| Drilling/Completion Operations | Form: (02 )
400660026
10/5/2014 | a. Preferred Option: It is the intent of the County that operators utilize closed-loop or modified closed-loop systems for drilling and completion operations in order to minimize or eliminate the need for earthen pits; however, notwithstanding the foregoing, where appropriate, and subject to prior County approval, the County generally supports: 1) the use of unlined drilling pits when bentonite or a similar clay additive is used during the drilling process, and 2) the use of lined single- or multi-well water storage pits in order to minimize the transport of water and promote recycling, subject to the requirements set forth in this subsection. Permitted modified closed-loop systems include oil and gas wells where air or fresh water is used to drill through the surface casing interval, defined as fifty (50) feet below the depth of the deepest aquifer, and a closed loop system is used for the remainder of the drilling and/or completion or recompletion procedures. Multi-well pits are defined as lined, engineered pits, constructed over an engineered base, with construction or liner specifications meeting or exceeding Commission pit lining rules, that will serve the functions of drilling, completion, and/or flowback pits for more than one well.
b. Water Storage Pits to Contain Fresh Water or Brine Water: Water stored in pits approved by the County and allowed under Commission Rules, must meet the definition of fresh water or brine water, except for water stored in pits listed in 2c below. Fresh water is defined as containing total dissolved solids (TDS) less than or equal to 5,000 milligrams/liter (mg/l). Brine water is defined as water produced from an oil and/or gas well with TDS of greater than 5,000 mg/l. The Operator is required to remove all free and visible oil within 24 hours of discovery. Upon closure of the pit, the Operator will ensure the protection of the public health and environment by following all Commission pit closure rules, including collecting analytical data to ensure compliance with state standards. As long as the pit is open and containing fluid, a representative water sample shall be taken every six months from the surface of the pit fluids, the first sample to be taken within 6 months of the pit becoming operational. Water quality data will also include an analysis of Sodium Adsorption Ratio (SAR). The County will review water quality data provided by the Operator every six (6) months. TDS, pH, and specific conductance can be measured with a field meter. TEPH (total extractable petroleum hydrocarbons), BTEX (Benzene, Toluene, Ethylbenzene, and Xylenes), and SAR will be analyzed by an accredited laboratory. If the presence of TEPH and/or BTEX is indicated after County review and/or inspection, other water quality analyses may be required by the County.
c. Additional Pits that Require County Review and Approval: Skimming, settling, percolation, evaporation, and any type of netted pits are generally discouraged by the County; however such pits may be approved on a case-by-case basis through the Use by Special Review ("USR") process. A copy of the Pit Plan submitted to the Commission will be provided to the County at the same time as the plans are submitted to the Commission. Construction of these pits will be preceded by collection of “baseline” soil samples from the center of the planned pit at 6 and 18 inches depth. Soil samples will be analyzed for pH, Sodium Adsorption Ratio (SAR), and Electrical Conductivity (EC). The Operator shall stake and photograph from the center of the planned pit (toward north, south, east, and west directions) for inclusion in the County’s copy of the Pit Plan. Upon closure of these pits, pH, SAR, EC, BTEX (Benzene, Toluene, Ethylbenzene, and Xylenes), and TEPH (total extractable petroleum hydrocarbons) analyses may be required if there is evidence of leaks or spills in the immediate area of the pits.
d. Pits That Do Not Require County Approval: Flare, Emergency, Plugging, and Workover pits will not require county review or approval prior to construction (unless within 1/4 mile of a residence as set forth below); however, the County will be copied on the notification(s) sent to the Commission and any pit plans, remediation plans, or analytical results submitted to the Commission.
e. Pit Setbacks: All pit construction within ¼ mile of a residence
or water well is generally discouraged by the County and may have additional County requirements, such as fencing. Such pits will be reviewed on a case-by-case basis by the County.
f. Multi-Well Pits: In addition to any requirements stated above, multi-well pits will be lined per the Commission’s lining standards. If a multi-well pit is planned for use over a 2-year or greater period, the pit will be double-lined with leak detection. Fluids stored in multi-well pits will be circulated through a four-phase separator or an API-approved settling tank or similar equipment prior to such fluids entering the pit, specifically designed to remove solids and reduce hydrocarbon content and emissions. Retention time in a settling tank and the volume of the tank must be sufficient to separate out any floating, dissolved, or emulsified hydrocarbon phases. Lined multi-well pits may be inspected and/or reviewed on an as-needed basis, over the life of the pit, to determine if the water to be stored in the pit or already stored in the pit meets the definition of fresh water or brine water. Upon closure of the pit, the Operator will ensure the protection of the public health and environment by following all Commission pit closure rules, including collecting analytical data to ensure compliance with state standards. As long as the pit is open and containing fluid, a representative water sample shall be taken from the surface of the pit every six months. Additional requirements, such as fencing, may be required by the County, pre- or post-construction, if such a pit is determined by the County to be adversely impacting residences, water wells, or wildlife habitats and migrations.
g. Technological Advances: The County may require additional measures, if new technological methods for pit construction or maintenance are developed pre- or post-construction and such methods are technologically sound, economically practical, and reasonably available to the Operator.
3. Berms. Berms shall be inspected by Operator on a weekly basis for evidence of discharge. Berms shall be inspected within 48 hours of a precipitation event.
4. Regular Meetings to Monitor and Discuss MOU Issues. The County and Operator agree to meet quarterly or as necessary, to monitor and discuss any pertinent issues associated with oil and gas facilities within the County.
5. Water Supply and Quality. In an effort to reduce truck traffic, where feasible, the Operator will identify a water source lawfully available for industrial use, including oil and gas development, close to the facility location, to be utilized by Operator and its suppliers. Operator will comply with the Colorado Department of Public Health and Environment requirements concerning water quality. Where feasible, temporary surface water lines are encouraged and will be utilized. Operator may be permitted to utilize County Road Right-of-Way, and County drainage culverts, where practical, for the laying and operation of temporary water li |