|Material Handling and Spill Prevention||New Flowine Rule 1100 Series BMP:
1. Integrity testing of flowlines connecting wellheads to the separators:
CONSTRUCTION PHASE: The flowlines that Operator uses are designed/constructed/tested to ASME B31.3/4/8 and API 1104 standards. Only materials with Material Test Reports (MTRs) provided by the pipeline supplier are used in the construction of the flowlines. Construction is tested with 100% x-ray and goes through hydrotest per the applicable B31-code.
OPERATIONS PHASE: Pressure testing of the flowlines is conducted on an annual basis. Additionally, Operator is already in compliance with 1104.i. Continuous Pressure Monitoring Requirements of the 1100 Series Flowline Regulations. Operator utilizes a series of standard operating procedures to define our flowline integrity testing program.
2. Frequency on valve and fitting inspections: Operator’s Lease Operators inspect all equipment on their locations at a minimum of once every 48 hours, but most sites are inspected every 24 hours. Valves and fittings inspections are part of the daily job duties of the lease operators. Any valve or fitting that is found to be leaking is either repaired immediately by the lease operator or shut-in procedures are implemented as described below. Additionally, lease operators conduct a documented monthly inspection of the facility and this includes inspection of all valves and fittings.
3. Description of Lease Operator Inspections, Monthly Documented Inspections & Environmental Inspections: The Operator lease operator inspections are done as a routine part of the lease operators job. The lease operator would typically visit each of their assigned locations daily. They conduct a visual inspection of the facility which includes all valves, fittings, wellhead, tanks, vapor control systems and all connections. The lease operator also checks our Scada automation system for system pressures and flows. Pressure and flow sensors are placed on multiple points throughout the system and are specifically designed to measure the system for irregularities that would indicate a leak in the system or change in production of oil, water, or gas. The Scada system is also set-up with alarms that are triggered by anomalous pressure or flows. Low pressure warnings can activate automatic shut-in of the well and system. Lease operator inspections would note any leaks of either gas or fluids which triggers an immediate repair or shut-in. The Lease operators also conduct CDPHE Regulation 7– Audible, Visual, and Olfactory (AVO) inspections, which focus on the tanks and vapor control system. The Regulation 7 AVO is also a documented inspection. In addition, the sites are inspected with optical gas imaging cameras on a routine schedule, annually for compliance purposes with our Spill Prevention Containment and Countermeasures (SPCC) plan, depending on the status of reclamation the sites are also inspected on either a 14-day, 30-day, annual or rain triggered event in accordance with both the COGCC and the CDPHE Stormwater Management Plans (SWMP).
4. Measures for when leaks are discovered:
If we suspect a leak we shut in the well and hydrotest the line. If it passes, then the well is brought back into production.
If there is an actual leak, the well is kept shut in while the leak is found and fixed. Not until the line has passed hydrotesting, would the well be brought back online.
|Storm Water/Erosion Control||Implement and maintain BMPs to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, and site degradation. Co-locate gas and water gathering lines whenever feasible, and mitigate any erosion problems that arise due to the construction of any pipeline(s).