HomeMy WebLinkAbout3.0 Conditions & CorrespondenceGuffield Coulnty
Community Development Department
December 8,2020
Jeff Kirtland
Terra Energy Partners (TEP)
4828 Loop Central Drive #900
Houston, TX77081
RE: Completeness Review Starkey Gulch Drill Cutting Facility (GAPA-11-20-8816)
Administrative Land Use Change Permit
Dear Mr. Kirtland
Thank you for the detailed application supplemental materials you've provided and the
supplemental email addressing completeness issues.
This letter is to inform you that your application has been deemed Technically Complete. Please
understand that a determination of technical completeness shall not be viewed as a
recommendation of approval, finding of an adequate application, or a finding of general
compliance with any goal or objective of the Land Use and Development Code or the Garfield
County Comprehensive Plan 2030. The date upon which the Director of the Community
Development Department will render decisions on the Applications has been set for December 29,
2020.
Public notice at least 15 days priorto the Director's Decision is required by written notice by
certified mail, to the owners of record of all property adjacent to the property and within 200 ft.,
and by certified mail return receipt requested to the mÍneral owners of record for the Applicant's
property. The Applicant shall be solely responsible for the mailing of the notice. The Applicant
shall present proof of the required notice to the Community Development Department prior to the
Director's Decision. Pursuant to Section 4-103(BX3) of the Land Use and Development Code, the
notice shall include a vicinity map, the property's legaldescription, a short narrative describing the
proposal, current zoning, the contact information forthe Community Development Department and
the date that the Director will make a decision.
I have enclosed an appropriate notice for the Director's Decision for your convenience. The
document is provided to you as a courtesy and the Applicant must verify that all information in the
notices is correct and attach or insert any changes to the legal description and vicinity map. lt
shall be the obligation of the Applicant to correct any deficiencies in the public notice such that
proper notice in form and substance can be established. lncluded for your convenience is the
following outline of the process from this point.
1. Referrals have been sent out.
2. Public Notice must be mailed by the Applicant no later than December 14th.
3. Applicant will need to provide a completed Public Notice Information Form along
with the proof of mailing and return receipts prior to the Director's Decision.
4. On December 29th, the Director of the Community Development Department will
render a Decision to approve, approve with conditions or deny the application.
5. The Board of County Commissioners will be provided notice of the Director's
decision and will have a 10 day call up period to request a public hearing.
6. lf the call up time period expires without a request for a hearing from the Board, or
the Applicant, or an adjacent property owner, the decision will become final.
7 . Once all conditions of approval have been met the Land Use Change Permit will be
signed and issued.L Following the Director's Decision, the Applicant will have one year to meet all
conditions of approval unless an extension is requested.
Please contact me if you have any questions regarding the scheduling and the public notice
requirements. Thanks again for allyourwork on getting the Application submitted and complete.
Sincerely,
,Ôru
Glenn Hartmann
Principal Planner
?
PUBLIC NOTICE
TAKE NOTICE that TEP Rocky Mountain LLC (Terra Energy Partners) has applied to the
Community Development Department Director, Garfield County, State of Colorado, to
request approval of a General Administrative Land Use Change Permit for Processing,
associated with the Starkey Gulch Waste Management Facility - Drill Cuttings; in Garfield
County; to-wit:
Leqal Description: LEGAL DESCRIPTION TO BE INSERTED OR ATTACHED BY THE
APPLICANT
Practical otion:The property is located approximately 4.7 miles north of Parachute
on private roadways off of County Road 215 within the NE%NE% Section 32 and the SE%
SE%section 29, T65, R96Wof the 6'n p.m.(Parcel No.2171-332-00-019)
Description of Request: The Applicant is requesting approval for a Non-Commercial,
Centralized Exploration and Production Waste Management Facilityfor Processing, known
as the Starkey Gulch Waste Management Facility - Drill Cuttings. The facility is located on
approximately 6.13 acres of an overall 1 ,234 +l- acre property. The facility is located on a
COGCC site and will be operated to treat, dispose, recycle, and beneficially re-use solid
wastes generated by TEP during drilling operations in the Piceance Basin. Materialwill be
transported to the site by trucks on existing private roadways. The property is zoned
Resource Lands - Gentle Slopes, Lower Valley Floor (RLGS) and the Applicant's
Representative is Jeff Kirtland, Regulatory Lead.
Vicinitv Map: VICINITY MAP TO BE ATTACHED BY THE APPLICANT
All persons affected by the proposed Administrative Land Use Change Permit are invited to
comment regarding the application. You may state your views by letter or you may call the
Community Development Department at (970) 945-8212 regarding the application. The
Director will give consideration to the comments of surrounding property owners, and
others affected, in deciding whether to approve, approve with conditions or deny the
request. The application may be reviewed at the office of the Community Development
Department located at 108 8th Street, Suite 401, Garfield County Plaza Building, Glenwood
Springs, Colorado between the hours of 8:00 a.m. and 4:30 p.m., Monday through Friday.
As our offices currently has restricted access, please call, email or contact ourwebpage for
instructions on how to view the application online. The application can be viewed at the
Community Development webpage and searching Applications under Review for File No.
GAPA-1 1-20-8816.
The Director will make a decision on this application on December 29, 2020. Any
comments to be considered must be received prior to that date.
Commu nity Development Department
Garfield County
LEGAL DESCRIPTION
TO BE INSERTED BY THE APPLICANT
TEP Rocþ MounrË¡n LLC
tIovÊilber 2t¡2tl
Le€al fÞscription for Parcel 2171-332{(H)1!t
Townshio 6 South. Range 96 West 6t P.M.
Section 27: Lot 13lswlasïltxl
Section 28: Lot I {NW!{SE!{}, NEXSWX, LÊt I INW!{$i¿{}, Lot 10 fSWtaSWt¡}, Lot 11 {SEtlSW¡}, Lot 12
(SW:{SE]{}, Lot 13 {SEISE:{}
Section 29: Lot 11{SEXSWI{}, SHSEX
Section 32: NEÍ, E {NWl{ Lot5 {Nf!{SEl{}
Section 33: Lot 1 {f{El{lìlE{}, tot 2 (NW,{ilEXI, tot 3 (}lEl{NWX}, W}lNlM{, SEftt¡W!{, SWr{NEt{, NXSWX,
sEx
Section il4: Lot 2 {NWXNìM{}, Lot 1g {NWKSIJ\r1(}, Lot 11 (SW!{SW!$
Ga rff eld County, Colorado
Township 7South. flenee96W€5t 6ü P.M.
Sest¡on 4 Lot 1 (¡¡E fIì¡E (l
6a rfr eld County, Colorado
1234+/- ecres
VICINITY MAP
TO BE INSERTED BY THE APPLICANT
Legend
O Slarkev Gulch cu/llF S¡te
i t -! ,, ntu.
"un",
N
Sta r key G u I c h Ce ntral i zed
Wa ste Ma nagement F ac i I ity
Vicinity Map
October 28, 2020
'@ Ð
-
Existinq TEP Road
Ex¡sl¡ng Pu¡rl¡c Road
Parcel Ovrnershrp {from Garfreld Counly)
s
a 2,250 4,500 9,000fFeet
I
l\proJecls\PrceanæìGEnd Valleylslarkey culch CWMRMsit {2}Garfreld Cdnty LUC Dæume¡lsvicinrtyMap-llxd AÏankersley I 0/282020 2 38:47 PM
GIenn Hartmann
Sent:
To:
Cc:
From Jeff Kirtland < JKirtland@terraep.com >
Friday, December 4,2020 11:41 AM
Glenn Hartmann
Bryan Hotard
lExternal] Starkey Gulch Land Use Change Permit address verification
Glenn,
Thanks for the conversation earlier today. Per our discussion please accept this email as verification that our required
notices will be sent to the following recipients identified in our application in conformance with the county assessor
data:
- Caerus Oil and Gas
- XTO
- Bargath
We will verify the addresses o.n the assessor website prior to the required mailing notice
Thank you,
Jeff Kirtland
Terra Energy Partners LLC
This message and any related attachments are intended only for the use of the addressee(s) and may contain
information that is PRIVILEGED and CONFIDENTIAL. lf you are not the intended recipient(s), you are hereby notified that
any dissemination of this communication is strictly prohibited. lf you have received this communication in error, please
erase all copies of the message and its attachments and notify the sender immediately.
Subject:
1
Glenn Hartmann
From:
Sent:
To:
Subject:
Jeff Kirtland <J Kirtland@terraep.com >
Wednesday, April T, 2021 7:47 AM
Glenn Hartmann
RE: [External] RE: Director's Decision Letter - Starkey Gulch Drill Cutting Processing
Facility
Glenn,
Good morning, thank you for the email. I forwarded your questions to Mike Gardner in environmental for response,
which are highlighted below.
I have time between L:30-3:00 pm for a calltoday on my cell9T0-312-5643
Thank you,
Jeff Kirtland
Regulatory Lead
TEP Rocky Mountain LLC
(Terra Energy Partners LLC)
From: G lenn Hartmann <ghartman n@ga rfield-county.com>
Sent: Monday, April 5,202L 5:01PM
To: Jeff Kirtla nd <J Kirtland@terraep.com>
Subject: RE: IExternal] RE: Director's Decision Letter- Starkey Gulch DrillCutting Processing Facility
HiJeff: Thanks very much for your responses to the Conditions. Outlined below is a quick summary of our review
Condition #3: Your site plan updates satisfy this conditions.
Condition #4:
o The liner questions is well addressed in your supplement.
. My understanding is that your reference to COGCC 915-1 Clean-Up Standard addresses the question of the use
of Trenches #2 and #3 for Cutting associated with Oil-Based Drilling Fluids and other Oily and E&P Waste soils.
Correct. I think we're saying the same thing: Trench #L = to be used for water based drill cutt¡ngs; Trench #2 =
to be used for oil-based cuttings (when and if we even ever go that direction); and Trench #3 = to be used for
oily wastes (mostly just contaminated.soils from small spills that require treatment to meet 91-5-1 cleanup
sta nda rds.
o Your description of how to cuttings will be managed to ensure that they are dry enough for placement was most
helpful. ls there a measurable standard that you reference or use? No. There is no measurable standard for a
target moisture content.
Condition #5: The updated lnspection Plan addresses Condition #5
Condition #6:
. My understanding is that references to calling 9-Lj- and/or the lncident Commander calling for activation of the
BCT address the potential shut down of the facility.
o The TEP Emergency Contact List should be double checked for updates. Please double check, Grand River Fire
Protection, and County Environmental Health (Ted White 970-945-6614 x81-06 twhite@earfield-countv.com has
taken over many of Morgan's responsibilities). While not relevant to the Parachute site some of the contacts for
iit tÌf ¡li
otherTowns m need
Condition f7: Thanks for your confirmation which addresses the condition
Condition #8: Thanks for your confirmation which addresses the condition
I will plan on giving you a call later today or tomorrow to go over any final clarifications. I anticipate based on that
phone conversation we should be good to move forward with getting you permit issued. I wlll also need to gêt you âny
final billing and/or planner hours. Thanks again and l'll look forward to talking with you shortly. Glenn.
Glenn Hartmann
Principal Planner
97O-945-L377 xL57O
G ha rtma n n@sarfield-countv.com
2
Memorandum
To: Glenn Hartmann, Principal Planner- Garfield County
From: Jeff Kirtland, Regulatory Lead - TEP Rocky Mountain LLC
Date: March 15,202I
ln response to the Decision Letter from the Garfield County Community Development Director (Ms. Sheryl
Bower), dated Februa ry 1,2,2O2!, re: the Starkey Gulch Drill Cutting Facility (GAPA-11-20-8816) Administrative
Land Use Change Permit, please see responses to Conditions Prior to lssuance for numbers 3-8 below:
3. "Prior to issuance of the Land Use Change Permit, the Applicant shall provide an updated site plan for review
and acceptance by County Staff, identifying the Temporary Staging and treatment areas forthe drill cuttings,
internal vehìcle circulation and parking areas for equipment and employees, maximum height of stockpile
areas and snow storage areas."
Please see attached an updated site plan that identifies the "Temporary Staging and treatment areas
for the drill cuttings, internal vehicle circulation and parking areas for equipment and employees,
maximum height of stockpile areas and snow storage areas".
4. "Prior to issuance of the Land Use Change Permit, the Applicant shall document that lining of the
trenches/pits is not required bythe COGCC and not required based on the type of treatmentthe drillcuttings
will undergo prior to placement in the trenches. Said response shall specifically address the uses of Trenches
#2 and #3 for drill cutting associated with Oil-Based Drilling Fluids and use for Oily and other E&P Waste soils.
The Applicant shall also provide a more detailed representation regarding the treatment standards and criteria
to ensure that the drill cuttings will be sufficiently dry for placement into the tranches."
Lining of the pits is not required by COGCC or required based on the type of treatment for drill cutting
based on: 1") No free fluids will be ever be managed, treated, or stored at this location. Only dry, solid
E&P wastes that have been treated to comply with COGCC 91"5-l- cleanup standards will be placed into
the individual cells for treatment / disposal. No materials exceeding these cleanup standards will be
allowed for direct burial /disposal. 2) As discussed with COGCC, a synthetic liner is not practical for
use at this facility due to types of heavy equipment (e.g., excavators, front-end loaders, dump trucks)
that will be required to mix, treat, and place the treated soils in the disposalcells. A synthetic liner
would be quickly destroyed / compromised due to the types of equipment being used and the amount
of heavy equipment traffic that will be concentrated in this area. Metaltracks on the excavators and
metal teeth on excavator / loader buckets would easily puncture and compromise a synthetic liner. 3)
1058 COUN]Y ROAD 215, PARACIIUTE, CO 81635
T 97 0 -263 -27 3 6 C 97 0 -312-56 43
TEP has completed the installation ol4 ground water monitoring wells around the perimeter of the
CWMF for the purposes of monltorlng any lmpacts to any shallow ground wäter that may be present
in the immediate area. The monitoring wells will be monitored quarterly and compared to baseline
water quality conditions to ensure there are no impacts to any localized ground water resources
resulting from the CWMF. 4) A 3-ft thick constructed soil / clay cap liner will be installed over the final
reclaimed facility which will effectively prevent infiltration of precipitation from coming into contact
with underlying treated waste materials. 5) To ensure that drill cuttings are sufficiently dry and suitable
for processing at the CWMF, the following procedure will be followed:
As drill cr-rttings are brought to the surface at the drilling rig, they are separated from the
water-based bentonitic drilling mud by going through series of shakers which effectively
separate the mud and water from the fresh cuttings. The drilling mud is captured and re-
circulated into mud tanks where it is re-used in the drilling process.
The cuttings come off the shaker assembly and are deposited into a large, heavy-duty, high-
walled, steel bin. After being separated, the cuttings consist of rock chips and a small residual
amount of drilling mud.
Saw dust is added and blended into the cuttings inside the metal bins to reduce the moisture
content of the material and to facilitate material handling.
The cuttings are now suitable to be transported from the well location to the disposal facility.
A front-end loader is used to remove cuttings from the large steel bins and place the material
into a dump truck.
The cuttings are trucked from the well pad to the Starkey Gulch CWMF where they are placed
into the treatment cell pending additional treatment.
At the treatment cell, clean native solls are mlxed with the processed cuttings to further
reduce the moisture content and to prepare the cuttings for burial/ disposal and to facilitate
compaction.
The processed drill cuttings are sampled on multiple occasions to determine compliance with
COGCC clea nup standa rds.
Samples of the processed cuttings are sent to an accredited analytical laboratory for detailed
compositiona I analyses.
Lab results must indicate that the processed cuttings material comply with COGCC cleanup
standards before the processed cuttings can be buried.
5. "Prior to the issuance of the Land Use Change Permit, the Applicant shall provide an Updated lnspection
Plan to include daily odor monitoring during operation consistent with wildlife activity monitoring."
Please see attached an Updated lnspection plan, which addresses daily odor monitoring and
inspections during operations.
6. "Prior to the issuance of the Land Use Change Permit, the Applicant shall provide documentation from the
TEP Emergency Prcparedness Plan confirming that the plan includes proccdurcs for coordination with thc
a
a
a
a
a
a
2
Grand River Fire Protection District for Fire Protection, Emergency Response, wildfire response/mitigation, and
emergency shut down procedures including current contact inforrnation."
ln response to this request, the follow items are submitted (attached) as documentation of TEP's
existing plans and procedures for coordinating with local Emergency Response Providers:
a
a
a
a
TEP Emergency Response Program Plan. This document provides general procedures for
Emergency Response incidents, roles and responsibilities, and working with Mutual Aid partners
during undesired events.
TEP Fire Prevention Program. This document provides basic procedures that employees are
trained in for fire prevention and control.
TEP Spill Response Plan. This document provides basic procedures that employees are trained in
for implementing spill prevention and response actions.
TEP Spill Response Plan, Appendix G: This document summarizes local agency contact notificatlon
information to be used in the event of emergency spill and response actions. Local agencies
include the Grand Valley Fire Protection District, the Colorado River Fire and Rescue District, the
Debeque Fire Protection District, Meeker Volunteer Fire & Rescue, Town of Parachute, Battlement
Mesa, Town of Silt, City of Rifle, Garfield County, Rio Blanco County, and BLM Colorado River Valley
Field Office and the White River Field Office.
TEP Emergency Contacts List: This document provides an up-to-date list of key contacts at TEP.a
Further, as discussed in Section 2.5 Emergency Response of the Starkey Gulch Centralized Waste
Management Facility Operating Plan, the wastes to be stored and managed at the Starkey Gulch
CWMF will consist entirely of soils / solid E&P wastes. No E&P liquid wastes, pits, storage tank batteries,
oil storage, or otherflammable materials will be allowed at this location. ln addition, the Starkey Gulch
CWMF location is largely void and free of any other naturally combustible materials (e.g., trees, shrubs,
brush, and other vegetation). ln accordance with TEP's Weed Management and Control Program,
weeds will be controlled at the location which will further reduce the potential risk of any wildfire
originating from activities associated with this facility.
ln summary, the Starkey Gulch CWMF location and the operations planned for this facility present an
extremely low risk of causing any type of emergency response situation that would threaten human
health or the environment. ln the event of some catastrophic event originating at the facility, the
emergency response protocols and procedures as outlined in the current TEP Emergency Response
Plan and the TEP Spill Prevention and Response Plan would be followed. These plans are maintained
TEP's main field office in Parachute, CO.
7. "Prior to issuance of the Land Use Change Permit, the Applicant shall confirm that the site is currently in
compliance with all existing COGCC conditions of approval and reclamation requirements. The Applicant shall
provide confirmation/verification that the reclamation bond for the site is still current."
-)
The Starkey Gulch CWMF location is currently Òompliant with existing COGCC conditions of approval
and reclamations requirements. As stated in the applicatiorr, tlre site wäs originally construc[ed [or use
as a cutting disposal location and has since been in an interim reclamation status. COGCC recently
approved a Form 2A (see attached) to amend the location for the new constrr¡ction proposed as a part
of this application. The financial assurance for reclamation is covered under the Waste management
Surety lD 2OI9-0I22 in the amount of $350,000.
8. "Prior to the issuance of the Land Use Change Permit, the Applicant shall confirm that they will comply with
the CPW recommendations contained in their referralcomment letters daledt2/21,/20and1,/79/21,, including
limitations on construction to outside of the t2/1 - 4/3 winter time period, excavated wildlife ramps and
fencing."
TEP will comply with the recommendations from CPW consultation and contained in the referral
comment letters daled 12/2/20 and 1,h9/21,, including constructing the location outside the winter
timing limitations between Dec. l- through April 3, and comply with wildlife ramps and fencing
recommendations.
Please contact me directly if you have any questions or concerns. I can be reached al970-263-2736
Thank you
4
Item 3:
Site Plan
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Construction Plan Prepared for:
TEP Rocky Mountain LLCT
FacilitgCentralized Waste
Section 32
?. 6 5., R. 96 W:
t\
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Prdp.
-tI rap
40
GRAPHIC SCALE IN FEET
1 lNcH = 80 FEET
Sediment
Cor #18
I
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Land Farm - 200 cy
(102'x54'x 1'd)
Proposed
Diversion Ditch
Approx. Limit
of Disturbance
^oá\
\
\
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)Range Fence
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\..- -,/
i
Exist. Culvert
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DitchEx¡st.
Proposed
Diversion Ditch
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Exist. Limit
of Disturbance
ø/4n8)
)..,/Road
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Notes:
1) Approximate height of Temporary Cuttings Stockpile is 1 0'
2) Approximate height of Snow Storage Area is 5'
Surface Roughening =@*
6/ 21
1
tValleu
Item 5:
lnspection Plan
Inspection Plan for Starkey Gulch Centralized Waste Management Facility
1,0 lnspections
To ensure that the Starkey Gulch C\NMF is performing as designed and is operated in compliance with
COGCC rule 907.8(8)D, the facility will be inspected for the following items at the specified frequency:
INSPECTION ITEM FREQUENCY
Fencing/Gates/Locks
Housekeeping
Monthly
Monthly
Berm lntegrity Monthly
Wildlife Activity lnside Facility Daily during active drilling operations
Excessive / Nuisance Odors Daily during active drilling operations
Stormwater BMPs Bi-weekly during construction; Monthly after
construction: + after any significant storm event
Drainage Diversion Channels Monthly + after any significant storm event
Accumulation of Liquids Monthly + after any significant storm event
Noxious Weeds Spring and Summer
Groundwater Monitoring Wells Quarterly
All inspections, environmental sampling, and on-going monitoring associated with the Starkey Gulch
CWMF will be performed by TEP's Environmental Compliance staff. Completed inspection forms will
be maintained in TEP's Parachute office. Any issues (i.e., Corrective Actions) observed during
inspections will be brought to the attention of TEP's Construction Superintendent and will be addressed
in a timely manner.
2.0 Maintenance
Maintenance and day-to-day operations of the Starkey Gulch CWMF will be the responsibility of the
TEP Construction Superintendent. Primary maintenance activities willconsist of:
¡ Receiving and managing waste materials within the facility. Routine treatment, mixing, and
placement of waste materials into the appropriate disposal area / cell within the facility.
. Maintaining integrity of site perimeter berms, working area berms, and storm water BMPs.
Ensuring there is no encroachment of storm water run-off / snowmelt coming into or leaving the
facility.
o Fence maintenance. A portion of the facility (i.e., along the south-eastern border and including
the entrance to the facility) will be fenced as needed to ensure site security. A metal panel gate
will be installed to control access at the site entrance and will be locked whenever there are no
a
active operations occurring on-site. Any fencing and gates installed will be maintained in good
working condition at all times, and repairs will be made as needed.
Weed control. The area will be kept free of noxious weeds (as listed by Garfield County) at all
times. Noxious weed control will be accomplished by using a contractor to inspect the site for
noxious weeds during the active growing seasons (i.e., spring and summer) and spray any noxious
weeds with an appropriate herbicide as needed'
Dust control. Typical dust-suppression methods such as applying fresh water or magnesium
chloride will be employed on disturbed areas / high traffic areas as needed.
Odor control. Odors are not expected to be an issue at this facility; however, if needed, any
nuisance odors will be controlled using an appropriate biocide product, or biologicaltreatment as
appropriate to mitigate nuisance odors.
Accumulation of liquids. Since only dry materials will be accepted and managed at this facility,
the only liquids that could accumulate inside the facility would be from occasional heavy rain
events or snow melt occurring within the boundaries of the facility. lf significant volumes of
rainwater and/or snow melt accumulate within the facility, a vac-truck will be used to remove the
water to prevent contact with waste materials being managed within the facility and reduce the
potential for leaching of contaminants into the sub-soils. Any accumulation of fluid in the treatment
area shall be removed upon detection. The treatment area will be monitored after any significant
precipitation event.
3.0 Environmental Monitorinq
. Groundwater: To comply with COGCC Rule 907.b.(9), TEP has completed installation 1 up-
gradient, 1 cross-gradient, and 2 down-gradient monitoring wells that will be used to monitor for
any subsurface contamination potentially migrating from the facility. These monitoring wells will
be sampled quarterly. The sampling results will be maintained at TEP's Parachute Field Office
and will be provided to COGCC upon request.
Item 6:
TEP Emergency Response Plan
TEP Fire Prevention Program
TEP Spill Response Plan
TEP Sill Response Plan, Appendix G
TEP Emergency Contacts List
TER-*-R Program
Emergency Response Program
Emergency Response Program
1.0 Purpose/Scope
Terra Energy Partners stríves to take preventative actions so that we have safe working
conditions for everyone while proteding the environment, public safety and company
assets. History has shown that companies, whích anticipate hazards and events, and
regularly exercise a plan for dealing with them, perform at a higher level during such an
event and are more successful in handling an emergency.
2.0 Definitions
No definitions specified.
3.0 General Requirements
¡ Terra recommends that the Emergency Response One Plan program and associated
templates be used by all company locations.
o Each location will develop a site-specific Emergency Response Plan and obtain the
appropriate level of approval upon completion.
r Each location will review its Emergency Response Plan on an annual basis.
r Terra personnel will be trained on the Emergency Response Plan lnitially and
periodícally as needed.
4.0 Key Responsibilities
o The operating supervisor, safety representative, and environmental coordinator shall
coordinate the preparation and implementation of Emergency Response Plans where
needed for each facility.
o The operating supervisor (lncident Commander) and safety representative wíll
determine if a situation is to be defined as a crisis (emergency) calling for activation
of the Houston Business Crisis Team (BCT) and implementation of the Houston
Business Crisis Plan.
o The operating supervisor at each location is responsible for initiating periodic drills to
assure understanding and provide evaluation of the plan's effectiveness.
5.0 Procedural Requirements
5.1 General
5.1.1 The ERP shall be prepared with the thought that the "First Aware" at
the location/incident may have to handle the emergency alone.
Created: 07-01-2016
Updated: 07-01-2016
Property of Terra Enerty Partners, LLC
May Not Be Reproduced without Permission
Paper copies are uncontrolled. This copy ¡s valid only at the t¡me of printing
Page 1 of4
Version:1
TER Program
Emergency Response Program
ENËRGY PARINFRg
Created: O7-0!-2OL6
Updated: 07-01-2016
Mutual aid is of great benefit, but it may not be available when
needed.
5.L.2 The framework of the emergency organízation shall be based on the
lncident Command Structure utilizing available personnel from existing
operations (departments and functions).
5.1.3 Each basin/location/operat¡ons center should have a trained individual
or individuals responsible for making statements to the public, These
individuals will follow the guidelines as established in the Terra Media
Relations Guide as published by the (Government and Public Affairs
group), and the Houston Headquarters Business Crisis Plan.
5.L.4 Each basin/location/operations center must maintain an ERP for use
and implementation in case of an emergency. All Terra and contractor
personnel must be trained as applicable in the facility's ERP.
5.1.5 lt is recommended that the basin/location/operations center conduct
a minimum of one full scale drill every three years and a functiqnal or
table top drill every year. Responses to actual incidents do satisfy
these requirements. Please see Emergency Response Drill Procedure
for more information about drilltypes. (lt is recommended that drills
contain an environmental component when possible.)
5.1.6 Facilities covered under OSHA CFR 29 1910.119(n) must include
procedures in their plan for handling small releases.
5.L.7 Each basin/location/operations center having an ERP must ensure that
the ERP links into or takes into consideration other applicable plans
affecting the facility, (i.e. Risk Management Plan, H25 Contingency
Plans, other applicable regulatory plans).
5.2 Guidelines and Strategies
5.2.L ERP must be clear, concise, well organized, and maintained in a
current state of readiness to maximize potential benefits. lMPs should
be reviewed and updated annually.
5.2.2 One key to effective and efficient emergency/contingency planning is
to conduct appropriate risk assessments to identify those "critical few"
or "worst case" scenarios which could have the greatest potential for
loss. This will ensure that the plans themselves, along with the
preparations enable responders to meet the challenge.
Property ofTerra Energy Partners, LLC
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TER Program
Emergency Response Progra m
5.2.3 Each basin/location/operations center shall coordinate the
preparatíon and implementation of the ERP to meet the requirements
orthe "rÏ,l,.jJ;.ii:ilffi::,':i: actions or key personner
o Emergency response and evaluation (Critique)
: :äi.îä;äiï*
: ::ï:::ïl'.îlil"å'u,,","n*
¡ Public and media relations
5.2.4 The following generic analysis checklist will help locations strengthen
or develop their own preparedness/planning for emergency situations.
'"ï'
iii{äh+;Íffitil ..,,, n ca, .n sys,e ms
¡ Emergency equipment and facilities
¡ Assessment of capabilities
: :,ï:i::,'"i:'i:i,ixï"
preparedness
5.3 MutualAid
5.3.1 lt is advantageous for each location/basin/operations center to define
and implement their own mutual aid agreements and plans, if the
''.,:''î;ïili::'JïïÏ:l;ïi:,iï,i:::"",î;Ji,:,i;,,"
mutual aid partners of the undesired event.
To identify the responsibilities and capabilities of each mutual
aid partner,
To review the plan with mutual aid agencies to ensure
compliance through understanding.
o To conduct simulations of potential emergency scenarios to
strengths and weaknesses of the plan and associated activities.
Simulations also serve to familiarize participants with pertinent
procedures and activities.
ÉNERGY PAATNERS
07-01-2016
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Updated
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TE Program
Emergency Response Program
Page 4 o1 4
ENËT<GY PAR I NER5
5.3.2 The followíng lmplementation Steps can lead to a useful, effective and
integrated mutual aid plan. Some potential mutual aid partners will
have emergency plans in place and it will require little effort to
complete some of these steps. ln those cases, a review of their plan
associated with each step is necessary to assure that it is complete and
usable. For example, a well-written plan may exist, but training may
be weak or there may be no provision for testing the plan. ln other
cases, significant effort will be required to complete each step.
Mutual Aid lmplementation steps are:
o ldentify mutual aid partners and establish their roles,
resources, concerns, and relationships,
¡ Establish a coordinating group.
r Evaluate risks and hazards that may result in the need for a
coordinated response.
o Have participants review their own emergency/contingency
plan for adequacy relative to a coordinated response.
¡ ldentify the required response tasks, which are currently not
covered by existing plans.
o Match the tasks with the resources available from identified
mutual aid partners.
o Make changes necessary to improve existing plans, integrated
them into overall mutual aid plan, and gain agreement and
necessary approvals.
¡ Educate participating individuals and groups about the
integrated plan and assure that all mutual aid responders are
qualified.
o Establish procedures for annual testing, review and updating of
the plan.
r Educate the general community about the integrated mutual
aid plan and the local emergency planning committee (LEPC).
5.4 Terra corporate shall be contacted for assistance when developing ERP.
6.0 key DocumentsÆools/References
6.1 Occupational Safety and Health Administration, Department of Labor; 29 CFR
1910.38, 1910.119, L9LO.LZO, and 1910.165.
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May Not Be Reproduced Without Perm¡ssion
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Created: 07-01-2016
updated: 07-oL-2o76 Version: 1
Program
Fire Prevention Program
FIRE PREVENTION & SAFEW PROGRAM
Purpose This program is designed to keep employees safe by educating and training
them about fire prevention and control. The program applies to all Terra
personnel working at Terra locations and sites.
Related Documents 29 CFR 1910.1-57 Portable Fire Extinguisher
Equipment & Materials ABC and/or BC - typefireextinguisher. A properlyworking and calibrated
(Multi-Gas) monitor where applicable.
PPE Sta ndard Personal Protective Eq uipment (PPE).
Effective Date 07-01-2016 Revised
TERMS AND DEFINITIONS
ABC-type Fire
Extinguisher
a A multipurpose dry chemical fire extinguisher
ROLES AN D RESPONSIBITITI ES
Employee
Supervisor and HSE
Manager or Designee
Follow all the procedures and appropriate actions listed in this program.
Conduct periodic inspections of fire extinguishers.
Provide training and proper equipment to employees for fire prevention
and control.
srEPs /AciloNsTASKS
A. Key Po¡nts
B. Fire Hazard
Awareness
Created:
Updated:
07-01-2016
07-ot-2016
L. lf a fire is beyond the incipient stage, evacuate the area and call 911 or
the emergency assistance number in yourarea.
2. Fire extinguishers must be regularly checked, tested, and serviced.
3. No smoking or open flame is permitted within 100 feet of the well.
1. Sources of fire at typical oil and gas well servicing operations include:
a. Smoking or open flames on location.
b. Weeds, trash, and debris located near ignition sources.
c. Flow back from wells.
d. Crude oil and natural gas produced and stored at wells and tank
batteries.
e. Hot work.
f. Electrical ignition sources (e.g., static, lighting, arcing, lightning, etc.)
g. Flammable treatment chemicals.
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Page 1 of 4
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TER".R Program
Fire Prevention Program
C, Perform
Housekeeping and
Safe Work Practices
D. Perform Fire
Prevention in Drilling,
Production, and
Servicing
E, Report Fireand
Response
Created:
1. Company facilities and worksites shall be maintained in such a manner to
prevent the likelihood of fires. Examples of good housekeeping are:
a. Clear tall grass and weeds around buildings, compressors, dehys, or
other compa ny facilities.
b. Do not let cardboard, paper, or other combustible materials
accumulate on site.
c. Do not accumulate oily or solvent-soaked rags; these should be
stored in a metal safety can that is properly disposed of in
compliance with regulatory requirements.
d. All flammable chemicals must be stored in approved containers
or in flammable-safety cabinets.
e. Follow the procedures in the Electrical Safety Program.
f. Always use a Hot Work Permit in hazardous locations.
g. Smoking is not permitted at company facilities, except in designated
areas.
1. .Company employees and contractors shall observe the following fire
prevention rules:
a. Company field personnel will visit facilities regularly. Unsafe or
potentially unsafe conditions will be corrected and reported
immediately to the area foreman or Health and Safety Department.
The Workplace Hazard Assessment Form (Appendix A) can be used
to document these issues.
b. lf the location has a lot of tallgrass, weeds, and otherflammable
material, clear the site before starting work.
c. No smoking is allowed within the rig guy lines, or within 100 feetof
the well.
d. Keep vehicles not involved in drilling production, or well servicing at
least 100 feet away, or the height of the derrick - whichever is greater
- from the well bore.
e. Be sure grounding straps are installed where necessary to prevent
static electricity build u p.
f. Before starting operations, the operator shall check the well's
pressure and take appropríate steps to remove pressure oroperate
safely under pressure before beginning work.
1. lf a fire is beyond the ¡ncipient stag, evacuate the area and call 911- or the
emergency assistance number in your area.
2. ln case of large fire, callemergency numbers (911) ímmediately and
notify Terra Energy Partners management. Remember:
a. See Table 1 for reminders when calling 911.
07-01-2016
07-01-2016
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Page 2 of 4
Updated:Verslon: 1
Program
Fire Prevention Program
Table 7: Reminders Cølls
Stcp Actlon
1 Speak clearly and slowly
2 Give the location and directions from the nearest
county roads. lf possible, provide GPS.
3 Describe the extent of the fire.
4 Wait forquestions.
5 Evacuate the immediate area, if necessary.
3. lf safe to do, use a portable fire extinguisher and shovel to extinguish the
fire, using the guidelines shown in Table 2:
Tøble 2: Extinguishing FÍres
1. Vehicles must be equipped with a portable ABC-type fire extinguisherfor
use in fighting smallfires. Fire extinguishers shall:
a. Meet the requirements of OSHA 29 CFR L9LO.757 '
b. Be checked at least monthly and documented on the vehicle
inspection form and/or have the tag updated.
F. UseFireExtinguishers
Created:07-oL-2016
07-0r-2016
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Do Don't
Stand 6 to 10 feet from theflame Turn your back on or move intothe
burned area even though theflames
appear to be extinguished as the flames
can easilyre-ignite
Wear flame-resistantclothing Be a hero - equipment andmachines
can be replaced; peoplecannot
Hold the ext¡ngu¡sherupright Use water on electricalfires
Stay low to avoid the smoke Use the fire extinguisher at distances
less than 6 feet or more than 10 feet
from the flames
P - Pull the Pin
A - Aim at the base of thefire
S - Squeeze the handle
S - Sweep from side toside
Use more than one extinguisher
Move forward as theflames
diminish to reach the far edge
of the flames
Continue to fight the fire even if you
experience symptoms of exposure
Shovel dirt or sand on
the extinguished area
Put a used fire extinguisherback
without recharging and inspection
Report allfíres to your supervisor
Updated:
TEß_---ml Program
Fire Prevention Program
c. Be hydrostatically tested and certified at the appropriate interval
shown in OSHA 29 CFR 1910.157(fX3)Table L-1, depending onthe
type and construction,
d. Be hydrostatically tested and certified whenever they show new
evidence of corrosion or mechanical injury.
e. Extinguisher shells, cylinders, or cartridges that fail a hydrostatic
pressure test, or that are not fit for testing, shall be removed from
service and from the workplace.
f. Be promptly serviced if used, even if for just a short time.
g. Be promptly serviced if the pressure is outside the acceptable range.
TRAINING
Terra Energy provides annual fire prevention and awareness trainingto
prevent fires and reduce fire-related injuries and losses. Training
includes:
o How to recognize fire hazards
o How to reduce potential fire hazards
o Types of fires
o Reporting fires and explosions
o Fire extinguisher use
o Knowledge of when a fire extinguisher must be checked and/or
serviced
o When not to fight a fire
RECORDS RETENTION
Appropriate records will be maintained by the Health and Safety
Department.
ADMINISTRATIVE IN FORMATION
The Company has the right to interpret, modify, terminøte or revise this informøtion in whole or inpart
without notice.
Cha
Created:
Updäted
07-01-2016
07-ot-20L6
Property ofTerra Energy partners LLC,,.
May Not Be Reproduced Without Permission
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TER
Piceance Basin
SPILL PREVENTION
ANI)
RESPONSE PLAI{
ENERGY PARTNERS
October 2019
TEP Rocky Mountain, LLC
PO Box 370
Parachute, CO 81635
Table of Contents
I.
II.
m.
IV.
A.
V.
Spill Prevention and Response Polioy ,)
Purpose and Scope
Plan Applicability .........
Spill/Release Prevention ........................
Standard Prevention and Training..........
Spill Management
A. Discovery
B. Containment.................
C. Notifìcation (TEP/Contractors)...............
D. Response
E. VerbalNotification........
F. WrittenReporting..........
VL
vu.
Training....
Spill /Release Costs and Invoicing
I
a
4
4
5
5
5
6
7
9
9
.10
.11
.l I
TEffi
Spill Response Plan
October 2019
Appendices
Appendix A
Emergency Response Control Valve Operation and Notification Procedures
Appendix B-L
Spill Notification Flowchart for E&P Waste
Appendix B-2
Spill Notification Flowchart for Non-E&P Waste
Appendix C
TEP Emergency Contact Card
Appendix D-l
Containment
Appendix D-2
Spill Response Station Locations
Appendix D-3
Spill Response Station Inventory
Appendix E
Environmental Incident Investigation Form
Appendix F-l
Federal, State, and County Verbal Notification Requirements
Appendix F-2
Federal and State Written Reporting Requirements
Appendix G
Agencies Contact Information
Appendix H-l
COGCC Spill Reporting Requirements
Appendix H-2
Garfield County Spill Reporting Requirements
Appendix H-3
CDPFIE Spill Reporting Requirements
I
TEffi
Spill Response Plan
October 2019
I. Spill Prevention and Response Policy
It is the policy of TEP Rocky Mountain, LLC (TEP) that its employees and contractors
implement spill prevention and response plans in order to avoid and minimize the
potential for spills and releases in the exploration and development of natural gas leases,
in accordance with federal and state regulations. This includes, but is not limited to the
development and implementation of Best Management Practices (BMPs), training, and
other actions that prevent and take action to manage spills and releases on federal, state
or private properties that are leased, managed, owned, or otherwise used by TEP.
IL Purpose and Scope
The purpose of this plan is to provide clear, comprehensive guidance and expectations
for TEP employees and its contractors to prevent, mitigate, and manage spills and
releases. This includes spill/release prevention, discovery, notifications, response
actions, reporting, and subsequent remediation actions (as applicable).
TEP management and employees supervising natural gas exploration and development
field activities, including contractor activities, are expected to have a working
knowledge of this plan, particularly the chain of command for notifrcation and reporting
of spills and releases.
Contractors are required to develop and implement their own spill prevention and response
plans tailored to the scope of activities as described in their Master Service Agreeurent
(MSA) and Request for Services (RFS), and assure their plan complies with the guidance
and expectations set forth in the TEP Spill Prevention and Response plan.
TEP contractors are fully rcsponsiblc for thcir spills and rclcascs, and those of their
subcontractors, in accordance with their (MSA). In the event of a contractor spill, TEP
rrsponsibilities are limited to ensuling that contractors cornply with applicable federal ancl
statc rcgulations and guidance (including safety). Corrective actions will be implemented
to avoid the potential for future spills.
2
TEffi
Spill Response Plan
October 2019
III. Plan Applicability
This plan is applicable to all aspects of TEP exploration and development operations
including, but not limited to, drilling, completion, production, and pipeline operations. It
is specifically applicable to any vehicles, facilities, and equipment that useo store,
transport, dispose, or otherwise handle or manage chemicals (MSDS-regulated
chemicals), hazardous materials, E&P wastes (drilling muds, produced water,
condensate), domestic wastes (septic holding tanks), hazardous wastes, extremely
hazardous substances, or any other Federal or state regulated substance or waste.
Federal and State Spill Prevention ønd Manøgement Regulations
Despite implementation of pollution prevention practices and BMPs, spills may still
occur. In the event of a spill, regulations for spill management can be found in several
Federal and state regulations, including but not limited to the following:
40 CFR ll2 part 112 SPCC
(CERCLA);40 CFR part 305 andpart3}T
C.
Colorado state requirements for spills and releases are contained in the following
regulations:
Garfreld County requirements for spills and releases are contained in the Source Water
Protection Plan, Garfield County, CO January 2013.
a
-)
TER
FNFRGY PAR'TNERS Spill Response Plan
October 2019
IV. SpitURelease Prevention
TEP's first and foremost priority is that it's employees and contractors take all
reasonable measures and implement BMPs to prevent both stationary and transportation-
related spills and releases from occurring. Measures and BMPs include, but are not
limited to the following:
A. Standard Prevention and Training
required to avoid potential spill situations such as:
. Checking for open or secured valves prior to, during and after
loading/unloading operations
. Monitoring tank levels (don't rely on alarms)
. Building berms around loading/unloading areas
. Providing portable spill basins during fluid transfers
' Checking equipment (tanks, hoses, valves) for deterioration and leaks
. Servicing vehicles/equipment (oil changes, lubrication) responsibly
¡ Maintaining vehicles to avoid accidents resulting in spills
. Being aware of surroundings when backing or moving vehicles
¡ Ensuring stable ground when placing equipment, tanks and pipelines
potential spill situations.
equipment (i.e., emergency response control valves / gates) that have been
strategically installed at critical drainage collection and control points in
Wheeler Gulch, Cottonwood Gulch, and the Beaver Creek area. Personnel
required to be trained in the operation of this equipment will include TEP
operations / fìeld personnel and certain contractor personnel. Procedures for
operating the Wheeler Gulch, Cottonwood Gulch, and Beaver Creek emergency
response control valves are located in Appendix A.
4
TEffi
Spill Response PIan
October 2019
V. Spill Management
For purposes of this plan, spill response and management addresses the major steps
listed below. A flowchart illustrating an overall view of how the TEP spill response and
notification process operates is included in Appendix B.
A. Discovery
Discovery includes either actual or potential spills/releases, and in some cases
situations that are not a spill or release, but someone has reported it as such. In any
event, it is important to confirm that an actual or potential spill situation has occurred
before implementing spill response. If in doubt, contact the appropriate spill response
personnel as listed in Appendix C for assistance prior to implementing this plan.
B. Containment
Containment, for purposes of this plan, means stopping the source of the spill and
preventing the spill or release from increasing in volume, size or duration. The
person/persons who discover the spill should attempt to contain the spill only if safe to
do so.
Under no circumstances should field personnel attempt to manage an unknown spill or
situation without adequate training, personal protective equipment (PPE) or without
exercising extreme caution.
If there is no immediate threat to human healtho safety or the environment, and
you are convinced that the spill can be safely contained then personnel can:
5
IF A SPILL OR RELEASE PRT,SENTS AN IMMEDIATE THRT,AT TO HUMAN
HEALTH, SAFETY, OR ENVIRONMENT, AND EVOLVES INTO, OR IS
ALR.EADY AN EMERGENCY SITUATION, CALL THE TEP SPILL
REPORTTNG HOTLINE (970-683-229s) OR SPrLL RESPONSB
COORDTNATOR (MIKE GARDNER AT 970-623-487s) TMMEDTATELY AND
MOVE A\ilAY FROM THE RELEASE.
DO NOT ATTEMPT TO CONTAIN THE SPILL IF UNSAFE TO DO SO
TEffi
Spill Response Plan
October 2019
ditches, making berms, etc.) as appropriate to minimize spilled materials from
sprcading, and reaching water ways or other water resourccs
Spill containment options and materials used may vary depending upon the media
affected. See Appendix D for spill response station locations, containment options, and
materials that can be utilized.
C. Notification (TEP/Contractors)
The person discovering the spill must make initial notifications in accordance with
Appendix C. When making the initial notifications, the information outlined in
Appendix C must be provided.
l. Anv snill of E&P waste (produced water, condensate, drilling mud) equal or greater
than I barrel and {ny Jplllof non-E&P waste (Diesel fuel, motor oil) equal or greater
than 5 gallons needs to be reported to the TEP Spill Response Hotline (970-683-2295) or
to the TEP Spill Response Coordinator (Mike Gardner at 970-623-4875) in order to
provide the due diligence requirements set forth in Section 3162.5-l of the Code of
Federal Regulations.
2. Anv spill of E&P or non-E&P waste that has migrated off-site needs to be reported to
your immediate Supervisor and the TEP Spill Response Coordinator Immediately.
URGENT NOTIFICATION REQUIRT,MENT*
l'or any spill/release that migrates ofT the pad and reaches live water, has the
potential to reach live water, or reaches a drainage that directly flows to live water,
immediately notify the TEP Field Lead / Operational Supervisor and the'l'EP Spill
Response Coordinator Immediately. (See Appendix C)
6
TEffi
Spill Response Plan
October 2019
D. Response
TEP Spills (i.e., "Company Spills")
A "company spill" is any spill / release for which TEP personnel or equipment were
directly responsible for causing the spill or release. Examples include: Production
equipment / pipeline failures, leaking pits, inadequate secondary containment, TEP
personnel error, etc. For spills in which TEP is the responsible party, the appropriate
response actions will be determined by one (or a combination) of the following TEP
designated personnel as outlined in Appendix C:
TEP will perform the following response actions:
l) Receive confirmation of containment actions
2) Direct further response actions as needed using approved spill response
contractors
3) Investigate and document the incident as appropriate (e.g., Environmental
Incident Investigation Form - Appendix E)
4) Perform required Federal, state, and local agency notifications if required
(Appendix F)
5) Coordinate with the TEP Land Department to ensure that the property/surface
owner is also notified in a timely manner
6) Report the status of individual spills on the weekly Spill Tracking Report which
will be placed on a share drive and available to interested parties
Contractor Spills
A "contractor spill" is any spill / release that was directly caused by actions of the
Contractor, or equipment belonging to the Contractor. Examples include: Failure to
close valves, overfilling a truck, using faulty / defective equipment, frac or drilling
fluid spills, etc.
With respect to notification and reporting responsibilities, if a oocontractor spill" occurs
on a TEP location / property, or involves an off-site spill of product/waste that legally
belongs to TEP at the time of the spill (e.g., produced water), the Contractor will
immediately notifu the TEP Spill Response Coordinator and the TEP Operations
Manager (or designee), and TEP will be responsible for reporting / notifying the
7
TEffi
Spill Response Plan
October 2019
appropriate regulatory agencics as outlincd in Appendix F. All othcr contractor spills
are to be reported, remediated, and managed by the Controctor.
Contractors with a valid MSA are [!!y responsible for their spills. This includes all
costs associated with rcsponding to, containmcnt, rcmcdiation, wastc management and
disposal, and implementation of corrective actions necessary to minimize the potential
for future spills.
Contractors will be responsible for the following items if it is determined that they are
the responsible party in the event of a spill or release:
the spill. The contractor's representative will be in a supervisory role and will
contact the TEP Spill Response Coordinator:
l. The contractor responsible will schedule a meeting with the TEP Spill' Response Coordinator within 24 hours of the spill.
2. The contractor will provide a spill investigation report which contains a
summary, root cause(s), and timeline of the incident, employees
involved, response actions taken, regulatory notifications made, impacts
(i.e., soil, surface water, ground water, etc.) resulting from the incident,
and conective measures to be implemented.
3. The contractor will be informed that the person or persons responsible
for the release will attend the next available spill prevention training.
In the event the spill occurs on a TEP lease or property, TEP's Spill Response
Coordinator will still provide oversight on TEP's behalf to assure the spill has been
managed correctly and there are no repercussions to TEP as a result of the spill or
release, if.
Contractor spill, response actions will be conducted in accordance with the
Contractor's Spill Prevention and Response Plan.
Contractors are required to include and maintain a current listing of all chemicals,
substances and wastes used in their operations (as well as the applicabte MSDS
sheets) in their Spill Prevention and Response Plan.
8
TEffi
Spill Response Plan
October 2019
E. Verbal Notification
Verbal reporting requirements to Federal, state, and local agencies for spill notification
purposes,are based on two criteria:
1. The type and volume of material spilled; and
2. Affected environmental media (i.e. soil, water)
These materials are further sub-divided into two categories:
1. Exploration and Production Waste (E&P Waste) such as produced water,
condensate, or any other material that has been down hole; and
2. Non-E&P Waste such as fuels and oils. This would include materials such
as diesel fuel, hydraulic oil, motor oil, glycol, corrosion inhibitor, etc.
The most common materials encountered when responding to spills and the associated
notification volumes are outlined in Appendix F-l. For materials that are not listed in
Appendix F-1, the TEP Spill Response Coordinator must be consulted to determine if
it is an E&P or Non-E&P waste, and to make the appropriate notification if the
reportable quantity is exceeded. Contact information for federal, state, and local
agencies is outlined in Appendix G.
In order to provide further due diligence, TEP has notification requirements for spills,
both company and contractor, with volumes that are less than the federal and state
requirements. These notification requirements are in place to satis$ environmental
obligations that the operator must comply with. These are set forth in Title 43 of the
Code of Federal Regulations. Specifrcally, they are found in Chapter II, Part 3160,
subpart 3162, Section 3162.5-l Environmental Obligations. These are outlined in
Appendix F-l.
F. Written Reporting
Federal and State wriffen reporting requirements for spills are based on:
l. The type and volume of material spilled; and
2. Affected environmental media (i.e. soil, water)
9
*URGENT NOTIFICATION REQUIREMENT*
For any spill/release that migrates off the pad and has the potential to reach surface
water or groundwater, or affects a drainage that flows to surface water; notify the
appropriate TEP Environmental Team Lead Immediatelv.
(See Appendix C)
TEffi
Spill Response Plan
October 2019
These materials are further sub-divided into two categories:
1. Exploration and Production Waste (E&P Waste) such as produced water,
condensate, or any other material that has been down hole and;
2. Non-E&P Waste such as fuels and oils. This would include materials such
as diesel fuel, hydraulic oil, motor oil, and glycol.
Snills or releases E&P wasfesl within secondarv containment
structures: steel or earthen. lined or unlined are reportable if thev exceed 5
barrels. The most common materials encountered when responding to spills and the
associated written reporting volumes are outlined in Appendix F-2.
For Non E&P wastes and other hazardous substances that are not listed in Appendix
F-2, the MSDS sheet for the material spilled must be consulted, and the quantity of the
hazardous / regulated substances calculated based upon the total spill amount and the
composition of material spilled. Once a quantity for the hazardous/regulated substance
has been calculated, it is compared to the list of Reportable Quantities (RQ) for
Hazardous substance as required by CDPHE, and as found at 40 CFR 302. Any release
of a hazardous substance in excess of its respective RQ is reportable to various State
and Federal agencies; contact information for these agencies is provided in Appendix
G.
In the event that a spill or release results in signifrcant damage to equipment, a
COGCC Accident Report (Form 22)will be submitted to the COGCC by TEP's safety
department within 10 days of the incident.
G. Remediation
In some instances, remediation may be required when a spill occurs. Whether or not a
spill requires remediation is dependent on the contaminant concentrations and
applicable Federal and/or state cleanup requirements.
Any wastes (both E&P and Non E&P) generated as a result of remedial actions
conducted pursuant to a spill / release event, will be managed and disposed of in
accordance with the TEP Waste Management Plan
URG ENT NOTIF"ICATION REQUIREMENT*
For any spill/release that rnigrates off the pad and has the potential to reach surf¿ce
water or groundwatero or affects a drainage that flows to surf¿ce water; notify the
appropriate TEP Spill Response Coordinator Immediately.
(See Appendix C)
10
TER
ENERGY PARTNERS Spill Response Plan
October 2019
VI. Training
It is strongly recommended that all TEP operations and field staff, and contractor
personnel complete the TEP Spill Prevention, Response, and Awareness Training on an
annual basis.
It is recommended that TEP and contractor personnel performing field response and
remediation activities complete the 24-Hour HAZWOPER course and annual refresher
courses.
As stated in Section IV, training for new TEP personnel and contractors will be offered
on at least a quarterly basis or more frequently as needed. This can be arranged through
the TEP Spill Response Coordinator. Documentation that your employees have
completed the necessary training will be provided.
VII. Spill /Release Costs and Invoicing
All company spills must be billed to the appropriate project charge code regardless of
where the spill actually occurred.
For contractor spills, all costs are the responsibility of the contractor causing the spill.
This includes all spill response, cleanupo and waste disposal costs that may be associated
with that spill/ release.
TEP will not accept invoices from third parties for contractor spills.
n
Appendix G
Agencies Contact Information
Reportable Quantities for E&P waste
. 1 bbl outside containment. 5 bbls inside or outside containment
o Any amount that impacts or threatens to impact any surface water supply area
Spill Notifications
. COGCC-all reportablespills-verballywithin 24hrs orinitial Form l9within the24 hrs. if the
initial notification was done verbally then initial form 19 needs to be submitted within 72hrs.
the final form 19 is due 10 days after discovery
. Appropriate fire district - all reportable spills. Email notification, unless an emergency, then
call 911. CDPHE - all spills that impact or threaten to impact any surface water supply areas
. Water intakes & town/city officials - all reportable spills inside the 317b areas and drinking
water supply areas (email)
. County - email notification to Kirby on all reportable spills
. Landowner notification - all reportable spills
r NRC - only spills that got into life water (after legal consultation ONLY)
. 911 - life threatening situations and real emergencies ONLY
Federal Contact Information
National Response Center
r-800-424-8802
BLM Colorado River Valley Field Office
Jim Byers
Natural Resource Specialist
o (970) 876 90s6
c (970) 319 2532
email: ibyers@blm.eov
BLM White River Field Office
Justin Wilson
Petroleum Engineer Technician
o (970) 878 382s
c (970) 942 704r
email: irwilson@blm. gov
State Contact Information
COGCC
Alex Fischer
Environmental Supervisor
o (303) 8942100 x5138
c (303) 9t2 6006
email : alex.fi scherØstate.co.us
CDPHE
Spill Report Hot Line
l 877 518 s608
Water Quality Control Division
(303) 692 3s00
County Contact Information
Garfield County:
Kirby Wynn
Oil and Gas Liaison
o (970) 625 s90s
c (970) 987 2ss7
email : kwynn@ garfi eld-county.com
Morgan Hill
Environmental Health Specialist
o (970) 625 5200, ext. 8106
c (970) 379 3826
email: mhill@earfield-county.com
Rio Blanco County:
Lannie Massey
Natural Resource Specialist
o:970 878 9586
c:
email : Lannie.Massey@co.rio-blanco.co.us
S h eri ff Anthony Mazzola
o: 970-878-9600
email: so@,rbc.us
Local Contact Information
Grand Valley Fire Protection District
Shift Captain
(970) 98s 8e7s
David Blair
Fire Chief
o (970) 28s 9rt9
c (970) 250 9851
email : fi rechief@ svfpd.ors
Robert Ferguson
Deputy Fire Chief
o (970) 28s 9rr9
c (970) 210 3263
email: opschief@evfpd.ore
Anthony Rowe
Division ChieflTraining Officer
o (970) 28s 9tr9
c (970) 2t6 8335
email: training@gvfpd.org
Colorado River X'ire Rescue
Emergency Dispatch
(e70) 625 80e5
Chad Harris
Deputy Fire Chief
o (970) 625 1243 ext25
c (970) 379 968r
email : chad.harris@crfr.us
Orrin Moon
Fire Marshal
o (970) 62s t243
c (970) 379 2932
email: orrin.moon@crfr.us
DeBeque Fire Protection District (Trail Ridge)
Nick Marx
Fire Chief
o (970) 283 8632
c (970) 216 330s
email: nimrx@)rahoo.com
Meeker Volunteer Fire & Rescue (Ryan Gulch)
Steve Allen
Fire Chief
o (970) 824 1682
c (970) 7s6 0990
email : sallen@meekerrescue.com
Town of Parachute
Stuart McArthur
Town Administrator
o (970) 28s 7630
email : stuartmclÐparachutecolorado.com
Mark King
Public Works Director (Water Intake notifications)
o (970) 285 7630
a (970) 986 r82r
em a i I : qt kine@ffi"9b:il,e*dçr¡dqpam
Battlement Mesa
Steve Rippy
District Manager
o (970) 285 9050
c (970) 987 t333
email: srinnvØacsol.net
Roger Bulla
Superintendent
o (970) 28s 7000
c (970) 433 2862
email: rbulla@cdmsinc.net
silt
Jack Castle
Utilities Director
o (970) 876 0460
c (970) 989 0041
email: iackc@townofsilt.org
Jerry Pace
o (970) 87623s3
Pam Woods
Town Administrator
o (970) 87623s3
email : administrator@townofsilt.ore
Rifle
Rick Barth
Public Works
o (970) 66s-6ss9
email: rbarth@rifl eco.ors
Robert Burns
Water Treatment Plant Supervisor
(970) 66s-6s99
rburns@rifleco.org
TEP Emergency Contacts List (Updated: 03/15/21)
Name Title/Position Cell#
Operafions Management - Houston Gorporate
Office
BJ Reynolds Vice President of Operations (832) 589-904e
Mark Mewshaw Drilling and Completions Manager (304) 612-7844
Wes Hobbs Production Manager (832) 980-8680
Sixto Mendez Facilities Engineer (832).726-1148
Operation Management - Parachute Field Office
Brad Moss District Production Manager (970) 987-1737
Eric DeKam Production Superintendent and Construction (970) 948-4303
Brandon Baker Production Superintendent (970) 260-8361
Brad Kesler Production Supervisor - Water Management Facilities (970) 216-8703
Lynn Cass Drilling Superintendent (970) 755-0083
Kyle Kohl Completions Superintendent (970) 623-8907
Envlronmental, Health & safety - Parachute Fleld
Office
Shawn Brennan Environmental, Health and Safety Manager (e70) 948-3166
Kevin McDermott Safety Supervisor (970) 309-1195
Delbert Dowling Safety Specialist Sr (970) 589-5736
Mike Gardner Environmental - Spill Response Coordinator (970) 623-4875
TEP Spill Response Hotline Number (970) 623-4875, or
(970) 683-2295
Land
Bryan Hotard Land Team Lead (970) 361-2006
Name TEP Gontractors Cell#
Bryan Clark BC Excavation (970) 987-2220
Dispatch D and J Gardner Excavation (970) 250-9307
Joe Barton C&J Field Services (Ryan Gulch / Trail Ridge)(970) 683-1433
Dispatch Stateline Trucking (Fluid recovery - Valley)(970) 270-5388
(970) 314-3304
Hank Kracht H&K Trucking (Fluid recovery - Valley)(970) 309-9700
Dispatch Gonzo Trucking - (Fluid recovery - KP field)(970) 985-8694
(970\ 712-1633
Dispatch Stateline (Fluid recovery - AP, TR & AP fields)(e70) 270-5388
t970) 314-3304
Dispatch Marsh (Fluid recovery - RGU field)(970) 773-3674
Glenn Hartmann
From:
Sent:
To:
Subject:
Attachments:
Jeff Kirtland <J Kirtland@terraep.com >
Thursday, January 7,2021 1 1:49 AM
Glenn Hartmann
lExternall Additional information from TEP
DOC0 1 072 1 -01 07 2021 09221 S.pdf
Glenn,
These were the quest¡ons and answers I posed to our folks internally, as we discussed
t. Glenn is considering adding a COA to the County Permit that we will have to provide confirmation that a liner
will not be required by COGCC. I did tell him that we are not planning to use a liner and do not expect COGCC
will require one since the facility will only be processing cutt¡ngs. lf we are okay with that COA, then there is no
need to provide a case for no liner to the County. That is correct, we do not plan to use a svnthetic liner for the
following reasons: 1-) No free fluids will be ever be managed, treated, or stored at this location. Only dry, solid
E&P wastes that have been treated to comply with COGCC 910-L (91-5-1-) cleanup standards will be placed into
the individual cells for treatment / disposal. No materials exceeding these cleanup standards will be allowed for
direct burial / disposal. 2) As discussed with COGCC, a synthetic liner is not practical for use at this facility due
to types of heavy equipment (e.g., excavators, front-end loaders, dump trucks) that will be required to mix,
treat, and place the treated soils in the disposal cells. A synthetic liner would be quickly destroyed /
compromised due to the types of equipment being used and the amount of heavy equipment traffic that will be
concentrated in this area. Metal tracks on the excavators and metal teeth on excavator / loader buckets would
easily puncture and compromise a synthetic liner. 3) TEP has agreed to install 4 monitoring wells around the
perimeter of the CWMF for the purposes of monitoring any impacts to any shallow ground water that may be
present in the immediate area. The monitoring wells will be monitored quarterly and compared to baseline
water quality conditions to ensure there are no impacts to any localized ground water resources resulting from
the CWMF. 4) A 3-ft thick constructed soil / clay cap liner will be installed over the final reclaimed facility which
will effectively prevent infiltration of precipitation from coming into contact with underlying treated waste
materials
2. ln addition to the site plan, Glenn is looking for a description or visual of how the cuttings will be brought on to
the location and initially unloaded into the temporary staging area described in the operating plan. Do we have a
post-construction layout showing the temporary staging areas prior to transferring to the phased pits? I think
Glenn is trying to distinguish in his mind how the cuttings will be initially staged and then disposed of, as
described in the operating plan. The attached Plan of Development and Construction Layout plats show how
and where the various types of drill cuttings and oily waste materials will be managed, treated, and ultimately
disposed. For example, the Phase 1 pit area shows the working area where water-based, bentonitic drill cuttings
will be staged and treated on site. Water-based, bentonitic drill cuttings will be brought to this area directly
from the well pad, and staged in small "batches" (i.e., L000 cubic yards or less) to ensure accurate
characterization of the waste material, and allow accurate identification of the treatment method (if
needed). Each individual batch of cuttings will be sampled and analyzed for compliance with COGCC Table 910-1
prior to placement and disposal in the cuttings trench. lf a batch of drill cuttings / waste material does not
meet the COGCC Table 910-1 concentration levels, the wastes will continue to be treated (in small batch units)
until the allowable concentration levels are met (see Section 8.0 for cuttings treatment options). Once a batch
of cuttings meets the COGCC Table 910-1 concentration levels, an appropriately sized portion of the cuttings
trench will be excavated to dispose of the treated batch of cutt¡ngs within the trench boundary. The disposal
trench area will only be excavated as treated materials become available and are ready for burial. Not
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excavat¡ng the entire trench area at once will minimize the amount of storm water that may come into contact
with waste materials inside the trench, and it will also reduce the amount of storm water that would otherwise
collect inside a large excavation area requiring removal and/or further management.
Let me know
Jeff Kirtland
Regulatory Lead
TEP Rocky Mountain LLC
(Terra Energy Partners LLC)
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