HomeMy WebLinkAbout20183303.tiffOFFICE OF BOARD OF COMMISSIONERS
PHONE: 970-336-7204
FAX: 970-336-7233
1150 O STREET
P.O. BOX 758
GREELEY, COLORADO 80632
October 15, 2018
Ms. Julie Murphy, Director
Colorado Oil and Gas Conservation Commission
1120 Lincoln Street, Suite 801
Denver, Colorado 80203
Re: Letter of Support for the Approval of Final Comprehensive Drilling Plan;
Docket No. 180700613
Dear Director Murphy,
The Board of County Commissioners of Weld County (the "Board") supports the final
Comprehensive Drilling Plan ("CDP" or "Plan") submitted by Noble Energy, Inc. ("Noble"), in
Colorado Oil and Gas Conservation Commission ("COGCC") Docket No. 180700613. The Board
concurs with the Colorado Department of Public Health and Environment comment letter submitted
to the you on July 26, 2018, which notes the CDP is a strong proposal that will give Noble,
landowners, neighbors, mineral owners and local governments more certainty and long-term
understanding of the activity associated with the Plan.
The Plan comprises approximately 64,133 contiguous acres wherein Noble has a very high
working interest. The CDP is located exclusively in Weld County and encompasses rural lands with
no municipalities within the boundaries.
The Board understands Noble intends to apply innovative best management practices to
minimize surface disturbance, increase efficiency, and reduce environmental impacts to the
surrounding communities. The CDP operations will be conducted in a systematic drilling corridor
or "row" concept drilling from west to east beginning in the southern half of the CDP. The drilling
corridor provides foreseeable timing and planning expectancies of operations as drilling progresses in a
predictable pattern, rather than sporadic development throughout the approximate 100 square miles of
the CDP area.
The operations will utilize "econode" development to minimize surface disturbance. A robust
pipeline infrastructure will be installed in the CDP area to transport all completion and production
fluids, reducing the number of truck trips and emissions. It is estimated that the proposal will
eliminate nearly 7 million truck trips over the life of the plan — or 152 million miles of truck traffic —
from Weld County's roads.
The CDP identifies approximately 1,471 existing Noble operated wells which will largely be
plugged and removed in conjunction with the drilling operations of the CDP. Reclamation of lands
due to the plugging and removal process will return lands and access roads to surface owners for
agricultural and other non -oil and gas uses.
CV\--Imvn; c a -t i d ns
2018-3303
Letter, Julie Murphy, Director
October 15, 2018
Page 2
Transportation routes identified for traffic associated with the CDP development have been
designed to utilize existing paved roads, such as WCR 49, that have been constructed to accommodate
heavy commercial traffic. Minimizing the overall truck trips throughout the life of the CDP
development will also lessen the potential for traffic accidents.
In conclusion, the Board fully supports the Plan and asks for its approval by the COGCC.
Please contact Jason Maxey, Weld County's Local Government Designee, if you should have
any questions or need further information. Mr. Maxey may be reached at (970) 400-3579.
Very truly yours,
BOARD OF COUNTY COMMISSIONERS
Steve Moreno, Chair
pc: Bruce T. Barker, Weld County Attorney
Jason Maxey, Weld County Local Government Designee
;COLORADO
Department of Public
Health & Environment
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July 26, 2018
Julie Murphy, Director
Colorado Oil and Gas Conservation Commission
1120 Lincoln Street, Suite 801
Denver, Colorado 80203
Re: Noble Energy, Inc. Preliminary Comprehensive Drilling Plan Comments
Dear Director Murphy:
The Colorado Department of Public Health and Environment (the Department) is providing
comments on the preliminary Noble Energy, Inc. (Noble) Comprehensive Drilling Plan (CDP)
located in Weld County (Docket No. 180700613).
The Department commends Noble for their holistic approaches to oil and gas exploration and
production. Noble has, and will continue to be, an important leader throughout Colorado. The
preliminary CDP is yet another example of that commitment to excellence.
The Department respectfully recommends that Noble employ best management practices
throughout the project area and is providing comments on the following topics:
• Inspector access
• Electrical equipment and devices
• Odors from drilling and completion activities
• Management of exploration and production waste
• Installation of pipelines
• Leak detection and repair
• Plugging and abandonment of vertical wells
Inspector access
The ability to provide compliance oversight is important to both the Department and to
Noble. From time to time, inspectors with the Department's Air Pollution Control Division
have experienced challenges accessing portions of the CDP area. In order to facilitate
compliance inspections, the CDP might address the right of access for all relevant portions of
the CDP area. The Department acknowledges that the issue of inspector access may be
potentially contentious and it understands the legal and historical challenges of this issue.
However, the Department notes that the CDP process is designed to overcome challenges like
this and facilitate solutions for all parties. The Department is appreciative of the steps Noble
has taken to date on this matter and is confident that a solution will be secured going
forward.
Electrical equipment and devices
The Department acknowledges that Noble's Gen IV Econode design will encourage
implementation of "fit for purpose" automation, according to electrical and control
schematics. The Department recommends that Noble utilize electrical equipment and devices
to the extent practicable in order to reduce emissions from diesel and natural gas powered
equipment and devices.
Odors from drilling and completion activities
The Department supports Noble's commitment to limit odors from materials storage. The
Department recommends that Noble continue to pursue methods and practices to reduce
odors during each phase of the exploration and production process throughout the duration of
the CDP, including but not limited to: using chillers and chemicals to mask or neutralize
hydrocarbon odors emulating from drilling mud; using a squeegee to remove drilling fluids
from the drilling pipe as they exit the wellbore and; using covered containers to store the
drilling mud on the well site and; minimizing the use of diesel fuels as additives in drilling
mud.
Management of exploration and production waste
The Department acknowledges that Noble will dispose of exploration and production waste,
including oil -based mud, to an offsite disposal facility in Colorado which is approved by the
Department. The Department recommends that the CDP's section on exploration and
production waste management (section 5, page 10) be revised to include testing for and
proper disposal of technologically enhanced naturally occurring radioactive materials
(TENORM). Additionally, Noble is encouraged to follow and participate in the TENORM
stakeholder process currently being undertaken by the Department's Hazardous Materials and
Waste Management Division. Information about this stakeholder process can be found at
https://www.colorado.gov/pacific/cdphe/tenorm-req-dev.
Management of Flowback and Produced 'Water
The Department acknowledges that Noble intends to dispose of flowback and produced water
through licensed third -party wastewater injection facilities. The Department believes this is
the preferred method compared to disposal by evaporation in open surface impoundments.
However, the Department encourages Noble to consider all available means to recycle and
reuse these waters beneficially.
Installation of pipelines
The Department supports Noble's commitment to not commence commercial production at
any specific oil and gas location until adequate pipeline takeaway capacity is available at the
facility. This practice ensures that green completions will be utilized to the extent
practicable during flowback operations and that the flaring of natural gas will be minimized,
thus reducing emissions from well sites.
Minimization of Flaring
The Department supports Noble's commitment to ensure gas gathering pipelines are in place
and to not use flares at any location except in emergencies and during maintenance. The CDP
area is within the Denver Metro/North Front Range (DMNFR) ozone nonattainment area. The
flaring of natural gas produces nitrogen oxides (NOx) as well as additional volatile organic
compound (VOC) emissions due to incomplete combustion. Both pollutants contribute to
ozone formation.
In 2008, EPA came out with a stricter ozone standard and the DMNFR was designated as a
"Marginal" nonattainment area for this standard. Although Colorado's air quality is getting
better, meeting the 2008 ozone standard continues to be a challenge.
The Department recommends that Noble limit the use of flares to the extent practicable in
order to facilitate emission reduction efforts.
Implementation of "Tankless" Facility Design
The Department supports Noble's commitment to expand the use of their Gen IV Econode
design in the proposed development area. The Department believes well production facility
design to minimize or eliminate the use of traditional atmospheric hydrocarbon and produced
water storage tanks controlled by flares is the best practice. This design reduces or eliminates
a significant contributor (e.g. storage tanks) of VOC and NOx emissions which are the primary
contributors to ozone formation. When supported by 3 -phase gathering system pipelines,
Noble is also able to reduce or eliminate substantial truck traffic and hydrocarbon loading loss
emissions that otherwise occur from transfer to and transport of produced fluids off site via
mobile sources. Noble is to be commended for their efforts to date around their Econode
design.
Leak detection and repair
The Department supports Noble's commitment to incorporate routine best practices under its
Leak Detection and Repair (LDAR) program including the use of infrared cameras and other
innovative technologies for leak detection. The Department stands ready to support Noble's
pursuit of any "next generation" detection technologies.
Plugging and abandonment of vertical wells
The Department supports Noble's commitment to plug and abandon virtually all legacy
vertical wells operated by Noble in the CDP area. The Department recommends that the
CDP's section on plugging and abandonment (section 11, page 10) be revised to include a
requirement that Noble implement measures to control unnecessary and excessive venting, to
protect public health and the environment, and to ensure that vapors and odors from well
plugging operations do not constitute a nuisance or hazard to public welfare.
Conclusion
The Department applauds Noble for its work to date to develop a strong CDP. As the
preliminary CDP develops over the coming months, the Department may submit additional
comments in an effort to minimize the impacts from oil and gas operations on public health
and the environment.
Sincerely,
Digitally signed by Sean
Sean Hackett Hackett
Date: 2018.07.26
16:19:54 -06'00'
Sean Hackett
Oil and Gas Liaison
Colorado Department of Public Health and Environment
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