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The Daily Sentinel recently published an article highlighting the Exchange's involvement in the Colorado Well Integrity Peer Assessment and how this assessment aided in the rulemaking process. The full article is provided below.
"State oil and gas regulators have released draft rules intended to reduce the possibility of oil and gas wells leaking and causing environmental impacts such as contamination of groundwater.
Colorado Oil and Gas Conservation Commission staff published the draft wellbore integrity rules Dec. 31 on its website, and the commission is scheduled to act on the proposal at its Feb. 26-27 meeting.
The rules rewrite is one of about a dozen that the commission is undertaking to comply with Senate Bill 181, which became law last year and largely rewrote how oil and gas development is to be regulated in the state. While some of the commission’s rulemaking processes are expected to be more contentious, the well integrity rulemaking may prove to be a smoother process. It is the result of a stakeholder process that has involved industry and other interests who came together to develop proposed rules that would largely implement the dozens of recommendations of a peer review conducted last year to look at the COGCC’s wellbore integrity rules. The review was conducted by the oil and gas regulatory officials and technical experts from several states through what’s called the State Oil and Gas Regulatory Exchange.
[Click here to see the full Well Integrity Peer Assessment.]
“I think that (stakeholder process) in and of itself is a great story of collaborating on some technical rules and coming up with something that is great on its face and also workable,” said Adam Peltz, an attorney with the Environmental Defense Fund who has been part of the stakeholder group.
Dan Haley, president and chief executive officer of the Colorado Oil & Gas Association, said in a statement provided to The Daily Sentinel, “We have been working through the recommendations made by the State Oil and Gas Regulatory Exchange (SOGRE) and talking with state regulatory staff and other stakeholders, and we are actively engaged in this rulemaking.”
Peltz said the draft rules respond to basically all the recommendations in the peer review report, and would put Colorado “near or at the head of the class” among states in terms of well integrity rules.
“It has some key policy innovations that are very much nation-leading,” he said. “And it works for industry.”
The rules cover things such as the cement and casing used in constructing wells, plugging of wells, updating of standards for blowout preventer systems, and ensuring that other nearby wells aren’t impacted when a well undergoes hydraulic fracturing.
For Peltz one of the most exciting proposed rules involves monitoring and testing the annular pressure of wells. That’s the space between well casing and the surrounding wellbore, or between strings of casing within a well. High pressure readings can indicate the potential for problems such as leaks.
Currently, annular pressure monitoring, testing and reporting are required in some oil and gas fields in the state, including some in Garfield County. The proposed rules would require monthly annular pressure monitoring of all wells statewide, and more involved pressure tests of them once a year.
“Because this part of the rule applies to all active wells it has an immediate impact on public safety and the environment around the state,” Peltz said.
COGCC data shows there are more than 52,000 active wells in the state, including nearly 12,000 in Garfield County and more than 1,200 in Mesa County.
“The purpose of annual testing is to provide a universal ‘health check’ on every well in the state, to ensure that wellbore integrity is monitored throughout the life cycle of every well,” the COGCC says in a draft document laying out the basis and purpose of the rules proposal.
Peltz said this rulemaking may be going smoothly because the peer review provided an outline to act on and the topic’s technical nature lends itself to engineering solutions, whereas others are more policy-oriented and can be more difficult to hash out. Still, he hopes the experience with this process can provide some goodwill that might help in some of the other more challenging rulemaking processes yet to come.
The COGCC says in its draft document, “The Commission commends this unique cooperation among diverse stakeholders, and encourages all its stakeholders to continue to work together, recognizing that input from stakeholders with a range of perspectives is crucial to developing protective, enforceable, and technically achievable regulations.”"