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HomeMy WebLinkAbout1.00 General Application Materials_PartLPage 3 of 10 another river, intermittent or perennial stream, lake, pond, or wetland and discard rinse water in an approved disposal facility. Disinfection practices will be repeated prior to completing work and before moving to the next water body. During operations associated with the development of the proposed Oil and Gas Location, freshwater trucks used to support construction, drilling, completion, and production operations will be cleaned by spraying and soaking the tank cavity and all suction hoses with water greater than 140° Fahrenheit for at least ten (10) minutes when the tank and/or hoses have been used previously in another river, intermittent or perennial stream, lake, pond, or wetland. During drilling operations TEP will only utilize trucks assigned directly to the rig. All suction hoses associated with the water source will remain in place throughout the duration of drilling operations. Any hoses switched out will be cleaned using the same guidelines mentioned above. 3. At new and existing Oil and Gas Locations, Operators will not situate new staging, refueling, or chemical storage areas within 500 feet of the Ordinary High Water Mark (“OHWM”) of any river, perennial or intermittent stream, lake, pond, or wetland. TEP will ensure that all staging, refueling, or chemical storage areas are more than 500 feet from the OHWM of any river, perennial or intermittent stream, lake, pond, or wetland. 4. To prevent access by wildlife, including birds and bats, Operators will fence and net or install other CPW-approved exclusion devices on new drilling pits, production pits, and other pits associated with Oil and Gas Operations that are intended to contain fluids. There are no drilling pits, production pits, or other pits associated with planned operations on this oil and gas location. 5. For trenches that are left open for more than 5 consecutive days during construction of pipelines regulated pursuant to the Commission’s 1100 Series Rules, Operators will install wildlife escape ramps at a minimum of one ramp per ¼ mile of trench. TEP will install wildlife escape ramps at a minimum of one ramp per ¼ mile of trench if any trench is left open for more than 5 consecutive days as required by COGCC regulations. 6. When conducting interim and final reclamation pursuant to Rules 1003 and 1004, Operators will use CPW-recommended seed mixes for reclamation when consistent with the Surface Owner’s approval and any local soil conservation district requirements. TEP will ensure a CPW recommended seed mix is used for interim and final reclamation when approved by the surface owner. 7. Operators will use CPW-recommended fence designs when consistent with the Surface Owner’s approval and any Relevant Local Government requirements. TEP is not planning to install a perimeter fence at this oil and gas location. However, if fencing is required to prohibit cattle grazing and establish a successful reclamation, TEP will utilize a CPW recommended fence design. Page 4 of 10 8. Operators will conduct all vegetation removal necessary for Oil and Gas Operations outside of the nesting season for migratory birds (April 1 to August 31). For any vegetation removal that must be scheduled between April 1 to August 31, Operators may implement appropriate hazing or other exclusion measures prior to April 1 to avoid take of migratory birds. If hazing or other exclusion measures are not implemented, Operators will conduct pre- construction nesting migratory bird surveys within the approved disturbance area prior to any vegetation removal during the nesting season. If active nests are located, Operators will provide work zone buffers around active nests. As mentioned in the Plan of Development, TEP has tentatively scheduled construction of the South Leverich 13-09 pad during November of 2022, which is outside the nesting season for migratory birds described above. However, if the timing of construction operations changes and are scheduled to occur during the nesting season, TEP will either implement hazing prior to April 1, or a pre-construction migratory bird survey will be conducted during the nesting season to determine if nesting migratory birds are present within the project area. If any active nests are located, TEP will provide work zone buffers around those active nests as allowed under Rule 1202.a.(8). 9. Operators will treat drilling pits, production pits, and any other pit associated with Oil and Gas Operations containing water that provides a medium for breeding mosquitoes with Bti (Bacillus thuringiensis v. israelensis) or take other effective action to control mosquito larvae that may spread West Nile virus to wildlife resources. Such treatment will be conducted in a manner which will not adversely affect aquatic wildlife resources. There are no drilling pits, production pits, or any other pits planned for construction on this oil and gas location. 10. Operators will employ the following minimum Best Management Practices on new Oil and Gas Locations with a working pad surface located between 500 feet and 1000 feet hydraulically upgradient from a High Priority Habitat identified in Rule 1202.c.(1).Q–S: a. Contain Flowback and Stimulation Fluids in Tanks that are placed on a Working Pad Surface in an area with downgradient perimeter berming. The South Leverich 13-09 pad will include construction of a perimeter berm around the entire working pad surface of the oil and gas location. Additionally, a drive over berm will be constructed at the entrance to the oil and gas location. Flowback and Stimulation Fluid storage tanks will be located on pad inside the pad perimeter berm. b. Construct lined berms or other lined containment devices pursuant to Rule 603.o around any new crude oil, condensate, and produced water storage Tanks that are installed after January 15, 2021. All proposed produced water tanks and condensate tanks on the South Leverich 13-09 pad will be located within a secondary containment structure designed to meet the requirements of Rule 603.o. c. Inspect the Oil and Location on a daily basis, unless the approved Form 2A provides for different inspection frequency or alternative method of compliance. Page 5 of 10 TEP is requesting a modified inspection frequency for this oil and gas location. Inspection at this location will occur daily for the first 6 – 9 months of production operations. Inspection frequency will then drop to once per week (minimum) for the remaining life of the wells. The oil and gas location will be equipped with Supervisory Control and Data Acquisition (SCADA) monitoring technology which enables remote monitoring of individual wells, produced water / condensate tanks, and other production facilities on the oil and gas location. Please see the Fluid Leak Detection Plan attached to the Form 2A for additional details on continuous monitoring. d. Maintain adequate Spill response equipment at the Oil and Gas Location during drilling and completion operations. Spill response equipment will be provided on site during drilling and completion operations. Additional spill response equipment will be staged at a nearby location that can be accessed quickly as needed during drilling and completion operations as well as during long-term production operations. e. Not construct or utilize any Pits, except that Operators may continue to utilize existing Pits that were properly permitted, constructed, operated, and maintained in compliance prior to January 15, 2021. There are no drilling pits, production pits, or any other pits planned for construction on this oil and gas location. Rule 1202.b.: As stated in Rule 1202.b, “operators will bore, rather than trench, flowline and utility crossings of perennial streams identified as aquatic High Priority Habitat unless the Operator obtains a signed waiver from CPW and the Director or Commission approves a Form 4 or Form 2A documenting the relief. When installing culverts or bridges, such structures will not impact or prevent the passage of fish unless otherwise directed by CPW.” The proposed natural gas gathering pipeline and produced water pipeline will not cross perennial streams; therefore, the proposed project complies with Rule 1202.b. Rule 1202.c.: As stated in Rule 1202.c., “Except as specified pursuant to Rule 1202.c.(2), Operators will not conduct any new ground disturbance and Well work, including access road and pad construction, drilling and completion activities, and Flowline/utility corridor clearing and installation activities in the High Priority Habitats listed in Rule 1202.c.(1).” New ground disturbance activities for the South Leverich 13-09 OGDP will be limited to reconstruction and expansion of the South Leverich 13-09 pad, installation of the proposed natural gas pipeline, and installation of the proposed produced water pipeline. South Leverich 13-09 Pad: The South Leverich 13-09 pad is not located within High Priority Habitat listed under Rule 1202.c.(1) and therefore complies with Rule 1202.c. Proposed Natural Gas Pipeline: New disturbance associated with construction and installation of the proposed natural gas pipeline will not be located within High Priority Habitat listed under Rule 1202.c.(1) and therefore complies with Rule 1202.c. Proposed Produced Water Pipeline: New disturbance associated with construction and installation of the proposed produced water pipeline will not be located within High Priority Habitat listed under Rule 1202.c.(1) and therefore complies with Rule 1202.c. Page 6 of 10 CPW CONSULTATION TEP conducted two (2) pre-application consultation meetings with Colorado Parks and Wildlife (“CPW”) to discuss the proposed development plan for the South Leverich 13-09 pad and the potential impacts to wildlife as a result of construction and operations of the proposed facility. The South Leverich 13-09 pad and associated permanent pipelines are not located within High Priority Habitat. However, based on the proximity of the oil and gas location to High Priority Habitat, TEP held a pre-application consultation meeting with CPW to discuss potential impacts associated with the facility and the existing access road. The first pre-application consultation meeting occurred on April 28, 2021, and was held at the South Leverich 13-09 pad. This meeting was the initial site review meeting by CPW, which provided CPW with the opportunity to review the staked oil and gas location and associated pipeline corridors and provide initial feedback on the development plan. The second pre-application consultation meeting occurred on June 23, 2022. During this meeting TEP provided updates to the proposed development plan, reviewed the draft Wildlife Protection Plan, discussed potential impacts to sensitive wildlife in the area, reviewed proposed best management practices, and discussed any necessary waivers needed for planned operations. Please see Appendix A, Colorado Parks and Wildlife Pre-application Consultation, for a detailed summary of CPW consultation. CPW Waivers During pre-application consultation, TEP requested a waiver to the “daily” inspection frequency best management practice under COGCC Rule 1202.a.(10).C., which is required for “Oil and Gas Locations with a Working Pad Surface located between 500 feet and 1000 feet hydraulically upgradient from a High Priority Habitat identified in Rule 1202.c.(1).Q-S”. Please see Appendix B, South Leverich 13-09 Drill Pad Colorado Parks and Wildlife Correspondence June 30, 2022, for CPW’s approval of this waiver request. WILDLIFE BEST MANAGEMENT PRACTICES The following wildlife Best Management Practices will be employed by TEP during development of the South Leverich 13-09 pad: 1. TEP will inform and educate all employees and contractors on wildlife conservation practices, including no harassment or feeding of wildlife. 2. TEP will install a proposed water pipeline from the Oil and Gas Location to TEP’s existing water management system to minimize truck traffic to the location and minimize the potential impacts to wildlife. 3. TEP will minimize direct impact to wildlife habitat by utilizing existing infrastructure and disturbance corridors whenever possible. 4. Well telemetry equipment will be installed to minimize site visitation through remote monitoring of production operations. 5. Black Bear BMPs: a. Wildlife – Avoidance: The operator agrees to report bear conflicts immediately to CPW staff. b. Wildlife – Avoidance: TEP will install and utilize bear proof dumpsters and trash receptacles for food- related trash at all facilities that generate trash. 6. Raptors BMPs: a. Wildlife – Minimization: Exclusionary devices will be installed to prevent birds and other wildlife from accessing equipment stacks, vents, and openings. b. Wildlife - Avoidance: TEP will conduct vegetation removal activities outside the migratory bird nesting season (April 1 - August 30). If vegetation removal must occur during the Page 7 of 10 nesting season, TEP will implement hazing or other exclusionary measures prior to April 1 to avoid take of migratory birds. Alternatively, TEP may conduct a migratory bird survey prior to vegetation removal as required by COGCC Rule 1202.a.(8) to avoid take of migratory birds. 7. Mule Deer and Elk BMPs: a. Wildlife - Avoidance: The operator agrees to reclaim mule deer and elk habitats with CPW identified native shrubs, grasses, and forbs appropriate to the ecological site disturbed. b. Wildlife - Minimization: To minimize the potential for wildlife related traffic accidents, TEP has implemented speed restrictions for all lease roads and requires that all TEP employees and contractors adhere to these posted speed restrictions. c. Wildlife - Minimization: Certified weed-free native seed in seed mixes, except for non-native plants that benefit wildlife will be used. TEP will use certified, weed free grass hay, straw, hay or other mulch materials used for the reseeding and reclamation of disturbed areas. 8. Cutthroat Trout BMPs: a. Wildlife - Minimization: TEP will utilize fresh water from Beaver Creek if available or potable water from a nearby source for dust suppression within cutthroat trout designated crucial habitat and native fish and other native aquatic species conservation waters. If feasible, dust suppression in proximity to Beaver Creek shall utilize potable water from a nearby source instead of raw water to avoid the spread of disease organisms and aquatic nuisance species. Potable water will be purchased from the City of Rifle Bulk Water Station or another local source of potable water. b. Wildlife - Minimization: TEP will stage a spill response trailer at the RU 31-12V pad adjacent to Beaver Creek, which will have supplies available for immediate response to spills or releases during operations on the oil and gas location. APPENDIX A SOUTH LEVERICH 13-09 DRILL PAD COLORADO PARKS AND WILDLIFE PRE-APPLICATION CONSULTATION CPW CONSULTATION TEP conducted two (2) pre-application consultation meetings with Colorado Parks and Wildlife (“CPW”) to discuss the proposed development plan for the South Leverich 13-09 pad and the potential impacts to wildlife as a result of construction and operations of the proposed facility. The South Leverich 13-09 pad and associated permanent pipelines are not located within High Priority Habitat. However, based on the proximity of the oil and gas location to High Priority Habitat, TEP held a pre-application consultation meeting with CPW to discuss potential impacts associated with the facility and the existing access road. The first pre-application consultation meeting occurred on April 28, 2021 and was held at the South Leverich 13-09 pad. This meeting was the initial site review meeting by CPW, which provided CPW with the opportunity to review the staked oil and gas location and associated pipeline corridors and provide initial feedback on the development plan. The second pre-application consultation meeting occurred on June 23, 2022. During this meeting TEP provided updates to the proposed development plan, reviewed the draft Wildlife Protection Plan, discussed potential impacts to sensitive wildlife in the area, reviewed proposed best management practices, and discussed any necessary waivers needed for planned operations. Pre-application Consultation April 28, 2021 On April 28, 2021, TEP, CPW, and others met onsite to discuss the proposed development plan for the South Leverich 13-09 pad. During the onsite TEP provided an overview of proposed development activities such as pad reconstruction, drilling and completion operations, facility installation (i.e. proposed pipeline), and a preliminary development schedule. Additionally, TEP provided details on potential impacts to wildlife: 1. Proximity to Beaver Creek: Pad location is within 1,000 feet of Beaver Creek, which is identified as Cutthroat Trout Designated Crucial Habitat and Aquatic Native Species Conservation Waters. Rule 1202.a.(10) best management practices will apply. 2. Existing Access Road: Road crosses Beaver Creek. Dust suppression methods will be evaluated. 3. Temporary Surface Frac Lines: Temporary lines will cross through Cutthroat Trout Designated Crucial Habitat. TEP stated that best management practices would be implemented to protect sensitive wildlife species during operations on the oil and gas location and installation and operation of the proposed pipelines. Best management practices would also be implemented to minimize potential impacts to Beaver Creek from vehicular traffic to and from the oil and gas location. BMPs would be further discussed during a pre- application meeting scheduled prior to submittal of the Oil and Gas Development Plan. Pre-application Consultation June 23, 2022 On June 23, 2022, TEP and CPW meet to review the updated proposed development plan, review the draft Wildlife Protection Plan, discuss potential impacts to sensitive wildlife in the area, review proposed best management practices, and discuss any necessary waivers needed for planned operations. Following review of the proposed development plan TEP and CPW reviewed the draft Wildlife Protection Plan and discussed the operating requirements under Rule 1202.a., 1202.b, and 1202.c. TEP stated that all operating requirements listed under 1202.a. will be adhered to during planned activities on the South Leverich 13-09 pad with the exception of Rule 1202.a.(10).C, which requires daily inspection of the oil and gas location if the working pad surface is between 500 feet and 1000 feet of High Priority Habitat listed in Rule 1202.c.(1).Q-S. TEP formally requested a waiver to Rule 1202.a.(10).C, which included a request to modify the inspection frequency. Daily inspection would occur during drilling, completion, and the first 6 – 9 months of production operations, followed by weekly inspection for the remaining life of the wells. TEP would install remote monitoring equipment on the oil and gas location to minimize site visitation, while also monitoring for potential operations issues. TEP has tentatively scheduled construction of the South Leverich 13-09 pad during November of 2022, which is outside the nesting season for migratory birds described above. However, if the timing of construction operations changes and are scheduled to occur during the nesting season, TEP will either implement hazing prior to April 1, or a pre-construction migratory bird survey will be conducted during the nesting season to determine if nesting migratory birds are present within the project area. If any active nests are located, TEP will provide work zone buffers around those active nests as allowed under Rule 1202.a.(8). TEP stated that all proposed permanent natural gas and produced water pipelines would not be installed within High Priority Habitat. Additionally, TEP will be in compliance with Rule 1202.b since there are no planned flowlines or utility crossings of perennial streams identified as aquatic High Priority Habitat. TEP also stated the proposed development plan would be in compliance with Rule 1202.c, as all ground disturbance activities would be located outside of the High Priority Habitats listed under Rule 1202.c.(1). TEP and CPW discussed installation and operation of the proposed temporary surface frac lines, and the best management practices being implemented during installation. The proposed temporary surface frac lines will be installed between the South Leverich 13-09 pad and the Youberg RU 44-7 pad and will be installed following existing pipeline corridors and the access road. The temporary surface frac lines will cross through approximately 1,000 feet of the Cutthroat Trout Designated Crucial Habitat boundary near the existing Youberg RU 44-7 pad. The temporary surface pipeline will be installed within the existing access road right-of-way. No new surface disturbance will occur from installation of the proposed temporary surface frac lines; therefore Rule 1202.c does not apply. However, TEP will implement best management practices such as integrity testing and inspections to minimize the potential for a spill or leak that may impact cutthroat trout habitat downstream of the temporary surface frac lines. TEP and CPW also reviewed the best management practices listed in the draft Wildlife Protection Plan, which includes dust suppression methods along the existing access road within Cutthroat Trout Designated Crucial Habitat. TEP stated that fresh water from Beaver Creek or potable water from a local source will be utilized for dust suppression near Beaver Creek to minimize the potential for introducing undesirable aquatic organisms. TEP and CPW reviewed the topographic map of the area and agreed that potential impacts to elk during development of the South Leverich 13-09 pad is unlikely based on the distance and topography of the area. Elk Production Area and Elk Winter Concentration Area boundaries are topographically isolated by a ridge line southeast and northwest of the oil and gas location. Furthermore, CPW agreed that noise and light impacts from operations at the South Leverich 13-09 pad are unlikely to impact wildlife resources and that a noise mitigation plan would not be necessary for the protection of wildlife. APPENDIX B SOUTH LEVERICH 13-09 DRILL PAD COLORADO PARKS AND WILDLIFE CORRESPONDENCE JUNE 30, 2022 From:Taylor Elm - DNR To:Adam Tankersley Cc:molly.west@state.co.us; Jeff Kirtland; Trevor Burrell Subject:Re: South Leverich 13-09 Pad - Wildlife Protection Plan & Rule 1202.a.(10).C Waiver Request Date:Thursday, June 30, 2022 1:43:52 PM CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Adam, Thank you for the email and detailed information regarding the proposed activities at the South Leverich 13-09 Pad. I have reviewed the information within the Wildlife Protection Plan and Development Plan and prepared the following responses to include in your pre-application consultation summary and permit application package. Waiver to Rule 1202.a.(10).C. (Variation to the daily inspection frequency)Colorado Parks and Wildlife understands that the working pad surface for the S. Leverich 13- 09 Pad is within 1,000 feet and upgradient of a 1202.c.(1).Q-S habitat and requires adherence to the best management practices outlined under Rule 1202.a.(10). One of the listed BMPs requires daily inspections of the facility unless a different inspection frequency or alternate method of compliance is identified. CPW agrees that with the use of remote monitoring (i.e., SCADA) and weekly visits after the first 6-9 months, there is no need for daily inspections at this facility. Furthermore, reducing the frequency of inspections will reduce overall vehicle traffic and disturbance to terrestrial wildlife species inhabiting this area. Consider this correspondence as CPW's written approval to waive the daily inspection frequency requirement under Rule 1202.a.(10).C. Noise and Light Impacts CPW attended the on-site tour of the S. Leverich 13-09 Pad on April 28, 2021 to discuss potential wildlife concerns and recommendations to avoid and minimize adverse impacts. CPW did not recommend any additional noise limits or monitoring requirements pursuant to Rule 423.b.(4)., because the location is not within a CPW-mapped High Priority Habitat (HPH). Additionally, CPW did not recommend any additional measures for lighting pursuant to Rule 424.c.(3).C., because there are no terrestrial HPH habitats within 2,000 feet of the location. CPW concurs that the applicable noise and light standards in the 400 series regulations, and the topographic barriers between the site and nearest terrestrial HPH are sufficient to avoid wildlife impacts associated with noise and light. If there are any questions or if we can supply additional information, please feel free to call or email. Thank you, Taylor Elm NW Region Energy Liaison P (970) 947-2971 | C (970) 986-9767 711 Independent Ave., Grand Junction, CO taylor.elm@state.co.us | cpw.state.co.us On Wed, Jun 29, 2022 at 2:37 PM Adam Tankersley <ATankersley@terraep.com> wrote:DI Good Afternoon Taylor, Thanks for meeting on June 23, 2022, to review the development pan for the South Leverich 13-09 pad and the Wildlife Protection Plan associated with the Form 2A. The Wildlife Protection Plan for this location has been updated per our discussion and has been attached for your review. Please review and let me know if you have any questions. As discussed during our meeting, the working pad surface of the Honea 19-05 pad is located within 1,000 feet of High Priority Habitat identified in Rule 1202.c.(1).Q-S and will be subject to the best management practices listed under Rule 1202.a.(10). However, TEP is requesting a waiver to the daily inspection frequency required under Rule 1202.a.(10).C. TEP is requesting a modified inspection frequency for this oil and gas location. Inspection at this location will occur daily for the first 6 – 9 months of production operations. Inspection frequency will then drop to once per week (minimum) for the remaining life of the wells. The oil and gas location will be equipped with Supervisory Control and Data Acquisition (SCADA) monitoring technology which enables remote monitoring of individual wells, produced water / condensate tanks, and other production facilities on the oil and gas location. As discussed, TEP has included the following best management practice to minimize potential for introduction of undesirable aquatic organisms into Beaver Creek: “TEP will utilize fresh water from Beaver Creek if available or potable water from a nearby source for dust suppression within cutthroat trout designated crucial habitat and native fish and other native aquatic species conservation waters. If feasible, dust suppression in proximity to Beaver Creek shall utilize potable water from a nearby source instead of raw water to avoid the spread of disease organisms and aquatic nuisance species.” For the South Leverich 13-09 pad, TEP is not requesting a Lesser Impact Area Exemption for the Noise Mitigation Plan and Lighting Mitigation plan, and will be submitted these plans with the Form 2A. TEP’s evaluation of noise and lighting impacts associated with our proposed operations indicated that the proposed activities would be in compliance with noise standards outlined in Rule 423 and with lighting standards outlined in Rule 424. During initial planning, TEP reviewed topographic maps, aerial imagery, and completed a site visit to evaluate siting considerations and potential impacts to wildlife. During this review TEP determined that it is unlikely for noise and light generated during construction, drilling, completion, or production operations to adversely impact wildlife resource. This is based on the overall distance and the topographic barrier between the oil and gas location and High Priority Habitat boundaries. The working pad surface of the South Leverich 13-09 pad is location 4,456’ from the Elk Production Area boundary and 5,244’ from the Elk Winter Concentration Area boundary. Furthermore, there are two topographic barriers between the working pad surface and the High Priority Habitat boundaries, one to the northwest and one to the southeast, minimizing the potential for noise and light impact on terrestrial wildlife. Due to these factors it is unlikely for noise and light generated during operations at this location to adversely impacts wildlife. As a best management practice TEP will direct all lighting on site during drilling and completion operations downward and inward toward operations to further minimize potential lighting impacts. TEP is not request a variance to the noise standards listed in COGCC Rule 423. Please let us know if you agree with this assessment. Attached is the Plan of Development, Wildlife Protection Plan, and Wildlife Habitat Drawing for you review. Please let me know if CPW has any question regarding the waiver request or BMPs listed in the Wildlife Protection Plan. Additionally, please let me know if CPW agrees with TEP assessment on noise and lighting impacts associated with activities planned at the South Leverich 13-09 pad. Thanks, Adam Tankersley | Planning Manager | TEP Rocky Mountain LLC | 1058 CR215 Parachute, CO 81635 ( (Office) 970-623-8994 | ( (Mobile) 970-589-6277 | * ATankersley@terraep.com This message and any related attachments are intended only for the use of the addressee(s) and may contain information that is PRIVILEGED and CONFIDENTIAL. If you are not the intended recipient(s), you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, please erase all copies of the message and its attachments and notify the sender immediately. TE8~ Water Plan – 304.c.(18) South Leverich 13-09 Oil and Gas Location Loc ID #335045 July 2022 Table of Contents TER INTRODUCTION The purpose of this Water Plan is to provide COGCC with specific information regarding the source and quantity of water that will be used during drilling and completion activities at the South Leverich 13-09 Pad. The sources of water to be used, the volumes, and the water take-out points are described in greater detail below. This Water Plan has been prepared in accordance with, and to comply with COGCC Rule 304.c.(18). SITE DESCRIPTION The South Leverich 13-09 Oil and Gas Development Plan (“OGDP”) is located within Lot 3 and Lot 4 of Section 13 of Township 7 South, Range 94 West, 6th P.M., which includes the reconstruction of the existing South Leverich 13-09 pad and associated pipeline infrastructure. TEP is proposing to reconstruct the South Leverich 13-09 pad to support drilling, completion, and production operations for twenty-one (21) proposed natural gas wells. The South Leverich 13-09 pad is located within Lot 3 and Lot 4 of Section 13, Township 7 South, Range 94 West, 6th P.M. on private land owned by Gordman Leverich, LLP and overlies private minerals. The land on which the pad would be located is classified as non-crop land, rangeland and recreation and is primarily used for grazing cattle. The South Leverich 13-09 OGDP involves reconstruction and expansion of one (1) existing Oil and Gas Location, construction of new pipeline corridors for natural gas transport, and the utilization of other existing facilities to support well completion and production operations. The pad location would have a constructed pad elevation of 8,007.1 feet. The proposed 6.43-acre South Leverich 13-09 pad will be reconstructed for drilling and completions operations of the twenty-one (21) proposed directional wells. The long-term disturbance following interim reclamation attributed to the South Leverich 13-09 pad would be approximately 1.74-acres. The existing access road will be utilized for development of the South Leverich 13-09 pad. Minor maintenance activities may occur along the existing access road; however, no new disturbance would occur. The proposed pipeline corridors would account for an additional 1.83-acres of disturbance with approximately 0.69-acres (existing roads) remaining after reclamation. The total South Leverich 13-09 OGDP disturbance will be approximately 16.11-acres. Approximately 4.79-acres of disturbance would remain long-term (include the Youberg SR 43-12 support pad and Youberg RU 44-7 remote frac pad) following interim reclamation of the proposed facilities and pipeline corridors. All proposed disturbance would be located on private surface. Please see the Plan of Development attached to the Form 2A for a detailed breakdown of disturbance acreage for all project components associated with the South Leverich 13-09 OGDP. WATER SOURCES AND VOLUMES Dust Control Fresh water will be required for dust control during site construction, drilling operations, and during long- term production operations. The primary fresh water sources to be used for dust control activities will be from the Giles Loadout Station. The Giles Loadout Station is a freshwater loadout located on private property along the Colorado River. All fresh water will be transported by private contract water hauling trucks equipped with 80 bbls tanks. The water hauling trucks will utilize existing county roads and lease roads and will follow existing truck routes where applicable. The intake on the water pumps at the source locations will be fitted with a quarter-inch (0.25”) mesh screen to prevent impacts to aquatic wildlife in the pond. TEP estimates that approximately 3,000 bbls (142.85 bbls per well) of fresh water will be used for dust control during construction. Dust control measures will be implemented as required per COGCC Rule 427.b-c. Only fresh water (potable or non-potable) will be used to conduct dust suppression activities within 300 feet of the ordinary high-water mark of any water body. Only potable water will be used to conduct dust suppression on sections of lease roads that are within high priority habitat for Cutthroat Trout Designated Crucial Habitat or other Native Aquatic Species Conservation Waters (within 500 feet of the ordinary high-water mark). On average, TEP estimates that approximately 500 bbls per well of fresh water will be used to control dust during drilling operations. Dust control measures are described in greater detail in the Dust Mitigation Plan attached to the Form 2A. The sources and volumes of fresh water required for dust control activities are summarized in Table 1, Water Source Table below. Drilling Operations Fresh water will be required for drilling operations (surface, intermediate, and production casing). The primary fresh water sources to be used for drilling activities will be from the Giles Fresh Water Takeout or the Airport Land Partners Limited Takeout. The Giles Fresh Water Takeout is located on the Colorado River on TEP property north of County Road 320 near Spruce Creek. The Airport Land Partners Limited Takeout is located on the Last Chance Ditch north of the Garfield County Airport along Garfield County Road 346. All fresh water will be transported by private contract water hauling trucks equipped with 80 bbls tanks. The water hauling trucks will utilize existing county, state, and lease roads and will follow existing truck routes where applicable. The intake on the water pumps at the source locations will be fitted with a quarter-inch (0.25”) mesh screen to prevent impacts to aquatic wildlife in the river or ditch. TEP estimates that approximately 4,000 bbls per well of fresh water will be used for drilling operations. Well Completions Operations Well completion operations will be conducted via simultaneous operations (SIMOPS), which utilizes recycled produced water from other producing wells operated by TEP. Recycled produced water will be transported from TEP’s existing water management facilities and staged at the Beaver Creek Pit 11-7-793 (COGCC Loc ID# 432702). From there, water will be pumped to a remote frac pad (Youberg RU 44-7 pad: COGCC Loc ID# 439173) via existing pipeline infrastructure. Fluids for well completion operations will then be pumped from the Youberg RU 44-7 remote frac pad to the wells on the South Leverich 13-09 pad via proposed temporary surface steel frac pipelines. The sources and volumes of recycled produced water required for completion activities are summarized in the Table 1, Water Source Table, below. WATER SOURCING INFORMATION Water to support dust control, drilling, and completion activities as described above will be obtained from the following sources:  Surface water (Primary source): Water will be supplied from Giles Loadout Station, private water rights owned by TEP Rocky Mountain, LLC., 1058 CR 215, Parachute, CO, 81635.  Surface water (secondary source): Water will be purchased from shares in the Last Chance Ditch that is owned by Airport Land Partners (Rifle Airpark), 312 AABC Suite A, Aspen, CO, 81611.  Fresh water (potable water): Water will be purchased from City of Rifle, Bulk Water Station, 2515 West Centennial Parkway, Rifle, CO 81650.  Recycled / Produced Water: Water will be provided from produced water supplies that are treated and recycled by TEP Rocky Mountain LLC., 1058 CR 215, Parachute, CO, 81635. Table 1, Water Source Table Name / Water Source Type Water Source Use Water Take-Out Point Permit Type Transport Method Volume Per Well (bbls) Latitude Longitude Surface Water - Primary Source: Giles Load Out Station - TEP Drilling activities: Surface Casing; Intermediate/ Production Casing; Dust Control 39.4866 -107.8839 Private Contract Trucking 3,643 Surface Water - Secondary Source: Airport Land Partners Takeout (Last Chance Ditch) Drilling activities: Surface Casing; Intermediate/ Production Casing; Dust Control 39.5294 -107.7336 Private Contract Trucking 500 Surface Water - City of Rifle, Bulk Water Station Potable water for Dust Control (as needed around Beaver Creek stream crossings) 39.5258 -107.81143 City of Rifle Trucking 500 Recycled / Produced Water Beaver Creek Pit 11-7-93 Completions, fracing, stimulation 39.4593 -107.82296 Private Pipeline 120,000 REUSE AND RECYCLING PLAN The South Leverich 13-09 OGDP and the twenty-one (21) proposed wells will benefit from reuse and recycling of produced water during hydraulic fracturing operations. Produced water generated from existing wells operated by TEP would be transported from one of TEP’s existing Centralized E&P Waste Management Facilities to the Youberg RU 44-7 pad for use during well completion operations. Produced water is collected, transported to, and treated at one of TEP’s Centralized E&P Waste Management Facilities. After treatment, the recycled water will be pumped via TEP’s existing waterline infrastructure and staged at the Beaver Creek Pit 11-7-793. From there, water will be pumped to the remote frac pad (Youberg RU 44-7 pad: COGCC Loc ID# 439173) via existing pipeline infrastructure where the water will be stored in six (6) Minion Tanks (aka. Modular Large Volume Tanks or MLVTs), each with a working capacity of approximately 9,000 bbls. Fluids for well completion operations will then be pumped from the Youberg RU 44-7 remote frac pad into the proposed wells on the South Leverich 13-09 pad via proposed temporary surface steel frac lines. Produced water, if not re-used or recycled during well completion operation, would otherwise require disposal via the methods described in the Waste Management Plan attached to the Form 2A, which includes (1) natural evaporation, (2) underground injection, (3) re-use/recycling in hydraulic fracturing operations, and/or (4) third party disposal. Reuse and recycling of produced water for well completion operations provides several benefits, including: 1) Decreases freshwater withdrawals from surface water sources, 2) Decreases reliance on injection wells for disposal of production/flowback water, 3) Decreases well completion costs versus alternative sources, 4) Increases operational efficiencies from re-using local supplies of production / flowback water to meet water demands for drilling, completion, and workover activities, 5) Reduces volume of truck traffic, versus alternatives that could involve trucking water from other sources. Proposed Volume TEP is currently planning to utilize approximately 120,000 barrels of produced water per well during well completion operations. With twenty-one (21) proposed wells, this totals approximately 2.52MM barrels of produced water that would be pumped to the Youberg RU 44-7 pad and utilized for hydraulic fracturing operations. The actual volume of water to be pumped during completion operations may vary depending on characteristics of the geologic formations and other factors. Method of Waste Treatment and Storage Treatment of Recycled Produced Water All water delivered to the Youberg RU 44-7 pad during well completion operations will generally be preprocessed and recycled produced water from one or more of TEP’s existing Centralized E&P Waste Management Facilities. Generally, produced water from these facilities is processed through gun barrels and other separation equipment to minimize the hydrocarbon concentration within the produced water. The produced water is then stored in a pit where it is treated with biocides, when necessary. Storage Tanks Recycled produced water delivered to the RU 44-7 pad for use during well completion operations will be stored in Minion Tank prior to being pumped to operations on the proposed wells at the South Leverich 13-09 pad. TEP’s contractor will erect six (6) ten-thousand-barrel (10,000bbl) Minion Tanks with an individual working capacity of nine thousand barrels (9,000bbls). The total capacity of the six (6) Minion Tanks is sixty thousand barrels (60,000bbls) with a total working capacity of fifty-four thousand barrels (54,000bbls). The Minion Tank is comprised of a ridged steel frame structure bolted together to form a cylindrical shell with an internal synthetic bladder secured to the steel frame. Each tank is 48.9 feet in diameter and thirty- two feet (32’) high. The bladder system is designed in accordance with API Standard 650 – Welded Tanks for Oil Storage. Containment System Each Minion Tank includes a synthetic bladder installed within the steel frame shell, which will serve as the primary containment for recycled water stored at the RU 44-7 pad during well completion operations. A secondary containment structure will be erected along the north side of the pad to provide one hundred and fifty percent (150%) containment of the largest tank. The secondary containment structure will be comprised of a Muscle Wall containment structure with an interior liner. The Muscle Wall is a portable, low-density polyethylene hollow plastic four-foot (4’) high barrier, which interlock to provide a ridged containment structure. Each section of Muscle Wall is six foot (6’) in length. Approximately 130 sections of Muscle Wall will be required to form the containment structure. The interior liner will be a thirty millimeter (30mil) reinforced polyethylene liner, which will be attached to the Muscle Wall using straps and clips as specified by the manufacture. The RU 44-7 pad has been constructed with a minimum one foot (1’) high pad perimeter earthen berm which has been constructed utilizing excavated subsurface material. The pad perimeter berm will be the tertiary containment for the proposed Minion Tanks providing approximately 224% containment of the largest tank. Please see the Preliminary Well Completion and Stimulation Layout Drawing in the Layout Drawing package attached to the Form 2A for a depiction of the preliminary layout of the proposed completions equipment on the Youberg RU 44-7 pad. Containment Calculation The total capacity of the six (6) Minion Tanks is approximately sixty thousand barrels (60,000bbls). The volume of the largest tank within the secondary containment structure will be ten thousand barrels (10,000bbls). Per COGCC Rule 603.o.(1), “[o]perators will design secondary containment structures to be sufficiently sized to contain at least 150% of the volume of the largest single [t]ank within the containment”. The total required holding capacity of the secondary containment must be a minimum of 15,000bbls plus tank displacement. With the displacement factored in for the additional five tanks, secondary containment should be: 150% of Largest Tank + (((π x r2 x containment high) x oil barrel conversion) x add’l tanks) 1.5 x 10,000bbls + (((π x 24.452 x 4’) x 0.17811) x 5) Total Secondary Containment = 21,446 bbls The proposed Muscle Wall secondary containment will be “L” shaped and was calculated as two individual rectangles, one approximately 188 feet in length by 92 feet, and the other approximately 184 feet in length by 80 feet in width by 4 feet in height. The secondary containment will have a total capacity of approximately 22,809 bbls. A minimum one foot (1’) high earthen perimeter berm will be used for tertiary containment. The tertiary containment is estimated to contain approximately 22,453 bbls, equating to 224% containment of the largest tank. Produced Water Quality and Quality Assurance Produced water delivered to the RU 44-7 pad for storage in the proposed Minion Tanks will be pre- treated at one of TEP’s existing water management facility. Produced water is generally processed through gun barrels and other hydrocarbon separating equipment to minimize the hydrocarbon content within the produced water. TEP does not use any of the chemicals identified in Table 437-1 as additives in any of our completion fluids. There are trace concentrations of some organic compounds (e.g., Benzene, Ethylbenzene, Xylene, etc.), but these are naturally occurring chemicals found within the formation water that is collected and treated. TEP complies with COGCC Rule 437.b, which does not prevent operators from recycling or reusing produced water that has naturally occurring, trace amounts of the chemicals listed in Table 437-1. TEP also complies with Rule 437.c, which allows for the use of those chemical constituents at either the Table 915-1 standard, or the unconcentrated naturally occurring background level, whichever is greater. Please see Table 2, Recycled Produced Water – Table 437-1 Concentrations, for detailed water sampling results. Flowback water may be stored in the proposed tanks following completion of initial well completion operations. All flowback water will go through a four-phase separator prior to storage in the Minion Tanks to separate gas, water, condensate, and sand that may return from the well following well completion. Flowback water processed and stored in the Minion Tank will be pumped back into TEP’s water management system during flowback operations. Table 2, Recycled Produced Water - Table 437-1 Concentrations Water Quality Sampling Results Data Summary - Table 437-1 Rulison Centralized E&P Waste Management Facility Facility ID: 149006 Date: October 8, 2021 Chemical Name Units Analytic Method Result Qual RL MDL DF Table 915-1 Levels Metals Arsenic MG/L 6010C 0.0055 U 0.01 0.0055 1 Cadmium MG/L 6010C 0.00243 U 0.005 0.00243 1 Chromium MG/L 6010C 0.000916 J, B 0.01 0.000811 1 Lead MG/L 6010C 0.00237 U 0.01 0.00237 1 Mercury MG/L 7470A 0.0000263 U 0.0002 2.63E-05 1 Volatile Organic Compounds Benzene UG/L SW8260C 0.13 U 1 0.13 1 5 Ethylbenzene UG/L SW8260C 0.5 U 1 0.5 1 700 m-Xylene & p-Xylene UG/L SW8260C 0.63 U 5 0.63 1 o-Xylene UG/L SW8260C 0.6 U 5 0.6 1 Xylenes, Total UG/L SW8260C 1.6 U 10 1.6 1 1400 to 10000 2-Ethylhexanol UG/L SW8260C 200 U 200 200 1 1,3,5-Trimethylbenzene UG/L SW8260C 0.56 U 1 0.56 1 67 1,4-Dioxane UG/L SW8260C 200 U 400 200 1 Semi-volatile Organic Compounds N,N-dimethylformamide UG/L SW8270D 1.13 J*_ 20.4 0.815 2 Method 8015D - Glycols - Direct Injection (GC/FID) 2-Butoxyethanol UG/L SW8015D 5 U 5 5 1 Method 8015D - Nonhalogenated Organic Compounds - Direct Injection (GC/FID) 1-Butanol UG/L SW8015D 2.77 U 5 2.77 1 Field Parameters Water temp, field deg C YSI 556 18.6 pH, field s.u. YSI 556 7.15 Specific cond., field uS/cm YSI 556 34276 Conductivity, field uS/cm YSI 556 --- DO saturation, field % YSI 556 154.1 DO, field mg/L YSI 556 --- ORP, field mv YSI 556 8.8 Turbidity, field ntu Micro TPI 47.05 Discharge cfs NA Color nu Light Brown Odor nu Low Effervescense nu None Field Parameters (cont.) Sediment nu None Bubbles nu None VOA Headspace nu None Table 437-1 Compounds Not Analyzed 2-mercaptoethanol benzene, 1,1’-oxybis-,tetrapropylene derivatives, sulfonated sodium salts (BOTS) butylglycidyl ether Quaternary ammonium compounds, dicoco alkyldimethyl chlorides (QAC) Bis hexamethylene tiamine penta methylene phosphonic acid (BMPA) Diethylenetriamine penta (methylene-phosphonic acid) (DMPA) FD&C blue no. 1 Tetrakis (triethanolaminato) Notes: U = not detected at the method detection limit; J = result between RL and MDL, estimated; H = hold time exceeded; NM = not measured; AV = result averaged; VAR = variable; *_ LCS and/or LCSD is outside of acceptable limit, low biased; --- = no standard for this parameter; SS = Suspended solids Proposed Timeline for Reuse and Recycling Produced water will be utilized during well completion operations on the South Leverich 13-09 pad, which is scheduled to occur between March 2023 and December 2023. Anticipated Method of Transport Produced water is transported from existing oil and gas locations to TEP’s existing Centralized E&P Waste Management Facilities via existing pipelines when existing pipelines are available. Produced water from other oil and gas locations that do not have existing water pipeline infrastructure is transported via truck to existing facilities closest to the source location. Water collected and stored at existing Centralized E&P Waste Management Facilities will be transported via pipeline to Youberg RU 44-7 pad for temporary storage prior to well completion operations. When well completion operations begin, produced water will be pumped through the five (5) proposed four-and one-half inch (4.5”) temporary surface steel frac lines from the Youberg RU 44-7 pad to the well or well(s) being completed. Final Disposition of the Waste Produced water will be utilized during well stimulation operations for the proposed wells by pumping the produced water downhole to stimulate the target formation. Any produced water that is returned during flowback operations will be reused and recycled at the Youberg RU 44-7 pad for completion of the remaining wells. Following well completion operations, flowback / produced water will be handled as described in the Produced Water section of the Waste Management Plan, which has been attached to the Form 2A. RATIONALE FOR USING FRESH WATER Drilling Operations: Fresh water (non-potable) is required for drilling operations to ensure that consistent drilling mud densities and compositions are achieved. Generally, recycled produced water contains Total Dissolved Solids (TDS) and chloride concentrations that are too high, and therefore unsuitable for use when drilling through shallow, fresh-water aquifers. Completion Operations: TEP is using recycled produced water for completion activities which is by far the most water-intensive aspect of well development. Fresh water will not be used for well completion operations. Dust Control: Many of the access roads in this area run parallel to or are near surface water features (Beaver Creek, Colorado River, etc.). The use of fresh water for dust control purposes is safer (i.e., more environmentally friendly) than using recycled produced water that typically contains higher concentrations of organic and inorganic compounds than fresh water. Use of fresh water for dust control on these roads will minimize any residual pollutants that could accumulate in soils, and which could potentially be transported to nearby surface waters. SITE SPECIFIC BEST MANAGEMENT PRACTICES The following Best Management Practices will be utilized during development of the South Leverich 13- 09 Oil and Gas Location: 1. Recycled produced water will be utilized for well completion operations minimizing the amount of fresh water required for development of the proposed wells on this location. 2. Only potable fresh water will be used on access roads within the high priority habitat buffers for Cutthroat Trout Designated Crucial Habitat and other Native Aquatic Species Conservation Waters. Edge Environmental, Inc. Cumulative Impacts Plan for the TEP Rocky Mountain LLC South Leverich 13-09 Oil and Gas Development Plan Prepared by Edge Environmental, Inc. 203 South Devinney Street Golden, CO 80401 303-988-8844 July 2022 Table of Contents 1 Edge Environmental, Inc. INTRODUCTION Edge Environmental, Inc. (Edge) was asked by TEP Rocky Mountain LLC (TEP) to prepare a Cumulative Impacts Plan pursuant to Colorado Oil and Gas Commission’s (COGCC’s) Rule 304.c.(19). This plan documents how the Operator (TEP) would address cumulative impacts to resources identified pursuant to Rule 303.a.(5). This Cumulative Impacts Plan for the South Leverich 13-09 Oil and Gas Development Plan (OGDP) was prepared based on the preliminary Oil and Gas Location Assessment (Form 2A) and Cumulative Impacts Data Identification (Form 2B) documentation provided by TEP. The South Leverich 13-09 pad (COGCC Location ID #335045) is an existing Oil and Gas Location on private surface owned by Gordman Leverich, LLP which would be reconstructed and slightly expanded to accommodate the drilling, completion, and production of 21 proposed directional natural gas wells. The existing South Leverich 13-09 pad is located within Lots 3 and Lot 4 of Section 13, Township 7 South, Range 94 West, 6th P.M., within Garfield County, Colorado. The existing access road from Garfield County Road 317/317A would continue to be used to access the existing Oil and Gas Location. Of the 21 proposed wells planned on this location, 2 wells would be directionally drilled into Federal Lease COC 63721, and 19 wells would be directionally drilled into the underlying Fee lease or adjacent Fee leases. The South Leverich 13-09 pad would be reconstructed and slightly expanded to accommodate the development of the proposed wells. The existing access road from Garfield County Road 317/317A will continue to be used to access the Oil and Gas Location. TEP would utilize three existing Oil and Gas Locations, the Youberg RU 44-7 well pad, the Youberg SR 43-12 well pad, and the Beaver Creek Pit, as support facilities during drilling, completion, and production operations associated with the proposed wells on the South Leverich 13-09 pad. The existing Youberg RU 44-7 (COGCC Location ID #439173) pad would be utilized as a remote frac support location for well stimulation operations for the proposed new directional wells on the South Leverich 13-09 pad. The Youberg RU 44-7 pad is located on private surface (Youberg Beaver Creek Ranch L.P.) in the SE¼SE¼ of Section 7, Township 7 South, Range 93 West, 6th P.M. It currently supports production operations for 13 natural gas wells and has been utilized to support remote well completion operations for multiple Oil and Gas Locations in recent years. The existing Youberg SR 43-12 (COGCC Location ID #413683) pad would be utilized as a produced water storage and transport facility where produced water would be temporarily stored and pumped before entering TEP’s water management system. It is located on private surface (Youberg Beaver Creek Ranch L.P.) in Lot 6 of Section 12, Township 7 South, Range 94 West and Lot 3 of Section 7, Township 7 South, Range 93 West, 6th P.M. The Youberg SR 43-12 pad currently supports production operations for 20 natural gas wells. The Beaver Creek Pit would be utilized for temporary storage and transport of recycled produced water for well completion operations for the 21 proposed wells on the South Leverich 13-09 pad. The Beaver Creek Pit is an existing Oil and Gas Location located on private surface (Youberg Beaver Creek Ranch, L.P.) in Lot 1 Section 7, Township 7 South, Range 93 West, 6th P.M. To support production operations on the South Leverich 13-09 pad, Summit Midstream (Summit) would install an 8-inch steel natural gas pipeline (approximately 2,125 feet in length) from the proposed meter on the South Leverich 13-09 pad to their existing/proposed gas gathering system located south of the South Leverich 13-09 pad. The proposed tie-in point 2 Edge Environmental, Inc. would be located on TEP surface south of the South Leverich 13-09 pad. TEP would install a 4- inch FlexPipe water pipeline (approximately 450 feet in length) from the separators on the South Leverich 13-09 pad to the existing pipeline corridor adjacent to the pad. The proposed water pipeline would tie-into infrastructure located in the pipeline corridor adjacent to the Oil and Gas Location. TEP would install several on-location pipelines to support onsite production operations. The proposed off-location pipelines would be installed within a 50-foot pipeline Right-of-Way located on property owned by TEP and Gordman Leverich, LLP. Well completion operations associated with the proposed wells on the South Leverich 13-09 pad would be conducted via simultaneous operations (SIMOPS) from the existing Youberg RU 44-7 pad. Water would be transported to the Youberg RU 44-7 pad via existing water pipelines operated and maintained by TEP. TEP would install five 4.5-inch steel temporary surface frac lines from the Youberg RU 44-7 pad to the South Leverich 13-09 pad to support remote frac and flowback operations. Temporary surface frac lines would be installed following the existing access road toward the Federal RU 23-17 pad, an existing pipeline ROW to the Caerus O-18 pad, and then the existing access roads to the South Leverich 13-09 pad. Recycled produced water would be pumped from existing TEP operated water management facilities to the Youberg RU 44-7 pad during completion operations. Flowback would be processed through four-phase separation equipment and transported via pipeline either to the Youberg RU 44-7 pad for recycle for future well completion operations, or transported to TEP’s water management facilities for processing, reuse, recycling, and/or disposal. Construction for the South Leverich 13-09 pad and the pipeline infrastructure is scheduled to begin in November 2022 and is expected to take approximately 60 days (±8.5 weeks) to complete. Drilling operations for the 21 proposed directional wells would begin in March 2023. Because SIMOPS is planned for development of these wells, well completion operations would begin in May 2023. Drilling is expected to take approximately 121 days (±17 weeks) and should be completed in July 2023. Well completion is expected to take approximately 210 days (±30 weeks) and should be completed in December 2023. Reclamation of the South Leverich 13-09 pad would be completed by May 2024, within 6 months following completion of well construction and stimulation activities. Site reclamation is dependent on weather conditions and project scheduling. The estimated productive life of the 21 proposed natural gas wells is approximately 30 years (360 months). Development may be accelerated or delayed based on market conditions and company constraints. SUMMARY OF RESOURCE IMPACTS Air Resources Air emissions produced during the pre-production and production phases of development have been evaluated based on the scale and scope of the proposed development plan for the following pollutants: oxides of nitrogen (NOx), carbon monoxide (CO), volatile organic compounds (VOCs), methane (CH4), ethane (C2H6), carbon dioxide (CO2), and nitrous oxide (N2O). A quantitative evaluation of the incremental increase in pollutants has been estimated for the entire proposed development plan for the South Leverich 13-09 OGDP. The emissions estimate includes both stationary and mobile sources of emissions during all pre-production activities (see Table 1) and both stationary and mobile sources of emissions for the first year of production based on all proposed wells and equipment (see Table 2). All pre-production activities are expected to be completed during 2023 and production would occur beginning in