BEFORE THE OIL AND GAS CONSERVATION
COMMISSION
OF THE STATE OF
IN THE MATTER OF THE PROMULGATION
AND ) CAUSE NOS. 139, 440, 479
ESTABLISHMENT OF FIELD RULES TO
GOVERN ) 495, 510
OPERATIONS IN THE RULISON,
PARACHUTE, AND )
GRAND VALLEY FIELDS,
440-23, 479-11, 495-3,
510-8
This cause came
on for hearing before the Commission at 10:00 a.m. on April 21, 2003 in the
Arvada City Council Chambers, 8101 Ralston Road, Arvada, Colorado on the
application of Williams Production Company RMT Company for an order to increase the number
of wells which can be drilled into and produced from the Williams Fork
Formation on the application lands which constitute existing drilling units (or
portions thereof) to the equivalent of one Williams Fork well per 10 acres for
certain lands in the Rulison, Parachute and Grand Valley Fields.
FINDINGS
The
Commission finds as follows:
1.
Williams Production Company RMT
Company (“WPC”), as applicant herein, is an interested party in the
subject matter of the above-referenced hearing.
2. Due notice of the time, place and purpose of
the hearing has been given in all respects as required by law.
3. The Commission has jurisdiction over the
subject matter embraced in said Notice, and of the parties interested therein,
and jurisdiction to promulgate the hereinafter prescribed order.
4.
On
Township 6 South, Range 93 West, 6th
P.M.
Sections 5 through 8: All
Sections 17 through 20: All
Township 6 South, Range 94 West, 6th
P.M.
Sections 1 though 3: All
Sections 8 through 17: All
Sections 19 through 24: All
Sections 27 through 33: All
5. On
Township 6 South, Range 93 West, 6th
P.M.
Sections 5 through 8: All
Sections 17 through 20: All
Township 6 South, Range 94 West, 6th
P.M.
Sections 1 though 3: All
Sections 8 through 24: All
Sections 27 through 33: All
6. On
Township 6 South, Range 95 West, 6th
P.M.
Sections 7 through 20: All
Sections 22 through 28: All
Sections 31 through 36: All
Township 7 South, Range 95 West, 6th
P.M.
Section 5 and 6: All
7. On
Township 6 South, Range 96 West, 6th
P.M.
Section 1: All
Section 12: All
Sections 23 through 27: All
Sections 34 through 36: All
Township 7 South, Range 96 West, 6th
P.M.
Section 1: All
8. On December 18, 1996, the Commission issued
Order No. 139-29 allowing up to four (4)
wells to be drilled into and produced from the previously established
320-acre drilling and spacing units for the production of gas and associated
hydrocarbons from the Williams Fork Formation including the below- listed
lands:
Township 6 South, Range 94 West, 6th
P.M.
Section 20: S½ NE¼
9. On December 18, 1996, the Commission issued
Order No. 510-2 which allowed four (4) wells to be drilled into and produced
from the Williams Fork Formation with each such well to have a bottom hole
location no closer than 400 feet from the bottomhole location of any other
Williams Fork Formation well and no closer than 200 feet from the boundary of
any lease line, with the below-listed lands to remain unspaced:
Township 7 South, Range 96 West, 6th
P.M.
Section 4: NE¼ NE¼
10. On
Township 6 South, Range 94 West, 6th
P.M.
Section 20: E½ SE¼, W½ W½
Section 21: S½ NW¼, S½
Section 22: SW¼
Section 27: S½ NW¼, NE¼ NW¼, NW¼ SW¼
Section 28: NE¼, N½ NW¼, E½ SE¼,
Section 29: N½ NE¼, NE¼ NW¼
11. On
Township 6 South, Range 94 West, 6th
P.M.
Section 10: N½ SE¼
Section 11: S½ NW¼, N½ SW¼, SE¼ SW¼
Section 14: E½
Section 15: All
Section 27: NW¼ NE¼
Township 6 South, Range 95 West, 6th
P.M.
Section 35: NE¼ NW¼, SW¼ NW¼, NW¼
NE¼
Township 7 South, Range 95 West, 6th
P.M.
Section 6: SW¼ NW¼
12. On March 21, 2000, the Commission issued
Order Nos. 139-32, 479-6, 495-2 and 510 allowing the equivalent of one (1) well
per 20 acres to be drilled into and produced from the Williams Fork Formation
including the below-listed lands:
Township 6 South, Range 96 West, 6th
P.M.
Section 27: SW¼ SW¼
Section 34: SE¼, E½ SW¼, SW¼ SW¼, NW¼ NW¼, SE¼ NW¼
Section 35: SW¼ SW¼, SE¼ SE¼
Section 36: SW¼, W½ SE¼
Township 7 South, Range 96 West, 6th
P.M.
Section 1: S½ N½, N½ NW¼, N½ S½
13. On March 21, 2000, the Commission issued
Order Nos. 139-32, 479-6, 495-2 and 510-3 establishing 40-acre drilling and
spacing units for certain lands including the below-listed lands which were
previously unspaced and within these 40-acre drilling and spacing units,
allowing up to two (2) wells to be drilled into and produced from the Williams
Fork Formation:
Township 6 South, Range 96 West, 6th
P.M.
Section 28: S½ S½
Section 29: SE¼ SE¼
Section 32: W½ NE¼, NE¼ NE¼, SE¼ NW¼
Section 33: N½ NW¼, SE¼ NW¼, N½ NE¼,
SW¼ NE¼
Township 7 South, Range 96 West, 6th
P.M.
Section 2: N½, SW¼, W½ SE¼, NE¼ SE¼¼
Section 3: NE¼
14. On
Township 6 South, Range 96 West, 6th
P.M.
Section 17: E½
Section 20: N½, SE¼, E½ SW¼
Section 28: S½ NW¼, N½ SW¼
Section 29: NE¼, NE¼ NW¼, NE¼ SE¼
Section 31: S½ NE¼, N½ SE¼
Section 32: NW¼ SE¼, SW¼ NW¼, N½ SW¼
15. On November 29, 2000, the Commission issued
Order Nos. 479-7, 440-19, 139-34, and 510-4 allowing the equivalent of one (1)
well per 20 acres to be drilled into and produced from the Williams Fork
Formation including the below-listed lands:
Township 6 South, Range 94 West, 6th
P.M.
Section 16: S½, W½ NE¼, E½ NW¼
Section 17: SW¼ SW¼
Section 18: SE¼ SE¼, W½ SE¼
Section 21: N½ NE¼, SW¼ NE¼
Section 22: N½, W½ SE¼
Section 27: SW¼ SW¼
Township 6 South, Range 95 West, 6th
P.M.
Section 26: S½ SW¼
Section 27: S½ SW¼, SW¼ SE¼
Section 28: S½ SE¼, E½ W½
Section 31: SE¼ SE¼
Section 32: SW¼, N½ SE¼, SW¼ SE¼, SE¼ NE¼
Section 33: S½, NE¼, NE¼ NW¼, SW¼ NW¼
Section 34: All
Section 35: NW¼ NW¼
Township 6 South, Range 96 West, 6th
P.M.
Section 23: SW¼ SW¼
Section 27: NE¼ NE¼, S½ NE¼, N½ SE¼, SW¼ SE¼, SE¼ SW¼
Section 34: NE¼ NW¼, NW¼ NE¼
Township 7 South, Range 95 West, 6th
P.M.
Section 5: NW¼ NW¼
Section 6: E½ NW¼, W½ NE¼, NE¼ NE¼
Township 7 South, Range 96 West, 6th
P.M.
Section 1: NW¼ NE¼, SE¼ SW¼
16. On July 18, 2001, the Commission issued Order
Nos. 139-37, 440-22, 479-9 and 510-6 allowing the equivalent of one (1) well
per 10 acres to be drilled into and produced from the Williams Fork Formation
for the below-listed lands:
Township 6 South, Range 94 West, 6th
P.M.
Section 20: E½ SW¼, W½ SE¼
Township 6 South, Range 96 West, 6th
P.M.
Section 33: SE¼
17. On
Township 7 South, Range 96 West, 6th
P.M.
Section 1: S½ SE¼
18. On February 14, 2003, WPC, by
its attorney, filed with the Commission a verified application requesting an
order from the Commission to allow additional wells to be drilled for the
production of gas and associated hydrocarbons from the Williams Fork Formation
of the Mesaverde Group, the equivalent of one (1) well per 10 acres for the
lands described below (“Application Lands”).
WPC requested that the NE¼ NE¼ of Section 4, Township 7 South, Range 96
West, 6th P.M. be constituted as a 40-acre drilling and spacing unit
for the Williams Fork Formation. WPC also
requested that the permitted downhole location for each new Williams Fork Formation
well drilled upon the Application Lands be located anywhere within a given
drilling and spacing unit but no closer than 100 feet from any boundary of a
drilling unit without exception being granted by the Director of the Oil and
Gas Conservation Commission. It is
provided however that no new Williams Fork Formation well shall be drilled with
a downhole location closer than 200 feet from the exterior boundaries of the Application
lands (with the exception of the Ten Acre Pilot Lands contiguous to the
Application Lands) without exception being granted by the Director of the Oil
and Gas Conservation Commission. The
application was not intended to result in more than one (1) well site or
multi-well sites per forty (40) acre nominal governmental quarter-quarter
section (except as previously authorized by Commission Order), nor did the
application request approval for additional wells that would result in more
than one (1) well site or multi-well sites per forty (40) acre nominal
governmental quarter-quarter section within existing drilling units (except as
previously authorized by Commission Order).
Although it was not required, the application included plans to protect
public health, safety, and welfare, and the environment.
Township 6 South, Range 94 West, 6th
P.M.
Section 10:
N½ SE¼
Section 11:
S½ NW¼, N½ SW¼, SE¼ SW¼
Section 14:
E½
Section 15:
All
Section 16:
S½, W½ NE¼, E½ NW¼
Section 17:
SW¼ SW¼
Section 18:
SE¼ SE¼, W½ SE¼
Section 20:
S½ NE¼, E½ SE¼, W½ W½
Section 21:
N½ NE¼, SW¼ NE¼, S½ NW¼, S½
Section 22:
N½, SW¼, W½ SE¼
Section 27:
S½ NW¼, NE¼ NW¼, W½ SW¼, NW¼ NE¼
Section 28:
NE¼, N½ NW¼, E½ SE¼
Section 29:
N½ NE¼, NE¼ NW¼
Township 6 South, Range 95 West, 6th
P.M.
Section 26:
S½ SW¼
Section 27:
S½ SW¼, SW¼ SE¼
Section 28:
S½ SE¼, E½ W½
Section 31:
SE¼ SE¼
Section 32: SW¼, N½ SE¼, SW¼ SE¼, SE¼ NE¼
Section 33: S½, NE¼, NE¼ NW¼, SW¼ NW¼
Section 34:
All
Section 35:
N½ NW¼, SW¼ NW¼, NW¼ NE¼
Township 6 South, Range 96 West, 6th
P.M.
Section 17:
E½
Section 20:
N½, SE¼, E½ SW¼
Section 23:
SW¼ SW¼
Section 27:
NE¼ NE¼, S½ NE¼, N½ SE¼, SW¼ SE¼, S½ SW¼
Section 28:
SW¼, S½ SE¼, S½ NW¼
Section 29:
NE¼, NE¼ NW¼, E½ SE¼
Section 31:
S½ NE¼, N½ SE¼
Section 32:
W½ NE¼, NE¼ NE¼, SE¼ NW¼, NW¼ SE¼, SW¼ NW¼, N½ SW¼
Section 33:
N½ NW¼, SE¼ NW¼, N½ NE¼, SW¼ NE¼
Section 34:
SE¼, E½ SW¼, SW¼ SW¼, N½ NW¼, SE¼ NW¼, NW¼ NE¼
Section 35:
SW¼ SW¼, SE¼ SE¼
Section 36:
SW¼, W½ SE¼
Township 7 South, Range 95 West, 6th
P.M.
Section 5:
NW¼ NW¼
Section 6:
E½ NW¼, W½ NE¼, NE¼ NE¼
Township 7 South, Range 96 West, 6th
P.M.
Section 1:
S½ N½, N½ NW¼, N½ S½, NW¼ NE¼, SE¼ SW¼, S½ SE¼
Section 2:
N½, SW¼, W½ SE¼, NE¼ SE¼¼
Section 3:
NE¼
Section 4:
NE¼ NE¼
19. Testimony and exhibits presented at the administrative
hearing showed the proposed ten (10) acre
density application lands in the
20.
Testimony and exhibits presented at the administrative hearing showed
the geologic development in the area, and that the Williams Fork Formation consists
of many vertically stacked, fluvial, and meander belt point bar sand bodies
that are discontinuous and compartmentalized across the Application Lands. Additional testimony indicated that wells
drilled under setbacks equivalent to ten (10) acre density intersect very few,
if any, of the same sand bodies, and that only gas from the sand bodies that
are intersected by a well is produced into the well. Further testimony indicated that even under
ten (10) acre density there are many partially drained and undrained gas
reservoirs left in place.
21. Testimony
and exhibits presented at the administrative hearing utilized findings
from the Multiwell Experiment project which described the abundant natural
fracture systems in the Williams Fork Formation and showed that these systems
do not communicate vertically. Williams
Fork Formation point bar sand bodies are naturally isolated from each other,
and drainage from a well is limited to the aerial extent of the point bar sand
bodies. Additional testimony indicated
that waste will occur if ten (10) acre density is not approved for the
Application Lands.
22. Testimony and exhibits presented at the
administrative hearing showed that in general, the ten (10) acre density wells
performed as well as in the Grand Valley Field, or better in the Rulison Field
than the forty (40) acre density wells and the twenty (20) acre density wells
after taking out the wells that were affected by direct fracture orientation.
23. Testimony and exhibits presented at the
administrative hearing indicated that the gas in place is one hundred five
(105) BCF per 640-acres for the Grand Valley Field, one hundred twenty (120)
BCF per 640-acres for the Parachute Field, and one hundred thirty-five (135)
BCF per 640-acres for the Rulison Field.
Additional testimony indicated an average recovery on ten (10) acre well
density of seventy-nine percent (79%) in the Grand Valley Field, eighty percent
(80%) in the Parachute Field, and seventy-eight percent (78%) in the Rulison
Field.
24. That the proposed density will allow more
efficient drainage, will prevent waste, will not violate correlative rights and
will assure a greater ultimate recovery of gas and associated hydrocarbons.
25. No protests to the application have been filed with the
Commission or the Applicant.
26. WPC agreed to be bound by oral order of the
Commission.
27. Based on the facts stated in the verified
application, having received no protests and having been heard by the Hearing
Officer who recommends approval, the Commission should enter an order to allow
additional wells to be drilled for the production of gas and associated
hydrocarbons from the Williams Fork Formation of the Mesaverde Group, the
equivalent of one (1) well per 10 acres for the lands described in Finding No.
18 above. The NE¼ NE¼ of Section 4,
Township 7 South, Range 96 West, 6th P.M. should be constituted as a
40-acre drilling and spacing unit for the Williams Fork Formation and the
permitted downhole location for each new Williams Fork Formation well drilled
upon the Application Lands should be located anywhere within a given drilling
and spacing unit but no closer than 100 feet from any boundary of a drilling
unit without exception being granted by the Director of the Oil and Gas
Conservation Commission. No new Williams
Fork Formation well should be drilled with a downhole location closer than 200
feet from the exterior boundaries of the Application lands (with the exception
of the Ten Acre Pilot Lands contiguous to the Application Lands) without
exception being granted by the Director of the Oil and Gas Conservation
Commission. The order should not result
in more than one (1) well site or multi-well sites per forty (40) acre nominal
governmental quarter-quarter section (except as previously authorized by
Commission Order), nor should the order result in additional wells that would
result in more than one (1) well site or multi-well sites per forty (40) acre
nominal governmental quarter-quarter section within existing drilling units
(except as previously authorized by Commission Order).
ORDER
NOW, THEREFORE, IT IS ORDERED, that
additional wells are hereby allowed to be drilled for the production of gas and
associated hydrocarbons from the Williams Fork Formation of the Mesaverde
Group, the equivalent of one (1) well per 10 acres for the lands described
below (“Application Lands”):
Township 6 South, Range 94 West, 6th
P.M.
Section 10:
N½ SE¼
Section 11:
S½ NW¼, N½ SW¼, SE¼ SW¼
Section 14:
E½
Section 15:
All
Section 16:
S½, W½ NE¼, E½ NW¼
Section 17:
SW¼ SW¼
Section 18:
SE¼ SE¼, W½ SE¼
Section 20:
S½ NE¼, E½ SE¼, W½ W½
Section 21:
N½ NE¼, SW¼ NE¼, S½ NW¼, S½
Section 22:
N½, SW¼, W½ SE¼
Section 27:
S½ NW¼, NE¼ NW¼, W½ SW¼, NW¼ NE¼
Section 28:
NE¼, N½ NW¼, E½ SE¼
Section 29:
N½ NE¼, NE¼ NW¼
Township 6 South, Range 95 West, 6th
P.M.
Section 26:
S½ SW¼
Section 27:
S½ SW¼, SW¼ SE¼
Section 28:
S½ SE¼, E½ W½
Section 31:
SE¼ SE¼
Section 32: SW¼, N½ SE¼, SW¼ SE¼, SE¼ NE¼
Section 33: S½, NE¼, NE¼ NW¼, SW¼ NW¼
Section 34:
All
Section 35:
N½ NW¼, SW¼ NW¼, NW¼ NE¼
Township 6 South, Range 96 West, 6th
P.M.
Section 17:
E½
Section 20:
N½, SE¼, E½ SW¼
Section 23:
SW¼ SW¼
Section 27:
NE¼ NE¼, S½ NE¼, N½ SE¼, SW¼ SE¼, S½ SW¼
Section 28:
SW¼, S½ SE¼, S½ NW¼
Section 29:
NE¼, NE¼ NW¼, E½ SE¼
Section 31:
S½ NE¼, N½ SE¼
Section 32:
W½ NE¼, NE¼ NE¼, SE¼ NW¼, NW¼ SE¼, SW¼ NW¼, N½ SW¼
Section 33:
N½ NW¼, SE¼ NW¼, N½ NE¼, SW¼ NE¼
Section 34:
SE¼, E½ SW¼, SW¼ SW¼, N½ NW¼, SE¼ NW¼, NW¼ NE¼
Section 35:
SW¼ SW¼, SE¼ SE¼
Section 36:
SW¼, W½ SE¼
Township 7 South, Range 95 West, 6th
P.M.
Section 5:
NW¼ NW¼
Section 6:
E½ NW¼, W½ NE¼, NE¼ NE¼
Township 7 South, Range 96 West, 6th
P.M.
Section 1:
S½ N½, N½ NW¼, N½ S½, NW¼ NE¼, SE¼ SW¼, S½ SE¼
Section 2:
N½, SW¼, W½ SE¼, NE¼ SE¼¼
Section 3:
NE¼
Section 4:
NE¼ NE¼
IT IS FURTHER ORDERED, that the NE¼
NE¼ of Section 4, Township 7 South, Range 96 West, 6th P.M. shall be
constituted as a 40-acre drilling and spacing unit for the Williams Fork
Formation
IT IS FURTHER ORDERED, that the permitted downhole location
for each new Williams Fork Formation well drilled upon the Application Lands shall
be located anywhere within a given drilling and spacing unit but no closer than
100 feet from any boundary of a drilling unit without exception being granted
by the Director of the Oil and Gas Conservation Commission.
IT IS FURTHER ORDERED, that no new Williams Fork Formation well
shall be drilled with a downhole location closer than 200 feet from the
exterior boundaries of the Application lands (with the exception of the Ten
Acre Pilot Lands contiguous to the Application Lands) without exception being
granted by the Director of the Oil and Gas Conservation Commission.
IT IS FURTHER ORDERED, that this order shall not result in
more than one (1) well site or multi-well sites per forty (40) acre nominal
governmental quarter-quarter section (except as previously authorized by
Commission Order), nor shall this order result in additional wells that would
result in more than one (1) well site or multi-well sites per forty (40) acre
nominal governmental quarter-quarter section within existing drilling units
(except as previously authorized by Commission Order).
IT IS FURTHER ORDERED, that the following shall be applied
to all new surface wellsites and existing surface wellsites on which new wells
are drilled that will be constructed in the application lands, in addition to
any requirements of applicable existing Commission Rules and Regulations:
Site Specific Reclamation Plan Requirements The operator shall submit a site-specific
reclamation plan along with each Application for Permit-to-Drill, Form 2
("APD") for all wells in the application lands for prior approval by
the Director. The Applicant's "2003 Reclamation Plan" is recognized
and endorsed as a suitable guidance document for wellsite and access road
design, construction, and reclamation in the application lands. The operator
shall provide an informational copy of the APD, the Drill Site/Access Road
Reclamation, Form 2A, and the site-specific reclamation plan to the surface
owner and a complete informational copy of the APD and all other attachments,
including the site-specific reclamation plan, to the Garfield County Local
Governmental Designee ("LGD") at or before the time of filing with
the Director. The Director shall provide
the Garfield County LGD with formal notice of the filing of the APD by
providing a complete copy of the APD and all other attachments, including the
site-specific reclamation plan, to the Garfield County LGD. The operator shall confirm that the
requirement to provide the surface owner with a copy of the APD has been
completed or waived before the Director approves an APD. A copy of the approved APD, including any
conditions of approval, shall be provided by the Director to the Garfield
County LGD and to the operator. The
operator shall provide a copy of the approved APD, including any conditions of
approval, to the surface owner prior to commencement of operations with heavy
equipment. The provisions of the
site-specific reclamation plan may be attached as conditions of approval for
the Permit-to-Drill. The discretionary
provisions of the plan should be structured according to the outline shown in
Appendix 1. The plan shall contain the
following mandatory provisions:
Interim and Final Reclamation Goals Considering Surface Owner Input
Schedule and Milestones for Reclamation
Revegetation Reference Areas The operator shall
identify the revegetation reference areas and provide a description,
photographs and a location map.
Soil Horizons
The operator shall conduct a high
intensity soil survey by mapping, sampling, and analysis and describe methods
that were used for this determination.
For wellsites where the operator has conducted high intensity soil
surveys under previous Commission orders, such surveys shall fulfill this
requirement.
Wellsite Diagrams Cut and fill diagrams for
construction of wellsite, including cross sections and plan views with
topographic contours.
Site
map showing the location of the wellbore, drilling and completion pits, access
road, soil stockpiles, and layout of drilling and completion equipment.
Interim
reclamation diagrams showing wellsite layout for life of well, including
fencing, reclaimed and unreclaimed areas, and layout of production facilities.
Final
reclamation diagrams showing the former wellsite after plugging and abandonment
of the well including cross sections and plan views.
Favorable Growth Medium Requirements A minimum of
twelve (12) inches of favorable growth medium shall be reapplied during interim
and final reclamation of non-crop land.
If this quantity of material is not available, existing soils shall be
treated with amendments and fertilizer to create a favorable growth
medium. Rocks greater than eight (8)
inches in diameter shall not make up more than ten percent (10%) of the
favorable growth medium.
Mulching Requirements All wellsites, access
roads, and flowline and gathering line rights-of-way shall be mulched
immediately after seeding with a weed-free straw or other type of weed-free
mulch.
Fencing Requirements Wellsites shall be fenced to ensure success of
interim and final revegetation. Once
revegetation has been shown to be successful, fencing may be removed.
Site Slope and Recontouring Requirements
Steep Slope Restriction To maintain site
stability and productivity, surface disturbance for oil and gas wellsites shall
not be allowed on slopes greater than fifty percent (50%).
Interim Reclamation All disturbed areas not
reasonably needed for production operations, including wellsites, flowline and
gathering line rights-of-way and access roads, shall be recontoured by placing
fill material back into cut areas to approximate original contours. Slopes shall be recontoured to minimize areas
that exceed a 3:1 slope. Any areas
exceeding the 3:1 slope criteria or highwalls shall be reclaimed using enhanced
stabilization and erosion prevention methods. Areas recontoured during interim reclamation
shall be reseeded with the intent of establishing vegetation suitable for final
reclamation.
Final Reclamation Additional disturbance of native
or previously reclaimed areas shall be minimized. Recontouring shall not be required in areas
that have been successfully reclaimed. Slope
requirements shall be the same as those for interim reclamation.
Reclamation Success Monitoring And Revegetation Inspections The operator shall hire a third party contractor
to monitor and inspect until interim and final reclamation and revegetation
efforts meet or exceed ninety percent (90%) of the desirable plant cover found
on the previously identified and approved reference areas and meet the 1000
Series Rule requirements.
The
operator shall submit a written report on the success of the reclamation and
revegetation to the Director on an annual basis by December 31st of
each year. This report shall include
photographs of each site and the reference areas, and discussion of any
additional work required to achieve the 90 percent (90%) plant cover and other
reclamation requirements.
Sanitary Facilities Requirements All operator and
contract personnel are required to use self-contained sanitary facilities while
conducting oil and gas operations in the application lands.
Spill Reporting To Surface Owners In the event of a
spill of E&P waste or any hazardous substance, the operator shall
immediately notify the surface owner(s) of the land(s) where the spill occurred
and any adjacent lands that may be impacted of the quantity, location, and type
of substance released. Surface owners
shall be notified in writing if telephone or other verbal communication is unsuccessful.
Surface Casing Setting Depth and Shoe Integrity Requirements The requirements in the COGCC staff documents
"Notice to All Operators Drilling Williams Fork Formation Wells in
Garfield County, Surface Casing Depth and Modification of Leakoff Test
Requirements" dated July 24, 1998, and "Notice to All Operators Drilling
Williams Fork Formation Wells in the Grand Valley Field, Garfield County,
Surface Casing Depth Requirements" dated August 9, 1998 are hereby adopted
as they apply to the application lands.
The
operator shall perform a surface casing shoe integrity test on all wells
drilled within the application lands. Each surface casing shoe integrity test shall
be designed to test the drilled out surface casing shoe to a pressure
equivalent to the hydrostatic pressure exerted by a full column of mud with the
maximum mud weight anticipated during the drilling of the well plus an
additional one-half (1/2) pound per gallon. The maximum mud weight anticipated during the
drilling of the well for the purpose of the surface casing shoe integrity test
shall be determined for each well by the operator. If at any depth during the drilling of the
well the actual mud weight exceeds the anticipated mud weight used for the
surface casing shoe integrity test, the operator shall be required to set and
cement a string of either intermediate casing or production casing at that
depth.
The
operator shall report the results of the surface casing shoe integrity test,
including the mud weight used, the pressure applied, and the total calculated
mud weight equivalent, to the Director via facsimile or e-mail within
twenty-four (24) hours of conducting the test. The report shall not be required if the
surface casing shoe integrity test is witnessed by a COGCC representative.
Loss of Well Control Notice to Residents In the event of a surface or subsurface loss
of well control, the operator shall notify all residents within one (1) mile of
the well as soon as possible. The
residents shall be notified in writing if telephone or other verbal
communication is unsuccessful.
Wildlife Requirements The operator shall
notify the Colorado Division of Wildlife ("CDOW") of the location of
any proposed additional wellsites and advise the Director of the date such
notice was provided. If the Director
receives comments from the CDOW within ten (10) days of the date notice was
provided, such comments may be considered in applying conditions to any APD. The Applicant's 2003 Wildlife and Wildlife
Habitat Protection Plan is recognized and endorsed as a suitable guidance
document for wildlife.
Water Well Sampling Requirements The operator shall
select for sampling six (6) water wells or springs located within or in close
proximity to the area of drilling activity planned for each year. A list of the selected wells or springs shall
be submitted to the COGCC by January 31st of that year. Each well or spring to be sampled shall be no
further than one (1) mile from the perimeter of that year's drilling activity. If fewer than six (6) wells or springs exist
within one (1) mile of the year's drilling activity the operator shall sample
all such wells and springs. For water
wells or springs where the operator has conducted sampling under previous
Commission orders, such sampling shall fulfill this requirement.
The
water samples shall be tested for benzene, toluene, ethyl benzene, and xylenes,
methane, major cations and anions, TDS, iron and manganese, nitrates, nitrites,
pH, presence of bacteria, specific conductance, and hydrogen sulfide.
The
initial baseline testing shall occur prior to the drilling of the proposed
additional wells. Within one (1) year
after completion of the proposed additional wells, a "post
completion" test shall be performed for the same parameters above and
repeated three (3) and six (6) years thereafter. If no significant changes from the baseline
have been identified after the six (6) year test, then no further testing shall
be required. Additional "post
completion" test(s) may be required if changes in water quality are
identified during follow-up testing. The
Director may require the operator to conduct further water well sampling at any
time in response to complaints from water well owners.
If
free gas or a methane concentration greater than 2 mg/L is detected, then a
sample of the gas shall be collected and analyzed for composition and the ratio
of stable carbon isotopes in the methane to determine gas type (thermogenic,
biogenic or mixture). If the testing
results indicate biogenic gas, then no further isotopic testing shall be
required. If the results indicate
thermogenic gas or a mixture of biogenic and thermogenic gas, the operator and
the Director shall determine an investigation strategy to determine the source
of the gas.
Copies
of all test results described above shall be provided to the COGCC,
Air Emission Requirements The operator shall install emission control equipment on
production facilities located within one thousand (1,000) feet of an occupied
building or in response to an odor complaint investigation that identifies an
offending facility greater than one thousand (1,000) feet from an occupied
building.
ADDITIONAL REQUIREMENTS
Annual Drilling Plan The operator shall provide the
Director and the Garfield County LGD a projected calendar year drilling plan
prior to December 1st of each preceding year. The operator shall not be bound by this plan
which would be expected to be adjusted in response to changes in product prices,
rig availability, corporate priorities and other factors.
Onsite Inspections The Director shall conduct an
onsite inspection: for any new wellsite whenever the operator and surface owner
have not entered into a surface use agreement specifically addressing the
proposed wellsite and access road; whenever the surface wellsite is proposed to
be located within any subdivision that has been approved by Garfield County; or
when ever the LGD believes that a significant adverse environmental impact or
adverse impact to public health, safety and welfare may occur and requests an
onsite inspection within ten (10) days from the day the Director sends the APD
to the LGD per Rule 303.d. The Director
may also conduct an onsite inspection to investigate conditions that threaten
to cause a significant adverse environmental impact or that threaten to
adversely impact public health, safety and welfare. The Director shall report any onsite
inspections conducted at the monthly Commission hearing following the date on
which any onsite inspection was conducted.
When
the Director conducts an onsite inspection, the Director shall invite
representatives of the surface owner, the operator, and LGD to attend. The Director shall attempt to select a
mutually acceptable time for the representatives to attend. The inspection shall be conducted within thirteen
(13) days, or as soon as practicable thereafter, of the date on which the APD
is received by the COGCC.
Site-Specific Drilling Permit Conditions of Approval Following the onsite inspection, the Director
shall apply appropriate site-specific drilling permit conditions of approval,
if necessary, to prevent or mitigate public health, safety and welfare or
significant adverse environmental impacts taking into consideration cost-effectiveness
and technical feasibility and relevant geologic and petroleum engineering
conditions as well as prevention of waste, protection of correlative rights,
and promotion of development. The
Director shall carefully consider any relevant input from the surface owner and
Examples
of the types of impacts and conditions of approval that might be applied if
determined necessary by the Director include (this list is not prescriptive or
all inclusive):
a.)
visual or aesthetic impacts - moving the proposed surface wellsite or access
road to take advantage of natural features for screening; constructing artificial
features for screening
b.)
surface impacts - moving or reducing the size, shape, or orientation of the
surface wellsite or access road to avoid disturbance of natural features or to
enhance the success of future reclamation activities; using an existing surface
wellsite or access road to avoid the impacts of new construction; using a
closed drilling fluid system instead of reserve pits to avoid impacts to
sensitive areas; directional drilling from an existing surface wellsite
c.)
noise impacts - locating or orienting motors and compressors used in drilling,
hydraulic fracturing, well completion, and production operations to reduce
noise; installing sound barriers to achieve compliance with COGCC rules
d.)
dust impacts - watering roads as necessary to control dust during drilling and
completion operations
e.)
ground water impacts - collecting and analyzing water and gas samples from
existing water wells or springs; installing monitoring wells, collecting
samples, and reporting water, gas and pressure data
f.)
safety impacts - installing security fencing around wellheads and production
equipment
g.)
wildlife impacts - limiting drilling and completion operations during certain
seasonal time periods when site-specific conditions warrant
h.)
financial assurance - requiring additional financial assurance for sites with
difficult reclamation conditions or if repeated reclamation attempts have been
unsuccessful
If
the operator objects to any of the conditions of approval for the
Permit-to-Drill, the Director shall suspend the APD and properly notice and set
the matter for the next regularly scheduled Commission hearing at which time
the Commission may determine conditions of approval for the Permit-to-Drill. The surface owner and
Hearing to Address Impacts If the Director has
reasonable cause to believe that any existing or proposed oil and gas
operations are causing, or are likely to cause, public health, safety and
welfare or significant adverse environmental impacts within COGCC jurisdiction
that may not be adequately addressed by COGCC rules or orders, the Director may
properly notice and set the matter for the next regularly scheduled Commission
hearing to request an order for appropriate investigative or remedial action.
APPENDIX 1 RECLAMATION PLAN
- OUTLINE OF DISCRETIONARY PROVISIONS
AFFECTED
COMMUNITIES/HABITATS
PREDISTURBANCE
INVENTORY AND SITE PLANNING
Wellpad and Facility Site Construction, Roads, Pipelines
TOPSOIL AND SUBSOIL
DETERMINATION AND SALVAGE
SOIL STOCKPILING
TEMPORARY REVEGETATION
EFFORTS
SOIL AMENDMENTS AND
FERTILIZERS
STABILIZATION AND INTERIM
RECLAMATION
TOPSOIL AND WETLAND SOIL
REPLACEMENT
FACILITY AND STRUCTURE
REMOVAL
BACKFILLING, GRADING, AND
RECONTOURING
SEEDBED PREPARATION/SOIL
TILLAGE
SEEDING METHODS AND TIMES
SEED MIXTURES
EROSION CONTROL BLANKETS
OTHER SPECIAL PROVISIONS
FOR EROSION CONTROL
WEED CONTROL PLAN
DESCRIPTION OF PROVISIONS
TO MEET MANDATORY REQUIREMENTS FOR FAVORABLE GROWTH MEDIUM, MULCHING, FENCING,
SLOPES AND RECONTOURING
IT IS FURTHER ORDERED,
that the provisions contained in the above order shall become effective
forthwith.
IT IS FURTHER ORDERED, that the
Commission expressly reserves its right, after notice and hearing, to alter,
amend or repeal any and/or all of the above orders.
ENTERED this day of April 2003, as of
OIL AND GAS
CONSERVATION COMMISSION
OF THE
STATE OF
By
Patricia C. Beaver, Secretary
Dated at