiing, Snowmobiling, or Snowshoeing. Battlement Trail Recreation and Scenic Value AIR RESOURCES Pre-Production Emissions Complete the following chart based on the estimated total equipment emissions (in tons) for the Oil & Gas Location during the pre- production (construction, drilling, completions) stage for Criteria Pollutants by equipment type. NOx CO VOCs Methane Ethane CO2 N2O Process Heaters or Boilers 0.71 0.6 0.04 0.02 0.02 852.71 0.02 Storage Tanks 0.32 0.08 1.07 0.91 0.27 328.21 0 Venting or Blowdowns 0 0 0 0 0 0 0 Combustion Control Devices 0.31 0.08 0.26 1.39 0.25 267.91 0 Non-Road Internal Combustion Engines 353.85 92.35 11.14 0.82 0 16832.8 8 0.14 Drill Mud 0 0 0.02 0 0 0 0 Flowback or Completions 0.06 0.01 0.05 0.27 0.05 51.3 0 Loadout 0 0 0 0 0 0 0 Production Emissions Complete the following chart based on the estimated full facility equipment emissions (in tons) for the Oil & Gas Location once the Oil & Page 4 of 11Date Run: 12/23/2022 Doc [#403218178] Gas Location has entered the production stage, for Criteria Pollutants. The table should be filled out based on ONE year of operation. NOx CO VOCs Methane Ethane CO2 N2O Stationary Engines or Turbines 4.13 6.95 0.06 0.43 0.13 205.54 0 Process Heaters or Boilers 3.73 3.13 0.21 0.09 0.12 4476.71 0.08 Storage Tanks 1.11 0.28 12.3 3.12 3.23 1155.28 0 Dehydration Units 0 0 0 0 0 0 0 Pneumatic Pumps 0 0 0 0 0 0 0 Pneumatic Controllers 0 0 0 0 0 0 0 Separators 0 0 0 0 0 0 0 Fugitives 0.01 0.06 0.01 0 Venting or Blowdowns 0 0 0 0 0 0 0 Combustion Control Devices 0.01 0.03 0.01 0.06 0.01 11.42 0 Loadout 0 0 0 0 0 0 0 Non-Road Internal Combustion Engines 0 0 0 0 0 0 0 Well Bradenhead 0.37 0.75 0.33 1.72 0.31 0.15 0 Well Maintenance 0.11 0.22 0.1 0.51 0.09 0.04 0 Diesel Vehicle Road Miles Complete the following chart for diesel vehicle road miles during each stage of oil and gas location operations. During Construction:2520 During Drilling:97031 During Completions:82497 During Interim Reclamation:504 During Production:49841 PUBLIC HEALTH RESOURCES Pre-Production Emissions Complete the following chart based on the estimated total equipment emissions (in lbs) for the Oil & Gas Location during the pre-production (construction, drilling, completions) stage for Hazardous Air Pollutants (HAP). BEN TOL ETH XYL NHE TMP H2S FDE MET HAP Process Heaters or Boilers 0.03 0.05 0 0 25.58 0 0 1.07 0 26.73 Storage Tanks 302.11 584.64 30.01 300.4 2 2642.6 7 236.56 0 0 0 4096.4 Venting or Blowdowns 0 0 0 0 0 0 0 0 0 0 Combustion Control Devices 3.1 4.8 0.07 0.68 12.13 0 0 0 0 20.77 Non-Road Internal Combustion Engines 169.03 62.41 0 42.93 0 0 0 35.47 0 309.83 Drill Mud 0.97 0.01 0 0.08 1.27 0 0 0 21.75 24.09 Flowback or Completions 0.59 0.92 0.01 0.13 2.32 0 0 0 0 3.98 Loadout 0.01 0 0 0 0.01 0 0 0 0.18 0.2 Production Emissions Complete the following chart based on the estimated total equipment emissions (in lbs) for the Oil & Gas Location once the Oil & Gas Location has entered the production stage, for Hazardous Air Pollutants (HAP). The table should be filled out based on ONE year of operation. BEN TOL ETH XYL NHE TMP H2S FDE MET HAP Stationary Engines or Turbines 5.9 2.09 0.09 0.73 0 0 0 76.61 0 121.15 Process Heaters or Boilers 0.16 0.25 0 0 134.3 0 0 5.6 0 0.14 Storage Tanks 143.13 185.17 7.56 32.78 1634.8 2 27.71 0 0 0 2031.1 8 Dehydration Units 0 0 0 0 0 0 0 0 0 0 Pneumatic Pumps 0 0 0 0 0 0 0 0 0 0 Pneumatic Controllers 0 0 0 0 0 0 0 0 0 0 Separators 0 0 0 0 0 0 0 0 0 0 Page 5 of 11Date Run: 12/23/2022 Doc [#403218178] Fugitives 0.13 0.19 0 0.03 0.49 0 0 0 0 0.84 Venting or Blowdowns 0.01 0.01 0 0 0.02 0 0 0 0 0.04 Combustion Control Devices 0.13 0.2 0 0.03 0.52 0 0 0 0 0.88 Non-Road Internal Combustion Engines 0 0 0 0 0 0 0 0 0 0 Loadout 0 0 0 0 0 0 0 0 0 0 Well Bradenhead 3.84 5.93 0.08 0.84 15 0 0 0 0 25.7 Well Maintenance 1.15 1.78 0.02 0.25 4.5 0 0 0 0 7.7 Provide a qualitative evaluation of any potential acute or chronic, short- or long-term incremental impacts to public health as a result of the estimated total pre-production hazardous air pollutant emissions. There will be no anticipated acute or chronic, short- or long-term incremental impacts to public health because of the closed loop drilling system without pits or ponds and the significant distance to the nearest residential building unit, which is greater than 1 mile away. Provide a qualitative evaluation of any potential acute or chronic, short- or long-term incremental impacts to public health as a result of the estimated annual production hazardous air pollutant emissions. There will be no anticipated acute or chronic, short- or long-term incremental impacts to public health because of the enclosed tanks, vapor controls, compliance with Colorado Department of Public Health and Environment permit requirements, and the significant distance to the nearest residential building unit, which is greater than 1 mile away. Dust Impacts The following are the estimated number of truck trips traveling on or off the Oil & Gas Location. Monthly Annual 140 140 During Construction During Drilling During Completions 24 245050 630 372 2966 During Interim Reclamation During Production 115 1380 Estimated total pounds (lbs) of proppant to be used during completions activities. Provide the type of proppant(s) that are planned to be used during completions activities. 100 mesh sand proppant Proppant will be trucked to the Oil and Gas Location using pre-pneumatic dry bulk trailers. At the location, proppant will be transferred to sand storage silos pneumatically using a hose and air blower to a blender bulk hopper and gravity fed chute with a vacuum system that captures fugitive dust in canisters. Dust will be contained during this transfer process. Silica dust will not leave the location. The silos will have secondary containment to capture an inadvertent spill during transfer of material. Secondary containment will consist of a rubber or plastic liner with 8" supported sides. Provide an evaluation of the proposed proppant management system that will be used to minimize dust during completions activities, including the estimated amount of silica dust that will leave the Oil & Gas Location. 846000 Total EXISTING OIL & GAS Total number of oil & gas locations within 1-mile of the Oil & Gas Location: Active, built 1 Total Number of Locations Permitted by COGCC, unbuilt 1 Permitted by Relevant Local Government & not COGCC, unbuilt 0 Proposed 0 Total acreage disturbance during construction of the active and proposed oil & gas locations within 1-mile of the proposed Oil & Gas Location:9.6 Field Observation/Measurement Source for acreage total: X COGCC Location Files Aerial PhotosOther Other If “Other” is selected, please describe the source use to determine the acreage total for construction disturbance of the active and proposed oil & gas locations within 1-mile of the proposed Oil & Gas Location. Active, built 2 Total Number of Wells Permitted by COGCC, unbuilt 0 Proposed 34 Plugged and Abandoned 0 Page 6 of 11Date Run: 12/23/2022 Doc [#403218178] Equipment and Facility Removal Total number of existing wells that are planned to be plugged and abandoned as part of this OGDP: Total number of tanks planned to be removed from existing locations through the approval of this OGDP: Oil Tanks:0 Condensate Tanks:0 Produced Water Tanks:0 Total number of existing locations that are planned to be closed and undergo final reclamation as part of this OGDP: 1 Total number of acres that are planned to be reclaimed through the closing of existing locations:0 reclamation as part of this OGDP: Total number of existing pits that are planned to be closed and undergo final 0 0 BENEFICIAL IMPACT INFORMATION List High Priority Habitats (HPH) that are estimated be disturbed by the construction of new roads, including access roads, pipelines, and utilities for this OGDP, along with the estimated disturbed acreage of each HPH. Construction New roads, including access roads Provide any further information regarding the HPH disturbance from the construction of new roads, including access roads, pipelines, and utilities for this OGDP. Number of miles of the existing lease road that are planned to be used to access these location(s): 0 A flowline corridor between Well Pad 36A and approved Well Pad 25A (Facility ID 334457) was previously quantified in the TPR Pad 25A OGDP (#482255). It will be constructed along the existing access road and in portions of the roadway. The Well Pad 36A location and access road are already constructed with no new proposed disturbance. High Priority Habitat (HPH) Name Estimated Acreage Disturbed Rule 1202.c.(1).R Cutthroat Trout Designated Habitat 0 List the total estimated of disturbed acreage and the total disturbed High Priority Habitat (HPH) area (in acres) during construction and the acreage that will remain disturbed after interim reclamation of the following for the entire OGDP: Post-interim Reclamation Total Acreage (acres) Total HPH Acreage (acres) Total Acreage (acres) Total HPH Acreage (acres) 0 Pipelines 0 0 Utilities 0 0 New roads, including access roads 0 0 Pipelines 0 0 Utilities 0 0 1.5 OIL & GAS DEVELOPMENT PLAN-SCALE DATA Total permitted capacity of on-location storage (in number of pits and tanks) of the active and proposed oil & gas locations within 1-mile of the Oil & Gas Location : NOTE: providing the existing number of pits and tanks on surrounding existing locations is optional. Oil 0 Permitted Onsite Storage Capacity Condensate 1 Produced Water 19 Pits 0 0 Existing Onsite Storage Capacity 1 1 0 Field Observation/Measurement Source for storage totals: X COGCC Location Files Aerial PhotosOther If “Other” is selected, please describe the source use to determine the tank totals for the active and proposed oil & gas locations within 1- mile of the proposed Oil & Gas Location. Other Page 7 of 11Date Run: 12/23/2022 Doc [#403218178] Provide a qualitative evaluation of any incremental beneficial impacts to the surrounding community directly and indirectly from this OGDP. 0basis): Estimated number of vehicle trips that are planned to be prevented from the above mentioned facility closures and equipment upgrades (on an annual Natural gas development on Tepee Park Ranch provides benefits to local economies in western Colorado from: 1. Wages paid to local employees of CPX Piceance Holdings, LLC. 2. Fees paid to local contractors and vendors for goods, services, and labor. 3. Capital expenditures paid to local businesses for materials and equipment. 4. Property and sales tax revenues to local governments. Provide a qualitative evaluation of any incremental beneficial impacts to the surrounding wildlife and ecosystems directly and indirectly from this OGDP. CPX's operating design incorporates the following environmental benefits: 1. Reuse of an existing and well-established disturbance and well pad for new natural gas wells. 2. Reuse of existing access roads. 3. Use of recycled produced water from a 3rd party operator to minimize use of freshwater for well drilling. 4. Disposal of produced water using a UIC well on Tepee Park Ranch to minimize truck traffic. MITIGATION INFORMATION Item Impacted Resource Mitigation Description 1 Air Resources • Use the existing Well Pad 36A to avoid new surface disturbance. • Use a closed-loop drilling system to minimize emissions. • Contain flowback and produced water in enclosed tanks. Vapors will be controlled using an enclosed combustor. • Implement a leak detection and repair (LDAR) program using audio, visual, and olfactory (AVO) monitoring for leak and spill detection. • Maintain and periodically test tank seals to ensure that they provide the required back pressure and prevent emissions. • Use automated tank gauges to gauge liquids without opening the thief hatch. • Commit to connecting to a gas gathering system after well drilling and completions. • Require that employees and contractors observe posted speed limits on public roads and a 25 mile per hour speed limit on TPR access roads. • Regularly inspect the access road for evidence of inadequate drainage and formation of potholes. • Grade, blade, and fill potholes to maintain the road surface and discourage vehicles from widening the roadway or contributing to erosion. • Use spot graveling to avoid erosion, formation of silts, and to stabilize surfaces for truck travel. • Use fresh water from an approved water source to wet the surface for control of fugitive dust on the well pad, access road, or pipeline corridor. • Mount the soil stockpile to prevent loose soils and promote vegetative growth. • Haul proppant in closed containers and offload it within secondary containment around the proppant storage silos. • Use existing flowlines and proposed new flowlines to reduce truck traffic for completions and life of operations. • Use a proposed CPX UIC well on Tepee Park Ranch for disposal of produced water and excess flowback generated on TPR to avoid truck trips. • Reclaim the areas not needed to support production in the first growing season and within 6 months after completing well development. Page 8 of 11Date Run: 12/23/2022 Doc [#403218178] 2 Water Resources • Protect surface water using steel secondary containment sized to 150 percent of the size of the largest tank. • Maintain an earthen berm around the perimeter of the well pad with 2-foot-high earthen berms, compacted to 95 percent soil/moisture density. • Capture stormwater on the location using a system consisting of a drain on the well pad, which is piped to a lined trench and lined catchment basin. • Ensure that the drill rig and horsepower equipment have liners to capture and contain drips or leaks. • Provide secondary containment for temporary equipment and materials used during well drilling and completions. • Provide continuous flow and pressure monitoring for temporary frac lines during completions for prompt identification of loss of pressure. • Monitor equipment and transfer lines daily during well drilling and completion for signs of drips, leaks, or spills, which will be corrected promptly. • Use a closed loop solids control system with no reserve pits. • Test tanks per manufacturer’s specifications prior to putting them into service for production. Periodic integrity testing after initial startup will occur per API or STI standards and manufacturer’s recommendations. • Develop wells using a closed-loop drilling system to reduce water use by recycling water in-situ. • Use recycled produced water in lieu of freshwater for completions. • Install a SCADA continuous monitoring platform for remote monitoring, alerting, and shut-in capabilities. • Perform interim reclamation during the first growing season and within 6 months after well development to reclaim disturbed soil. 3 Ecosystem and Wildlife Resources • Contain flowback and stimulation fluids in tanks that are placed on a Working Pad Surface in an area with downgradient perimeter berming. • Construct lined containment devices pursuant to Rule 603.o around any new condensate and produced water storage tanks. There will be no crude oil storage on the well pad. • Maintain adequate spill response equipment on the location during drilling and completion operations. • Maintain the existing earthen berms compacted to 95 percent soil/moisture density during well development. • Maintain a 6-inch drain on the well pad during drilling and completions operations that is piped outside of the berm to a trench and catchment basin. • Divert stormwater on the access road to a borrow ditch on the upslope side with stormwater culverts to avoid long runs of stormwater and slow velocity. • Avoid open liquids storage on the locations during pre-production and production. • Keep the location unlit during production. • Consolidate and centralize fluid collection and distribution facilities to minimize impacts to wildlife. • Install screening or other devices on the stacks and on other openings of the heated separator to prevent entry by migratory birds. • Downsize the location during interim reclamation to a 1.34-acre Production Pad. • Reclaim the remaining portion of the Oil and Gas Location to pre-construction habitat. • Cross rip the reclaimed area to decompact the soil and establish a seedbed. Seed the area using a U.S. Forest Service-recommended seed mix, which is appropriate to the site’s plant community. • Use a proposed CPX UIC well for disposal of produced water and flowback generated on TPR to avoid truck trips. 4 Soil Resources • Protect topsoil from contamination by stockpiling it in a location free from drilling, fuel storage, and parking. • Protect soil from compaction by designating it as topsoil for reclamation. • Protect the topsoil stockpile from wind degradation by mounding to prevent loose soils while promoting continued microbial activity. • Protect the topsoil stockpile from erosion by ensuring that stormwater controls and diversions are installed, where needed, to divert stormwater away from the stockpile. • Allow vegetation to establish on the topsoil stockpile to stabilize it, outcompete weeds, and promote soil microbial activity. • Maintain erosion controls to prevent stormwater runoff from the well pad. • Use the existing 5.45-acre Oil and Gas Location, Tepee Park Ranch Road, and 0.14- acre access road from the Tepee Park Ranch Road. • Conduct interim reclamation during the first favorable growing season and within 6 months after well drilling is complete. Page 9 of 11Date Run: 12/23/2022 Doc [#403218178] Nick Kurtenbach Title:Print Name: Email:Date:nick@cpxpiceance.com Principal Based on the information provided herein, this Cumulative Impacts Data Identification Form 2B complies with COGCC Rules and is hereby accepted into the Cumulative Impacts Data Evaluation Repository (CIDER database). Contact OGLA Staff for consultation. COGCC Approved:Director of COGCC Date: OPERATOR COMMENTS AND SUBMITTAL This OGDP has been prepared as an amendment to CPX's approved OGDP (ID 482255) on TPR. CPX proposes the continued development of the existing Well Pad 36A on Tepee Park Ranch (TPR). TPR is privately owned and operated by CPX, predominantly for the exploration and development of natural gas. Well Pad 36A was constructed in 2008. It will not be expanded. Soil disturbance is complete. The location has three permitted wells. One is designated spud but uncompleted (DG). Two are designated expired permit (EP). CPX proposes to develop a total of 32 natural gas wells on the location in CPX fee minerals and federal minerals and to plug and abandon the spud but uncompleted well. Based on the location's proximity to Rule 1202.c.(1).R high priority habitat and surface water, CPX conducted an Alternative Location Analysis and consultation with Colorado Parks & Wildlife. CPX received a waiver and variance recommendation from CPW on June 18, 2021 on the basis that the location is established and stable, has a multi-layer system of spill, stormwater, and erosion controls, and CPW incentivizes the continued use pf already disturbed locations when no adverse impacts are anticipated. CPW stated that construction of an alternative location would cause undesired habitat fragmentation and pose more risk to HPH and the watershed. CPW renewed the waiver and variance recommendation on July 13, 2022. Well Pad 36A design also will avoid or minimize adverse impacts by using recycled produced water for 97% of water use. Produced water will be disposed of using CPX's proposed Class 2 underground injection control well to avoid truck traffic for hauling produced water. Takeaway capacity was previously developed on TPR with buried flowlines to transport natural gas and condensate to CPX's off-location Pad 2 Tanks and further avoid truck truck trips. 5 Public Welfare • Maintain equipment and vehicles in proper working condition to minimize noise. • Cast lights downward on the operations during well drilling and completions. • Water the well pad and access when indicated by loose soils to stabilize the soil and form a crust. • Reclaim the areas not needed to support production during the first growing season and within 6 months of completing well development. • Comply with the noise levels specified in Rule 423.b.(1). • Reduce truck traffic by using CPX's proposed UIC well and buried flowlines. • Paint tanks to blend with the surrounding landscape. Page 10 of 11Date Run: 12/23/2022 Doc [#403218178] User Group Comment Comment Date Stamp Upon Approval Total: 0 comment(s) General Comments Attachment Check List Att Doc Num Name Total Attach: 0 Files Page 11 of 11Date Run: 12/23/2022 Doc [#403218178]