COGCC STANDARD OPERATING PRACTICES (SOP)
3.15 STORMWATER MANAGEMENT INSPECTION SOP
Document Control:
Created Date:
Last Updated Date:
Last Updated By:
Review Cycle:
Systems Used:
Document Owner:
December 7, 2015
December 7, 2015
Dave Kulmann
Yearly Review
Field Inspection Form
Margaret Ash
Background
Purpose of this Document:
The purpose of this standard operating practice (SOP) is to provide an internal tool
for COGCC field inspectors to use during stormwater inspections of oil and gas
locations with the goal of achieving greater inspection consistency. An ancillary
benefit is providing greater clarity to oil and gas operators regarding what COGCC
field inspectors will review related to stormwater so that operators can implement
required actions to achieve greater and quicker compliance.
Regulatory History:
COGCC Rule 1002.f became effective, in this current language, April 1, 2009 and
gives the COGCC authority over stormwater management on oil and gas locations
during all phases of operations. Below is a high level summary of Rule 1002.f:


Rule 1002.f.(1)
o Provides the general scope and intent of the rule.
Rule 1002.f.(2)
o Prior to the 2008 rulemaking, the requirements for these stormwater
best management practices (BMP) already existed in different sections
of Rule 1002. These BMP requirements were consolidated and moved
into this section.
o Applies to all phases of oil and gas operations from pad construction to
final reclamation.
Stormwater Management Inspection SOP
STORMWATER MANAGEMENT INSPECTION SOP

o Requires operators to implement BMPs to control stormwater and lists
six major categories of BMPs that operators should consider when
implementing BMPs.
o Tier 1 Oil and Gas Locations, as defined in the 100 series Rules, are not
exempt from this section.
Rule 1002.f.(3)
o This section was created in the 2008 rulemaking and applies only after
the CDPHE stormwater permit is terminated, which is typically after
interim reclamation is achieved.
o Does not apply to Tier 1 Oil and Gas Locations as defined in the 100
series Rules.
o Requires a post construction stormwater program.
COGCC Stormwater Management Program Objectives:
The COGCC’s stormwater program objectives are performance oriented whereas the
CDPHE’s program objectives have a strong preventative focus, including a
permitting process prior to site construction. While CDPHE focuses exclusively on
maintaining surface water quality, COGCC focuses on the following:
1.
2.
3.
4.
5.
Maintaining surface water quality (Rule 1002.f.(2)A).
Minimizing erosion and limiting site degradation (Rule 1002.f.(2)).
Ensuring proper surface reclamation (Rules 1002.e.(1), 1003 and 1004).
Minimizing alterations of natural features (Rule 1002.e.(1)).
Minimizing adverse impacts to wildlife habitat (Rule 1002.e.(3)).
Areas of Inspection:
Areas covered by Rule 1002.f. include the following:
1. Oil and Gas Locations as defined in the 100 series rules.
2. Centralized E&P Waste Management Facilities as defined in the 100 series
rules.
3. Oil and gas access roads.
4. Disturbed areas associated with Flowlines as defined in the 100 series rules.
Public Roads to the Location:
The operator has no control over county or other public roads and, therefore, little or
no ability to maintain these roads for stormwater management. Accordingly, COGCC
inspectors should not include any issues found on public roads in their inspection
reports. Any issues on public roads could be informally discussed with the operator
and the LGD if necessary or if safety issues exist.
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This does not apply to vehicles tracking mud or sediment offsite, which is addressed
below in the “Inspect vehicle tracking control BMP” section. If mud or other
sediment is tracked off of the location and onto any road, including public, the
COGCC inspector should note this as an issue as discussed in the “Inspect vehicle
tracking control BMP” section.
At times, it might be difficult to determine if a road is a public road or an access road.
If not known, inspectors should perform the required steps listed below to determine
this:
1. Review GIS layer, which lists public roads including highways and county
roads.
2. Review county records.
3. Contact the LGD or county planning department.
4. Ask the operator if they have documentation on who owns this road.
5. Contact your supervisor.
Best Management Practices (BMPs) Discussion and Differences
Stormwater BMPs are required per Rule 1002.f.(2) and the Rule lists six categories to
consider. BMPs can come in many forms and practices and include both structural
and nonstructural BMPs.
Structural BMPs are used to treat stormwater at the point of generation, the point of
discharge, or at any point along the stormwater "treatment train." Structural BMPs
can serve many different functions based on their design.
Non-structural BMPs are designed to limit the amount of pollutants available in the
environment that could potentially end up in stormwater runoff. Non-structural
BMPs can be achieved through such things as education, management, and
development practices. Some examples include planning and design, inspection and
maintenance protocols, good housekeeping, and comprehensive site planning.
Erosion control BMPs are practices that prevent the erosion of soil and include (1)
minimizing the amount of disturbed soil through phasing, temporary stabilization, or
leaving existing vegetation and (2) diverting runoff around disturbed areas.
Sediment control BMPs are practices to minimize sediment from runoff and include
but are not limited to (1) retaining stormwater in ponds or behind silt fence to settle
out sediment and (2) filtering stormwater through filter fabric on inlets.
The table below includes examples of both structural and nonstructural BMPs that
can be implemented to manage stormwater. Both must be assessed by COGCC
inspectors. Please note this list is not exhaustive and other methods not specifically
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listed may control stormwater. For examples of additional BMPs, refer to sources
such as the EPA webpage on Construction Site Stormwater Control listed directly
below and the CDOT Erosion Control Manual provided during your stormwater
training.
http://water.epa.gov/polwaste/npdes/swbmp/Construction-Site-Stormwater-Run-Off-Control.cfm
BMP Type
Category
BMP Example
Structural BMPs
Erosion and Sediment Control
Straw Bales
Wattles / Sediment Control Logs
Silt Fences
Earth Dikes
Drainage Swales
Sediment Traps
Subsurface Drains
Pipe Slope Drains
Inlet Protection
Outlet Protection
Gabions
Hay or straw bales
Sediment traps/basins
Sediment Basins
Non Structural BMPs
Erosion and Sediment Control
Temporary Vegetation
Permanent Vegetation
Mulching
Geotextiles
Sod Stabilization
Slope Roughening
Vegetative Buffer Strips
Protection of Trees
Preservation of Mature Vegetation
Vegetated buffers
Non Structural BMPs
General
Good Housekeeping
Waste Management
Spill Prevention
Inspection and Maintenance Program
Planning and Design
Construction Phasing and Sequencing
Training for Contractors and Staff
Documented Procedures
Gathering lines and public roads (see below for public roads) are not in the scope of
COGCC’s inspections related to stormwater.
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COGCC Stormwater Inspection Procedures
The five appendices at the end of this document provide a general sequence and
outline for conducting stormwater inspections and more detailed examples of the
COGCC stormwater inspection program.
Related to stormwater, COGCC inspectors focus their inspection on the following
three areas:
1. Onsite Erosion.
2. Sediment movement offsite/onsite.
3. Non-sediment pollution sources.
Onsite Erosion and Sediment Movement Offsite/Onsite:
Note: The three steps identified below for onsite erosion and sediment movement
offsite/onsite can be performed at the same time by the COGCC inspector but the
necessary steps are separately discussed for purposes of clarity.
Step 1
COGCC inspections related to onsite erosion and sediment movement offsite/onsite
are performance based. This means a COGCC inspector, for all “areas of inspection”
described above, should look for the following:
1. Evidence of onsite erosion such as gullies, rills, or ruts that have the potential
to allow sediment to leave the location.
2. Evidence of sediment runoff from the “areas of inspection.”
3. Evidence of sediment run on to the “areas of inspection.”
If evidence of any of the above is identified, the COGCC inspector should document
the impact, size, location, and associated risk level of the issues in the inspection
report, including photographs. Specifically, the report should include language
addressing the following:
1. Does the issue pose a potential threat to any of the objectives listed in the
“COGCC Program Objectives” section above?
2. Is the issue isolated to a small area or does it cover a majority of the area?
3. Are the actual gullies or rills large in size (use judgement on what “large”
means)?
4. Where on the “area of inspection” is the identified issue (e.g. SE corner)?
As an example, if an inspector identifies an “area of inspection” that contains several
gullies, the inspector should measure a reasonable subset of the gullies (using
measuring devices including, but not limited to, range finder, measuring wheel, tape
measure, GPS units, or stepping it off) and document the measurements in the
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inspection report. This information will help COGCC staff and operators better
understand the size of the issue.
Also, the above factors should be documented and considered when writing the
inspection report.
If any of the above items are identified, COGCC inspector must determine if
an upset weather event could have caused the impact and whether the
operator is proactively working to address the issue. This will help
determine the steps as outlined in the “Inspection Report” section below.
Step 2
The inspector should then inspect all sediment control BMPs that are designed to
catch and store sediment onsite to ensure the following:
1. The BMPs are inventoried for the inspection report by BMP category. For
example, if multiple berms exist on the location and all are working effectively,
the inspector should simply select “Berms” on the inspection report under one
line.
2. BMPs are capable of working as intended.
3. There is no imminent risk of failure or overflow of sediment. Inspectors should
interpret imminent risk of failure to mean the sediment control BMP is full of
sediment and one more weather event of any size would cause sediment to
overflow and runoff the “area of inspection”. NOTE: Stormwater is allowed to
leave the location as long as BMPs have been implemented to minimize
sediment transport and erosion.
If evidence of issues with these sediment control BMPs exist, COGCC inspector
should clearly document these issues in the inspection report, including photographs.
Step 3
The COGCC inspector should then identify the erosion control BMPs, runoff / run on
control BMPs, and non-structural BMPs on the “areas of inspection” and perform the
following:
1. Inventory the BMPs for the inspection report by BMP category. For example,
if multiple berms exist on the location and all are working effectively, the
inspector should simply select “Berms” on the inspection report under one line.
2. Perform a review of the existing BMPs looking for obvious flaws or
maintenance concerns that could cause an impact. Detailed sizing calculations
will not be performed.
a. Examples of obvious flaws or maintenance concerns include mulching
washed away or slope diversions damaged or altered.
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3. Review the structural BMPs to ensure no major installation issues exist that
could cause an impact.
a. Example of an installation issue includes putting only one stake in a
wattle.
Both structural and non-structural BMPs must be assessed during this review. The
appendices will go into specific examples related to access roads and location.
In performing this step, the inspector must evaluate the collective performance of all
BMPs installed. This means if there are issues with one BMP but other downstream
BMPs are working as intended and site degradation is not occurring as a result, then
the fact that, collectively BMPs are working, needs to be noted in the inspection
report.
Non Sediment Pollution Sources:
COGCC inspectors must then identify all non-sediment pollution sources located on
“areas of inspection.” The following is a non-inclusive list of non-sediment pollution
sources:
1. Fuel cans.
2. Fueling equipment.
3. Frac tanks.
4. Water tanks.
5. Bulk drilling fluid additives and cuttings drying material.
6. Vehicle maintenance areas.
7. Vehicle fueling area.
8. Equipment storage.
9. Chemical additives.
10. Lube oil or other chemical products.
Once the COGCC inspectors identify all of the non-sediment pollution sources, they
must identify the BMPs that control releases from these sources. Some of the same
BMPs used for sediment may apply to these sources. As with the sediment BMPs,
the COGCC inspector must:
1. Inventory the BMPs for the inspection report.
2. Perform a review of the existing BMPs looking for obvious flaws or
maintenance concerns. Detailed sizing calculations will not be performed.
3. Review BMPs to ensure they were appropriately installed.
Portable latrines located on “areas of inspection” could be an issue with CDPHE’s
rules but not necessarily with COGCC rules. If the inspector notices a portable
latrine without BMPs, the inspector will simply put the following general comment
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without a corrective action date in the inspection report: “CDPHE may require BMPs
for portable latrines. COGCC inspector identified a portable latrine without BMPs.
This is not a corrective action required for this report but could be an issue if the
CDPHE inspects this location.” The inspector should not mark this as an action
required issue.
Documenting Results in the Field Inspection Report
Field Inspection Documentation
COGCC staff should use the COGCC inspection report to document BMP inventory,
results from the above inspection steps, and areas that require corrective actions
identified in the above steps. The report should be objective and detailed.
Photographs
COGCC inspectors must take photographs of impacts identified during the inspection
along with BMPs and attach the photographs to the inspection report. When issues
are discovered, the report must include photographs close enough to show specifics
and photographs from a distance to show the surrounding background conditions.
Including both types of photographs provides context for the impact or issue
identified. When taking a photograph, keep perspective in mind. If the viewer will
have difficulty understanding how large something is (for example, a rill/gully), then
use a scaling device such as a person, shovel, hardhat or other object to provide
perspective. Finally, document the location from where the photograph is being
taken and which direction it is facing (e.g. Northeast).
Scenario Examples
COGCC inspectors should contact their supervisor with questions related to
documenting stormwater issues in the COGCC inspection report. Below are some
scenarios that will provide inspectors guidance on how to document certain
situations. These are just guidelines and a site specific analysis, such as risk
to water features and repeat issues, allow COGCC inspectors to deviate
from the below examples.
1. If the inspection shows that sediment or non-sediment pollution left the “area
of inspection” and entered a water feature (such as perennial stream,
intermittent stream, lake, or pond), the COGCC inspector will document a
corrective action and elevate to the Field Inspection manager for next steps.
2. If the inspection shows there were identified impacts as described above (e.g.
erosion, gullies, rills, etc.) but sediment or non-sediment pollution did not
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3.
4.
5.
6.
leave the “area of inspection”, the COGCC inspector will document corrective
action to fix these issues and work with the operator as required.
If a recent upset storm event caused the impacts identified above and evidence
exists that the operator has been working, prior to the inspection, to fix the
BMPs, the COGCC inspector will document a general comment to encourage
the operator’s continued repair of the BMPs. The inspection report should
clearly document what the operator has already performed and their proposed
fixes that are not yet completed.
If the inspector did not identify impacts as described above but did identify
minor issues with maintenance or installation of BMPs, the COGCC inspector
will document a general comment identifying the minor issues and required
actions in the comments of the inspection report.
If the inspection shows no stormwater issues, the COGCC inspector will
document no corrective actions or no general comments, assuming no other
inspection related issues existed.
Other scenarios should be discussed with the inspector’s supervisor and
determined on a case-by-case basis.
Corrective Action Language and Timing
The following will be the corrective action language for most stormwater related
issues:
 “Perform required actions by [30 DAYS FROM WHEN REPORT SENT TO
THE OPERATOR] or if not possible to complete required actions by this date,
provide a work plan, with associated timeframes, by [10 DAYS FROM
REPORT SENT TO OPERATOR] that details the actions the operator will
perform within the associated timeframes.”
Generally, it is important for inspectors to provide operators 30 days to perform the
required actions or 10 days for a work plan from the date the inspection was sent to
the operator and not the date of inspection. For example, if the inspection was
February 22, 2015 but the report was not sent to the operator until March 1, 2015,
then the corrective action dates should be March 31, 2015 to correct or March 11,
2015 for the work plan.
Some exceptions to the 30 days listed above include the following:
1. Instances where there is an immediate threat to surface water quality. In
those cases, the operator should correct the issue immediately.
2. Instances where a COGCC inspector found the same stormwater issues on the
same location in the same general area in a previous inspection report. In
those cases, a shorter duration may be appropriate and discuss with your
supervisor.
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3. Perimeter controls during construction of the location. Since construction of
the location will end within 30 days, these controls should be implemented
immediately. In these cases the inspector should contact the operator to set a
timeframe and schedule.
It is important to note that these are guidelines for COGCC inspectors and 30 days
provides a reasonable timeframe for a COGCC inspector to be able to reinspect the
location. COGCC strongly prefers for operators to correct issues as soon as possible
and not wait until day 29, and inspectors should share this preference with
operators.
Natural Erosion Areas
The COGCC inspector, after discussions with a supervisor, should document in the
inspection report “areas of inspection” that have significant natural erosions features
nearby, which the natural areas might contribute to the stormwater issues.
Sediment movement confined to the oil and gas location, related to natural erosion,
and which is an indication of alteration of natural features should not warrant an
NOAV, but may require corrective actions to reduce sediment movement and site
degradation.
Staff should work with operators to assist in identifying higher risk sites that have
significant natural erosion features that may require a higher frequency of
inspections and BMP maintenance by the operator due to these natural erosion
features. These high risk factors may include proximity to drainage areas, proximity
to streams, slope gradients, and potential for flooding.
NOAVs
NOAVs will not be issued to an operator for stormwater related issues unless first
reviewed by both the Field Inspection Manager and the Hearings Manager. The
Field Inspection Manager and the Hearings group will review to ensure that
adequate physical evidence exists to support the issuance of an NOAV.
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Appendix 1 – General Construction Inspection SOP
A note about construction activity:
Construction activity, by its very nature, is a “dirty” business. In many cases, land is
cleared and graded to conform to the new site requirements. During a rain event or
snow melt, even the best-managed construction sites will look “muddy.” An
inspector’s role during an inspection is to perform the inspection with the objectives
listed in the “COGCC Program Objectives” section above in mind.
Inspection Sequence:
1. Plan your inspection





Stormwater inspections could be conducted during initial construction
activity when clearing, grubbing, grading or other earth disturbing actions
are in progress. Stormwater construction inspections will also be part of
any COGCC Location Inspection at sites that have not passed an interim
reclamation inspection. Initial construction (earth moving) inspections will
typically be conducted by the reclamation specialist.
Review the aerial photographs or site map in the 2A and plan how you will
conduct the inspection (this is particularly important for large construction
sites).
Identify the significant sources of pollutants and BMPs to inspect such as
silt fence installation, sediment basins, slope stabilization, material storage
areas, etc.
Consider the stormwater flow direction as you plan the inspection.
Consider beginning your inspection at the low point on the location,
observing all discharge points and walk up the slope to inspect the rest of
the site.
2. Areas to inspect

Refer to the “Areas of Inspection” section above to identify sites that are
within COGCC jurisdiction.
3. Inspect discharge points and downstream, off-site areas for signs of impact


When inspecting discharge points from the site, if it appears that sediment
is leaving the site, walk downstream to document the extent of travel and
impact on receiving waters or storm drain systems, such as road ditches.
Walk “down slope” if necessary to inspect off-site areas for signs of
discharge. Inspect catch basin inlets to ensure that they are adequately
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protected. Note in the inspection report all environmental impacts and
document these impacts with photographs.
Appendix 2 -- Inspection of Access Roads to the Location
Access roads are those roads built and/or maintained by operators for the main
purpose of accessing the oil and gas location. The operator, or group of operators, has
direct control over the road. Access roads are not public roads.
Inspect condition and slope of the access road:
COGCC inspectors may look for the following:
1. Access road not stabilized.
2. Access road not constructed or maintained appropriately to allow stormwater
to drain from the road to drainage ditches, culverts, or other sediment
catchment basins.
3. Pot holes and ruts.
o Ruts on access roads of 4 inch depth or evidence of vehicles avoiding
ruts or pot holes should require corrective actions.
o Ruts less than 4 inch depth should be noted in the comments of the
inspection report but generally should not have a corrective action
associated with the comment.
4. Areas where vehicle traffic is driving off established road surface to avoid ruts,
pot holes, or standing water.
5. Evidence that cut slope stabilization is introducing sediment to the access
roads.
6. Evidence that road maintenance activities are, or potentially are, allowing
sediment to approach water features.
Inspect drainage channels on both sides of the access road:
COGCC inspectors may look for the following during this review:
1. Evidence of erosion.
2. Road damage (from operations or maintenance) that may cause run off.
3. Evidence of wash out, gullies, rilling, and erosion channels along the edge of
the road.
Inspect all check dams, wattles, water bars, and retention ponds located along access
roads and inspect outlet protection around retention ponds:
COGCC inspectors will look for the following during this review:
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1. Retention ponds not armored to prevent undercutting.
2. Check dams not installed properly to prevent erosion.
3. BMPs not installed, not installed correctly, or not maintained.
Inspect all culverts along the access roads and inspect outlet protection at culverts:
COGCC inspectors will look for the following during this review:
1. Damage to culverts or evidence of poor maintenance of culverts.
2. Sediment build up around or in culverts that prevents the culvert from
functioning as designed.
3. Inadequate inlet and outlet protection that prevents the culvert from
functioning as designed.
4. Improperly constructed retention pond or catchment basin within the culvert.
5. Improperly designed or installed culvert that allows energy of moving water to
cause erosion.
How to Address Issues Found with Access Roads:
If issues with access roads are identified from the above review where an action
required inspection report is issued, the inspector should perform the following based
on the below situations:
1. Access road is used by only one operator (No evidence that it is a private road):
o Inspector should send the report to that operator. The inspector should
also add the following language to the inspection report: “The COGCC
has no information that this is a private road or a road shared or owned
by other private interests (other than the landowner). If this is the case,
as part of your corrective action, please provide information related to
what responsibilities you have to maintain the access road. The
COGCC is available to discuss this issue as required.”
2. Access road is shared by more than one operator:
o Inspector should send a separate report to each operator describing the
issue found. The reports must include the following language in the
stormwater section: “The COGCC recognizes that multiple operators
use this access road. However, the COGCC does not have the ability to
know which operator is responsible to maintain the access road and has
therefore sent a similar inspection report to “OPERATOR NAME”. The
COGCC encourages you to coordinate with “OPERATOR NAME” to
resolve the issue. The COGCC is available to discuss this issue as
required.”
o Inspector, with inspection supervisor as required, will meet with the
operator or operators to discuss if requested.
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o Generally, an NOAV will not be issued unless a discussion with the
operator first occurs.
3. Access road is shared with, and/or owned by, private non-oil and gas interests:
o Inspector should send the report to the operator. The report must
include the following language in the stormwater section: “The COGCC
recognizes that this road is shared, and potentially owned, by private
interests other than oil and gas operators. However, the COGCC does
not have the ability to know what responsibility the operator has to
maintain the access road. As part of your corrective action, please
provide information related to what responsibilities you have to
maintain the access road. The COGCC is available to discuss this issue
as required.”
o Inspector, with inspection supervisor as required, will meet with the
operator to discuss if requested.
o Generally, an NOAV will not be issued unless a discussion with the
operator first occurs.
Note: If operators have entered into an agreement for road maintenance where a
single operator has taken the lead to maintain a road, and a sign is present at the
road, then the inspection report can be sent to just that operator. This is a situation
that exists in the Southwest portion of the state through the La Plata County Energy
Council.
Appendix 3 -- Inspection on the Location:
Determine all non-sediment pollution sources located on the location:
As documented in the “Non Sediment Pollution Sources and Associated BMPs”
section above.
Inspect all temporary berms implemented around equipment located on the location
(not perimeter berm):
COGCC inspectors will look for the following during this review:
1. Berms not compacted or damaged, thereby making them a pollutant source.
2. Berms not maintained properly.
NOTE: This SOP is not stating temporary berms are required around all such
equipment. The SOP is simply stating if a temporary berm is being used as a
stormwater BMP, then these BMPs, like any other BMP, should be working
appropriately.
Inspect for site degradation on the location:
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COGCC inspectors will look for the following during this review:
1. Location is not stabilized appropriately, which would include lack of
compaction, insufficient gravel, or existence of ruts, etc.
o Ruts on a pad in three or more different areas that are all 4 inches or
deeper should require corrective actions.
o Ruts below the above criteria should be noted in the comments of the
inspection report but not have a corrective action associated with it.
2. Areas of site degradation on the location exist that can lead to stormwater
pollution.
3. Evidence of erosion (rilling, gullies, channeling).
4. Catchment basins are at imminent risk of discharging sediment.
5. Rig wash allowed to run onto location with no control.
6. Spills and releases of chemicals uncontrolled on location.
7. Insufficient BMPs for the size of the location. For example, location sloped to
direct stormwater to one area, but the ditch in that area is not sufficient in
size to contain the sediment.
Inspect vehicle tracking control BMP:
COGCC inspectors will look for the following during this review:
1. Evidence of tracking sediment or mud off of location, and may include
tracking, onto an access road or public road.
2. Look for BMPs (tracking pad, wash rack, scraping, or other sediment controls).
3. Review condition of vehicle tracking pad if present.
4. Review condition of cattle guard, if cattle guard is being used as a stormwater
BMP.
Observe run on and run off potential on all sides of the location:
COGCC inspectors will walk the perimeter of the location and look for the following
during this review:
1. Evidence of run off or run on of sediment due to lack of appropriate control
measure.
2. Perimeter berm, if one exists, not compacted, damaged, or otherwise stabilized.
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Appendix 4 - Common Compliance Problems
The following compliance problems are commonly found at small construction sites.
Inspectors should keep these common problems in mind while conducting
inspections.
Problem #1 – No temporary or permanent cover.
In areas of the site where construction has temporarily or permanently ceased,
exposed soil areas should be stabilized.
Problem #2 – No sediment controls on site.
No sediment control practices (e.g., sediment traps/ basins, down-gradient silt fences
or sediment barriers, check dams, etc.) were implemented on down-gradient
perimeters before up-gradient land disturbing activities begin.
Problem #3 – No sediment control for temporary stock piles.
Temporary stockpiles should have silt fence or other effective sediment BMPs.
Problem #4 – No BMPs to minimize vehicle tracking of sediment or mud off of the
“area of inspection”.
Vehicle exits should use BMPs such as stone pads, wash racks, or equivalent systems
to prevent vehicle tracking of sediment or mud off of the “area of inspection”.
Problem #5 – Improper solid waste or hazardous materials management.
Trash and other debris should be disposed of properly, and hazardous materials
(including oil, diesel fueling, glycol, etc.) should be properly stored and have specific
BMPs in place, such as secondary containment.
Appendix 5 - Definitions
These definitions are documented to provide additional guidance to COGCC
inspectors on some commonly used terms related to stormwater management.
Best Management Practices (BMPs) -- practices that are designed to prevent or
reduce impacts caused by oil and gas operations to air, water, soil, or biological
resources, and to minimize adverse impacts to public health, safety and welfare,
including the environment and wildlife resources. (From 100 Series Rules)
Last Revised 12/7/2015
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STORMWATER MANAGEMENT INSPECTION SOP
Minimize adverse impacts -- wherever reasonably practicable, to avoid adverse
impacts to wildlife resources or significant adverse impacts to the environment from
oil and gas operations, minimize the extent and severity of those impacts that cannot
be avoided, mitigate the effects of unavoidable remaining impacts, and take into
consideration cost-effectiveness and technical feasibility with regard to actions and
decisions taken to minimize adverse impacts. (From 100 Series Rules)
Minimize erosion -- implementing best management practices that are selected
based on site-specific conditions and maintained to reduce erosion. Erosion control
practices include, but are not limited to, re-vegetation of disturbed areas, mulching,
berms, diversion dikes, surface roughening, slope drains, check dams, and other
comparable measures. (From 100 Series Rules)
Natural Feature -- includes land or water features which are not man-made and
can include mountains, arroyos, plateaus, rivers, lakes, ravines.
Site Stabilization -- the process of implementing specific BMPs for the purpose of
preventing the discharge of sediment from construction sites. Additional information
on site stabilization can be found in the STORMWATER FACT SHEET –
CONSTRUCTION at OIL and GAS FACILITIES provided by the Colorado Water
Quality Control Division.
Site Degradation -- any unnecessary and undesirable change or disturbance to the
location that may result from stormwater run-on, runoff, or impacts due to nonsediment pollutants.
Examples include evidence of erosion including rilling,
gullying, and other forms of channelized water flow, movement of sediment, ruts of 4”
or more in depth, or local of compaction.
Upset -- means an exceptional weather event that is outside the scope of reasonable
and standard engineering design and planning. It is an incident in which there is
unintentional and temporary noncompliance with the requirement to install and
maintain BMPs. An upset does not include noncompliance to the extent caused by
operational error, improperly designed BMPs, lack of preventive maintenance, or
careless or improper operation.
Document Change Log:
Change Date
December 7, 2015
Last Revised 12/7/2015
Description of Changes
Document created and finalized
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