DENVER — Tuesday, Feb. 13, 2018 — The Colorado Oil and Gas Conservation Commission (COGCC) today approved comprehensive new regulations addressing oversight of flowlines and related infrastructure associated with oil and gas development.
The nine-member commission unanimously approved the updated regulations following three days of testimony from the public, local governments, homebuilders, citizen groups, trade associations and members of the oil and gas industry on more than 20 pages of proposed new and amended rules.
“We believe these new rules are another important step in the aftermath of the Firestone tragedy,” said Governor John Hickenlooper. “State government and local municipalities depend on the commitment that industry is doing everything to to keep our communities safe.”
The flowline rules take numerous steps to strengthen requirements for design, installation, maintenance, testing, tracking and abandoning flowlines. Flowlines describe the kinds of pipelines that most typically move fluids around specific oil and gas development locations from wells to separators to storage tanks or to larger pipelines.
The new rules include dozens of changes and improvements to flowline oversight, including:
Requirements for more detailed tracking, location data and record-keeping for flowlines that carry fluids away from a specific oil and gas location, such as lines that may travel from a well to a storage tank not co-located on the same wellpad, or to a gathering line. The rule permits COGCC to share resulting, more specific geospatial information with local governments through a confidentiality agreement.
Requirements that any flowlines not in use – but not yet abandoned – are locked and marked. All such lines must continue to undergo integrity testing under the same standards as active lines until abandonment. Any risers associated with abandoned flowlines must be cut below grade. This rule change makes permanent the post-Firestone order to eliminate above-ground risers connected to abandoned flowlines.
More detailed requirements for operators to demonstrate flowline integrity, including updated standards for integrity-testing lines, more testing options that align with newer technology, and the elimination of pressure-testing exemptions for low pressure lines.
Requirements for full operator participation in the Utility Notification Center of Colorado’s “one-call” program to ensure a centralized home for all data on flowline locations and access to that information through the established 811 “call-before-you-dig” system.
The new flowline rules and enhanced participation by operators in 811 include three key components of state actions outlined by Gov. Hickenlooper following a three-month review of oil and gas operations last year. The review followed the home explosion in Firestone last April that killed two people and injured a third.
“Our work with operators last spring and summer to identify, quantify and test all flowlines near residential areas was a significant start,” said COGCC director Matt Lepore. “These rules – and additional actions ordered by the Governor that are still unfolding – continue to keep our focus on this work.”
The final draft of the proposed rules can be found here, and an overview of the COGCC’s basis and purpose for the rules here. The latter provides context and analysis for the rulemaking. All documents associated with the rulemaking, including formal statements from parties to the hearing, are housed here.
The Commission also directed COGCC staff to empanel a stakeholder group representing a cross-section of interests to review current and developing instrument-based technologies and methods for preventing or detecting leaks and spills from flowlines. COGCC staff will present to the Commission quarterly on the group’s progress with a final presentation of the results of the stakeholder group’s study, along with any associated recommendations for changes to COGCC’s policies or rules, within a year.
The flowline rulemaking is the latest in a consistent and long-running effort to strengthen the regulatory oversight of the COGCC, dating to 2008.
The COGCC, under the Hickenlooper Administration, has crafted rules to increase distances between drilling and neighborhoods; reduce the effects of light, noise and odors; protect groundwater; reduce air emissions in partnership with the Colorado Department of Public Health and Environment; disclose hydraulic fracturing chemicals; tighten requirements for spill reporting; significantly elevate penalties for operators violating Commission rules; toughen requirements for operating in floodplains; and amplify the role of local governments in siting large operations near communities.
The Commission has also significantly expanded inspection, engineering, reclamation, and environmental staff; increased ease of access and the volume of data available to the public; intensified collaboration with local governments; sponsored ongoing studies to increase understanding of impacts to air and water; and adopted several formal policies to address health, safety, and environmental issues brought about by new technologies, all while experiencing an unprecedented increase in oil and gas development in Colorado.