As we previously discussed in our January 22, 2015 post " Upcoming COGCC Rulemaking: Front Range Flood Lessons Learned," the Colorado Oil and Gas Conservation Commission ("COGCC") is considering the September 2013 Front Range Flood as a learning opportunity.
New rules were unanimously approved by the COGCC on Monday, March 2, 2015, implementing several recommendations that the COGCC staff made in the March 2014 report entitled "Lessons Learned" in the Front Range Flood of September 2013.
The new rules reportedly require:
- All storage tanks, both new and existing, be surrounded with hardened berms made of steel instead of earthen barriers.
- Critical equipment must be anchored according to an engineered anchoring plan.
- Existing pits used for exploration and product waste must be removed.
- Operators must be able to shut down the well remotely.
The new rules are effective June 1, 2015, for new wells and equipment and April 1, 2016, for retrofitting of existing equipment.
April 1, 2016 is also the deadline to create an inventory of wells and critical equipment located in floodplains and register the equipment and locations with the COGCC. Creation of a formal plan outlining how companies will respond in a potential flood situation is also mandated.
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