Any Air Quality Monitoring required under Article 12 of the Town’s oil and gas regulations would only apply to operations within the Town limits.
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There were many questions posed to the COGCC in particular during this Q&A session. The COGCC requests that interested residents view the responses given live in the meeting, live in the meeting.
The Mae J site is not located within the Town limits so the Town’s regulations and requirement do not apply to sites outside of the Town. Operations at this site are subject to COGCC regulations and inspections and/or any regulations and inspections by Weld County.
Answer from Weld County:
The original permits were considered using the rules and regulations at the time - for both Weld County and the State - and the Operator was issued a valid permit for development. They are currently not subject to re-evaluation.
Answer from Occidental:
Audio, visual, and olfactory (AVO) inspections are completed daily when an operator is on location. Potential leaks are reported to our emissions team to follow-up with an infrared (IR) camera. Weekly AVO inspections are completed by a member of our emissions team. Any detected leaks are recorded, repaired, and re-screened with an IR camera to verify repair. In addition, our Integrated Operations Center monitors the wells from Platteville and is staffed 24/7.
At the end of the well life cycle, we will retire the wells and reclaim the pad to match the existing landscape. This procedure is commonly referred to as plugging and abandonment and is regulated by the Colorado Oil and Gas Conservation Commission (COGCC).
Answer from Occidental:
Local emergency response agencies determine the evacuation distance required to protect the health, safety, welfare, environment, and wildlife resources.
In 2021 we paid approximately $169,000,000 to Weld County in Ad Valorem taxes for our 2020 operations; approximately $24,000,000 of which was designated for Fire Agencies. We are founding members and on the board of the Colorado Preparedness Response Network (CPRN). This is a non-profit, member-owned, oil and gas industry-driven initiative that promotes best management practices and shared resources, with an emphasis on responding to oil and gas emergencies. CPRN develops and fosters relationships between industry and public emergency response organizations to build preparedness, response, recovery, and mitigation solutions.
The Mae J, Papa Jo, and Yellowhammer wells are the last wells we have in the area that are drilled and awaiting the completions phase
Background checks are conducted on all Occidental employees prior to employment. The completions contractors operating at this location are required to conduct background checks on their employees. This process is done in full compliance with the Federal Fair Credit Reporting Act ("FCRA”) requirements.
All water used for the completions locations near Erie will be piped in via our water-on-demand system eliminating an estimated 46,800 truck trips. Wastewater will be removed by truck. We estimate 167 truck trips per day during the completions process. The completions process at each location is expected to last 30 days
We have developed a rigorous process for analyzing and mitigating surface impacts at each of our locations. For the pads near Erie, this includes a quiet completions fleet, sound walls, our water-on-demand system, continuous air quality monitoring, and paved access roads.
Per COGCC rules, baseline water quality samples were collected from nearby water wells prior to drilling the wells. Subsequent water samples will be collected after the completions activity is complete to ensure water quality in the area has not been affected. All water well sample results are provided to the COGCC and can be accessed on the COGCC website.
We contract with a third-party environmental air quality expert to perform continuous air monitoring during the drilling and hydraulic fracturing phases. Please see our air monitoring plan for more details.
Permits expire after three years. In this case, the Weld County WOGLA permit for the MAE J 14-8HZ pad was approved on June 6, 2019. The COGCC 2A was approved on Aug. 9, 2019. Development of the MAE J 14-8HZ pad has commenced and therefore the three-year operations were commenced prior to the expiration of either permit in compliance with local and state rules.
We estimate 167 truck trips per day during the completions process. Truck routes include HWY 52, CR 3, CR 7, and CR 10. The travel distribution to the proposed location is expected to be approximately 50% from the north (HWY 52 to CR 3 or CR 7) and approximately 50% from the east (HWY 1-25 to CR 10).
The walls are designed for noise mitigation. The outer material that is used to reinforce the acoustic material is "emboss" and is fire resistant. The acoustic material is technically ethyl vinyl acetate (EVA) or a mass loaded vinyl.
During the hydraulic fracturing and flowback all produced water will be diverted to enclosed water tanks. After flowback, during the cleanout phase, the water and sand removed from the well is stored in open tanks. The cleanout process lasts approximately 8-10 days and is permitted under new COGCC rules which go into effect on May 1, 2021.
There will be 12 flowlines on the MAE J 14-8HZ pad which will flow from the well heads to the production facility. All flowlines will be mapped in accordance with COGCC regulations.
Halliburton Oilfield Services and Cutters Wireline Service will be providing hydraulic fracturing and wireline services, respectively.
The industrial water pumped through our water-on-demand system will save an estimated 46,800 truck trips avoiding water transportation emissions and the resulting traffic, dust, road wear, and disturbance to stakeholders. The water used in our operations is sourced from multiple locations. As such, it would be inaccurate to identify an exact source(s) that will be used during our operations near Erie.
Please refer to the Fact Sheet.
We utilize an enclosed flowback method. All hydrocarbons and fluids from the well are diverted to enclosed production facilities. Continuous air monitoring will be conducted during the flowback process. Flowback operations are anticipated from March 18 to April 17 for Mae J, and April 12-28 for Papa Jo and Yellowhammer.
You are encouraged to contact the Occidental Response Line at 1-866-248-9577 or email at ColoradoStakeholder@oxy.com.
Other communities near our operations have reported that the completions phase is quieter than the drilling phase. Residents should not expect to hear or feel C-scale noise. Residents will not be able to feel the actual completion operations.
The completions engines are classified as tier four engines, which produce the least amount of emissions. We have contracted with an environmental air quality expert to conduct continuous air monitoring at these three locations during development.
During cold weather situations, water and steam evaporation might be seen from freshwater tanks, and exhaust might be seen from vehicles and engines.
Twelve flow lines will flow from the well head to the production facility location. The size of flow lines is typically two inches in diameter. Flow lines will be constructed from steel pipe, are typically buried 3-7’ deep, and will equal the distance between the well heads and the production facility. All flowlines will be mapped in accordance with COGCC regulations.
Our security team is actively involved with the Northern Colorado and Denver Metro Joint Terrorism Task Force that are staffed by local law enforcement as well as the FBI and Homeland Security.
The locations and monitoring equipment are equipped with cameras and operational alarms.
Our Integrated Operations Center (IOC) is staffed 24 hours per day, seven days per week, 365 days per year. It enables real-time monitoring of the majority of our wells, water tanks, and pipeline system pressures. The IOC enables employees to shut-in many of the wells remotely, and enhances collaboration with local emergency response agencies.
The completions engines are classified as tier four engines, which produce the least amount of emissions. We have contracted with a third-party environmental air quality expert to conduct continuous air monitoring at these three locations during development.
More frequent proximity inspections will be performed according to Table 3 Section II.E.4.e. All leaks will be repaired within five days or equipment will be shut in to repair the leaks where possible. We have an internal emissions team that performs all inspections and completes most of the repairs, so repairs and rescreens are typically complete very quickly. For leaks that cannot be repaired within 5 days and are not eliminated by shutting in equipment, notification will be provided to the CDPHE and local government within seven days of the leak detection.
The facility will not have any natural gas actuated pneumatic controllers, no oil storage tanks, no vapor recovery units or other compressors (other than an electric air compressor for instrument air pneumatics). In addition, there is automation at the facility that allows remote and/or automatic shut ins at facilities when there are instances of high or low pressures or temperatures, when pilots are not lit and when tank pressures are approaching relief points. We have an integrated operations center that is staffed 24/7 to view and respond to automated data.
Communities do not have the legal ability to require another jurisdiction to justify a particular land-use decision made within that other jurisdiction.
Weld County permits are valid for three (3) years, but only expire after that period if construction has not started. Once construction begins, it is then treated as an "active" site. Active sites are then held to conditions and development standards for the life of the Location. Active Locations and their permits do not expire, until the Operator chooses to plug and abandon the location, which can be and usually is multiple years after production begins.
For the Mae J site, the Town could only require the land developer of the Colliers Hill development to comply with the setback requirements from various oil and gas facilities that were in development at the time of the initial land plot within the Colliers development area. Those setback requirements have been met.
We do not have a Town contact for these types of concerns. We would encourage residents to send complaints to the developer of any given well site and to CDPHE if the concerns are health-related.
- Oil and Gas Health Information and Response Program (residents can report health concerns to this program and find information about the community investigations the program has conducted so far, the health risk assessment one resident referenced tonight as well as a glossary of common oil and gas terms): www.colorado.gov/oghealth (direct link to memo about Health Guideline Values available here)
- Air quality monitoring 101 and continuous monitoring 101: https://cdphe.stg.colorado.gov/oil-and-gas-methane-other-hydrocarbons-monitoring-forum
- Sign up for APCD Updates (including oil and gas): https://cdphe.stg.colorado.gov/air-pollution-contacts
- Air Quality Control Commission (AQCC) Regulations: https://www.colorado.gov/pacific/cdphe/aqcc-statutes-and-regulations
- AQCC Website (with rulemaking calendar)- https://www.colorado.gov/pacific/cdphe/aqcc
- Getting Involved in the Rulemaking Process: https://drive.google.com/file/d/1ajTTHzQuJC1obnYmk35x7LV1_3Xe3LqW/view
- Oil and Gas Compliance and Recordkeeping: https://cdphe.stg.colorado.gov/apens-and-air-permits
- Air quality monitoring, modelling, and data (including forecasts and advisories): https://www.colorado.gov/airquality/
The Town cannot require this area to be annexed into the Town. If this area were to be annexed into the Town of Erie in the future, by the request of the land owner, any new development of the land would need to comply with the applicable regulations in effect at that time.
Town of Erie employees do submit to a standard background check when hired. There are also more stringent background check requirements for employees at the Police Department and for those in roles working with youth. Please contact HR for more specific details about background check requirements per each job classification.
There may be ways to require this during the permitting process if a well site were proposed within the Town’s jurisdiction. We would need to consult with our Town Attorney.
At the time of this specific permit being submitted to and considered by Weld County, there were no air monitoring rules or requirements in County Code. The Operator has voluntarily committed to air monitoring at this Location. Even in our updated County Code, air monitoring is not a requirement at all Locations, and the Code specifically mentions that Operators must follow State and Federal rules. Many Operators are voluntarily agreeing to air monitoring to have evidence of compliance with all State and Federal rules. Current County Code addresses Air Permits in Sec. 21-5-480.
The Town of Erie - like all municipalities and local governments in Colorado - are not legally able to ban oil and gas development. There are increased opportunities for local control and regulations under SB-19-181 that was passed through the State legislature in 2019, but that does not allow any local government to add a blanket ban on this type of development.