The COGCC Integrity Group has both engineering and inspection personnel to ensure flowlines meet Colorado regulations.Flowline Integrity refers to the design, construction, operation, maintenance and repair parameters necessary to make a flowline compatible with the fluids being transported, allow it to withstand anticipated operating conditions, and prevent failure. Flowline regulations are contained in the Colorado Oil and Gas Conservation Commission’s (COGCC) 1100 series rules. In many cases flowlines are considered the safest method of transporting water, oil and gas. Flowlines are those pipelines that start at the wellhead and move produced fluids to well site production facilities, remote production facilities, or that connect to larger transportation pipelines regulated by other government entities. Detailed Flowline definitions can be found in the 100 Series Rules.
The Integrity Group conducts reviews on all Off-Location Flowlines, Produced Water Transfer Systems, Crude Oil Transfer Systems, and Domestic Taps registered in Colorado via Form 44 Flowline Report. The COGCC requires Geographic Information System (GIS) data that includes the flowline path and other attributes such as the pipe diameter, fluids transferred, and pipe material for all existing Off-Location Flowlines, Produced Water Transfer Systems, and Crude Oil Transfer Systems. The Integrity Group also requests the operators provide the status of each line segment in the GIS data set that indicates if the line is active, out of service, or abandoned.
The Integrity Group performs field inspections during flowline construction, repair, and abandonment. During these inspections flowline pressure test and construction methods are observed for compliance with COGCC rules. The Integrity Inspectors and/or Engineering staff complete a field inspection report, which is electronically sent to the operator after the inspection. The report may require an operator to take actions to correct instances of non-compliance and may refer more serious alleged violations to the Hearings Unit for enforcement.
The Integrity Group conducts reviews related to the registration, modification, and change of operatorship of gas gathering systems, compressor stations, gas processing plants, and underground gas storage facilities via the Form 12 Gas Facility Registration Report.
The Integrity Group audits operator’s flowline systems for regulatory compliance. Audits are prioritized based on a data-driven flowline ranking model. Flowline Audits help ensure operators take reasonable precautions to prevent damage to flowlines, prevent failures that cause spills and releases, identify systemic flowline issues, and identify and address instances of non-compliance. COGCC reviews flowline registrations and pressure testing records as part of the audit. Flowline spill reports and maintenance programs are also discussed with the operator, to ensure systems are in place to prevent flowline releases.
The Integrity Group is notified of flowline spills and interfaces with COGCC environmental protection specialists and operators throughout the state to determine the root cause of the release and the mitigations used to prevent future releases. The Integrity Group also receives reports of Grade 1 Gas Leaks from flowlines, which are gas leaks that ignite or represent an existing or probable hazard to people or property and requires immediate repair or continuous action until the conditions are no longer hazardous.
COGCC requires operators to submit pre-abandonment notices at least 30 days prior to abandonment using the Form 44 for Off-Location Flowlines, or using the Form 42 for on-location flowlines. This notice contains the proposed abandonment date and details about the proposed abandonment method. Flowlines must be removed or abandoned in place. Abandonment in place is acceptable if the line meets any of the criteria listed in Rule 1105 d.(2)-(3). Lines abandoned in place must meet the requirements outlines in 1105.e. The Integrity Group interfaces with Environmental Protection Specialists regarding Form 27 Remediation Workplan requirements, if any, when reviewing pre-abandonment notices. Once the abandonment is complete, COGCC requires operators to report it within 90 days. Rule 1105.f. outlines the requirements for abandonment verification. The Integrity Group interfaces with the Engineering Group regarding flowline abandonment that is associated with well abandonment.