A nonprofit organization that conducts voluntary reviews of state oil and natural gas regulations has made a few minor recommendations for Colorado's hydraulic fracturing (fracking) regulations, but concluded that the program is well managed and contains some strengths the shale gas industry would find noteworthy.
In its 33-page report, the State Review of Oil and Natural Gas Environmental Regulations (STRONGER) said its eight-member review team and other observers were given unfettered access to staff of the Colorado Oil and Gas Conservation Commission (COGCC) for its study from June to September.
"The review team has concluded that the Colorado program is well managed and professional and generally meets the 2010 Hydraulic Fracturing Guidelines," the report said. "The review team identified a number of program strengths that warrant special recognition [and] also made some specific recommendations for improvement in the program based on the guidelines."
STRONGER lauded the COGCC for enacting Rules 205 and 341, which respectively require operators to inventory chemicals kept at well sites during operations, and to monitor and record bradenhead annulus pressure during fracking operations, with operators reporting readings greater than 200 psig to the state agency.
The two rules, STRONGER noted, "[allow] government officials and medical professionals to investigate and address allegations of chemical contamination associated with [fracking]," and also "help to ensure that groundwater is protected and that prompt action is taken if conditions arise that could lead to the subsurface release of [fracking] fluids."
COGCC also received high marks for its management staff and website, and for conducting its own in-house review of fracking regulations in 2008.
But STONGER did recommend that Colorado enact minimum and maximum surface casing depths, and said the state should meet with stakeholders to discuss the issue.
"The setting of surface casing to an appropriate depth is critical for meeting anticipated pressures and for protecting fresh water aquifers," the report said. "The recommended review should include a determination of the percentage of surface casing depths determined on the basis of existing water well depths, oil and gas well electric logs, area aquifer studies, or a combination of these sources of information. Additionally, this review should determine the percentage of wells in which the surface casing is set through the base of the freshwater aquifer."
The nonprofit also came across some potential notification issues.
"In some areas, but apparently not all, conditions of approval on drilling permits require notification to the inspector before the commencement of [fracking] operations," STRONGER said. "It is not clear whether and how the inspector is notified of [fracking] operations on a well that is being recompleted. [We recommend] that COGCC review its notification requirements to ensure they are sufficient to allow for the presence of field staff to monitor hydraulic fracturing operations."
STRONGER also recommended that the COGCC and the state Division of Water Resources (DWR) work together to find water sources for fracking. The nonprofit found more than 50% of flowback water from wells in the state was being recycled, and 290 Class II disposal wells were in operation to handle the remainder.
"Given the significant water supply issues in this arid region, this project should also include an evaluation of whether or not availability of water for [fracking] is an issue and, in the event that water supply is an issue, how best to maximize water reuse and recycling for oil and gas [fracking]," the report said.
STRONGER has conducted similar reviews of Ohio and Pennsylvania (see Shale Daily, Feb. 7; Daily GPI, Sept. 24, 2010). Both of those state programs were also deemed to be well managed.