Wednesday, March 13, 2013
Dana Mack, PMP, Environmental Assessment
The Colorado Oil and Gas Conservation Commission (COGCC) recently approved groundbreaking new groundwater protection rules that are considered the most robust in the nation. Starting May 1, 2013, Colorado will become the first state in the nation to implement a statewide, mandatory baseline water sampling program for oil and gas companies. The new rules contained under Rule 318A.e(4) require that oil and gas operators sample nearby water wells both before and after drilling activities as a way to ensure that water supplies are unaffected by oil and gas development. The sampling also identifies potential problems in the instance of a groundwater impact. The new rules were approved following months of stakeholder discussions and public hearings involving regulators, industry representatives, and the public. The rules closely resemble the Colorado Oil and Gas Association (COGA) Voluntary Baseline Groundwater Quality Sampling Program recommendations.
Before finalizing the new rules, the COGCC had not promulgated a statewide rule requiring baseline water sampling and monitoring of water wells. However, in 2006, the COGCC passed Commission Rule 318A.e(4), which was an area-specific rule for the Greater Wattenberg Area (GWA) that required baseline water sampling. Rule 318A.e(4) has been amended as part of the new rulemaking to expand the existing water sampling requirements within the GWA but still recognizing the unique conditions in the GWA.
Based on the numerous, existing oil and gas wells in the GWA, new wells are often installed (called “spudding”) in sections where producing wells are present and where groundwater samples have been previously collected. The amended Rule 318A.e.(4)B. requires that operators collect one baseline water quality sample from a source within the governmental quarter section where any new well will be located. If a sample has been collected within that quarter section within the 60 months before spudding, no initial sample is required. If no sampling has taken place in the prior 60 months, Rule 318A.e.(4)D requires operators to take an initial sample within 12 months before setting a conductor pipe in a well or commencing drilling an injection well. Operators must also take a sample between six and 12 months after completing the well.
Both the new statewide baseline sampling and the newly amended GWA rules incorporate a more substantial list of required laboratory analyses. The rules also increase requirements for electronically submitting analytical data to the COGCC.
Contaminants can occur naturally in groundwater (e.g., selenium, methane) and can also be the result of agricultural activity, septic system use, household chemical use/disposal, the age and composition of the plumbing pipes (e.g., lead), or industrial activity. Based on the potential presence of these contaminants, it is important to collect groundwater samples before beginning drilling operations to establish baseline water quality conditions. Additional testing following drilling and completion activities is similarly important to monitor for possible changes in water quality or the presence of contaminants over time.
Oil and gas operators need to be prepared to address these requirements. Having a consultant on board who understands the new regulations, who has a broad range of baseline water sampling experience, and who offers a team of experts from basic groundwater sampling to impact analysis will be a key component in successfully managing these new regulations.
The Olsson team is poised to respond quickly to any client request. We have 17 dedicated compliance and remediation personnel located throughout eastern and western Colorado. As part of Olsson’s standard suite of services related to baseline sampling, all field and analytical data obtained for each well sample is entered and retained in a specialty database with correlating GIS maps for easy and on-demand querying. Olsson has strong relationships with several specialty well contractors and industry leading geochemists whom we can consult if any constituent issues arise.
Olsson provides its clients with the best long-term value of any other environmental compliance and remediation team in the region, and we’ve been providing water sampling services for oil and gas clients for over 10 years. The senior team at Olsson has been providing a variety of environmental services to the oil and gas industry in Colorado for more than 30 years and has intimate knowledge of the evolution of oil and gas regulations in the state.