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Home My WebLink AboutRADEMACHER 14-30HZ - Other - Kerr McGee - 3/25/2024 (2)State of Colorado Energy & Carbon Management Commission 1120 Lincoln Street, Suite 801, Denver, Colorado 80203 Phone: (303) 894-2100 Fax: (303) 894-2109 Oil and Gas Location Assessment FORM 2A Rev 05/22 This Oil and Gas Location Assessment is to be submitted to the COGCC for approval prior to any ground disturbance activity associated with oil and gas operations. Approval of this Oil and Gas Location Assessment will allow for the construction of the below specified Location; however, it does not supersede any land use rules applied by the local land use authority. Please see the COGCC website at https://cogcc.state.co.us/ for all accompanying information pertinent this Oil and Gas Location Assessment. Document Number: 403278425 09/13/2023 Date Received: This Location includes a Rule 309.e.(2).E variance request. This Location is within 2,640 feet of a GUDI or Type III Well per Rule 411.b.(4). This Location or its associated new access road, utility, or Pipeline corridor meets Rule 309.e.(2).A, B, or C. CONSULTATION This location is included in a Comprehensive Area Plan (CAP). CAP ID # X This location includes a Rule 309.f.(1).A.ii. variance request. djregulatory@oxy.com (720) 9296564 ( ) Rachel Friedman email: Fax: Phone: Contact Information Name: 80217-3779COZip:State:DENVER P O BOX 173779 KERR MCGEE OIL & GAS ONSHORE LP 47120 City: Address: Name: Operator Operator Number: FINANCIAL ASSURANCE FOR THIS LOCATION (check all that apply) Plugging, Abandonment, and Reclamation 20010124 Gas Gathering, Gas Processing, and Underground Gas Storage Facilities Centralized E&P Waste Management Facility X Federal Financial Assurance In checking this box, the Operator certifies that it has provided or will provide at least this amount of Financial Assurance to the federal government for one or more Wells on this Location. Amount of Federal Financial Assurance $ Surface Owner Protection Bond. New LocationX Refile Amend Existing Location # If this Location assessment is a component of an Oil and Gas Development Plan (OGDP) application, enter the OGDP docket number(s). Docket Number OGDP ID OGDP Name 230900284 If this Location assessment is part of an approved Oil and Gas Development Plan, enter the OGDP ID number(s). OGDP ID Number OGDP Name 485787 SPROUT 14-30HZ Number:RADEMACHER Name: LOCATION IDENTIFICATION 03/05/2027Expiration Date: Location ID:486288 OGDP ID:485787 Page 1 of 31Date Run: 3/19/2024 Doc [#403278425] 04/11/20011.5 Date of Measurement:GPS Quality Value: 4820667W 3N 30 Ground Elevation:Meridian:Township:SESW QuarterQuarter:Section: Provide the location description and the latitude and longitude of a single point near the center of the Working Pad Surface as a reference for this Location. Range: Type of GPS Quality Value:PDOP Latitude:40.191307 Longitude:-104.933703 RELEVANT LOCAL GOVERNMENT SITING INFORMATION WELD Municipality: Per § 34-60-106 (1)(f)(I)(A), the following questions pertain to the “Relevant Local Government approval of the siting of the proposed oil and gas location.” N/ACounty: This proposed Oil and Gas Location is in an area designated as one of State interest and subject to the requirements of § 24-65.1-108, C.R.S. Yes Does the Relevant Local Government regulate the siting of Oil and Gas Locations, with respect to this location?Yes A siting permit application has been submitted to the Relevant Local Government for this proposed Oil and Gas Location:Yes Date Relevant Local Government permit application submitted:08/22/2023 Current status or disposition of the Relevant Local Government permit application for this proposed Oil and Gas Location:Approved Status/disposition date:11/02/2023 If Relevant Local Government permit has been approved or denied, attach final decision document(s). Provide the contact information for the Relevant Local Government point of contact for the local permit associated with this proposed Oil and Gas Location: Stephanie FrederickContact Name:Contact Phone:970-400-3581 Contact Email:sfrederick@weldgov.com PROXIMATE LOCAL GOVERNMENT INFORMATION For every Proximate Local Government (PLG) associated with this proposed Oil and Gas Location, provide the PLG’s point of contact and their contact information. Type of Proximate Govt County Municipality Contact Name Contact Phone Contact Email Municipality Firestone Todd Bjerkaas 303-531-6276 TBjerkaas@firestoneco. gov (Enter as many Related Locations as necessary. Enter the Form 2A document # only if there is no established COGCC Location ID#) This proposed Oil and Gas Location is:LOCATION ID #FORM 2A DOC # RELATED REMOTE LOCATIONS FEDERAL PERMIT INFORMATION A Federal drilling permit (or related siting application) has been submitted for this proposed Oil and Gas Location: No Date submitted: Current status or disposition of the Federal drilling permit (or related siting application) for this proposed Oil and Gas Location: Status/disposition Date: If Federal agency permit has been approved or denied, attach the final decision document(s). Provide the contact information of the Federal point of contact for the Federal permit associated with this proposed Oil and Gas Location. Contact Name:Contact Phone: Contact Email:Field Office: Page 2 of 31Date Run: 3/19/2024 Doc [#403278425] Additional explanation of local and/or federal process: COMMENT: A WELD COUNTY PERMIT WAS SUBMITTED 8/22/23 and determined complete 9/12/23 No 08/31/2022Date of local government consultation: Complete this section for any pre-application consultation related to this proposed Oil and Gas Location that occurred prior to the submission of this Form 2A. If a pre-application Formal Consultation Process occurred, attach a Consultation Summary. RELEVANT LOCAL GOVERNMENT OR FEDERAL PRE-APPLICATION CONSULTATION Did a pre-application Formal Consultation Process occur with the Federal land manager per Rule 301.f.(3)? Did a pre-application Formal Consultation Process occur with the Relevant Local Government per Rule 301.f.(3)?Yes Date of federal consultation: Was an ALA that satisfies Rule 304.b.(2).C (or substantially equivalent information per Rule 304.e) developed during a federal or local government permit application process? If yes, attach the ALA to the Form 2A. No Complete this section for any pre-application consultation related to this proposed Oil and Gas Location that occurred prior to the submission of this Form 2A. If a pre-application Formal Consultation Process occurred, attach a Consultation Summary. ALA APPLICABILITY AND CRITERIA If YES, indicate by checking the box for every Rule 304.b.(2).B criterion met by this proposed Location, and attach an ALA. See Rule 304.b.(2).B.i-x for full text of criteria. Does the proposed Oil and Gas Location meet any of the criteria listed in Rule 304.b.(2)B?Yes i. WPS < 2,000 feet from RBU/HOBUX ii. WPS < 2,000 feet from School/Child Care Center iii. WPS < 1,500 feet from DOAA iv. WPS < 2,000 feet from jurisdictional boundary and PLG objects/requests ALA v. WPS within a Floodplain vi.aa. WPS within a surface water supply area vi.bb. WPS < 2,640 feet from Type III or GUDI well vii. WPS within/immediately upgradient of wetland/riparian corridor viii. WPS within HPH and CPW did not waive ix. Operator using Surface bond X x. WPS < 2,000 feet from RBU/HOBU/School within a DIC X Is the proposed Oil and Gas Location within the exterior boundaries of the Southern Ute Indian Reservation, and the Tribe objects to the Location or requests an ALA? If YES, attach an ALA to the Form 2A. Operator requests the Director waive the ALA requirement per Rule 304.b.(2).A.i: No Provide an explanation for the waiver request, and attach supporting information (if necessary). Page 3 of 31Date Run: 3/19/2024 Doc [#403278425] ALTERNATIVE LOCATIONS DASHBOARD List every alternative location reviewed and included in the ALA. Provide a latitude and longitude for the approximate center of the alternative location, all Rule 304.b.(2).B Criteria met, if a variance would be required to permit the location, and a brief comment on the key points of the alternative location. #latitude longitude i ii iii iv v vi vii viii ix x Variance Required?Comments 40.195011 -104.874396 x x Sec 27: 3 RBUs with 2,000 feet of the working pad surface A Riverine corridor in the open area reduces the amount of available acreage The location would place the heels of the wellbores in the Longmont Fault, increasing operational risk 45% of the DSU would be left undeveloped without a second surface location This Location is located within crop land. KMOG attempts to avoid or minimize the impact to agriculture 40.196461 -104.949765 x Sec 25: The location is 1 foot north of an NWI mapped freshwater emergent wetland. Future housing development and school planned in this location. Approximately 1760 acres or 47% of the development could not be developed from this location without a second location. This alternative location is within cropland. 40.183026 -104.893612 Sec 33: KMOG would not be able to fully develop 60% of the DSU without a second or potentially third location. This location is located within crop land. KMOG attempts to avoid or minimize the impact to agriculture which is important to both the landowners and the relevant local government, Weld County 40.196033 -104.893711 x x Sec 28: Three RBUs with 2,000 feet of the working pad surface . Within a floodplain Approximately 1600 acres or 45% of the development could not be developed from this location without a second location. This Location is located within crop land. KMOG attempts to avoid or minimize the impact to agriculture which is important to both the landowners and the relevant local government, Weld County. 304.b.(2).B.i-x Criteria Met: SURFACE & MINERAL OWNERSHIP Page 4 of 31Date Run: 3/19/2024 Doc [#403278425] Name:Boedle Creek LLC Phone: Fax:21671 S. 223rd Pl Address: Address: Email:dale@road13.com City:Queen Creek State:AZ Zip:85142 Surface Owner Info: X IndianFederalStateFeeSurface Owner at this Oil and Gas Location: All operations on this Oil & Gas Location will develop the minerals beneath the Location, and the Operator intends to use a surface bond per Rule 703 to secure access to this Location – attach lease map or provide lease description. All operations on this Oil & Gas Location will develop the minerals beneath the Location, and the surface owner owns the minerals beneath this Location and is committed to an oil and gas lease – attach lease map or provide lease description. The Operator has a signed Surface Use Agreement for this Location – attach SUA. The Operator/Applicant is the surface owner. Check only one: X Minerals beneath this Oil and Gas Location will be developed from or produced to this Oil and Gas Location: Mineral Owner beneath this Oil and Gas Location: Surface Owner protection Financial Assurance type:Surety ID Number: Lease description if necessary: X IndianFederalStateFee Yes N/A Wells Indicate the number and type of major equipment components planned for use on this Oil and Gas Location: SITE EQUIPMENT LIST 18 Drilling Pits 0 Pump Jacks 18 Gas or Diesel Motors 0 Dehydrator Units 0 Oil Tanks 0 Production Pits 0 Separators 5 Electric Motors 0 Vapor Recovery Unit 0 Condensate Tanks 1 Special Purpose Pits 0 Injection Pumps 0 Electric Generators 0 VOC Combustor 1 Water Tanks 4 Multi-Well Pits 0 Heater-Treaters 0 Fuel Tanks 0 Flare 0 Buried Produced Water Vaults 0 Modular Large Volume Tank 1 Gas Compressors 0 LACT Unit 1 Enclosed Combustion Devices 0 Pigging Station 0Meter/Sales Building 2 Vapor Recovery Towers 0 OTHER PERMANENT EQUIPMENT Permanent Equipment Type Number FG Scrubbers 1 Communication Towers 1 E Houses 1 Air Compressors 1 Chemical Totes 4 Well Manifold 18 Electrical Boxes 2 OTHER TEMPORARY EQUIPMENT Page 5 of 31Date Run: 3/19/2024 Doc [#403278425] Temporary Equipment Type Number Water Tanks 32 Enclosed Combustion Devices 7 Propane Tanks 1 Purge Flares 3 Generator 1 FLOWLINE DESCRIPTION Per Rule 304.b.(6), provide a description of all onsite and off-location oil, gas, and/or water flowlines. Flowlines - 2""-3"" size (outside diameter), constructed of carbon steel. Oil, gas and water pipelines will be used at this location. Water for completions operations will be brought to the location through temporary water lines using KMOG's Water on Demand system. The oil and gas pipelines will be constructed by a 3rd party midstream company. GAS GATHERING COMMITMENT Operator commits to connecting to a gathering system by the Commencement of Production Operations? If the answer is NO, a Gas Capture Plan consistent with the requirements of Rule 903.e MUST be attached on the Plans tab. Yes Provide the distance and direction to the nearest cultural feature as measured from the edge of the Working Pad Surface. Building:1083 Feet Designated Outside Activity Area:5280 Feet Public Road:1782 Feet Above Ground Utility:1718 Feet Railroad:5280 Feet Property Line:61 Feet CULTURAL DISTANCE AND DIRECTION Distance W SW W W W S Direction School Facility:5280 Feet Child Care Center:5280 Feet S S Rule 604.b Conditions Satisfied (check all that apply): 604.b. (1)Details of Condition(s) Disproportionately Impacted (DI) Community: 5280 Feet S 604.b. (2) 604.b. (3) 604.b. (4) XResidential Building Unit (RBU):1139 Feet W High Occupancy Building Unit(HOBU)5280 Feet S SFeet5280RBU, HOBU, or School Facility within a DI Community. RULE 604.a.(2). EXCEPTION LOCATION REQUEST Operator requests an Exception Location Request from Rule 604.a.(2) [well is less than 150 feet from a property line]. Exception Location Request Letter and Waiver signed by offset Surface Owner(s) must be attached. CULTURAL FEATURE INFORMATION REQUIRED BY RULE 304.b.(3).B. Provide the number of each Cultural feature identified within the following distances, as measured from the Working Pad Surface: Building Units 0 0-500 feet 0 501-1,000 feet 3 1,001-2,000 feet Page 6 of 31Date Run: 3/19/2024 Doc [#403278425] Residential Building Units High Occupancy Building Units School Properties School Facilities Designated Outside Activity Areas 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2 Drilling Fluids Disposal: DRILLING WASTE MANAGEMENT PROGRAM OFFSITE Commercial DisposalDrilling Fluids Disposal Method: Cutting Disposal:OFFSITE Commercial DisposalCuttings Disposal Method: Other Disposal Description: PLEASE SEE ATTACHED WASTE MANAGEMENT PLAN Multiple E&P waste management facilities are used - they are outlined in the Waste Management Plan Beneficial reuse or land application plan submitted?Yes Reuse Facility ID:or Document Number: Centralized E&P Waste Management Facility ID, if applicable:456644 Will a closed-loop drilling system be used? Is H2S gas reasonably expected to be encountered during drilling operations at concentrations greater than Will salt based (>15,000 ppm Cl) drilling fluids be used? Will salt sections be encountered during drilling: Estimated post-construction ground elevation: Size of location after interim reclamation in acres: 12.77Size of disturbed area during construction in acres: CONSTRUCTION 4.25 DRILLING PROGRAM Yes No Will oil based drilling fluids be used?Yes 4820 or equal to 100 ppm?If YES, attach H2S Drilling Operations Plan.No No CURRENT LAND USE Other Residential RecreationForestry CommercialIndustrial Rangeland Conservation Reserve Program (CRP)Non-IrrigatedIrrigated Subdivided: Non-Crop Land: Crop Land: Current Land Use: check all that apply per Rule 304.b.(9). X Describe the current land use: AGRICULTURE Describe the Relevant Local Government’s land use or zoning designation: AGRICULTURE Describe any applicable Federal land use designation: N/A Final Land Use: check all that apply per Rule 304.b.(9). X FINAL LAND USE Page 7 of 31Date Run: 3/19/2024 Doc [#403278425] Other Residential RecreationForestry CommercialIndustrial Rangeland Conservation Reserve Program (CRP)Non-IrrigatedIrrigated Subdivided: Non-Crop Land: Crop Land: Reference Area Latitude: If Final Land Use includes Non-Crop Land (as checked above), the following information is required: Describe landowner’s designated final land use(s): REFERENCE AREA INFORMATION AGRICULTURE Reference Area Latitude: Provide a list of plant communities and dominant vegetation found in the Reference Area. < No row provided > Noxious weeds present: SOILS List all soil map units that occur within the maximum extent of the proposed Oil and Gas Location. Attach the National Resource Conservation Service (NRCS) report showing the "Map Unit Description" listing the typical vertical soil profile(s). This data is to be used when segregating topsoil. The required information can be obtained from the NRCS website at https://www.nrcs.usda.gov/wps/portal/nrcs/surveylist/soils/survey/state/ or from the COGCC website GIS Online map page. Instructions are provided within the COGCC website help section. NRCS Map Unit Name:24-Fort Collins loam, 0 to 3 percent slopes NRCS Map Unit Name:50-Otero sandy loam 0 to 1 percent slopes NRCS Map Unit Name:68-Ustic Torriorthents, moderately steep GROUNDWATER AND WATER WELL INFORMATION Provide the distance and direction, as measured from the Working Pad Surface, to the nearest: water well:984 Feet N Spring or Seep:5280 Feet N Estimated depth to shallowest groundwater that can be encountered at this Oil and Gas Location:Feet Basis for estimated depth to and description of shallowest groundwater occurrence: SB00306732BCB1 Water level - 7.26' (4805.02-7.26= 4797.76) 4820.1-4797.76 = 22.5 Rounded to 23' 23 SURFACE WATER AND WETLANDS Provide the distance and direction to the nearest downgradient surface Waters of the State, as defined in the 100-Series Rules, measured from the Working Pad Surface: Feet W28 If less than 2,640 feet, is the Waters of the State identified above within 15 stream miles upstream of a Public Water System intake?No Provide the distance and direction to the nearest downgradient wetland, measured from the Working Pad Surface:WFeet28 Page 8 of 31Date Run: 3/19/2024 Doc [#403278425] DELINEATED WETLAND Provide a description of the nearest downgradient surface Waters of the State: If the proposed Oil and Gas Location is within a Rule 411.a Surface Water Supply Area buffer zone, select the buffer If the proposed Oil and Gas Location is within a Rule 411.b GUDI/Type III buffer zone, select the buffer Is a U.S. Army Corps of Engineers Section 404 permit required for the proposed Oil and Gas Location, access road, or If a U.S. Army Corps of Engineers Section 404 permit is required, provide the permit status, and permit number if available: zone type: associated pipeline corridor?No zone type: Public Water System Administrator - Contact Name Email Public Water System Administrator - Contact Name Email Is the Location within a Floodplain?No Floodplain Data Sources Reviewed (check all that apply): Federal (FEMA)X State X County Local Does this proposed Oil and Gas Location lie within a Sensitive Area for water resources, as defined in the Yes Other 100-Series Rules? CONSULTATION, WAIVERS, AND EXCEPTIONS This Oil and Gas Location or associated new access road, utility, or pipeline corridor falls within federally designated critical habitat or an area with a known occurrence for a federal or Colorado threatened or endangered species. Provide description in Comments section of Submit tab. X When Rule 309.e.(2) Consultation must occur, check all that apply: This location is included in a Wildlife Mitigation Plan This Oil and Gas Location or associated new access road, utility, or pipeline corridor falls within an existing conservation easement established wholly or partly for wildlife habitat. Provide description in Comments section of Submit tab. When Rule 309.e.(3) Consultation is not required, check all that apply: This Oil and Gas Location has been included in a previously approved, applicable Wildlife Protection Plan. This Oil and Gas Location has been included in a previously approved, applicable Wildlife Mitigation Plan. This Oil and Gas Location has been included in a previously approved, applicable conservation plan. Pre-application Consultation: X A pre-application consultation with CPW, regarding this Oil and Gas Location, occurred on: 02/08/2023 CPW Waivers and Exceptions (check all that apply and attach all CPW waivers to this Form 2A): The applicant has obtained a Rule 304.b.(2).B.viii CPW waiver for the requirement to complete an ALA. The applicant has obtained a Rule 309.e.(2).G CPW waiver and consultation is not required. The applicant has obtained a Rule 309.e.(5).D.i CPW waiver and is requesting an exception from Rule 1202.c. (1).R. The applicant has obtained a Rule 309.e.(5).D.ii CPW waiver and is requesting an exception from Rule 1202.c. (1).S. Page 9 of 31Date Run: 3/19/2024 Doc [#403278425] No Target Species BMP Type Description 1 MULE DEER & ELK Wildlife - Minimization If new oil and gas operations must occur within CPW-mapped mule deer and elk severe winter range and/or winter concentration areas, the operator agrees to conduct new oil and gas operations outside the time period from December 1 through April 30. Operator Proposed Wildlife BMPs No BMP CPW Proposed Wildlife BMPs The applicant has obtained a Rule 309.e.(5).D.iii CPW waiver of Rule 1202.c.(1).T. The applicant has obtained a Rule 309.e.(5).D.iv CPW waiver and is requesting an exception from Rule 1202.c.(1) in accordance with an approved CAP. The applicant has obtained a Rule 1202.a CPW waiver. The applicant has obtained a Rule 1202.b CPW waiver. In accordance with Rule 1203.a.(3), the applicant requests an exception from compensatory mitigation Rule(s): HIGH PRIORITY HABITAT AND COMPENSATORY MITIGATION This Oil and Gas Location, associated access roads, utility, or Pipeline corridor falls wholly or partially within the following High Priority Habitats (Note: dropdown options are abbreviated - see Rule 1202 for full rule text): High Priority Habitat (list all that apply) Oil and Gas Location Access Road Utility or Pipeline Corridor 1202.d.(3) - Mule deer migration & winter x x x The following questions are for Oil and Gas Locations that cause the density to exceed one Oil and Gas Location per square mile in Rule 1202.d High Priority Habitat: Direct Impacts: Is Compensatory Mitigation required per Rule 1203.a for this Oil and Gas Location? Is a Compensatory Mitigation Plan proposed to address direct impacts for this Oil and Gas Location? Have all Compensatory Mitigation Plans been approved for this Location? If not, what is the current status of each Plan? N/A Is a Compensatory Mitigation Fee proposed for this Oil and Gas Location? Direct impact habitat mitigation fee amount: $ No No Yes 13750 Yes Indirect Impacts: Is a Compensatory Mitigation Plan proposed to address indirect impacts for this Oil and Gas Location? Have all Compensatory Mitigation Plans been approved for this Location? If not, what is the current status of each Plan? N/A Is a Compensatory Mitigation Fee proposed for this Oil and Gas Location? Indirect impact habitat mitigation fee amount: $ No No No No 0 Is Compensatory Mitigation required per Rule 1203.d for this Oil and Gas Location? Page 10 of 31Date Run: 3/19/2024 Doc [#403278425] AIR QUALITY MONITORING PROGRAM Will the Operator install and administer an air quality monitoring program at this Location?Yes No BMP Target CDPHE Recommendation COGCC Action Air Description Operator will use lease automated custody transfer (LACT) system to remove/reduce the need for truck loadout CDPHE Comment Water Description Dust suppression: Operator will not use produced water or other process fluids for dust suppression CDPHE Comment Water Description Documentation / stormwater management plan: If it is infeasible to install or repair a control measure immediately after discovering a deficiency, operator will document and keep on record in the stormwater management plan: (a) a description of why it is infeasible to initiate the installation or repair immediately; and (b) a schedule for installing or repairing the control measure and returning it to an effective operating condition as soon as possible. CDPHE Comment Air Description Odor mitigation: operator will cover trucks transporting drill cuttings CDPHE Comment Air Description Electrification: Operator will use electric equipment and devices (e.g. vapor recovery units or VRUs, fans, etc.) to minimize combustion sources on site (if yes, operator will provide a list outlining which equipment and devices will be electrified) CDPHE Comment Air Description Odor mitigation: operator will use a squeegee or other device to remove drilling fluids from pipes as they exit the wellbore CDPHE Comment PFAS Description If PFAS-containing foam is used at a location: operator will properly capture and dispose of PFAS-contaminated soil and fire and flush water CDPHE Comment Air Description Venting/Flaring: Operator will control emergency flaring with an enclosed combustor with a destruction efficiency of 98% or better CDPHE Comment Air Description Operator will implement a "hybrid production flowack method" or "modern production flowback method" (unlike the conventional or legacy flowback method, which uses temporary equipment to separate the oil, natural gas and water, the "hybrid-production flowback method" or "modern production flowback method" eliminates tanks by routing the oil, natural gas and water directly to permanent production equipment) CDPHE Comment Operator Proposed BMPs Page 11 of 31Date Run: 3/19/2024 Doc [#403278425] Water Description Down gradient controls: Operator will install adequate down gradient controls if they can not have a control at the source CDPHE Comment Air Description Operator will implement ambient air quality monitoring on site CDPHE Comment PFAS Description CDPHE Comment Water Description CPGCC permit will incorporate other agency water quality protection plans by reference as applicable (e.g. stormwater management plan) CDPHE Comment Air Description Ozone mitigation on forecasted high ozone days: operator will eliminate use of VOC paints and solvents CDPHE Comment Air Description Engines: Operator will use tier IV or better engines for hydraulic fracturing CDPHE Comment PFAS Description If PFAS-containing foam is used at a location: operator will properly characterize the site to determine the level, nature and exent of contamination CDPHE Comment Air Description Operator will use non-emitting pneumatic controllers CDPHE Comment Air Description Operator will properly maintain vehicles and equipment CDPHE Comment Air Description Ozone mitigation on forecasted high ozone days: operator will minimize vehicle and engine idling CDPHE Comment Water Description Stream crossing and Road Construction: Operator will ensure that control measures are designed, installed and adequately sized in accordance with good engineering, hydrologic and pollution control practices CDPHE Comment Air Description Tankless design: Operator will not store hydrocarbon liquids in storage tanks on site (other than a maintenance tank possibly used for well unloading or other maintenance activities). CDPHE Comment Air Page 12 of 31Date Run: 3/19/2024 Doc [#403278425] Description Venting/Flaring: Operator will control bradenhead/casinghead venting CDPHE Comment Water Description Vehicle fueling: Operator will ensure that a fueling contractor is present during the entire fueling process to prevent overfilling, leaks and drips from improper connections CDPHE Comment Air Description Pipelines: Operator will shut in the facility to reduce the need for flaring if the pipeline is unavailable CDPHE Comment Air Description Odor mitigation: Operator will ensure that all drilling fluid is removed from pipes before storage CDPHE Comment Water Description Vehicle fueling: Operator will refuel vehicles only on impervious surfaces and never during storm events CDPHE Comment Waste Description Operator will properly characterize and dispose of all waste (i.e. the specific landfill/waste disposal location allows for acceptance of the waste stream) CDPHE Comment PFAS Description If PFAS-containing foam is used at a location: operator will perform appropriate soil and water sampling to determine whether additional characterization is necessary and inform the need for and extent of interim or permanent remedial actions CDPHE Comment Water Description Operator will use Modular Large Volume Storage Tanks CDPHE Comment Water Description Outfall locations: Outlet protection should be used when a conveyance discharges onto a disturbed area where there is potential for accelerated erosion due to concentrated flow. Outlet protection should be provided where the velocity at the culvert outlet exceeds the maximum permissible velocity of the material in the receiving channel. CDPHE Comment Air Description Pipelines: Operator will have adequate and committed pipeline take away capacity for all produced gas and oil CDPHE Comment PFAS Description Operator will coordinate with nearby fire district(s) to evaluate whether PFAS-free foam can provide the required performance for the specific hazard CDPHE Comment Air Description Pipelines: Operator will use pipelines to transport water for hydraulic fracturing to and from location CDPHE Comment Page 13 of 31Date Run: 3/19/2024 Doc [#403278425] Air Description Venting/Flaring: Operator will not flare or vent gas during completion or flowback, except in upset or emergency conditions, or with prior written approval from the Director for necessary maintenance operations CDPHE Comment Waste Description Operator will properly test for and dispose of TENORM CDPHE Comment CDPHE Proposed COAs OR BMPs No BMP PLANS Total Plans Uploaded: 16 (1) Emergency Spill Response Program consistent with the requirements of Rules 411.a.(4).B, 411.b.(5).B, & 602.j X (2) Noise Mitigation Plan consistent with the requirements of Rule 423.a (3) Light Mitigation Plan consistent with the requirements of Rule 424.aX (4) Odor Mitigation Plan consistent with the requirements of Rule 426.aX (5) Dust Mitigation Plan consistent with the requirements of Rule 427.aX X (6) Transportation Plan X (7) Operations Safety Management Program consistent with the requirements of Rule 602.d X (8) Emergency Response Plan consistent with the requirements of Rule 602.j (9) Flood Shut-In Plan consistent with the requirements of Rule 421.b.(1) (10) Hydrogen Sulfide Drilling Operations Plan consistent with the requirements of Rule 612.d (11) Waste Management Plan consistent with the requirements of Rule 905.a.(4)X (12) Gas Capture Plan consistent with the requirements of Rule 903.e (13) Fluid Leak Detection PlanX (14) Topsoil Protection Plan consistent with the requirements of Rule 1002.cX (15) Stormwater Management Plan consistent with the requirements of Rule 1002.fX X (16) Interim Reclamation Plan consistent with the requirements of Rule 1003 X (17) Wildlife Plan consistent with the requirements of Rule 1201 X (18) Water Plan X (19) Cumulative Impacts Plan (20) Community Outreach Plan X (21) Geologic Hazard Plan VARIANCE REQUESTS Check all that apply: This proposed Oil and Gas Location requires the approval of a Rule 502.a variance from COGCC Rule or Commission Order number: Page 14 of 31Date Run: 3/19/2024 Doc [#403278425] ALL exceptions and variances require attached Request Letter(s). Refer to applicable rule for additional required attachments (e.g. waivers, certifications, SUAs). RULE 304.d LESSER IMPACT AREA EXEMPTION REQUESTS Check the boxes below for all Exemptions being requested. Lesser Impact Area Exemption Request must be attached, and will include all requested exemptions. 304.b.(1). Local Government Siting Information 304.b.(2). Alternative Location Analysis 304.b.(3). Cultural Distances 304.b.(4). Location Pictures 304.b.(5). Site Equipment List 304.b.(6). Flowline Descriptions 304.b.(7). Drawings 304.b.(8). Geographic Information System (GIS) Data 304.b.(9). Land Use Description 304.b.(10). NRCS Map Unit Description 304.b.(11). Best Management Practices 304.b.(12). Surface Owner Information 304.b.(13). Proximate Local Government 304.b.(14). Wetlands 304.b.(15). Schools and Child Care Centers 304.c.(1). Emergency Spill Response Program 304.c.(2). Noise Mitigation Plan 304.c.(3). Light Mitigation Plan 304.c.(4). Odor Mitigation Plan 304.c.(5). Dust Mitigation Plan 304.c.(6). Transportation Plan 304.c.(7). Operations Safety Management Program 304.c.(8). Emergency Response Plan 304.c.(9). Flood Shut-In Plan 304.c.(10). Hydrogen Sulfide Drilling Operations Plan 304.c.(11). Waste Management Plan 304.c.(12). Gas Capture Plan 304.c.(13). Fluid Leak Detection Plan 304.c.(14). Topsoil Protection Plan 304.c.(15). Stormwater Management Plan 304.c.(16). Interim Reclamation Plan 304.c.(17). Wildlife Plan 304.c.(18). Water Plan 304.c.(19). Cumulative Impacts Plan 304.c.(20). Community Outreach Plan 304.c.(21). Geologic Hazard Plan Comments OPERATOR COMMENTS AND SUBMITTAL Page 15 of 31Date Run: 3/19/2024 Doc [#403278425] rachel_friedman@oxy.com Geological Advisor 09/13/2023 Rachel Friedman COGCC Approved:Director of COGCC Date:3/19/2024 Based on the information provided herein, this Oil and Gas Location Assessment complies with COGCC Rules, applicable orders, and SB 19-181 and is hereby approved. Title: Email:Date: Print Name: Signed: I hereby certify that the statements made in this form are, to the best of my knowledge, true, correct and complete. A Weld County 1041 WOGLA will be submitted in association with this pad. This location is not proposed within 2,000 feet of a Residential Building Unit High Occupancy Building Unit, or School Facility located within a Disproportionately Impacted Community, a Rule 304.c.(20) Community Outreach Plan is not required. KMOG's "Community Consultation Plan" attached as "Other" is intended to provide supplemental information regarding efforts on community outreach and communication. The attached EAP will be submitted to the Weld County Office of Emergency Management. Once the plan is approved a signed copy will be sent to the ECMC OGLA staff. KMOG`s general Air Monitoring Plan has been approved by the CDPHE and is attached to the 2B. A site-specific Air Monitoring Plan for this location will be submitted to the ECMC and CDPHE for approval of air monitor locations prior to operations. Flowlines: Flow lines will flow to the production facility location. During production, flow direction in the flow lines is from the wellhead to the production facility. Flow lines will be constructed from steel pipe, buried, and will equal the distance between the well heads and the production facility. Gas custody transfer will occur at the custody transfer meter located on the proposed production facility location. Oil custody transfer will occur at the LACT Unit located on the proposed production facility location. Gas lift lines are also occasionally installed (one per well) from the well head to the production facility. During operation flow direction in the gas lift lines will be from the production facility to the well head. The size of the gas lift lines is typically 2''. Gas lift lines will be constructed from steel pipe, buried, and will equal the distance between the well heads and the tank battery. Air Supply Lines: Compressed air supply lines will also be installed from the well head to the production facility. During operation flow direction in the supply lines will be from the production facility to the well head. The size of the supply lines is typically 1''. Supply lines will be constructed from steel pipe, buried, and will equal the distance between the well heads and the production facility. KMOG held a pre-submission consultation with CDPHE on 7/11/23. The BMPs KMOG has committed to on the CDPHE Consult Tab were discussed at that consultation but are subject to change during the formal consultation that will occur after the OGDP has passed completeness. KMOG is proposing one 25,000 BBL MVLT for this location for use during completions – 36 feet tall with a 70 foot diameter. The proposed manufacturer and vendor is Shalestone Resources. The MLVT is approximately 1,456 feet from the nearest RBU and is a temporary piece of equipment (on location for approximately 2 months). Please see the Operator BMP tab for further information. COA Type Description 0 COA Conditions Of Approval All representations, stipulations and conditions of approval stated in this Form 2A for this location shall constitute representations, stipulations and conditions of approval for any and all subsequent operations on the location unless this Form 2A is modified by Sundry Notice, Form 4 or an Amended Form 2A. Best Management Practices No BMP/COA Type Description 1 General Housekeeping All loadlines shall be bullplugged or capped. ` Page 16 of 31Date Run: 3/19/2024 Doc [#403278425] 2 General Housekeeping During drilling, completions, and facility construction, human waste and septic from temporary buildings will be stored in tanks. These tanks will be emptied via vacuum truck for disposal. Temporary portable restrooms will also be available for workers during this phase. Good housekeeping measures for these include regular servicing and inspections. Temporary portable restrooms will be staked to the ground to prevent from tipping over.` 3 General Housekeeping Wastes will be stored in containers or on lined containment that are chosen for compatibility and checked periodically for leaks or integrity problems. Examples of containment include but are not limited to 3-sided steel tanks, steel tanks, lined containment, plastic totes, drums, etc.` 4 General Housekeeping Light: Construction Phase: • During construction of all phases, KMOG will only conduct day light operation and there will be no nighttime operations that require lighting. • Exterior lighting shall be directed away from residential and other sensitive areas or shielded from said areas to eliminate glare. Light spillage beyond the perimeter of the well site shall be minimized. • Bulbs shall be fully shielded to prevent light emissions above a horizontal plane drawn from the bottom of each fixture. Drilling: Derrick mast lighting in Section 6.1 is facing horizontally to provide adequate lighting for safe operation. • Lighting is angled to mitigate the amount of light leaving the location boundary, and away from surrounding off site buildings. • Lighting within the Drilling area has been reduced to provide a minimum acceptable value for safe operation. • Light masts are automatically switched off/on based on lighting sensors. • Lights are switched off when not required. • Low power (63 W) LED lights are used for the drill rig. Completions and Flowback Phases: • KMOG will utilize LED fixtures to reduce skyglow. • KMOG will position all lights to point in a downward direction where vertical lighting is not required. Where it is required, lights are angled in a vertical direction to provide task lighting for safety and operations involving personnel. • Lighting is angled to mitigate the amount of light leaving the location boundary, and away from surrounding off site buildings. • Lighting within the Completion and Flowback areas have been reduced to provide a minimum acceptable value for safe operation. • Light masts are automatically switched off/on based on lighting sensors. • Lights are switched off when not required Production Phase: • KMOG will utilize LED fixtures to reduce skyglow. • KMOG will position all lights to point in a downward direction, in order to mitigate light leaving the location boundary. • Lighting within the Production areas have been reduced to provide a minimum acceptable value for safe operation` 5 Wildlife An environmental assessment will be conducted immediately prior to pad construction, drilling, and completion operations. ` 6 Wildlife Location construction will occur outside the winter season (December 1 to April 30) in order to minimize impacts on the Mule Deer Severe Winter Range.` 7 Wildlife KMOG will survey for nesting raptors if project activities start between February 1 and August 15. For ground disturbances beginning between March 15 and August 31, 2023, the full three-survey CPW protocol will be completed no more than 7 days prior to the start of work. KMOG has agreed to comply with seasonal stipulations associated with severe winter range, therefore pre-production activities will not occur between December 1 and May 1. Migration Corridor impacts are based on surface density limitations of one pad per square mile and less than one linear mile of routes per square mile. CPW recommends an indirect impacts mitigation fee if this cannot be achieved. Associated with the Rademacher development, KMOG will reclaim 15.75 more acres than it disturbs in the area by reclaiming 49 wells and 10 facilities therefore no mitigation fees are required, and the development will lead to habitat de- fragmentation in the area.` 8 Storm Water/Erosion Control KMOG will conduct stormwater inspections immediately after storm eventfor active construction locations. 72 hr window is allowed for idle construction locations. ` 9 Storm Water/Erosion Control KMOG will conduct weekly stormwater inspections during normal operations and post- precipitation or melt response. ` Page 17 of 31Date Run: 3/19/2024 Doc [#403278425] 10 Storm Water/Erosion Control A spillway and/or outlet are designed to capture sediment transported in surface runoff and slowly release flows to allow time for settling of sediment prior to discharge from the location. Spillway and/or outlet will be installed concurrently with the facility diversion berm. A spillway/outlet will be installed in the southern and southwestern portions of the facility pad berm for Rademacher 14-30HZ during interim reclamation. All spillways and outlets will remain in-place until final reclamation activities are complete.` 11 Storm Water/Erosion Control Culverts will be installed at the southeastern access off the well pad and facility pad, as well as along the western portion of the access road for Rademacher 14-30HZ intersecting with Weld County Road 13. Culverts will be evaluated at the time of construction and installed as needed.` 12 Storm Water/Erosion Control A berm will be installed around the southern and southwestern edges of the Rademacher 14- 30HZ facility pad to divert stormwater run-on & run-off to a designated outlet structure This BMP will be installed during construction disturbance reduction, and prior to removal of construction perimeter controls. ? Diversion ditch and berm will remain in-place until final reclamation activities commence. During construction, inspections shall be conducted every 14 days, and after a major precipitation or melt event, which has the potential to cause surface runoff. For sites earthwork and construction is completed, but final stabilization is not achieved due to vegetative cover, inspections shall be conducted every 30 days and exclude precipitation or melt event response. Inspections will continue until all reclaimed areas have achieved a cover of 70% the pre-construction reference vegetation (i.e. final stabilization).` 13 Material Handling and Spill Prevention KMOG will recycle 100 percent of liquid and slurry non-produced E&P wastes streams from drilling and well preparations to offset freshwater use in completion operations. ` 14 Material Handling and Spill Prevention Automation technology will be utilized at this facility. This technology includes the use of fluid level monitoring for the tanks and produced water sumps, high-level shut offs, and electronic sensors to monitor the interstitial space of double-walled produced water sumps. All automation is monitored by Kerr-McGee's Integrated Operations Center (IOC), which is manned 24 hours per day, 7 days per week.` 15 Material Handling and Spill Prevention The temporary produced water storage tanks will be staged on a geosynthetic liner and surrounded by an earthen berm. The berms will enclose an area sufficient to provide secondary containment for 150% of the volume of the largest single tank and will be sufficiently impervious to contain spilled or released material. Berms and the liner and all secondary containment devices will be inspected at the same time as stormwater inspections, with personnel on location, daily inspections will occur. During non-active, but while under construction, site inspections will occur every 14 days.` 16 Material Handling and Spill Prevention Berm Construction: A geosynthetic liner will be laid under the permanent tanks on this location and a metal containment will be constructed. Secondary containment devices will be constructed around crude oil, condensate, and produced water storage tanks and will enclose an area sufficient to contain and provide secondary containment for150% of the largest single tank. Secondary containment devices will be inspected at the same time as stormwater inspections, with personnel on location, daily inspections will occur. During non-active, but while under construction, site inspections will occur every 14 days. When construction is completed and the Location is on production, site inspections will occur every 28 days. b. Automation technology will be utilized at this facility. This technology includes the use of fluid level monitoring for the tanks and produced water sumps, high-level shut offs, and electronic sensors to monitor the interstitial space of double-walled produced water sumps. All automation is monitored by Kerr-McGee's Integrated Operations Center (IOC), which is manned 24 hours per day, 7 days per week. c. Field Inspections include the following: Field-Constructed Above Ground Containers; Secondary Containment Structures; Shop-Built Containers; Generators / Fuel Tanks and associated secondary containment; Pressure Vessels (separators, heater treaters, pigging stations); Portable Containers and all Manifolded Piping; Onsite and Offsite Pipelines (flowlines, production piping, gathering lines) Field Drainage Systems (oil traps, sumps, or skimmers); and Additional equipment used during separation, storage, containment, or transferring of produced fluids.` 17 Dust control Access roads are not paved, they are constructed with a minimum of four - inches of gravel road base` Page 18 of 31Date Run: 3/19/2024 Doc [#403278425] 18 Dust control KMOG will proactively deploy fresh water to suppress dust along access road to well pad/ facility during all phases of pre-production operations ? Speed limits will be reduced to 10 mph on access road and 5 mph once vehicles reach well pad/ facility. Access roads and Vehicle Tracking Control will receive maintenance as needed throughout operations ? In the event of high winds that generate dust that cannot be mitigated with an application of water, KMOG will shut down construction operations During the Completions phase, KMOG will utilize a fully enclosed sand containerized proppant delivery system that eliminates the use of pneumatic transfer on location. This methodology Kerr-McGee Oil & Gas Onshore LP (KMOG) Dust Mitigation Plan – Rademacher 14-30HZ 3 utilizes a gravity choke feed system that reduces dust significantly. The dust levels from this system are minimal and below Occupational Safety and Health Administration (OSHA) permissible exposure limit which eliminates the need for additional Personal Protective Equipment (PPE)` 19 Construction KMOG will extend an existing access road off of the intersection of CR 28 and Colorado Blvd. to access the location for drilling, completions, and production operations, including maintenance of equipment. The road will be properly constructed and maintained to accommodate for emergency vehicle access. ` 20 Construction KMOG will only construct during day light and there will be no nighttime operations that require lighting. ` 21 Noise mitigation • Prior to commencement of drilling and completion activities, a partial-perimeter, engineered sound wall consisting of approximately 1,340 linear feet of 32-foot-tall, STC32 wall, and 100 linear feet of 24-foot-tall STC43 wall will be installed around the edge of the well pad to reduce noise levels at the critical receptor points. The total sound wall footage is broken down as below: o 640 linear feet on the north edge of the well pad o 480 linear feet on the west edge of the well pad o 320 linear feet on the south edge of the well pad. • Throughout the duration of pre-production operations and any construction lasting longer than 24 hours, KMOG will conduct continuous noise monitoring at the ambient monitoring locations. KMOG will utilize a low noise completions fleet for all completions operations` 22 Emissions mitigation All storage tanks used for active production rig drilling operations, used in lieu of pits, will contain pit level monitors with Electronic Drilling Recorders (EDR). KMG uses EDRs with pit level monitor(s) and alarm(s) for production rigs. Basic level gauges will be used on tanks associated with the surface rig. ` 23 Emissions mitigation Temporary ECD(s) will be utilized to mitigate releases of emissions from temporary produced water storage tanks for the duration which the tanks are on location and being used. ` 24 Emissions mitigation KMOG will shut in production when pipeline is not available. ` 25 Emissions mitigation Ozone mitigation on forecasted high ozone days: KMOG will postpone the refueling of vehicles as feasible given the number of ozone action days, the operations ongoing at the time, and safety considerations. ` 26 Emissions mitigation Ozone mitigation on forecasted high ozone days: KMOG will suspend or delay the use of fossil fuel powered ancillary equipment as feasible given the number of ozone action days, the operations ongoing at the time, and safety considerations. ` 27 Emissions mitigation Ozone mitigation on forecasted high ozone days: KMOG will postpone construction activities as feasible given the number of ozone action days, the operations ongoing at the time, and safety considerations. ` Page 19 of 31Date Run: 3/19/2024 Doc [#403278425] 28 Emissions mitigation Ozone mitigation on forecasted high ozone days: KMOG will reschedule non-essential operational activities such as pigging, well unloading and tank cleaning as feasible given the number of ozone action days, the operations ongoing at the time, and safety considerations. ` 29 Emissions mitigation KMOG will have permanent water storage tanks on the Rademacher location. The tanks will be controlled with VOC combustors. Tank emissions monitoring systems will be in place, which means that tank pressures will be continuously recorded, and the location will be shut in if tank pressures start to approach the pressure at which relief devices would vent emissions to the atmosphere. Therefore, the possibility of venting from tanks is eliminated. The tank components and control device will be on preventative maintenance schedules to ensure device integrity and minimize the potential for leaks/failure. The tanks (and entire facility) will have Leak Detection and Repair (LDAR) surveys completed. KMOG has a dedicated emissions team that conducts the LDAR program. This team performs weekly audio visual and olfactory (AVO) inspections to make sure equipment is working per design and in a manner safe for the environment. The entire facility will be inspected to ensure that there are not any leaks that can be detected using hearing, sight, or smell. If a leak is found it is reported to the state, repaired and reinspected with a FLIR camera to confirm the repair has been completed. Facilities will also be inspected for gas leaks at least monthly using an infrared camera. KMOG maintains the IOC where facilities are monitored and can be shut in remotely if a leak is suspected.` 30 Emissions mitigation There will be maintenance tanks at the Rademacher Location, that will only be used during maintenance operations. The maintenance tanks are not used as part of normal operation and are only used to manually flow to the tanks for activities such as equipment blowdowns for maintenance or well unloading. In the event the tanks are utilized, it is standard KMOG practice to empty maintenance tanks within 24 hours in order to minimize emissions. The maintenance tanks are equipped with monitoring devices that report data such as temperature, pressure and fluid level and can be monitored from KMOG’s IOC in Platteville. The maintenance tanks are attached to the tank vapor recovery piping that goes to the Enclosed Combustion Device (ECD). If any vapors are recovered, then they are sent to the ECD and not released into the atmosphere.` 31 Odor mitigation drilling: All oil-based drilling fluids will be built using a Group III base oil with negligible aromatic content and PAH less than 0.001% so that it does not emit odor during all production drilling operations. • The Group III base oil will be utilized in a closed loop drilling fluid system and eliminate odor at the shakers, transfer tank, active/reserve tanks, and cuttings in collection tanks and during transport. • All drill cuttings are processed through centrifugal dryers to remove residual oil-based drilling fluid not removed by shale shakers. • All tubulars pulled out of the hole will be wiped prior to being racked in the derrick or laid down. • Cuttings storage time on location will be minimized prior to transport to local landfills. • New drilling fluid will be built using transfer line outlets located below tank fluid level to minimize splashing/agitation. New fluid will only be built using Group III base oils.` 32 Drilling/Completion Operations Test separators and associated flow lines, sand traps and emission control systems? shall be installed on-site to accommodate completions techniques. When commercial? quantities of salable quality gas are achieved at each well, the gas shall be? immediately directed to a sales line or shut in and conserved. If a sales line is? unavailable or other conditions prevent placing the gas into a sales line, KMOG shall? not produce the wells. KMOG agrees to comply with both Rules 903.c.(3).B. and 903.c.(3).C.? ` 33 Drilling/Completion Operations Guy line anchors will not be used. Base Beams will be used to stabilize the rig and removed after drilling. ` 34 Drilling/Completion Operations Rig power will be supplied by two natural gas engines with a battery energy storage system and an automated engine management system. As necessary, a diesel generator will be used to supplement additional power during the highest demand portions of the wells.` Page 20 of 31Date Run: 3/19/2024 Doc [#403278425] 35 Drilling/Completion Operations KMOG is proposing one 25,000 BBL MVLT for this location for use during completions – 36 feet tall with a 70 foot diameter. The proposed manufacturer and vendor is Shalestone Resources. The MLVT is approximately 1,456 feet from the nearest RBU and is a temporary piece of equipment (on location for approximately 2 months). The MLVT will be in compliance with the following COGCC safety setbacks. 1. Seventy-five (75) feet from a wellhead, fired vessel, heater-treater, or a compressor with a rating of 200 horsepower or more; 2. Fifty (50) feet from a separator, well test unit, or other non-fired equipment. 3. Signs shall be posted on each MLVT to indicate that the contents are fresh water and that no E&P waste fluids are allowed. Location and additional signage shall conform to Rule 210. 4. MLVTs will be operated with a minimum of 1 foot freeboard at all times. 5. Access to the tanks shall be limited to operational personnel. 6. Construction and installation of the tank structure, liner and sub-grade shall meet or exceed the manufacturer specifications. 7. KMOG follows manufacturers Standard Operating Procedures (SOPs) and will provide these SOPs upon request to the COGCC. 8. KMOG will conduct daily, visual inspections of the exterior wall and general area for any integrity deficiencies before, during, and after filling the MLVTs. If deficiencies are noted, KMOG will repair them as soon as practicable. Records of repairs will be maintained per Rule 205. 9. KMOG will follow pre-construction risk assessment measures to address safety concerns and minimize environmental impacts and property damage in the unlikely event of a MLVT release. 10. In the event of a catastrophic MLVT failure, KMOG shall notify the COGCC as soon as practicable but not more than 24 hours after discovery, submit a Form 22- Accident Report within 10 days after discovery, conduct a root cause analysis´ and provide same to COGCC on a Form 4-Sundry Notice within 30 days of the failure. 11. All MLVT liner seams shall be welded and tested in accordance with applicable ASTM international standards. Any repairs to liners shall be made using acceptable practices and applicable standards. 12. The MLVT shall be constructed and operated in accordance with a design package certified and sealed by a Licensed Professional Engineer either in Colorado or the state where the MLVT was designed or manufactured. 13. KMOG hereby certifies to the Director that the MLVT at this location will be designed and implemented consistent with the Colorado Oil and Gas Conservation Commission policy dated June 13, 2014. ` Page 21 of 31Date Run: 3/19/2024 Doc [#403278425] 36 Drilling/Completion Operations The following are BMPs agreed on by the Operator as an outcome of the CDPHE consultation: • Operator will properly maintain vehicles and equipment • Operator will use non-emitting pneumatic controllers • Operator will use Tier IV or equivalent engines, such as NG Tier II w/ battery assist, (or better) for drilling (dual-fuel engines are not considered equivalent) • Operator will use Tier IV or equivalent engines, such as NG Tier II w/ battery assist, (or better) for hydraulic fracturing (dual-fuel engines are not considered equivalent) • Operator will use electric equipment and devices (e.g. vapor recovery units or VRUs, fans, etc.) to minimize combustion sources on site (if yes, operator will provide a list outlining which equipment and devices will be electrified) • Operator will use service providers who utilize at least 50% Tier IV or equivalent engines, such as NG Tier II w/ battery assist, (or better) for nonroad construction equipment (dual-fuel engines are not considered equivalent) • Operator will not store hydrocarbon liquids in permanent storage tanks on site (other than a maintenance tank possibly used for well unloading or other maintenance activities) • Operator will implement a "hybrid or modern" production flowack method (eliminates tanks by routing the oil, natural gas and water directly to permanent production equipment) • Operator will use pipelines to transport water used for hydraulic fracturing to location • Operator will have adequate and committed pipeline takeaway capacity for all produced gas and oil • Operator will shut in the facility to reduce the need for flaring if the pipeline is unavailable • Operator will use lease automatic custody transfer (LACT) system to remove/reduce the need for truck loadout • Operator will use OGP Group III drilling fluid • Operator will cover trucks transporting drill cuttings • Operator will use a squeegee or other device to remove drilling fluids from pipes as they exit the wellbore • Operator will ensure that all drilling fluid is removed from pipes before storage • Ozone mitigation on forecasted high ozone days: operator will eliminate use of VOC paints and solvents • Ozone mitigation on forecasted high ozone days: operator will minimize vehicle and engine idling • Ozone mitigation on forecasted high ozone days: operator will reduce truck traffic and worker traffic • Ozone mitigation on forecasted high ozone days: operator will postpone the refueling of vehicles • Ozone mitigation on forecasted high ozone days: operator will suspend or delay the use of non-essential fossil fuel powered ancillary equipment • Ozone mitigation on forecasted high ozone days: operator will adjust construction schedules to postpone non-essential construction activity, including but not limited to temporary tank removals and cleaning on ozone action days • Ozone mitigation on forecasted high ozone days: operator will send notification to all operational staff requesting that where possible, they delay all non-essential operational activity (such as pigging, well unloading and tank cleaning) on ozone action days • Operator will use Modular Large Volume Storage Tanks • Operator will not use fracturing fluids which contain PFAS compounds • Operator will continue to participate in the Colorado Preparedness Resources Network (CPRN)CPRN, which has a non-PFAS foam location identification to be sure, in an emergency, that non-PFAS foam will be available • Operator will coordinate with nearby fire district(s) to evaluate whether PFAS-free foam can provide the required performance for the specific hazard • If PFAS-containing foam is used at a location: operator will properly characterize the site to determine the level, nature and extent of contamination • If PFAS-containing foam is used at a location: operator will perform appropriate soil and water sampling to determine whether additional characterization is necessary and inform the need for and extent of interim or permanent remedial actions • If PFAS-containing foam is used at a location: operator will properly capture and dispose of PFAS-contaminated soil and fire and flush water` Page 22 of 31Date Run: 3/19/2024 Doc [#403278425] 37 Interim Reclamation The completed wellsite will be surrounded with a fence and gate with adequate lock to restrict access to authorized personnel only. KMOG personnel will monitor the wellsite upon completion of the wells. Authorized representatives and/or KMOG personnel shall be on-site during drilling and completions operations. ` 38 Interim Reclamation Interim reclamation: After topsoil re-distribution, the interim reclamation area shall be cross ripped to a depth of eighteen inches with an agricultural ripper/subsoiler; however, this depth may be adjusted in rocky or shallow soils. Chiseling/ripping will be performed at the minimum depth of topsoil. Cultipacking or disking may be required to reduce soil clod size. Ripping with construction style shanks, for the purpose of surface ridge roughness as a stormwater BMP, is only allowed to a six-inch depth, and will be maintained following any precipitation or surface erosion which has the potential to compromise the BMP.` 39 Interim Reclamation Topsoil will be managed during construction by a combination of site-specific erosion and sediment control measures including: a temporary diversion ditch & berm around the entire location to manage run-on and run-off; short term management of topsoil will include track packing to prevent wind and water erosion, long term management includes seeding with a native seed mix and crimping straw mulch for erosion control and water retention; vegetation establishment on stockpiles and weed control will reduce erosion as well as maintain microbial activity; during the construction phase topsoil will be stockpiled ~12 feet tall and with a 3:1 slope north of the well pad to minimize erosion potential. Topsoil managed during interim and production phases will be maintained with BMPs including seeding with a native seed mix and crimped straw mulch; weed monitoring; the long-term topsoil stockpile will be ~6 feet tall at a 4:1 slope west of the facility pad and ~3 feet tall at a 5:1 slope on the north and south sides of the well pad to maintain microbial activity for an extended time. Inspections will review all control measures / BMPs implemented, their status, and whether repair or replacement is needed, including weed maintenance when necessary. Maintenance and repair will be completed as soon as practicable, immediately in most cases.` 40 Final Reclamation The wellsite will be cleared of all non-essential equipment within ninety (90) days after all wells associated with the pad have been plugged and abandoned. ` 41 Final Reclamation Once the wells have been plugged and abandoned, KMOG will identify the location of the wellbores with permanent monuments that will detail the well names and date of plugging. ` Total: 41 comment(s) Page 23 of 31Date Run: 3/19/2024 Doc [#403278425] Attachment List Att Doc Num Name 21316817 GEOLOGIC HAZARD MAP 21316818 LAYOUT DRAWING 21316819 CORRESPONDENCE 21316821 CDPHE CONSULTATION 21316825 LOCAL GOVERNMENT PERMIT 21316826 OTHER 21316827 OTHER 21316828 OTHER 21316829 WILDLIFE HABITAT DRAWING 21316830 DIRECTOR'S RECOMMENDATION 21316835 INFORMED CONSENT LETTER 21316836 INFORMED CONSENT LETTER 21316837 INFORMED CONSENT LETTER 403278425 FORM 2A SUBMITTED 403495464 ACCESS ROAD MAP 403495468 HYDROLOGY MAP 403495469 LOCATION DRAWING 403495470 LOCATION PICTURES 403495472 LOCATION PICTURES 403495496 NRCS MAP UNIT DESC 403495501 DIRECTIONAL WELL PLAT 403495572 CPW WAIVER 403495579 CULTURAL FEATURES MAP 403495584 LGD CONSULTATION 403496215 WILDLIFE HABITAT DRAWING 403496615 CPW CONSULTATION 403505914 PRELIMINARY PROCESS FLOW DIAGRAMS 403522197 SURFACE AGRMT/SURETY 403522198 NRCS MAP UNIT DESC 403522199 OTHER 403522201 OIL AND GAS LOCATION GIS SHP 403522519 ALA NARRATIVE SUMMARY 403614719 ALA DATASHEET 403614824 LOCAL/FED FINAL PERMIT DECISION 403614825 LOCAL/FED FINAL PERMIT DECISION 403627664 RELATED LOCATION AND FLOWLINE MAP Total Attach: 36 Files Page 24 of 31Date Run: 3/19/2024 Doc [#403278425] User Group Comment Comment Date OGLA Due to a technical glitch, the comments Weld County provided did not save onto this Form. Weld County emailed the following to ECMC staff: 1041WOGLA23-0013 – Kerr McGee – Rademacher 14-30HZ The Weld County Oil and Gas Energy Department (OGED) submits the following comments: 1. Case number 1041WOGLA23-0013 has been assigned to the Rademacher 14-30HZ Location. All files associated with the processing and review of this permit are accessible through the Weld County E-Permit Center at https://aca- prod.accela.com/WELD/Default.aspx If there are any questions relating to the ability to access these files, please call the OGED office at 970-400-3580. 2. The Kerr-McGee Oil & Gas Onshore LP (KMG) Rademacher location was reviewed and processed under Weld County Code, ORD2021-17. 3. A pre-application meeting was held on August 31, 2022. Attendees included OGED Staff, KMG Staff, ECMC, Weld County Staff, Town of Firestone representatives. 4. The 1041 WOGLA Application was received on August 22, 2023. OGED did not receive any public comments or any Applications for Intervention. 6. The application submitted is compliant with all requirements of Section 21-5-320 of the Weld County Code. 7. Weld County sent referrals to appropriate parties on August 14, 2023. 8. A 1041 WOGLA Hearing was held on November 2, 2023. 9. The OGED Hearing Officer considered testimony at the 1041 WOGLA hearing, and subsequently approved 1041WOGLA23-0013. 10. The approved Weld County 1041 WOGLA Permit, and KMG’s commitment to best management practices outlined in the application, will protect the health, safety, security and general welfare of the present and future residents of Weld County, while also protecting both the environment and wildlife. 11. The final order was recorded with the Weld County Clerk Recorder on November 15, 2023, reception number (4931125) and was noticed in the Greeley Tribune on November 18, 2023. Approval and of KMG’s application creates a vested property right pursuant to Article 68 of Title 24, C.R.S. 12. The approved permit is valid for three (3) years – construction must commence within the timeframe, or an extension must be requested and approved, or the permit will expire. 13. Due to the fact that KMG has completed the 1041 WOGLA Application process, and that a final order has been issued, recorded and legally published, Weld County has no additional concerns with the pending ECMC permit, and would recommend approval. 03/14/2024 OGLA OGDP ID# 485787 and this Form are approved by Commission Order Number 407-3580 03/14/2024 OGLA Attach Informed Consent letters provided by Operator as discussed in the hearings on 3/6. 03/14/2024 General Comments Page 25 of 31Date Run: 3/19/2024 Doc [#403278425] OGLA The Director has determined that the OGDP application that this Form is a component of meets all requirements of Rule 306.a. The Director’s Recommendation has been attached to the Form 2A. 02/22/2024 OGLA Through a google-chat on 2/21/24, CPW informed ECMC that the CPW consultation information would be provided by CPW through a comment on the Form 2A and not through a formal letter or email. The CPW liaison provided the comments on the Form 2A on 2/21/2024. Replaced Wildlife plan with revised plan based on CPW consultation and attached wildlife habitat acreage disturbance drawing. 02/22/2024 CPW CPW’s Wildlife Consultation Summary BACKGROUND The purpose of this Wildlife Consultation Summary is to give ECMC’s Commissioners and staff, and interested stakeholders insight into CPW’s consultation history, and the resultant wildlife recommendations and conclusions regarding Kerr McGee’s (KMOG) Sprout Oil & Gas Development Plan (OGDP). This OGDP is comprised of three nearby locations (Alfalfa, Clover, and Rademacher). CPW’S WMP CONCLUSION CPW-NE approves KMOG’s Wildlife Mitigation Plan (WMP) for the Rademacher location. CPW’s wildlife and High Priority Habitat (HPH) concerns have been resolved through KMOG’s efforts to avoid, minimize, and mitigate their remaining unavoidable adverse impacts. CPW does not have any unresolved wildlife concerns, or objections, with this OGDP application. SUMMARY Only the Rademacher pad is located within the CPW-mapped HPH; hence, this location will be the primary location discussed in this Summary. The HPHs intersected by the Rademacher pad include the 2022 and 2023 Mule Deer Severe Winter Range (SWR) and Migration Corridor, which are ECMC Rule 1202.d habitats. These HPH intersects require KMOG to complete a WMP per Rule 1201 for both locations. CPW has consulted on these locations since August 2022. SITE CONTEXT The proposed Sprout OGDP is located near Firestone, specifically on the eastern side of town for the Alfalfa and Clover locations, and on the northern side of town for the Rademacher location. The Rademacher location is located southeast of State Highway 66 [AKA Weld County Road (WCR) 30], and Colorado Blvd [AKA WCR 13], specifically in T3N, R67W, S30, SESW. The Alfalfa pad is located in T2N, R67W, S20, SENE; while the Clover pad is located in T2N, R67W, S29, NWNE. CPW’S UNDERSTANDING OF THIS OGDP The proposed Rademacher location consists of eighteen (18) wells and a production facility. The total surface disturbance area of the pad will be approximately 12.27 acres. The anticipated start date is May 1, 2024. KMOG will avoid construction of this pad, drilling, and completion activities during the mule deer winter season (Dec. 1 to April 30). The Rademacher Pad plus access road will have 6.95 acres of temporary (3.02 acres) and permanent (3.93 acres) impacts within the two mule deer HPHs (2023 maps). All three locations were received by ECMC on 9/13/23, which means they are technically subject to the 2022 maps (since the 2023 HPH maps were eventually effective starting 11/30/23). However, given the uncertainty of the 2023 HPH hearing date, KMOG proactively chose to submit under the 2023 HPH layers. The 2022 and 2023 HPH impacted layers are the same for the Mule Deer Migration Corridor. The 2023 HPH layer for Mule Deer SWR is significantly less when compared to the 2022 layer. But when the Mule Deer SWR acres are combined with the Mule Deer Migration Corridor layers, both disturbance totals are within roughly an acre of each other, and both are less than 11.0 acres. That means that KMOG’s eventual payment of $13,750 to CPW would be the same if they are subject to the 2022 or 2023 maps (CPW appreciates their proactive approach to using the 2023 maps). KMOG will have pipeline takeaway for both oil and natural gas, but have truck takeaway for the produced water. KMOG estimates that the initial high flow period during the first two winter seasons will be five (5) trucks per day for the Rademacher location (vs. per well at the Rademacher location) before it drops to the average of two (2) trucks per day. There will be four produced water tanks and one maintenance tank. There will be no upstream flowline disturbances that will occur outside these areas. 02/21/2024 Page 26 of 31Date Run: 3/19/2024 Doc [#403278425] A sound wall is proposed for 320 feet of the south/HPH-facing side of the Rademacher location Working Pad Surface (roughly 550 feet wide from west to east). A 1202.a.(3) waiver was required only for the Rademacher location. The Rademacher location only proposes fencing (chain link)just around wellheads outside of HPH. Page 27 of 31Date Run: 3/19/2024 Doc [#403278425] CPW (CPW Comment 2/3) A very small portion of the proposed haul route is located within the Mule Deer SWR. The eastern ~45% of the haul route is located within the HPH for Mule Deer Migration Corridor, while the western ~55% half is not within a mapped HPH. WILDLIFE CONSULTATION HISTORY While CPW & KMOG had many discussions regarding this location, this list highlights key dates in 2022-2024. 8/16/22 - CPW received a Weld [County] Oil and Gas Location Assessment (WOGLA) pre-application meeting notice for 8/31/22 for three locations - Salazar, Rademacher, and Brighton pads. CPW was unable to attend, but the County encouraged KMOG to keep communicating with CPW. 12/27/22 - KMOG initially reached out to CPW to begin pre-consultation. 1/24/23 - CPW received a WOGLA pre-application meeting notice for 2/1/23 for the Alfalfa and Clover pads. 2/8/23 - CPW attends a site visit at the Rademacher location with KMOG and ECMC Commissioner Cross. 2/27/23 - KMOG sent CPW a Notice of Intent to Submit 1041 WOGLA. 6/19/23 - KMOG requested a 1202.a.(3) wetlands waiver from CPW since there are wetlands 300 feet away from the Rademacher’s chemical storage units. Based on the stormwater prevention measures and since the wetlands are not mapped as an HPH for Aquatic Native Species, CPW sent a signed waiver on 6/28/23. 9/14/23 - CPW received a WOGLA application from the County. CPW responded to the WOGLA application on 9/26/23 about the two deer HPHs, and a recommendation for KMOG to maintain “the riparian corridor to allow for the migration corridor to the maximum extent practicable during and after construction.” 12/28/23 CPW received the ECMC’s approved Form 2C for this OGDP. 1/30/24 - CPW had a formal consultation call with ECMC and KMOG and received the Rademacher WMP. 2/14/24 - CPW received the revised WMP with the corrected direct mitigation fees and timing stipulation. 2/21/24 - CPW approves their Wildlife Task for the Rademacher location in ECMC’s Webform System. HPH ASSESSMENTS CPW appreciates that Alfalfa and Clover are sited outside any 2022 or 2023 HPHs. The Rademacher pad is not located in a 1202.c No Surface Occupancy Habitat, but the pad and access roads partially intersect the 1202.d Density Habitats for Mule Deer SWR and Migration Corridor, which require the evaluation of direct impacts. The Rademacher site visit revealed the wintering habitat is available and accessible to wintering mule deer, even though some nearby existing wells are nearby. Since the Rademacher pad will have direct impacts less than 11.0 acres of permanent and temporary habitat disturbances from the road and pad, KMOG chose to pay CPW $13,750.00. The Rademacher Pad is not the first active location within a square mile. Furthermore, this pad is located within the red “>5 active locations per square mile” layer, which means this area has a reduced use for mule deer and does not require the evaluation of indirect impacts and, thus, indirect mitigation. CPW’s WILDLIFE AND HPH CONCERNS During the WOGLA pre-app call, CPW noted that while the Alfalfa and Clover Locations were not within High Priority Habitat, there is the potential for nesting Burrowing Owls in the prairie dog colony in/near the Alfalfa location, and nesting Red-tailed Hawks in the mature trees near the Clover location. KMOG is planning to conduct these surveys. CPW also voiced concerns about potential spills getting to the nearby Coal Ridge Ditch (not mapped as an aquatic HPH), but was not concerned about impacts to Firestone Lake, which is located two miles to the west and is designated as HPH (Aquatic Sportfish Management Water). KMOG did not need a 1202.a.(3) wetlands waiver since their chemical storage areas are more than 500 feet from that ditch or the playa to the northwest, and they have adequate stormwater BMPs. 02/21/2024 CPW (CPW Comment 3/3) When discussing alternative locations outside of HPH, KMOG informed us that this pad is surrounded by a NORAD fiber optic line and wetlands to the south, a different landowner 02/21/2024 Page 28 of 31Date Run: 3/19/2024 Doc [#403278425] to the east, and a natural gas pipeline and water line on the north side. CPW continued by asking about moving the entire site outside of the HPHs and away from the buried utility lines, but stated Residential Building Unit (RBU) buffers would have been impacted, hence why it’s pushed to the southeast corner of this parcel. CPW further asked about flip-flopping the equipment and topsoil stockpile, and KMOG responded by trying to keep the equipment as far from RBUs as possible. Even though these HPHs are still proposed to be impacted, CPW’s wildlife and HPH concerns were resolved through KMOG’s below efforts to avoid, minimize, and mitigate their remaining unavoidable adverse impacts. AVOIDANCE, MINIMIZATION & MITIGATION MEASURES AND RESOLUTIONS The Avoidance Measures that KMOG proactively included were to locate two of these three locations outside of HPHs. Furthermore, for the Rademacher site, KMOG will avoid site pad construction, drilling, and completions during the Mule Deer winter season (December 1 to April 30). Minimization Measures that KMOG included as a result of CPW consultation was siting the majority of the wells and access road are located outside of HPH. Also, KMOG will have as minimal fencing as possible, and where fencing does need to occur, will be wildlife-friendly fencing. KMOG will use CPW’s Mule Deer Seed Mix for revegetation (with landowner approval), and will develop a noxious weed management plan. Per Rule 1202.a.(8), KMOG will survey for songbirds before site pad construction, should it occur between April 1 to August 31. The Mitigation Measures that KMOG included as a result of CPW consultation was choosing to pay CPW (vs. mitigating with acres impacted) $13,750.00 for direct impacts for the Rademacher location. These combined avoidance and minimization measures should allow wintering Mule Deer to continue to use this HPH, though likely at a lower rate since its located in a high density for oil and gas locations. KMOG’s remaining unavoidable impacts will be mitigated through direct fees paid to CPW as a forthcoming CPW-determined Mule Deer mitigation project. Taken together, these actions are necessary to ensure that impacts to wildlife resources are effectively avoided, minimized, and mitigated based on this development proposal. ********************* ECMC’s Form 2A Document Numbers for these locations are as follows: Rademacher - 403278425 Alfalfa - 403278400 Clover - 403278417 OGLA Operator provided the approved local permit - attached to the Form 2A and updated the local government tab. Attached response to public comments as "OTHER" doc 21316827 and Executive Summary as "OTHER" doc 21316826. CDPHE Consultation occurred on 1/22/2024. The BMPs from the consultation have been added to the Operator BMP section of this Form 2A and the consultation letter is attached. 02/16/2024 OGLA Public comment period for this location is 30-days. A technology glitch initially assigned 45 days for public comment ending on 2/11/24. The date has been updated to be 30 days post the OGDP considered Complete on 12/28/2023 for the public comment to end on 1/27/2024. This location is in HPH with 60-days for CPW consultation. 01/09/2024 OGLA Check the 309.e.(2) box on the 2A has the location is in HPH. Inform CPW for the consultation and task date. Inform CDPHE the location is in the 8-hour ozone area. CDPHE requested a consultation for the proposed location and OGDP. 01/08/2024 OGLA The Director has determined this OGDP application is complete. Form pushed to IN PROCESS. 12/28/2023 OGLA Attached Completeness spreadsheet as correspondence doc no 21316819 12/28/2023 OGLA The Conditions of Approval (COA) and Best Management Practices (BMPs) on the Form 2A and the Final Order are the final enforceable permit conditions for this Oil and Gas Location. Any plan or attachment that contains information or language that is contrary to or less protective than ECMC rules or the COAs and BMPs on the Form 2A or Final Order does not relieve the operator from compliance with the applied COAs, BMPs or any ECMC rules. 12/27/2023 Page 29 of 31Date Run: 3/19/2024 Doc [#403278425] OGLA At the time of Completeness review, the Wildlife mitigation compensatory mitigation between the plan and the 2A doe not match. Wildlife mitigation costs will be updated in the Form 2A to match the finalized numbers by CPW while the form is In Process. Replaced Geologic Hazard Plan and map and equipment list. per email and phone correspondence with the Operator. 12/27/2023 OGLA Completeness review - return to draft 12/01/2023 Total: 16 comment(s) Public Comments No.Comment Comment Date 1 As a Colorado resident and mineral right owner within the Sprout development project, I support Kerr-McGee's efforts in the Rademacher plan. I respectfully request approval of this permit application. 01/22/2024 2 Transcribed from hand delivered letter per stakeholder preference: January 22, 2024 Julie Murphy, Director Colorado Energy & Carbon Management Commission (formerly known as the Colorado Oil and Gas Conservation Commission) 1120 Lincoln Street Suite 801 Denver, Colorado 80203 Re: Sprout OGDP Application Dear Director Murphy, In the matter of the application submitted by Kerr-McGee O&G for the Sprout development plan, I have thoroughly read through the application, corresponding documents, the ECMC rules and regulations. I have followed the policies and statutes closely for a number of years and I appreciate and understand the significance of this development in the Wattenberg Field. I respectfully ask you to take the following into consideration: W.E. Russell established the Russell Coal Company in 1913. He had come from Scotland, arriving in Denver in 1889 and is considered a well respected Colorado Pioneer. He owned the Emerson/Russell Mine from 1913-1947. The land remained in the family until recent years, but in that time, the ranch was cared for and respected, including but not limited to the below surface mineral resources. Enormous contributions to Colorado and the development of local communities have been provided by generations of this ancestral family of Colorado pioneers. Not only was W. Russell President of the Russell Coal company, he was also former President of the Denver Chamber of Commerce. His extended family was commissioned by the State of Colorado to construct the Colorado State Capital Building, the Cheeseman Dam and many landmark buildings & structures in Colorado, many in downtown Denver that still stand today. Generations of the family, Colorado natives, have honorably & humbly held positions of public service and have passed on a continued sense of pride & responsibility in supporting the stability, strength, economics & appreciation for the state of Colorado. Their care and consideration for the safety and wellbeing of the communities they lived and worked in throughout Colorado is notable and their contributions in Weld County is equally important. So much of that continues and is driven by the respect and values that began with a family of Colorado pioneers and continues to this day. They are good values with relevance in this project. Mr. Russell provided the resources needed for Colorado families to heat their homes with the contributions he could provide. In 1970-1971 the original Oil, Gas & Mineral leases were signed. Those leases, an important part of the history of the ranch in Weld County, are still in place today and held by family and Kerr-McGee. They too are part of County, State and family history. In examining the Sprout Development Plan and the care and consideration of all interests, public health, safety, welfare, the environment and wildlife resources, I strongly believe this development not only is consistent with the love and respect this pioneer family considered important when it was in their care, but I believe they would appreciate and take pride in the advances in technology, commitment to the environment and to their vision of providing resources for the local community and State of Colorado. From contributing to the State's GDP, intelligently using science and technology by providing a resource to heat homes, as well as much needed tax revenues into the State & local funds as a solution to budget needs, jobs & local economic benefits, this permit application has far reaching benefits. I respect the due diligence of Kerr-McGee/Oxy, their commitment to meeting and exceeding every 01/24/2024 The following comments were provided by members of the public and were considered during the technical review of this application. Page 30 of 31Date Run: 3/19/2024 Doc [#403278425] expectation, rule and regulation, their consideration of community needs and the value Kerr-McGee places on being one of, if not, the BEST operator in the State of Colorado, with their attention to detail, safety & responsibly commitments in transitioning from old, outdated wells, to new industry advancements in construction, development, operations, safety & reclamation, all meeting the Colorado's statutes and mineral owners expectations. All phases of this energy development provides a reasonable solution and confidence this is a good plan for Colorado. These are important Colorado natural resources. I and others consider Kerr-McGee to be leading in smart, scientifically driven, environmental advances and production technology, a highly respected operator that brings full integrity and transparency with this application. The work they do on and off the field is appreciated. I hope you agree this application and supporting documents is evidence of proof that satisfies the requirements. I strongly support the owners who legally own these resources and have a legal right to develop them, as has historically been the case with precedence here. Many of them are the descendants of hard working visionaries, Colorado pioneers, who settled in Colorado on this ranch. I believe there is an important historical value in this project, with these multi- generational mineral right owners and Kerr McGee leading the way in this transition. I respectfully request you grant full approval of the Sprout (Clover, Alfalfa & Rademacher) permit application and development plan. It is an exciting time to advance this important new science and technology in Colorado and allow Sprout to proceed with support and approval from ECMC. Sincerely, Maureen T. Hartman 1651 Adams Street Denver, CO 80206 Total: 2 comment(s) Page 31 of 31Date Run: 3/19/2024 Doc [#403278425]