HomeMy WebLinkAbout1.00 General Application Materials_PartI
INTRODUCTION
TEP Rocky Mountain, LLC (“TEP”) has prepared the following Operations Safety Management Plan as
an attachment to the South Leverich 13-09 Form 2A to address the requirements under the Colorado Oil
and Gas Conservation Commission (“COGCC”) Rule 602.d, which requires operators to establish and
maintain a written operations safety management program to address change management and pre-startup
safety procedures for all new and existing Oil and Gas Locations. TEP strives to conduct all operations in
a safe and orderly manner to eliminate and/or minimize the potential for injury, accidents, spills, or any
potential impacts to public health, safety, welfare, the environment, and wildlife resources. This
Operations Safety Management Plan details the key elements of TEP’s change management program and
the pre-startup safety review for changes made to any new or existing Oil and Gas Location.
CHANGE MANAGEMENT PROGRAM
Purpose
The purpose of the Change Management Program is to establish the process by which changes to equipment
and operational procedures are documented for an Oil and Gas Location. The process by which changes
are made to equipment and operational procedures is critical to the safe and effective operation of the
facility, worker safety, and minimize potential impacts to public health, safety, welfare, the environment,
and wildlife resources.
Scope
A change review will be administered by personnel in the Engineering Department and the Operations
Department with assistance from the Safety Department and will address the elements outlined in the
COGCC regulations. A change review will be conducted on proposed new equipment and proposed
significant modifications to existing equipment as applicable in the regulations.
Program
This change management program is in place to assure that the following items have been adequately
addressed prior to installing new equipment or significantly modifying existing equipment:
1. The technical basis for the proposed change,
2. Potential impacts on existing facilities and equipment,
3. Required modifications to operating procedures,
4. Potential impacts on employee safety and health, and
5. Potential impacts on the environment (i.e., air emissions, Spill Prevention, Stormwater).
Implementation
A change review meeting will be conducted to thoroughly review proposed changes to ensure that all
equipment is properly designed prior to construction or installation. The meeting participants may
include, but are not limited to, Subject Matter Experts (SME) from the Operations Department,
Engineering Department, Measurement Department, and the Environment Health & Safety Department.
In addition, a Pre-Startup Safety Review (PSSR) will be conducted prior to startup of the new or modified
equipment.
All changes will be reviewed, documented, and approved by each department’s manager prior to
installation and operation of the equipment, or execution of changes to operational procedures.
Documentation
The change review meeting will be documented along with any recommendations resulting from the
review. Documentation of the changes will include the following elements:
1. Date of Change Review Meeting
2. Attendees of Review Meeting
3. Purpose for the Change
4. Description of Equipment or Procedural Change
5. Evaluation of Potential Impacts to Employee Safety
6. Evaluation of Potential Impacts to Public Health, Safety, Welfare, and the Environment
Records Keeping
All documentation of the proposed change to equipment or facilities at a site will be kept on record on
TEP’s internal servers for a period of no less than five (5) years. Upon formal written request by the
COGCC, TEP will provide documentation of the specific change, as outlined above, to the COGCC
within thirty (30) days of the request.
PRE-STARTUP SAFETY REVIEW
Purpose
The purpose of the Pre-Startup Safety Review (“PSSR”) ensures that a safety and technical review of the
proposed operation is conducted prior to startup of any new or modified equipment or implementing any
new operational procedure at an Oil and Gas Location.
Scope
A PSSR will be administered by personnel in the Operations Department (e.g. Superintendents,
Supervisors, Field Technicians, Measurement Technicians) with assistance from the Safety Department,
and will address the elements outlined in the regulations. PSSRs will be conducted on newly installed and
significantly modified equipment as applicable in the regulations.
Program
The objective of the PSSR program is to assure that the following items have been adequately addressed
and are in place prior to start-up of any new or significantly modified facility or process:
1. Construction and modifications are in accordance with the design specifications and applicable codes.
2. Necessary safety, operating, maintenance and emergency procedures are in place and are adequate.
3. All safety and operability recommendations have been addressed and actions necessary for startup have
been completed.
4. The training of each employee and/or contractor involved in the operating process has been completed.
Implementation
A walk-through inspection of newly installed or significantly modified equipment will be conducted prior
to introducing fluids (e.g., natural gas, oil, condensate, water) to the equipment. The inspection may be
conducted by a team of qualified personnel, or a Subject Matter Expert (SME) designated by the Facility
Supervisor or Superintendent. The intent of the inspection is to ensure that all equipment is properly
installed, and all safety equipment is functioning prior to startup.
Documentation
A PSSR Checklist will be used to document the inspection.
Operation Safety Management
PSSR Checklist
Date: ___________________________ Location: ___________________________
1. Process Vessels and Piping
Piping/vessels have been reviewed and approved by the Facilities Engineering Group
All pipe fittings are connected and tightened according to manufacturer specifications
All tubing fittings are connected and tightened according to manufacturer specifications
2. Instrumentation & Electrical
I&E equipment has been reviewed and approved by the Facilities Engineering Group
I&E equipment has been connected to a power source
I&E equipment is functioning properly
3. Operability & Training
Access to all valves/instruments, etc. is adequate for operation, isolation, and maintenance
All gauges, meters, etc. are accessible and easy to read
Platforms and ladders provide safe access to instruments, valves, PSVs, etc.
Sample points/stations are easily accessible and oriented properly
All necessary operating procedures have been written/updated
Proper training/notification of personnel has been conducted
4. Safety & Environmental
Working area is level/even, clear of debris, and free of slip hazards
Area lighting is adequate for tasks required
Tank vapor combustion equipment is functioning properly
Storage tank spill containment is adequate and free of damage
Stormwater BMPs are in place and free of damage
All applicable signage is in place and legible
Actions to be completed prior to startup (PTS):
Item # Action to be Completed Prior to Start-Up Responsible
Person
Target
Date
Actual
Date
Actions to be completed after startup (AS):
Item # Action to be Completed After Start-Up Responsible
Person
Target
Date
Actual
Date
Emergency Response Plan – 304.c.(8)
South Leverich 13-09 Oil and Gas Location
Loc ID #335045
July 2022
Table of Contents
TER
INTRODUCTION
TEP Rocky Mountain LLC (“TEP”) has developed the following Emergency Response Plan (“ERP”) to
help Company Personnel quickly evaluate and effectively manage incidents and limit consequences related
to operations at the South Leverich 13-09 Oil and Gas Location. Colorado Oil and Gas Conservation
Commission (COGCC) regulations requires operators to submit an ERP under Rule 304.c.(8). This Plan
utilizes an Incident Command System/Unified Command System (ICS/UCS) structure to assist in the
management of major incidents. A summary of TEP’s comprehensive ERP is below and organized as listed
in Table 1. TEP’s basin wide ERP is compliant with the requirements of COGCC Rule 602.j and is
available upon request.
Table 1, Required Content for the Emergency Response Plan
1 Local response agency and contact
2 Date the plan was finalized and approved by the local response agency
3 Directions to the location
4 Location ingress and egress
5 Legal description
6 Operator emergency contact information
7 Mutual aid agencies
8 Local and mutual aid agency staffing
9 Site setting
10 Location layout
11 Equipment and stored material
12 Sensitive areas
13 Potential impacts, prevention, and mitigation
14 Response equipment
15 Health and safety action levels
16 Training coordinated with local responders
1. Local Response Agency and Contact
Table 2, Local Response Agency and Contacts
Agency Contact Contact Information
Garfield County Sheriff’s Office
Chris Bornholdt
Emergency Operations
Commander/Manager
Emergency 911
Office Phone 970-945-0453
2. Date the Plan was Finalized and Approved by the Local Response Agency
TEP’s field wide emergency response plan was coordinated with the local emergency response manager,
Chris Bornholdt, and approved on April 6, 2021.
3. Direction to the Location
Beginning at the City of Rifle Exit (Exit 90) head south on Colorado Highway 13 approximately 0.19 miles
to the intersection with Airport Road, use the traffic circle to head east on Airport Road approximately 0.24
miles to the intersection with Megan Avenue, turn right (south) on Megan Avenue and proceed for
approximately 0.26 miles to the intersection with Last Chance Drive, turn right (west) on Last Chance Drive
and proceed for approximately 0.41 miles to the intersection with Garfield County Road 320, proceed
westerly on County Road 320 for approximately 2.49 miles to the intersection with Garfield County Road
317, turn left on County Road 317 and proceed southerly for approximately 5.85 miles to the intersection
with a dirt/gravel road (lease road) east of Beaver Creek, stay right on the lease road in a northerly, then
southerly direction for approximately 0.65 miles to the South Leverich 13-09 pad.
Location Coordinates
Latitude: 39.435546
Longitude: -107.829300
4. Location Ingress and Egress
The existing access road to the existing South Leverich 13-09 pad will provide ingress and egress to the oil
and gas location. At the intersection with Garfield County Road 317 and the existing lease road, a steel
frame gate has been installed to limit access to the oil and gas location. The gate has been fitted with a steel
chain and padlock to only allow authorized access to the oil and gas location.
5. Legal Description
Township 7 South, Range 94 West, 6th P.M.
Section 13: Lot 3 & 4
Garfield County, Colorado
6. Operator Emergency Contact Information
Table 3, Operator Emergency Contact Information
Role Contact Contact Information
Operations Chuck W. Smith, Supervisor
Eric DeKam, Superintendent
970-216-8703
970-263-2723
EHS/Safety
Shawn Brennan, EHS Manager
Kevin McDermott, Safety Spvsr.
Delbert Dowling, Safety Spc.
970-948-3166
970-309-1195
970-589-5736
Land Bryan Hotard, Landman 970-361-2006
7. Mutual Aid Agencies
Table 4, Mutual Aid Agencies
Agency Contact Contact Information
Colorado River Fire
Rescue District
Leif Sackett, Chief
Colorado River Fire Rescue
Emergency 911
Non-Emergency 970-625-8095
Rifle Office Phone 970-625-1243
8. Staffing of Local and Mutual Agencies
The Garfield County Sheriff’s Office is under the authority of Sheriff Lou Vallario. Under the Sheriff and
Garfield County government, the Garfield County Emergency Operations Plan (EOP) outlines how the
county government complies with and implements the requirement of the Colorado Division of Emergency
Management to protect the lives and property of the citizens of the county. The county EOP serves as a
bridge between the Local Municipal Emergency Operations Plan and the State of Colorado Emergency
Operations Plan. The EOC Manager coordinates with multiple agencies, including fire protection districts
in support of emergency response and management.
9. Site Setting
The South Leverich 13-09 OGDP will be located in the vicinity of existing oil and gas infrastructure in
rural Garfield County, Colorado. There are five (5) active Oil and Gas Locations within one (1) mile of the
existing South Leverich 13-09 pad (COGCC Loc ID: 335045). The South Leverich 13-09 pad is located on
private surface owned by Gordman Leverich, LLP within Lots 3 & 4 of Section 13, Township 7 South,
Range 94 West, 6th P.M., Garfield County, Colorado. Garfield County has a zoning designation of Rural
for the property. The land on which the pad is located is classified as non-crop land, rangeland, and
recreation, and is primarily used for grazing cattle. The property in the immediate vicinity of the Oil and
Gas Location is primarily used for cattle grazing but is also periodically used for recreation, including
hunting.
10. Location Layout
The expanded 6.43-acre South Leverich 13-09 pad would be constructed to support drilling, completion,
and long-term production operations of the twenty-one (21) proposed natural gas wells. The long-term
disturbance of the production pad following interim reclamation will be approximately 1.74-acres. Please
see the Layout Drawing included as an attachment to the Form 2A for additional site details.
11. Equipment and Stored Materials
TEP would install wellhead telemetry and other wellhead specific equipment on the South Leverich
13-09 pad to support production of the proposed wells. TEP would also install production facilities,
including separators, tanks, Enclosed Combustion Devices (“ECD”), and other production equipment
on the South Leverich 13-09 pad to effectively produce the proposed wells. Twenty-eight (28)
separators (6 quad separators, 1 single separator, and 3 low pressure separators) would be installed
along the west side of the pad within a one hundred and thirty-five foot (135’) long by thirty-foot (30’)
wide area. Six (6) five-hundred-barrel (500bbl) condensate tanks and two (2) eighty-barrel (80bbl)
steel fluid storage tanks, used for well blowdown and pipeline venting operations, would be installed
within an eighty foot (80’) by forty foot (40’) lined steel containment structure along the south side of
the pad. The tank battery would be installed with a minimum of seventy-five feet (75’) setback from
the proposed separators, wellheads, and ECD. One (1) air compressor and dual fuel generator pack will
be installed adjacent to the separators for operation of instrument air supply. One (1) natural gas meter
would be installed by Summit within the existing pipeline right-of-way south of the pad entrance.
Three (3) ECDs would be installed on the pad seventy-five-feet (75’) west of the proposed tank battery
to control emissions. A temporary buy-back meter will be installed on location during drilling
operations to supply fuel gas to the drilling rig.
Table 5, Production Equipment Details
Pad Name Equipment Description Equipment
Count Capacity Status COGCC Class
South Leverich
13-09 Pad
Quad Separators 6 NA Proposed Major Equipment
Single Separator 1 NA Proposed Major Equipment
Low Pressure Separator 3 NA Proposed Major Equipment
Condensate Tanks 6 500bbl Proposed Major Equipment
Blowdown/Vent Tanks 2 80bbl Proposed Other Permanent Equip.
Enclosed Combustion Devices 3 NA Proposed Major Equipment
Chemical Pumps 4 NA Proposed Other Permanent Equip.
Chemical Tank 4 500gal Proposed Other Permanent Equip.
Air Compressor / Generator 1 NA Proposed Other Permanent Equip.
Meter/Sales Building 1 NA Proposed Major Equipment
Temp. Buy-Back Meter 1 NA Proposed Other Temporary Equip.
12. Sensitive Area
The South Leverich 13-09 pad is located in Garfield County, Colorado in the vicinity of existing oil and
gas well pads and infrastructure. There are no day care centers or school facilities within 1-mile of the oil
and gas location. There are four (4) residential building units within 2,000 feet of the working pad surface
of the oil and gas location. Only one (1) of the four (4) residential building units is occupied full time by
the owner. The other three residential building units are recreational dwellings only periodically occupied.
The South Leverich 13-09 pad is located 640 feet east of Beaver Creek. The oil and gas location has been
designed with control measures to minimize the potential for impacts to groundwater and surface water.
The South Leverich 13-09 pad has been designated as a sensitive area due to the proximity to Beaver Creek,
approximately 640 feet to the west of the proposed working pad surface.
13. Potential Impacts, Prevention, and Mitigation
The South Leverich 13-09 oil and gas location will be reconstructed to provide the necessary working
surface to support safe and efficient working conditions for all TEP employees and contractors during every
phase of development, including drilling, completions, and production operations of the twenty-one (21)
proposed natural gas wells and the four (4) existing natural gas well.
Prior to commencement of construction activities, TEP will hold a pre-construction meeting with
contractors to review proposed site construction and installation of stormwater control measures, and
conditions of approval included in the approved permits and ROWs. The site will be staked for construction
prior to the preconstruction meeting. Staking will identify the boundaries of the proposed site to protect
existing vegetation in areas that should not be disturbed. Vehicular traffic will be minimized as much as
possible to reduce nuisance dust and prevent soil erosion, any trash generated during the project will be
disposed of properly at a commercial disposal facility, and any chemicals used will be kept to a minimum.
No cumulative adverse impacts are anticipated in the development of the South Leverich 13-09 oil and gas
location and associated facilities for air resources, public health, water resources, terrestrial and aquatic
wildlife resources, soil resources, or public welfare. A description of the potential impacts, prevention and
mitigation are outlined in the Cumulative Impact Plan and other plans attached to the Form 2A.
14. Response Equipment
Occasionally, spills of productions fluids may occur during oil and gas operations (drilling, completion,
and production) that result in localized impacts to soils on or near the well pad. TEP will stage a spill
response trailer at the existing RU 32-12V pad, which will have supplies available for immediate response
to spills or releases during operations on the South Leverich 13-09 oil and gas location. Well telemetry
equipment will be installed to minimize site visitation through remote monitoring of production operations
and aid in proactive response to well operation.
15. Health and Safety Action Levels
Incident Classification: TEP uses a tiered system of classification for incidents in rising levels of
serious impact. Incidents are classified as:
Near Miss (does not require use of the Emergency Response Plan)
Minor Event
Significant Event
Serious Event
Major Event
Purpose: Emergency response management describes the tactical actions taken to directly mitigate an
emergency and protect human life, health, environment, and/or property from the physical impact of an
event.
The TEP ERP specifically applies to E&P Production located in Garfield and Rio Blanco Counties. The
ERP includes details on how to:
Categorize the incident impact on an increasing scale
Create a safer environment for the facility
Isolate the area/facility
Establish evacuation routes and meeting locations
Identify medical and rescue responsibilities for trained employees
Establish methods for reporting fires and other emergency events
Provide labor, materials, and equipment
Identify emergency shutdown procedures for affected equipment
Handle hazardous substances
Establish and maintain adequate notification and communication with governmental agencies (fire,
police, public officials, etc.)
Scope: The procedures outlined in the ERP were developed under the assumption that local fire protection
and emergency response agencies will respond to emergencies at the TEP site when notified and will assist
to the extent of their respective capabilities.
The ERP provides procedures for communication with employees, governmental agencies, and the public
during emergencies to assure an effective response during an emergency situation.
The plan can be followed when responding to various incidents/events, including but not limited to the
following:
(a) Natural disasters and severe weather conditions including:
Floods
Damaging storms (tornadoes, hurricanes)
Earthquakes
Weather extremes (cold, blizzards, heat)
Lightning
Wildfires
(b) Disruption to normal operations:
Hazardous material / chemical releases from stationary or mobile sources
Unscheduled valve closure or safety equipment shutdown, or any unscheduled emergency
shutdown
Major accidents involving TEP vehicles or equipment owned by contractors
Bomb threats or other security events
Threats against employees or TEP facilities
Fatalities or multiple hospitalizations involving employees, contractors, or members of the
public
Disturbances on TEP property
Damage to TEP property that interferes with the performance of normal business
Disruption of service to customers (scheduled or unscheduled)
(c) Catastrophic failure and/or damage:
Major fire
Major environmental release
Significant destruction of a facility
Health and Safety: The ERP reflects TEP’s health and safety policies and procedures. When the
site/facility, or a portion of the facility, is involved in an emergency event, Company Personnel shall take
the appropriate action to safeguard human life and protect the public, the environment and surrounding
property, and to maintain or restore operations if possible.
Field personnel must immediately communicate information about any emergency event to their supervisor.
The supervisor will immediately initiate appropriate notification procedures. In the event a supervisor
cannot be reached, field personnel will initiate necessary notifications.
16. Training Coordinated with Local Responders
TEP is a member of the Garfield County Local Emergency Planning Committee (LEPC) and the Garfield
County Public Safety Council (PSC). Both groups provide a forum to discuss current oil & gas issues and
concerns. Oil & gas emergency response plans are periodically reviewed. In addition, historical industrial
accidents are routinely reviewed and discussed. National Incident Management System (NIMS) training
has been provided through the LEPC. Rio Blanco County does not currently have equivalent emergency
response groups, however in the recent past they have performed tabletop and mock incidents through their
County Road 5 Emergency Preparedness Group (CR5EPG) which several upstream and midstream
operators participated in. The CR5EPG also provided NIMS training to industry personnel.
Waste Management Plan – 304.c.(11)
South Leverich 13-09 Oil and Gas Location
Loc ID #335045
July 2022
Table of Contents
TER
Page 2 of 12
INTRODUCTION
TEP Rocky Mountain LLC (“TEP”) has developed the following Waste Management Plan to address
Exploration and Production (“E&P”) and other wastes related to its proposed operations on the South
Leverich 13-09 Pad (COGCC Loc ID: 335045). This plan provides an overview of methods TEP will use
for managing waste materials as required by Colorado Oil and Gas Commission (“COGCC”) Rule
304.c.(11) and Rule 905.a.(4).
E&P wastes are not regulated (i.e., exempt) as hazardous wastes by the Environmental Protection Agency
(EPA) (40 CFR 261) or by the COGCC. The COGCC regulates E&P wastes in the State of Colorado.
Both agencies publish a list of E&P exempt wastes on their websites. To qualify as an E&P waste, the
waste must be generated during the drilling, completions, or production operations. These wastes must be
managed (treated, stored, transported, and disposed of) in accordance with COGCC, County and
municipal regulations, and land use codes and ordinances.
Non-E&P Wastes are those that are not generated as part of Oil and Gas downhole operations and are
generally classified as non-hazardous or hazardous. These wastes must be managed in accordance with
Colorado Department of Public Health and Environment (“CDPHE”) regulations, and County and Local
landfill or waste disposal facility requirements.
The following documents the general practices and procedures TEP will use to manage the identified
waste streams to be generated during development of the twenty-one (21) proposed wells on the South
Leverich 13-09 pad.
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 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 would be reconstructed for drilling and completions
operations of the twenty-one (21) proposed directional wells. The long-term disturbance attributed to the
South Leverich 13-09 pad would be approximately 1.74-acres. The existing access road would 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 would be approximately
16.11-acres. Approximately 4.79-acres of disturbance would remain long-term (including 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
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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.
DEVELOPMENT PHASE AND POTENTIAL WASTE STREAMS
Development of the proposed Oil and Gas Location and the proposed wells will generally occur in the
following order of operations:
1) Construction operations;
2) Drilling operations;
3) Well completion operations;
4) Flowback operations;
5) Production operations;
6) Interim reclamation activities;
7) Spill response and remediation;
8) Plugging and abandonment; and
9) Final site reclamation
The potential waste streams identified for operations at the South Leverich 13-09 pad are listed in Table
1, Potential Waste Streams by Operations Phase. This table identifies the types of waste streams likely to
be generated during development of the proposed wells and the operational phase when the waste may
occur.
Table 1, Potential Waste Streams by Operations Phase.
Potential Waste
Streams Operational Phase Description
Drilling Fluids Drilling Operations
Water-based circulating fluid/mud used in drilling operations
to clean and condition the hole and to counterbalance
formation pressure.
Drill Cuttings Drilling Operations
Drill cuttings, and small quantities of cured cement in the
shoe track, generated by drilling into the subsurface
geological formations.
Excess Cement Drilling Operations
Excess cement circulated to surface to protect groundwater
and comply with COGCC Rule 408.i.(2) when conductor
/surface casing is set.
Frac Sand Completions Returned frac sand following completion operations.
Produced Water Completion, Flowback,
and Production
Produced water utilized during well completion operations
and returned fluid during flowback and production.
Contaminated Soils All Phases Soils contaminated at any phase of development.
Sewage All Phases
Sewage generated while location is occupied during
construction, drilling, completion, flowback, and potentially
production activities.
Solid Waste / Trash All Phases Solid waste materials produced during any phase of
development at the Oil and Gas Location.
TYPES OF WASTES AND DISPOSAL METHODS
Drilling Fluids Management
Unless noted otherwise, water-based drilling fluids will be utilized during drilling operations on the
proposed oil and gas location and are classified as E&P waste. During drilling operations water-based
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drilling fluids are necessary to ensure proper well control and to return cuttings generated during
construction of the well back to the surface. Drilling fluids are pumped down hole and returned up the
annulus and processed through a closed loop drilling fluid system separating liquids and solids. Drilling
fluids will be re-used throughout the drilling process on the multi-well Oil and Gas Location. Once
drilling operations are complete, drilling fluids will be processed through solids control and dewatering
equipment on the Oil and Gas Location to reduce volume and weight of the drilling fluid. The processed
drilling fluid is then stored in tanks and recycled for future drilling operations. Approximately one
thousand barrels (1,000bbls) of drilling fluids could be recycled for future drilling operations following
completion of drilling operations.
Drill Cuttings Management
Drill cuttings generated during drilling operations on the South Leverich 13-09 pad will be managed
within a cuttings trench constructed along the south side of the pad. The cuttings trench will be
approximately 424 feet in length by 50 feet in width, with a depth between 13 feet and 19 feet. The
estimated volume of drill cuttings generated per well at this location is approximately 590 cubic yards
(cy). Hence, the total volume of drill cuttings estimated for the 21 proposed wells to be drilled at this
location is approximately 12,390 cy. The cuttings trench has been designed with a maximum capacity of
6,360 cy, which is approximately 51 percent of the expected cuttings volume. Once the trench has
reached capacity, cuttings will be stacked against the cut slope of the pad. Any remaining cuttings will be
hauled to a commercial disposal facility. The cuttings trench will be constructed with a two and one-half
foot (2.5’) high earthen berm extending along the north side of the cuttings trench to ensure containment
of drill cuttings. A wildlife ramp will be constructed near the east end of the trench to prevent entrapment.
Please see the Layout Drawings attached to the Form 2A for additional details on the proposed cuttings
trench. Also, please see the Access Road Map attached to the Form 2A for details on the haul route from
I-70 to the Oil and Gas Location.
Protocol for Managing Cuttings
As water-based bentonite drill cuttings (to be managed as Oily Waste per COGCC Rule 905.g.(1)C) are
brought to the surface, they will be temporarily placed into a high-walled, heavy-duty, metal storage bin
that is placed close to the rig’s shaker assembly. If needed, sawdust (or another acceptable, inert fill
material) may be mixed with the cuttings during this phase to moderate and reduce the moisture content
of the cuttings. Once the storage bin becomes full, a loader is used to move the cuttings from the storage
bin to multiple 3-sided storage bins for mixing with clean fill material and sampling. Once all drill
cuttings are placed into the cuttings trench, contingency sampling will occur if the background sampling
has determined TEP is not yet in compliance with COGCC Table 915-1 standards. Additional treatment
or amendment of the cuttings may be needed to ensure that COGCC Table 915-1 standards are met prior
to reclamation. If needed, additional clean fill material may be mixed with the cuttings to ensure that
cleanup standards are met. Representative samples of the blended material will be collected and submitted
to an approved analytical laboratory and analyzed for the full COGCC list of organic, inorganic, and
metal compounds (in soils) to confirm that the drill cuttings comply with the appropriate COGCC Table
915-1 cleanup standards (see detailed sampling protocols below). After the representative drill cuttings
sample data has been received and confirm compliance with COGCC cleanup standards, TEP will submit
a Form 27 for Director approval for cuttings burial during interim reclamation.
The moisture content of any water/bentonite-based drilling mud (WBM) generated cuttings will be
minimized through good engineering practices and mechanical processes to prevent the accumulation of
liquids greater than de minimis amounts. In cases where weather conditions, safety concerns, or
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operational constraints require, drill cuttings may be transported via truck to an approved third-party
commercial disposal facility in accordance with COGCC rules for treatment and final disposal.
Drilling Cuttings Sampling Protocol
Water-based bentonite drill cuttings (to be managed as Oily Waste per COGCC Rule 905.g.(1)C)
generated during construction of the proposed wells will be sampled and characterized for compliance
with COGCC Table 915-1 Cleanup Concentrations.
All samples will be collected by qualified individuals experienced with sampling and sent to a laboratory
certified by the National Environmental Laboratory Accreditation Program.
Representative Samples of water-based bentonite drilling cuttings (to be managed as Oily Waste per
COGCC Rule 905.g.(1)C) will be collected and analyzed in accordance with COGCC Rule 900 series.
Sampling activities and methods will adhere to COGCC applicable rules and will follow soil sampling
procedures. Soil samples will consist of composite samples, a combination of two or more samples
collected at different times, depths, or locations within a specified sample area. Upon collection of each
composite sample, the individual aliquots will be combined and blended to represent one sample.
Equipment used for sample collection will be decontaminated prior to each sample to prevent cross-
contamination.
Soil samples will be collected in laboratory-approved sterilized containers and preservatives will be
obtained from the contract laboratory. Soil samples will be analyzed for contaminants as listed in COGCC
Table 915-1 Concentration Levels.
All drilling cuttings generated from the proposed wells will be characterized based on the following
sampling procedure to ensure consistency, comparability, and completeness of data.
Baseline Sampling: As drill cuttings are generated during well construction on the South Leverich 13-09
pad, cuttings will be stockpiled and blended with clean fill material in multiple 3-sided bins prior to
storage in the cuttings trench. Based on geology and proposed drill depth, TEP estimates about 590 cubic
yards of water-based bentonite drilling cuttings (to be managed as Oily Waste per COGCC Rule
905.g.(1)C) will be generated from each well. Baseline samples of the cuttings will be collected to assess
constituent levels listed in COGCC Table 915-1, the cuttings pile will then be thoroughly mixed with
clean fill material to create a composite of the stored materials prior to placement in the cuttings trench.
TEP anticipates that the drill cuttings to soil ratio will be 1:1. Any excess material excavated during initial
grading activities will be utilized for blending material. Composite soil samples will be collected once
blending is complete.
A 6-point composite sample will be collected for every 590 cubic yards of material placed in the trench.
Each point will represent approximately 100 cubic yards as recommended by COGCC’s Rule 915.e.(2)
Soil Sampling and Analysis Guidance document. All twenty-one (21) wells will be drilled in the same
geologic formation.
All six composite samples will be collected at random depths at least one foot below the surface of the
pile within the cuttings bin(s). A homogenous sample of the accumulated cuttings will be analyzed
according to Table 915-1 criteria, since all cuttings accumulated will be from the same geologic formation
using the same drilling mud program. This data set will also establish baseline criteria levels for future
remediation and reclamation. Per Rule 913.b.(2).C. “[c]omposite sample results may be submitted for
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preliminary analysis and waste profiling. Discrete sample results will be required for confirmation
sampling.”
Contingency Sampling: If the blended water-based bentonite drilling cuttings (to be managed as Oily
Waste per COGCC Rule 905.g.(1)C.) do not meet Table 915-1 (or current COGCC analytical
requirements), the 590 cubic yard treatment cell, from which the composite samples were taken, will
undergo additional blending and aeration/turning process on location. Samples will be collected
approximately 2 weeks after re-blending. After treatment, on average, water-based bentonite drilling
cuttings samples will be collected monthly until stored material meets Table 915-1 or are within
background limits in the footnotes listed in Table 915-1.
Soils that were in contact with (beneath or adjacent to) the cuttings treatment area will be sampled
according to Table 915-1 criteria and remediated as appropriate.
Final Disposition of Waste: The material will be sampled and analyzed to determine if cuttings are in
compliance with Table 915-1. Once the water-based bentonite drilling cuttings meet the requirements of
Table 915-1 as determined upon sampling and analysis, the water-based bentonite drilling cuttings will be
managed and disposed of pursuant to Rule 905.g.(2) Drill Cuttings.
“Operators will demonstrate compliance with Table 915-1 through sampling and analysis. Management
of drill cuttings that exceed Table 915-1 for constituents listed under soil suitability for Reclamation by
the methods listed below is subject to prior approval by the Director, pursuant to Rule 915.b. Operators
may manage drill cuttings that comply with Table 915-1, are not Oily Waste, and are generated using
water-based bentonitic drilling fluids through one of the following methods:”
Water-based bentonite drilling cuttings at the South Leverich 13-09 pad will be buried in accordance with
Rule 905.g.(2).E. Subject to Surface Owner approval, and prior to Director approval of a Form 27,
burial in a cuttings trench. The treated drill cuttings will serve as fill material to allow for natural
contouring during reclamation of the site. Pending Director approval of the Form 27, TEP will use
salvaged topsoil as coverage in accordance with Rule 1003.e.(2) Revegetation of non-crop lands.
“All segregated soil horizons removed from non-crop lands shall be replaced to their original relative
positions and contour as near as practicable to achieve erosion control and long-term stability, and shall
be tilled adequately in order to establish a proper seedbed.”
The cuttings trench will be re-contoured to blend as nearly as possible with the natural topography per the
South Leverich 13-09 Reclamation Plan.
As required by Rule 905.g.(2).E, TEP will submit a Form 27 for Director approval for final cuttings burial
during interim reclamation. TEP intends to permanently bury drilling cuttings onsite in the cuttings
trench.
Per the South Leverich 13-09 Reclamation Plan, Interim Reclamation of the South Leverich 13-09 pad
will begin within six (6) months following completion of drilling and well completion operations. A
working area (production pad) must be maintained around each wellhead and production equipment to
ensure site accessibility and safe working conditions during long-term production operations.
Excess Cement
Wellbore cement that is returned to surface during cementing operations of the surface casing and
conductor sections will be diverted to, and accumulated in, an open-top bin on location. This cement
waste stream, defined as Excess Cement on Table 1, will subsequently be transported as solid waste via
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truck to an approved disposal facility in accordance with COGCC rules for treatment and final disposal.
Solidified excess cement waste will be managed separately on location to minimize the number of trucks
and miles driven by maximizing volume per truck load. Excess cement generated while setting surface
casing and the conductor, while circulated downhole, does not contact any hydrocarbon zones.
Frac Sand & Filter Socks
Returned stimulation fluids generated during flowback operations are processed through two (2), four (4)
phase separators to remove gas, water, condensate, and sand. Water will be reused during future well
completion operations on the South Leverich 13-09 pad or transported via pipelines as described in the
Produced Water section below. Frac sand will be managed within a forty-foot (40’) by forty-foot (40’)
earthen containment cell with two and one-half foot (2.5’) high earthen berms surrounding all sides of the
containment cell. This frac sand containment cell will be located on pad within the pad perimeter berm.
Once flowback operations are complete, returned frac sand will be hauled off-site to an approved
Centralized E&P Waste Management Facility or third-party commercial disposal facility.
Spent filter socks generated during the completion / flowback process are collected and stored separately
from garbage / trash. The filters will be sampled and profiled for disposal at an approved third-party
commercial disposal facility that is permitted and authorized to accept waste filter socks for disposal.
Please see the Waste Handling Table (Table 5) below for additional details.
Produced Water
Produced water (water produced from the wells after the wells are turned over to production) will be
transported through the proposed four-inch (4”) produced water pipeline to the tie-in point with an
existing four-inch (4”) water pipeline at the Youberg SR 43-12 pad (Location ID 413683). Water will
then be transported via existing water pipelines to one of the following TEP-operated Centralized E&P
Waste Management Facilities for treatment, recycling, or disposal.
Table 2, Existing E&P Waste Management Facilities
Facility Name Location COGCC
Location ID
COGCC
Facility ID
Spruce Creek 14-4-794 SWSW Section 4 T7S R94W 427810 441099
Smith Gulch 31-32-796 NWNW Section 32 T7S R96W 430110 446561
KP 32-17 Completions Pit SWNE Section 17 T6S R91W 323844 418807
Parachute E&P
Waste Management Facility SWSW Section 36 T6S R96W -- 149015
Rulison E&P
Waste Management Facility NWSW Section 20 T6S R94W -- 149006
Mautz Ranch E&P Waste Fac. SENW Section 19 T2S R98W 422672 444993
Produced water will be treated with biocide at the water management facility. Produced water will also be
treated with biocide prior to disposal if necessary. Produced water is then disposed of through (1) natural
evaporation at the evaporation ponds, (2) delivered and injected into one of the approved TEP-operated
underground injection control (“UIC”) facilities, (3) re-used in hydraulic fracturing operations, or (4)
hauled to an approved third party, commercial disposal facility as described below.
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Natural Evaporation Ponds
Produced water that has been collected and treated at any of the various Centralized E&P waste
management facilities is stored in large, lined, engineered evaporation storage ponds that have been
permitted and constructed to comply with COGCC Rule 907, Centralized E&P Waste Management
Facilities, Rule 909 Pits – Construction and Operation, and Rule 910 Pit Lining Requirements and
Specifications. These water storage ponds are purposefully designed with a large surface area to
maximize evaporation of the produced water. Exposure to the sun, warm temperatures, and wind
effectively evaporate water from the ponds and return that water to the atmosphere and ultimately to the
hydrologic cycle. The arid climate of western Colorado is an ideal location for use of natural evaporation
ponds as the annual evaporation rate typically is 3 – 4 times the annual precipitation rate for the area.
Underground Injection Control (UIC) Facilities
Disposal of produced water at permitted underground injection control facilities is another viable option
for disposal of excess produced water. Currently, TEP owns and operates 38 UIC injection wells (see
Table 3) that are used for produced water disposal as needed. These UIC disposal wells / facilities are a
critical component of TEP’s water management process as they help to maintain the balance between the
total volume of production water generated, and the volume of water that is re-used / recycled or
otherwise evaporated. All UIC facilities have been permitted per the Rule 800 series.
Table 3, Approved UIC Facilities
Well Name Location UIC Facility
Number Ownership API
Circle B Land 33A-35-692 NWSE-S35-T6S-R92W 159277 Fee 05-045-18493
GGU Roderick NENW-S31-T6S-R91W 159176 Fee 05-045-13803
Scott 41D-36-692 NENE-S36-T6S-R92W 159159 Fee 05-045-11169
Specialty 13A-28 NWSW-S28-T6S-R92W 159212 Fed 05-045-14054
KP SWD 9-12D NESE-S8-T6S-R91W 159301 Fee 05-045-18532
PWD Federal 21-6 SWSE-S21-T6S-R91W 159479 Fed 05-045-21277
GM 14-36 Lot 4-S36-T6S-R96W 159262 Fee 05-045-07501
GM 239-36 NESW-S36-T6S-R96W 159369 Fee 05-045-14693
GM 523-36 NESW-S36-T6S-R96W 159266 Fee 05-045-13979
GM 923-1D SWNE-S1-T7S-R96W 159295 Fee 05-045-18424
GM 931-1D SWNE-S1-T7S-R96W 159297 Fee 05-045-18425
GM 943-1D SWNE-S1-T7S-R96W 159296 Fee 05-045-18426
Fed 299-23-1 SESW-S23-T2S-R99W 159478 Fed 05-103-10488
Fed 299-23-2 NESE-S23-T2S-R99W 159452 Fed 05-103-10490
Fed 299-26-1 SWNW-S26-T2S-R99W 160001 Fed 05-103-10364
Fed 299-26-2 NWNW-S26-T2S-R99W 159413 Fed 05-103-10538
Fed 299-27-5 SWNE-S27-T2S-R99W 159317 Fed 05-103-10624
Fed 299-27-6 NENW-S27-T2S-R99W 159396 Fed 05-103-10644
RG 41-16-397 NWNE-S16-T3S-R97W 159410 Fed 05-103-11517
RMV 215-21 NESW-S21-T6S-R94W 159388 Fee 05-045-07465
RWF 434-21 SWSE-S21-T6S-R94W 159386 Fee 05-045-10469