HomeMy WebLinkAboutCLOVER 2-29HZ - 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:
403278417
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 #
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
2-29HZ Number:CLOVER Name:
LOCATION IDENTIFICATION
03/05/2027Expiration Date:
Location ID:486289
OGDP ID:485787
Page 1 of 23Date Run: 3/19/2024 Doc [#403278417]
05/02/20231.4 Date of Measurement:GPS Quality Value:
4996667W 2N 29 Ground Elevation:Meridian:Township:NWNE 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:40.114904 Longitude:-104.912186
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:10/09/2023
Current status or disposition of the Relevant Local Government permit application for this proposed Oil and Gas Location:Approved
Status/disposition date:01/11/2024
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
Municipality Frederick Ali van Deutekom 720-382-5500 avandeutekom@frederi
ckco.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.
Page 2 of 23Date Run: 3/19/2024 Doc [#403278417]
Contact Name:Contact Phone:
Contact Email:Field Office:
Additional explanation of local and/or federal process:
No
02/01/2023Date 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
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.
< No row provided >
304.b.(2).B.i-x Criteria Met:
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?No
i. WPS < 2,000 feet from RBU/HOBU
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. WPS < 2,000 feet from RBU/HOBU/School within a DIC
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 23Date Run: 3/19/2024 Doc [#403278417]
SURFACE & MINERAL OWNERSHIP
Name:CAMENISCH CHARITABLE REMA Phone:
Fax:C/O ROXIE M KOLDEWAY
TRUSTEE
Address:
Address:9842 HIGHWAY 52
Email:rocmkold2@gmail.com
City:FORT LUPTON State:CO Zip:806218
430
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
No
N/A
Wells
Indicate the number and type of major equipment components planned for use on this Oil and Gas Location:
SITE EQUIPMENT LIST
12
Drilling Pits 0
Pump Jacks 12
Gas or Diesel Motors 0
Dehydrator Units 0
Oil Tanks 0
Production Pits 0
Separators 6
Electric Motors 0
Vapor Recovery Unit 2
Condensate Tanks 0
Special Purpose Pits 0
Injection Pumps 0
Electric Generators 0
VOC Combustor 0
Water Tanks 0
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
Communication Tower 1
Water Pump 2
Gas Manifold 12
Maintenance Pump 1
Oil Cooler 1
Chemical Totes 3
Air compressors 1
FG Scrubbers 1
E houses 1
Electrical Boxes 2
Page 4 of 23Date Run: 3/19/2024 Doc [#403278417]
OTHER TEMPORARY EQUIPMENT
Temporary Equipment Type Number
Generator 1
Sand Tanks 4
Propane Tanks 1
Sand Trap 3
Purge Flares 3
Enclosed Combustion Devices 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 KMG'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:1874 Feet
Designated Outside Activity Area:5280 Feet
Public Road:100 Feet
Above Ground Utility:146 Feet
Railroad:5280 Feet
Property Line:113 Feet
CULTURAL DISTANCE AND DIRECTION
Distance
NW
NW
N
N
SW
N
Direction
School Facility:5280 Feet
Child Care Center:5280 Feet
SW
SW
Rule 604.b Conditions Satisfied
(check all that apply):
604.b.
(1)Details of Condition(s)
Disproportionately Impacted (DI)
Community:
5280 Feet SW
604.b.
(2)
604.b.
(3)
604.b.
(4)
Residential Building Unit (RBU):2003 Feet E
High Occupancy Building Unit(HOBU)5280 Feet SW
SWFeet5280RBU, 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.
Page 5 of 23Date Run: 3/19/2024 Doc [#403278417]
Provide the number of each Cultural feature identified within the following distances, as measured from the Working Pad Surface:
Building Units
Residential Building Units
High Occupancy Building Units
School Properties
School Facilities
Designated Outside Activity Areas 0
0
0
0
0
0
0-500 feet
0
0
0
0
0
0
501-1,000 feet
0
0
0
0
0
0
1,001-2,000 feet
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 WMP.
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:
11.71Size of disturbed area during construction in
acres:
CONSTRUCTION
3.79
DRILLING PROGRAM
Yes
No
Will oil based drilling fluids be used?Yes
4996
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:
NON-IRRIGATED CROP LAND - Tall Wheatgrass.
Describe the Relevant Local Government’s land use or zoning designation:
AGRICULTURE
Describe any applicable Federal land use designation:
Page 6 of 23Date Run: 3/19/2024 Doc [#403278417]
NONE
Other
Residential
RecreationForestry
CommercialIndustrial
Rangeland
Conservation Reserve Program (CRP)Non-IrrigatedIrrigated
Subdivided:
Non-Crop Land:
Crop Land:
Final Land Use: check all that apply per Rule 304.b.(9).
X
FINAL LAND USE
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
NON-IRRIGATED CROP LAND Tall Wheatgrass.
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:4-Aquolls and Aquepts, flooded
NRCS Map Unit Name:44-Olney loamy sand, 1 to 3 percent slopes & 47-Olney fine sandy loam, 1 to 3 percent slopes
NRCS Map Unit Name:72-Vona loamy sand, 0 to 3 percent slopes & 73-Vona loamy sand, 3 to 5 percent slopes
GROUNDWATER AND WATER WELL INFORMATION
Provide the distance and direction, as measured from the Working Pad Surface, to the nearest:
water well:1097 Feet S
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:
Monitoring wells were drilled to a depth of 8' within the proposed oil and gas location. Groundwater was encountered at 66 inches
and 90 inches. KMOG conservatively estimates depth to groundwater at 5'.
5
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 W77
If less than 2,640 feet, is the Waters of the State identified above within 15 stream miles upstream of a Public Water
Page 7 of 23Date Run: 3/19/2024 Doc [#403278417]
POND
System intake?No
Provide the distance and direction to the nearest downgradient wetland, measured from the Working
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:
N/A
zone type:
associated pipeline corridor?No
Pad Surface:WFeet77
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.
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:
A pre-application consultation with CPW, regarding this Oil and Gas Location, occurred
on:
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.
Page 8 of 23Date Run: 3/19/2024 Doc [#403278417]
No BMP
Operator Proposed Wildlife BMPs
No BMP
CPW Proposed Wildlife BMPs
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.
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):
< No row provided >
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
No
No
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
Is Compensatory Mitigation required per Rule 1203.d for this Oil and Gas Location?
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AIR QUALITY MONITORING PROGRAM
Will the Operator install and administer an air quality monitoring program at this Location?Yes
No BMP
Operator Proposed BMPs
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:
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This proposed Oil and Gas Location requires the approval of a Rule 502.a variance from COGCC Rule or Commission
Order number:
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 11 of 23Date Run: 3/19/2024 Doc [#403278417]
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 Mountain View Fire Protection District. Once the plan is approved a signed
copy will be sent to the COGCC 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 COGCC 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 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 2,214 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.
As part of this OGDP the production facility equipment on the RUCA 20-5HZ (Loc ID: 458592) location will be removed
and the wells connected by flowlines to the new proposed Alfalfa location. A Form 4 Sundry will be submitted to reflect the
planned equipment inventory reduction at the RUCA 20-5HZ location
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 12 of 23Date Run: 3/19/2024 Doc [#403278417]
2 General Housekeeping 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.`
3 General Housekeeping 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. • 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. • In the event of a lightning
complaint, KMOG will address the complaint and work with all parties involved to
ensure the complaint is resolved. 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 directed to task areas only.
• In the event of a lightning complaint, KMOG will address the complaint and work with
all parties
involved to ensure the complaint is resolved.
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.`
4 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.
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.`
5 Wildlife An environmental assessment will be conducted immediately prior to pad construction,
drilling, and completion operations.
`
6 Wildlife If construction coincides with the raptor nesting season. KMOG will perform pre-
construction surveys to determine nearby nest statuses. If construction occurs during
the Burrowing Owl nesting season, CPW protocol-level surveys will be performed prior
to construction. If active Burrowing Owl burrows are identified within 1/4 mile of the
Site, KMOG will proceed with CPW consultation.`
Page 13 of 23Date Run: 3/19/2024 Doc [#403278417]
7 Wildlife Avian protection will be installed on openings larger than two inches. Approximately
two weeks prior to construction start, the approved locations will be surveyed by third
party biological contractor for nests. A site-specific spill prevention, control, and
countermeasure plan compliant with EPA rule 40 CFR 112 has been created and
submitted with the 2A for these locations. Automated emergency response systems
and emergency shutdown systems will be installed. Remote monitoring systems will be
utilized at these locations. Periodic inspections for nests and of avian protection will
occur throughout the life of the project. Training is provided to employees and
contractors on wildlife conservation practices, including no harassment, feeding of
wildlife, or illegal hunting. KMOG maintains a Standard Operating Procedure (SOP) for
water suction hoses and transportation Tanks that meets 1202.a.(2).A requirements
with 3rd party contractors when moving equipment from locations. The contractor will
use a CPW-approved disinfectant solution capable of destroying whirling disease
spores and other aquatic nuisance species defined by CPW. KMOG does not use
drilling pits, production pits or any other pits at oil and gas locations in the Denver-
Julesburg Basin.`
8 Storm Water/Erosion
Control
If it is infeasible to install or repair a control measure immediately after discovering a
deficiency, KMOG 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.
`
9 Storm Water/Erosion
Control
KMOG will install adequate down gradient controls if they can not have a control at the
source.
`
10 Storm Water/Erosion
Control
KMOG will ensure that control measures are designed, installed and adequately sized
in accordance with good engineering, hydrologic and pollution control practices.
`
11 Storm Water/Erosion
Control
KMOG will install perimeter controls to control potential sediment-laden runoff in the
event of spill or release from Modular Large Volume Storage Tank.
`
12 Storm Water/Erosion
Control
Outlet protection will 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.
`
Page 14 of 23Date Run: 3/19/2024 Doc [#403278417]
13 Storm Water/Erosion
Control
? A diversion ditch and berm will be implemented to divert stormwater run-on & run-off
throughout Clover 2-29HZ to a designated outlet structure(s). ? This BMP will be
installed prior surface disturbing activities and will surround the entirety of the location
to create continuous perimeter control. ? An additional berm will be installed on the
western and northwestern portions of the well pad and the facility pad working surface.
? Diversion ditch and berm will remain in-place until interim reclamation activities are
complete.
? A temporary 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 ditch and berm, and prior to commencement of surface disturbing
activities. ? A temporary spillway/outlet will be installed in the northwestern segment of
the disturbance area ditch and berm, the western and northwestern segments of the
facility berm and the northwestern and southwestern segments of the well pad berm
for Clover 2-29HZ. ? All spillways and outlets will remain in-place until interim
reclamation activities are complete
Inspections will be conducted to document the status of construction activities,
stormwater control measure placement, maintenance needs, and effectiveness, to
evaluate pollution sources, and to document reclamation / final stabilization progress.
Inspections will be managed by the Stormwater Manager and SWMP Administrator
and conducted by their designated representative(s). Inspection forms will document
non-compliance conditions, including any release of sediment or other contaminants,
additional control measures that are needed, or repair and maintenance work orders.
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).`
14 Material Handling and Spill
Prevention
KMOG will ensure that a fueling contractor is present during the entire fueling process
to prevent overfilling, leaks and drips from improper connections.
`
15 Material Handling and Spill
Prevention
KMOG will properly test for and dispose of TENORM.
`
16 Material Handling and Spill
Prevention
KMOG will refuel vehicles only on impervious surfaces and never during storm events.
`
17 Material Handling and Spill
Prevention
KMOG will use Modular Large Volume Storage Tanks.`
18 Material Handling and Spill
Prevention
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.`
19 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.
When construction is completed and the location is on production, site inspections will
occur every 28 days at a minimum.`
20 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.`
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21 Material Handling and Spill
Prevention
Completion: During completions operations, the following site-specific best
management practices will be used: KMOG will monitor pressure responses and
containment to identify potential leaks. Lines will also be walked continuously
throughout operations (between stages) to identify potential leaks. In addition, there is
a slam valve and control valve with Emergency Shut Down system in line to the
external temp tanks to prevent overflowing tanks during the green flowback duration.`
22 Material Handling and Spill
Prevention
production: 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. All
personnel on location on behalf of KMOG are trained in AVO techniques. All personnel
are empowered with ‘Stop Work Authority’ and to report an leaks immediately.`
23 Dust control KMOG will not use produced water or other process fluids for dust suppression.
`
24 Dust control Access roads are not paved, they are constructed with a minimum of four - inches of
gravel road base
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 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)
Sand boxes are used during hydraulic stimulation to reduce the risk of silica dust.`
25 Construction KMOG will properly construct or modify a road to access the location for drilling,
completions, and production operations, including maintenance of equipment. The
road will be adequately constructed and maintained to accommodate for emergency
vehicle access.`
26 Construction 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.`
27 Noise mitigation Prior to commencement of drilling and completion activities, a perimeter, engineered
sound wall consisting of approximately 1,540 linear feet of 32-foot-tall, STC32 wall,
and 80 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 footage is
broken down below: o 320 linear feet on west edge of the well pad o 540 linear feet on
north edge of the well pad o 380 linear feet on the south edge of the well pad o 380
linear feet on the east edge of the well pad • KMOG will utilize a modified drilling rig
designed to reduce overall noise levels. This will include low noise level shale shakers
and modifications to the generator house to reduce noise levels from the exhaust
vents and radiator fans. Additional noise reduction modifications may also be
implemented depending on the rig contractor utilized following a noise survey study. •
KMOG will utilize a low noise completions fleet for all completions operations. •
Flowback operations and equipment were reviewed as part of this Noise Mitigation
Plan (NMP). Flowback utilizes a fraction of similar, but smaller equipment compared to
the three other operations studied. Perimeter sound walls will be left in place until flows
are initiated to appropriately manage noise levels for this operation.`
28 Emissions mitigation KMOG commits to monitoring ambient air quality during drilling and completion
operations and for the first 6 months of production.
`
29 Emissions mitigation KMOG will control bradenhead/casinghead venting.
`
Page 16 of 23Date Run: 3/19/2024 Doc [#403278417]
30 Emissions mitigation KMOG will control emergency flaring with an enclosed combustor with a destruction
efficiency of 98% or better.
`
31 Emissions mitigation KMOG 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.
`
32 Emissions mitigation 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. KMOG
uses an automated engine management system that preferentially uses natural gas
engines over diesel for rig
power.
During Completions: During completions KMOG uses a closed loop system. As a
standard practice, KMOG has also implemented the pipelined Water on Demand
(WOD) system which will eliminate approximately 393,676 truck trips at the Sprout
OGDP locations during completions activities.
During Flowback: Fluids will flow through separation equipment where the gas will be
collected through a gas gathering line instead of vented or burned.`
33 Emissions mitigation Produced water will be piped from the Clover location.`
34 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.
production: • KMOG uses pipelines to transport hydrocarbons (oil & gas) from the
production facility eliminating odors that could occur during truck loading.
• Production facilities are inspected regularly by KMOG to make sure the equipment is
working property and necessary maintenance is performed, to reduce potential odors.
KMOG incorporates Audio, Visual, Olfactory (AVO) observations at production facility
inspections.
• KMOG will use Best Management Practices to reduce unloading events and to
reduce potential odor causing emissions when liquids unloading is necessary (i.e.,
maintenance activities to remove liquids from existing wells that are inhibiting
production).
• KMOG remotely monitors production facilities, this reduces traffic onto production
facilities which may create odors from truck traffic.`
35 Drilling/Completion
Operations
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.`
36 Drilling/Completion
Operations
Guy line anchors will not be used. Base Beams will be used to stabilize the rig and
removed after drilling.
`
37 Drilling/Completion
Operations
KMOG will ensure that all drilling fluid is removed from pipes before storage.
`
Page 17 of 23Date Run: 3/19/2024 Doc [#403278417]
38 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 2,214 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.`
39 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
Page 18 of 23Date Run: 3/19/2024 Doc [#403278417]
• 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
In addition, CDPHE supports incorporation of each of the BMPs that Oxy has
committed to exclusively for the Alfalfa and Clover pads in the Sprout OGDP, as listed
below:
• Operator will not store produced water in permanent storage tanks on site (other than
a
maintenance tank possibly used for well unloading or other maintenance activities)
• Operator will use pipelines to transport water used for hydraulic fracturing from
location`
40 Interim Reclamation Topsoil piles will have stabilization with mulch, seeding, track walking, perimeter
control or a combination of BMPs. Weeds on stockpiles shall be controlled as to
prevent production of weed seed and/or enough biomass that would interfere with
redistribution of soil or cause onsite debris. Signage shall be installed to identify topsoil
stockpiles to facilitate subsequent reclamation and indicate to personnel that the area
may not be disturbed by drilling and completion operations
? Ditch and berm shall be installed around the perimeter of the location, and
subsequently around all topsoil stockpiles, to intercept and divert stormwater run-
on/run-off and sediment from precipitation and melt events. ? Track packing all topsoil
stockpiles will occur to prevent erosion from stormwater and wind, as well as provide
temporary stabilization. ? Seeding and crimped straw mulch will be applied to prevent
erosion and soil loss from stormwater and wind. ? Vegetation establishment through
seeding efforts will promote soil health and maintain carbon exchange. ? Weed control
will occur seasonally and as needed to hinder the spread of weeds throughout the
topsoil stockpile(s) and help native grass establishment.
Vegetation establishment through seeding efforts will promote soil health and maintain
carbon exchange. ? Weed control will occur seasonally and as needed to hinder the
spread of weeds throughout the topsoil stockpile(s) and help native grass
establishment.`
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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.
`
42 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.
`
43 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.
`
Total: 43 comment(s)
Attachment List
Att Doc Num Name
21316816 GEOLOGIC HAZARD MAP
21316819 CORRESPONDENCE
21316821 CDPHE CONSULTATION
21316824 LOCAL GOVERNMENT PERMIT
21316826 OTHER
21316827 OTHER
21316828 OTHER
21316830 DIRECTOR'S RECOMMENDATION
403278417 FORM 2A SUBMITTED
403497738 ACCESS ROAD MAP
403497742 DIRECTIONAL WELL PLAT
403497743 HYDROLOGY MAP
403497749 LOCATION PICTURES
403497751 LOCATION PICTURES
403497775 PRELIMINARY PROCESS FLOW DIAGRAMS
403497776 WILDLIFE HABITAT DRAWING
403498288 LOCATION AND WORKING PAD GIS SHP
403498289 OTHER
403498292 CULTURAL FEATURES MAP
403498297 LGD CONSULTATION
403522150 SURFACE AGRMT/SURETY
403627608 RELATED LOCATION AND FLOWLINE MAP
403627612 NRCS MAP UNIT DESC
403628723 OTHER
403637770 LAYOUT DRAWING
403637776 LOCATION DRAWING
Total Attach: 26 Files
Page 20 of 23Date Run: 3/19/2024 Doc [#403278417]
User Group Comment Comment Date
OGLA “OGDP ID# 485787 and this Form are approved by Commission Order Number 407-3580 03/14/2024
OGLA Due to a technical glitch, Weld County comments did not save. Weld County emailed the
following to ECMC staff:
1041WOGLA23-0048 – Kerr McGee – Clover 2-29HZ
The Weld County Oil and Gas Energy Department (OGED) submits the following
comments:
1. Case number 1041WOGLA23-0048 has been assigned to the Clover 2-29HZ 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) Alfalfa location was reviewed and
processed under Weld County Code, ORD2021-17.
3. A pre-application meeting was held on February 1, 2023. Attendees included OGED
Staff, KMG Staff, ECMC, CPW, Weld County Staff, Town of Firestone representatives.
4. The 1041 WOGLA Application was received on October 9, 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 November 7, 2023.
8. Kerr McGee Oil & Gas Onshore, LP held a Community Outreach meeting on December
6, 2023 at 6pm at the Firestone Town Hall. OGED Staff members attended. There were
no residents or community members in attendance.
9. A 1041 WOGLA Hearing was held on January 11, 2024. The OGED Hearing Officer
considered testimony at the 1041 WOGLA hearing, and subsequently approved
1041WOGLA23-0048.
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 January 23,
2024, reception number (4940730) and was noticed in the Greeley Tribune on January
26. 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 Update on the Form 2A the distance to the nearest wetland and surface water body to be
77 feet vs. 130 feet. 77 feet is indicated on the hydrology map. The man-made pond is the
surface water body and mapped wetland. According to the operator and photos, the pond
is used for cattle and there is little to no vegetation around the pond.
02/22/2024
General Comments
Page 21 of 23Date Run: 3/19/2024 Doc [#403278417]
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 Operator provided the approved local permit - attached to the Form 2A and updated the
local government tab. Removed the comment "A 1041WOGLA will be submitted for this
location. KMOG will update OGLA staff when that is submitted." Attached response to
public comments as "OTHER" doc 21316827 and Executive Summary as "OTHER" doc
21316826.
02/16/2024
OGLA Consultation with CDPHE occurred on 1/22/2024, the letter is attached and the BMPs
have been added to the BMP section of the Form 2A.
02/12/2024
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.
01/09/2024
OGLA 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 Attached Completeness spreadsheet as correspondence doc no 21316819 12/28/2023
OGLA The Director has determined this OGDP application is complete.
Form pushed to IN PROCESS.
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
OGLA Replace Geologic Hazard Plan and Map and update equipment list per email and phone
correspondence with Operator. Missing Location drawing and the Layout drawing file is
corrupt. Push back to draft.
12/27/2023
OGLA Completeness review - return to draft 12/01/2023
Total: 13 comment(s)
Public Comments
No.Comment Comment Date
1 Colorado has some of the strictest oil and gas regulations in the country. These rules are designed to
regulate the industry in a way that protects both the public and the environment. The ECMC has
proven that they are not out to shut down the industry or 'keep it in the ground', but looking to find a
balance between local communities, the environment, and the oil and gas industry.
Operators in Colorado have stepped up to the call to operate safely, neighborly, transparently, and
with a reduced impact to the environment. Colorado is an example for the rest of the country.
Occidental has done a wonderful job engaging the communities they operate in and complying with
both the letter and spirit of the updated oil and gas regulations.
While the world is in an energy transition, there is still a great need for fossil fuels. Why shouldn't
those fossil fuels be produced responsibly? Colorado can lead the way in responsible exploration,
development, production, transportation, and processing of fossil fuels. Colorado is a model for other
industry regulators.
I believe that the Sprout OGDP (Rademacher, Clover, and Alfalfa pads) is compliant with current
regulations and rules. I believe that Occidental is a responsible operator. Therefore, I support the
Sprout OGDP and hope that the ECMC approves this application and subsequent well permits.
01/23/2024
The following comments were provided by members of the public and were
considered during the technical review of this application.
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2 I am writing to you to let you know how important it is to our family to continue drilling Township 2
North, Range 67 West 6th P.M. These were mineral rights bequeathed to the children of Salena
Hittson Ernest Moore(my Great-Grandmother). She was the daughter of a great sheriff and cattleman
John Hittson from Texas. Due to his cattle business the family moved to Denver about 1870 their
ranch was just outside Denver. Salena married Finis Ernest in 1880 who was also a cattleman. They
were very prominent in Denver and she was active in society including dinners with the Governor.
Later in life she was on the only women's committee at the1904 St. Louis World’s Fair. She continued
being involved in women's suffrage and Indian rights in her later years. In 1907 she was widowed and
several years later married W.T. Moore of San Antonio who was an oil man. She was widowed again
several years later and eventually bought mineral rights in Weld County Co. These wells did not start
producing until the late 1990's. These mineral rights have been a legacy to many of her heirs over the
last 20 or so years. Approximately 12 cousins including myself and brother have all received mineral
rights. Some have passed on and handed down to their families. All of us are very proud of our
heritage and ties to Colorado, Denver and Manitou. The mineral rights has enabled my husband and I
to help pay for four of our grandchildren’s’ college education. The last who is a freshman this year so
has at least three years to go and his sister is starting her masters this fall. This means so much to us
to help them on this road of educations and bright futures. I am sure my great grandmother had no
idea she would still be helping her great-great-great grandchildren in 2024!
We were visiting Colorado this fall for our daughter’s wedding. We took a side trip to Fairmount
Cemetery in Denver where my great grandparents are buried and many other relatives. We were not
disappointed in the beautiful burial spot or the Denver area! Our hopes are you will see that there are
many people who prosper from these mineral rights not just big corporations.
We also hope this area of drilling will continue to prosper for many years to come.
Thank you for your time.
Judith Grimmer
01/23/2024
3 To: Energy and Carbon Management Commission
From: Vivian Teets
InRe: Kerr-McGee Sprout Oil and Gas Development Plan
Alfalfa 8-20HZ, Clover 2-29HZ, Rademacher 14-30HZ
I am in full support of the application for permitting the three pads planned for this development.
As a mineral rights owner, I have always found them to be helpful, available to answer questions, and
prompt in making royalty payments.
As a previous owner of surface areas in Sections 20 and 29, I found that Kerr-McGee was a
responsive, reliable and conscientious producer. They were careful and efficient, always proactive
and completely transparent during the development and operation of their wells. They respected the
land and land owners.
I believe that this is the right action at the right time by the right company and I urge the Commission
to approve this application.
Thank you.
Vivian Teets
10091 Prima Run Place
Colorado Springs, CO 80924
vivian@teets.net
01/23/2024
4 Please, there doesn't need to be more O&G drilling in this state.01/25/2024
Total: 4 comment(s)
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