HomeMy WebLinkAboutExibit LL - Lisa Dee email dated 06.14.2013Microsoft Office Outlook - Memo Style
1 Tamra Allen From: Dee, Lisa [Lisa.Dee@wpxenergy.com] Sent: Friday, June 14, 2013 11:51 AM To: Tamra Allen Cc: Moss, Brad; Bittner, Tyler; Kirtland, Jeff Subject: GarCo Code Language
Hi Tamra – Happy Friday! I hope you’re having a good day. Please review WPX’s recommendations made below and pass them along to the BOCC for consideration during the hearing next Monday.
I believe Brad Moss, our production manager, will be attending the hearing as well, so we should have a “subject matter expert” available who can provide additional clarity about water
tanks, compression, gas lift etc. Thanks for your help and I look forward to seeing you on Monday. 1. Sensitive Area Survey. A Sensitive Area Survey shall be submitted by a qualified
professional and provide the types and areas of concern within and adjacent to the pipeline right-of-way, including but not limited to sensitive plant and animal populations, wildlife
critical habitat, and Wetlands. The Survey shall provide a method or plan for mitigating identified impacts to these sensitive areas. This submittal requirement does not apply in previously-disturbed
corridors or rights-of-way and/or areas permitted by the COGCC. Overall this language appears to encompass protection measures that are typical for most operators. However WPX recommend
additional language that clarifies the intent and attempts to eliminate potential conflicts with other agencies. Mitigation methods or plans: mitigation is a bit of a soft science,
much like viewshed protection. It also takes on a variety of meanings across agencies, operators and the general public. WPX recommends that the county clarify the language by requesting
that we commit to complying with any state or federal protection measures for sensitive plant and animal populations, as defined by BLM, CPW and USFWS. Since these applications will
be referred to agencies such as CPW, the reality is that any protection/mitigation measures will come from the referral agencies or from surface owner requests. Tiering the definition
of sensitive plant and animal populations to those defined by BLM, USFWS and CPW should eliminate the potential for misinterpretation. As far as protection of sensitive areas such
as wetlands, WPX recommends clarifying that these protection measures consist of compliance with SPCC, SWMP, local watershed district permits, and ACE 404 permits. This would eliminate
the enforcement issues that Chairman Martin referenced in the last hearing, while still offering local protection of wetlands and water bodies. WPX recommends the following revisions.
1. Sensitive Area Survey. A Sensitive Area Survey shall be submitted by a qualified professional and provide the types and areas of concern within and adjacent to the pipeline rightof-way,
including but not limited to sensitive plant and animal populations and wildlife critical habitat as defined by BLM, USFWS, and CPW, and Wetlands and waterbodies as defined by US ACE..
The Survey shall provide a method or plan for mitigating compliance with protecting required protection measures identified by these agencies impacts to these pertaining to the identified
sensitive areas.
2 This protection plan should demonstrate compliance with state and federal laws as applicable, and should incorporate requirements of the surface owner, as applicable. This submittal
requirement does not apply in previously-disturbed corridors or rights-of-way and/or areas permitted by the COGCC. WPX also recommends modification of the definitions listed below. We
look forward to continued dialogue with County Staff, the BOCC and the general public: Compressor, Booster: Typically consist of a single compressor unit located on an existing well
pad and are generally skid mounted. Multi-well pads may require additional Booster Compressor Units. Booster Compressors are commonly used to create the same gas velocity that existed
earlier in the life of the well or for a new well. WPX Energy supports reinstatement of this definition into the code. As discussed in last week’s hearing, “Compression” is a term
that encompasses a broad spectrum of facilities, and therefore means different things to different people. The typical “gas lift” or “booster” compression is typically quite different
from the large compressor stations located throughout the valley floor that support gas pipelines. Elimination of this definition could create a “one size fits all” type approach that
does not account for the vast differences between gas lift compression and gas pipeline compression. COGCC definitions may be helpful. Booster compression is included in the COGCC
definition of Production Facilities: All storage, separation, treating, dehydration, artificial lift, power supply, compression, pumping, metering, monitoring, flowline and other equipment
directly associated with oil wells, gas wells or injection wells. Injection Well, Served by Pipeline. A vertical pipe in the ground into which water, other liquids, or gases that are
transported to the site through a pipe system are pumped or are allowed to flow. The injection well shall include production equipment, as approved and regulated by the COGCC, required
for operation of that injection well including (as appropriate) pump equipment required to move water or gas downhole, filtering equipment, and adequate tankage required for cleaning
and processing water prior to injection. The thought here is that the amount of “adequate tankage required for cleaning and processing water prior to injection” will be negotiated
by the Working Group. This would also exclude large storage volumes from being authorized via use by right. For our purposes, WPX recommends a tankage threshold for cleaning and processing
of 3,000 BBLS per well or 6,000 BBLS per well pad without elevating the review level,” however we would recommend reconvening the working group before deciding on a firm number. This
threshold would then have to be added to the Use Tables. The COGCC definition of Production Facilities may also be useful here. Production Facilities: All storage, separation, treating,
dehydration, artificial lift, power supply, compression, pumping, metering, monitoring, flowline and other equipment directly associated with oil wells, gas wells or injection wells.
3 Oil & Gas Drilling and Production: Any operation utilizing equipment that advances a borehole into the substrata for the purpose of discovery, development and/or production of oil
or gas that occurs on an approved COGCC site. WPX Energy recommends the following revisions as stated in the previous hearing (I believe this definition is substantially similar to
the recommendation made by Phil Vaughan): Oil and Gas Drilling and Production. Any operation utilizing equipment that advances a borehole into the substrata for the purpose of discovery,
development and/or production of oil or gas including all surface facilities associated with such operations. This activity includes surface or tank produced water and condensate impoundments
as those terms are used by the oil & gas industry. NOTE: COGCC definition of Production Facilities may be helpful here too: All storage, separation, treating, dehydration, artificial
lift, power supply, compression, pumping, metering, monitoring, flowline and other equipment directly associated with oil wells, gas wells or injection wells. Water Impoundment: Surface
storage and water tank storage including wastewater treatment and settling ponds, surface mining ponds, detention and retention ponds, artificial lakes and ponds, and similar water features.
“Water Impoundment” also includes surface or tank produced water and condensate impoundments as those terms are used by the Oil & Gas industry. Classification of tankage as a water
impoundment is potentially disingenuous because individual tanks within a tank battery are not manifolded together so that a release of a single tank causes a release of the entire contents
of the tank battery. For example, a 3,000 BBL tank battery consisting of 6 tanks effectively functions as 6 separate vessels containing 500 BBLs each that are co-located on the same
well pad and within the same battery to minimize impacts and for ease of operation. This concept is reflected in the SPCC regulations, which require that secondary containment be configured
to hold the contents of the largest tank in the battery, less the displaced areas occupied by the surrounding tanks. WPX Energy recommends tiering the COGCC definition of Production
Facilities to avoid enforcement issues. It could be in the best interests of everyone to move away from a “Webster dictionary” definition of impoundment to avoid creating enforcement
/primacy issues. Classification of tankage as a water impoundment has implications with other agencies: The COGCC definition of Production Facilities may be helpful here (see above)
EPA study of Industrial Surface Impoundments clearly refers to an inground type impoundment, not a self-enclosed structure such as a tank Colorado Division of Water Resources 4.2.16
-“Impound Water” means to accumulate water in a reservoir for immediate or future use, including the purpose of flood control and detention.
4 Thanks Tamra! Have a great weekend and I will see you on Monday. Lisa E. Dee Regulatory Specialist Piceance Planning Team WPX Energy Rocky Mountain, LLC Direct: (970) 263-2738 Cell:
(720) 470-4919 Lisa.Dee@WPXEnergy.com <image003.jpg>