Current events at the cogcc
This presentation is the property of its rightful owner.
Sponsored Links
1 / 37

Current Events at the COGCC PowerPoint PPT Presentation


  • 50 Views
  • Uploaded on
  • Presentation posted in: General

Current Events at the COGCC. Jake Matter Assistant Attorney General [email protected] 720. 508.6289 . New COGCC Water Sampling Rule New COGCC Setbacks Rule CDPHE Oil and Gas Stakeholder Group. NEW WATER SAMPLING RULES. Different rules for GWA. Greater Wattenberg Area, or “GWA”

Download Presentation

Current Events at the COGCC

An Image/Link below is provided (as is) to download presentation

Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author.While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server.


- - - - - - - - - - - - - - - - - - - - - - - - - - E N D - - - - - - - - - - - - - - - - - - - - - - - - - -

Presentation Transcript


Current events at the cogcc

Current Events at the COGCC

Jake Matter

Assistant Attorney General

[email protected]

  • 720.508.6289


Current events at the cogcc

  • New COGCC Water Sampling Rule

  • New COGCC Setbacks Rule

  • CDPHE Oil and Gas Stakeholder Group


New water sampling rules

NEW WATER SAMPLING RULES


Different rules for gwa

Different rules for GWA

  • Greater Wattenberg Area, or “GWA”

  • GWA is an oil and gas field northeast of Denver encompassing 2,916 square miles

  • GWA accounts for 60% of oil produced in state

  • GWA has nearly 20,000 producing wells

  • Long history of production

  • Different treatment in rules


Historic water sampling requirements

Historic Water Sampling Requirements

  • 2000 – CBM wells in the San Juan Basin

  • 2005 – GWA wells (infill wells only)

  • 2009 – CBM wells statewide

  • 2009 – Water sampling as a COA

  • 2011 – GWA wells, not just infill wells


Old gwa water sampling rule

Old GWA Water Sampling Rule

  • Baseline sample required where the first well was proposed in a governmental section

  • Hundreds previously collected

  • Domestic well in Laramie/Fox Hills Aquifer was highest priority

  • If no water well within ½ mile, no testing required

  • Sampling and reporting requirements

  • COGCC Rule 318A.e(4)


New gwa water sampling rule 1 source 2 samples

New GWA Water Sampling Rule1 source, 2 samples

  • Baseline sample required where the first well is proposed in a governmental quarter section

  • One follow-up sample (6-12 months post completion)

  • Amended COGCC Rule 318A.e(4)


New statewide water sampling rule up to 4 sources 3 samples

New Statewide Water Sampling Rule Up to 4 sources, 3 samples

  • Sample all sources within ½ mile of well, up to four

  • Baseline (within 12 months prior to drilling)

  • First follow-up sample (6-12 months post-completion)

  • Second follow-up sample (5-6 years post-completion)

  • New COGCC Rule 609


Similarities

Similarities

  • Apply to wells, multi-well sites and injection wells

  • “Available” water sources

  • No requirement to drill monitoring well

  • “Piggybacking”

  • No presumption of liability

  • “Recommended” Sampling and Analysis Plan

  • Not a limit on COGCC Director authority; COAs

  • Notify well owner of thermogenic gas, or where methane levels increase or exceed thresholds


New setback rules

NEW SETBACK RULES


Purposes

Purposes

  • Advance notice to impacted parties

  • Advise affected parties of how to participate in permitting process

  • Increase engagement among operator, surface owners and Local Governmental Designees (LGD)

  • Increase distances from homes and nuisances


Old setbacks rules the numbers

Old Setbacks Rules – The Numbers

  • Minimum – 150’ or 1.5 times height of derrick

  • High Occupancy Area (HOA) – 350’


New setback rules the numbers

New Setback Rules – The Numbers

  • Urban Mitigation Area – 500’

  • Non Urban Mitigation Area – 500’

  • Schools, hospitals, daycares etc. – 1,000’


New setback rules the effect

New Setback Rules – The Effect

  • Heightened mitigation if well / facility would be within 1,000’ of a home. Rule 604.c.

    • Drilling noise limitation reduced from industrial (80/75 db) to light industrial (70/65 db)

    • Closed loop drilling systems

    • Green completions

    • Traffic plans

    • Use existing facilities and well bores

    • Berm construction

    • Fencing


Designated setback locations dsl

“Designated Setback Locations” (DSL)

  • If a proposed well falls within one of many enumerated DSLs, additional notification, consultation and operational requirements are triggered


Dsls include

DSLs include:

  • High Occupancy Building Unit DSL. Is a hospital or school within 1,000’ of the proposed well?

  • Buffer Zone DSL. Is a home within 1,000’ of the proposed well?

  • Exception Zone DSL. Is a home within 500’ of the proposed well?


High occupancy building unit dsl

High Occupancy Building Unit DSL

  • Full Commission must approve well within 1,000’ of a High Occupancy Building Unit

  • No staff-level approval

  • If Commission approves such a well, mitigation measures required for “Exception Zone DSLs” apply, including noise restrictions, closed loop drilling, green completions, steel rimmed containment berms


Buffer zone dsl

Buffer Zone DSL

  • Homeowners within 1,000’ receive “Notice of Intent to Conduct Oil and Gas Operations” from operator 30 days prior to operator submitting application materials to COGCC

    • Operator and LGD contact information

    • Location, description, timing

    • Governor’s task force recommendation


Buffer zone dsl continued

Buffer Zone DSL, continued

  • Homeowners within 1,000’ receive “Notice of Comment Period”

  • Sent after COGCC staff deems APD is complete

  • COGCC staff consider public comments in final approval of application

  • Operators must invite meetings with notified parties and hold such meetings if public or LGD requests

  • Public meetings to address security, nuisance impacts and mitigation measures


Buffer zone dsl continued1

Buffer Zone DSL, continued

  • No well will be approved if within 1,000’ of a home unless the COGCC permit contains site-specific COAs “as necessary to eliminate, minimize or mitigate potential adverse impacts to public health, safety, welfare, the environment, and wildlife.” Rule 604(a)(2).

  • Rules are a floor and do not limit the Director’s ability to impose site-specific COAs


Exception zone dsl

Exception Zone DSL

  • Exception Zone DSL applies where the planned well is within 500’ of a home

  • All mitigation measures required under Buffer Zone DSL are required, plus other berm construction requirements, including steel rimmed containment berms and liners. Rule 604.c.(3).

  • Requires an exception from the COGCC


Exception zone dsl1

Exception Zone DSL

  • Homeowners within 500’ receive “Notice of Intent to Conduct Oil and Gas Operations” from operator 30 days prior to operator submitting application materials to COGCC

    • Operator and LGD contact information

    • Location, description, timing

    • Governor’s task force recommendation


Exception zone dsl2

Exception Zone DSL

  • Homeowners within 500’ receive OGLA notice upon completeness determination by COGCC

    • List of equipment to be used at site

    • Engineering drawings

    • Access map

    • Instructions on how to contact LGD and meet with operator

    • Invitation to provide written comments to COGCC

    • OGLA notice not required in GWA


Exceptions to the 500 setback

Exceptions to the 500’Setback

  • Exceptions may be granted by the Director

  • Director must report all exceptions to Commission monthly

  • Criteria for granting an exception differs depending on whether location is in a Urban Mitigation Area, or not


Current events at the cogcc

UMA

  • Urban Mitigation Area (UMA) is a new term of art, but is a similar concept to the old High Occupancy Area (HOA)


Uma is a lower threshold than hoa

UMA is a lower threshold than HOA


Exceptions inside outside uma

Exceptions inside / outside UMA

  • If inside UMA, waivers must be received from all property owners within Exception Zone / 500’

  • If outside UMA, no waivers needed

  • If outside UMA, Director must insure that the COGCC permit contains site-specific COAs “sufficient to eliminate, minimize or mitigate potential adverse impacts to public health, safety, welfare, the environment, and wildlife to the maximum extent technically feasible and economically practicable.” Rule 604.a.(1).B.


Cdphe apcd oil and gas stakeholder group

CDPHE APCD Oil and Gas Stakeholder Group


Purposes1

Purposes

  • Discuss revisions to the Air Quality Control Commission’s Regulations Numbers 3, 6, 7, and Common Provisions.

  • Discuss full adoption of 40 CFR Part 60, Subpart OOOO (“NSPS OOOO”)

  • Discuss additional control measures for oil and gas operations and equipment.


Timeline

Timeline

  • December 27, 2012 – APCD announces stakeholder process

  • January 28, 2013

  • February 28, 2013

  • March 28, 2013

  • April 25, 2013

  • May 22, 2013

  • All meetings at CDPHE Campus, Building A, Sabin Cleere Rooms


March 28 2013 agenda

March 28, 2013 Agenda

  • APCD will discuss comments received and any revisions made concerning the potential revisions to Regulations Numbers 3, 6, and 7.

  • APCD will discuss further potential revisions to Regulation Number 7 and the Common Provisions.


Rulemaking process goal

Rulemaking Process Goal

  • August 2013 Request for Hearing

  • November 2013 Hearing


Rules under consideration would

Rules under consideration would:

  • Go “well beyond existing federal and state requirements”

  • Reduce VOCs, methane and other pollutants.

  • Focus on reducing fugitive emissions and leaks from large emissions sources, i.e., condensate tanks

  • Find and fix leaks via infrared cameras or other technologies

    • Denver Post Guest Commentary, March 13, 2013, Dr. Chris Urbina and William C. Allison of CDPHE.


Questions

Questions?

Jake Matter

303.866.5041

[email protected]


  • Login