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NOTICE TO OPERATORS DRILLING WELLS WITHIN 3/4 MILE OF THE RIM OF THE ROAN PLATEAU IN GARFIELD COUNTY. PIT DESIGN, CONSTRUCTION, AND MONITORING REQUIREMENTS. Timing. May 20, 2008 COGCC Field Tour to observe current fluid management practices near the rim of the Roan Plateau

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NOTICE TO OPERATORS DRILLING WELLS WITHIN 3/4 MILE OF THE RIM OF THE ROAN PLATEAU IN GARFIELD COUNTY

PIT DESIGN, CONSTRUCTION, AND MONITORING REQUIREMENTS

timing
Timing
  • May 20, 2008 COGCC Field Tour to observe current fluid management practices near the rim of the Roan Plateau
  • May 21, 2008 COGCC met with operators and other interested parties in Battlement Mesa to discuss our intentions regarding the NTO
  • May 23, 2008 COGCC issued the first draft of the NTO and solicited comments from interested parties
  • June 5, 2008 COGCC issued the second draft of the NTO.
  • June 12, 2008 COGCC intends to issue the final NTO
justification for continued use of pits
JUSTIFICATION FOR CONTINUED USE OF PITS
  • Current infrastructure development in the Area of Concern is limited, which results in logistical problems with implementation of closed loop or semi-closed loop (CL/SCL) systems
  • CL/SCL systems may result in greater land disturbance associated with pad construction (additional room for tanks) and pipeline construction (additional water pipelines for a consistent water supply)
  • CL/SCL systems may result in the potential for spills associated with increased truck and heavy equipment traffic for handling drill cuttings and fluids, mechanical failures, and freezing of above-ground piping
justification for continued use of pits1
JUSTIFICATION FOR CONTINUED USE OF PITS
  • CL/SCL systems may result in other logistical problems related to observed water flows and containment requirements for emergency control of fluids.
  • Despite these issues, COGCC intends to work with operators to continue evaluating CL/SCL systems.
pit use
Pit Use
  • Pit requirements apply to short-term multi-purpose pits, which may be used as a flare pit, a blooey pit, a surface interval / well control pit, a cement returns pit, a reserve pit, and/or a flowback pit.
  • Production pits must comply with the requirements presented below and must be permitted on a Form 15 (Earthen Pit Report/Permt). Additional monitoring and/or more stringent construction practices may apply.
  • Drill cuttings pits or bermed cuttings piles must not be lined. No free liquids exceeding de minimis amounts will be permitted in drill cuttings pits in the Area of Concern.
general requirements
General Requirements
  • Pits shall not be constructed on known intermittent or perennial springs, seeps, or other surface water features.
  • If groundwater is encountered during pit construction an alternate location shall be proposed or a CL/SCL may be considered.
general requirements1
General Requirements
  • A minimum of two (2) feet of freeboard shall be maintained at all times, and operators shall maintain fluids in pits at the lowest practicable level, subject to the type of operation in process.
  • Any accumulation of oil in a pit shall be removed within twenty-four (24) hours of discovery, unless the pit is a properly permitted, fenced, lined, and netted production (skim) pit.
general requirements2
General Requirements
  • Where necessary to protect public health, safety and welfare or to prevent adverse environmental impacts resulting from access to a pit by wildlife, migratory birds, domestic animals, or members of the general public. Operators shall install appropriate netting or fencing and construct escape ramps.
  • No portion of any pit shall be constructed on fill material, unless the pit and fill slope are designed and certified by a Professional Engineer, subject to review and approval by the Director prior to construction of the pit.
pit design and construction
Pit Design and Construction
  • Pits shall be constructed with a double liner system. Operators will have the option of using a compacted clay liner overlain by a synthetic liner or a double synthetic liner underlain by compacted soil or recycled drill cuttings to protect the synthetic liners.
  • Pit sidewall slopes shall not be steeper than 1 vertical to 2 horizontal in order to facilitate installation of the bedding materials and the synthetic liner(s).
pit design and construction1
Pit Design and Construction
  • If site-specific conditions do not allow for compliance with minimum requirements in the NTO, then the operator must submit a pit design which is certified by a Professional Engineer, subject to review and approval by the Director prior to construction of the pit.
hydrotesting
Hydrotesting
  • After installation of the uppermost liner and prior to operating the pit, the synthetic liner(s) shall be tested by filling the pit with at least four (4) feet of fresh water, measured from the base of the pit (not to exceed the two (2) foot freeboard requirement). The operator shall monitor the pit for leaks for a period of seventy-two (72) hours prior to commencing operations.
pit monitoring
Pit Monitoring
  • Pit fluid levels shall be monitored using a pit level indicator at least once every twelve (12) hours whenever fluid is present in the pit in quantities greater than de minimis amounts. The monitoring frequency shall increase to once every six (6) hours when the pit is being actively used for drilling, completion or production operations.
  • The operator must cease use of the pit within forty-eight (48) hours if there is any observed loss of integrity from the pit liner or if the operator suspects a loss of more than five hundred (500) barrels of liquid from the pit, based on fluid level measurements or throughput measurements.
suspension of use
Suspension of Use
  • If operations are suspended and the pit is not in use for more than seven (7) calendar days, then fluids in the pit must be removed such that only de minimis amounts of fluids are left in the pit to hold down the synthetic liner(s).
  • If operations are suspended for more than six (6) months, then the pit shall be closed, unless specifically approved by the Director.