HomeMy WebLinkAboutWATERS' EDGE - PDP - PDP160006 - SUBMITTAL DOCUMENTS - ROUND 1 - APPLICANT COMMUNICATION1
OPINION SUPPORTING 100 FOOT
SETBACKS FROM PLUGGED AND
ABANDONED OIL AND GAS WELLS
WITHIN THE WATERS’ EDGE
SUBDIVISION, LARIMER COUNTY,
COLORADO
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Executive Summary:
The Waters’ Edge Subdivision (Waters’ Edge) will encompass four existing oil and
gas wells and an associated injection well. All five of these wells are currently
producing hydrocarbons or are capable of hydrocarbon production or injection.
Waters’ Edge West LLC (WEW) and the well owners are currently discussing the
option of plugging the three active producing wells and two non-active wells. After
these wells are plugged and abandoned, WEW believes that the existing 350 foot
setback requirement between the well sites and future residential development
should be reduced to a 100 foot setback from roads and associated infrastructure for
the well located in the northeast corner of Waters’ Edge and 150 foot setbacks from
roads and associated infrastructure for other wells on the property. Figure 1 below
shows the Waters’ Edge Subdivision and the locations of existing well sites within
the property.
Single well site.
(100’ setback)
Single well site.
(150’ setback)
Three well site.
(150’ setback)
Fig 1 – Showing the Waters’ Edge Subdivision with existing well sites and
recommended setbacks.
Existing off-site
plugged wells.
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All oil and gas producing states provide for the plugging of oil and gas wells through
the placement of cement and other materials into the wellbore in a manner that
prevents the upward migration of oil and gas. In Colorado, this process is regulated
by the Colorado Oil and Gas Conservation Commission (COGCC), which has strict
requirements and exercises active oversight for this purpose. To date, more than
33,000 wells have been successfully plugged and abandoned in Colorado, including
several wells in the area of the Waters’ Edge Subdivision.
After plugging and abandoning the three producing wells and two non-producing
wells within Waters’ Edge Subdivision, the residential setback requirement may be
reduced from 350 feet to 100 feet or 150 feet, as applicable in WEW’s proposal,
without material risk to public health or safety or the environment. This opinion is
based upon the following considerations:
The plugging process has a proven record of protecting the public and the
environment in Colorado and other states by preventing oil and gas from
reaching useable ground water or the ground surface;
The remaining risk associated with a plugged well is the potential need to re-
enter and repair the well at a later time, and this contingency can be
addressed through a setback of much less than 100 feet;
No well plugged under the current rules of the COGCC has needed additional
well work after the initial plugging operation;
The COGCC has not required or recommended any setback for residential
structures from plugged and abandoned wells, and the Province of Alberta
recently adopted a five meter (16.5 feet) setback requirement for this
purpose;
Several plugged and abandoned wells in the area of Waters’ Edge have
setbacks of 55 feet or less with no discernible impact or threat to public health
or safety; and
After wells are physically plugged and abandoned, casing is cut off four to six
feet below ground level and the surface area is restored. A “dry hole” marker
maybe placed on the surface at the land owner’s discretion. The COGCC
requires all plugged wells to be surveyed using a GPS system in the event
the well needs to be located at some future date. This survey information
replaces the requirement for surface markers.
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Site Information:
The Waters’ Edge Subdivision project is located in the S/2 of Section 30, T8N,
R68W. The project is located within the northern city limits of Fort Collins, Colorado
and is positioned just west of Turnberry Road between Larimer County Road 54 and
Richards Lake Road as shown in Figure 2.
The Waters’ Edge project encompasses the southern tip of the Fort Collins oil and
gas field. This deposit of oil and gas covers an area approximately four miles north
to south and ½ to one mile east to west as shown in Figure 3. The field was
discovered in 1924 and currently contains 71 wells, including 29 producing wells, 16
non-producing wells, and 12 water injection wells. The field also contains a total of
14 wells that were previously plugged and abandoned. The field is operated by
Prospect Energy of Houston, Texas.
Fig 2 - Showing general vicinity of Waters Edge Subdivision.
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The specific area of Section 30 around Waters’ Edge is shown in Figure 4. The
section contains four water injection wells, fifteen producing wells, and nine non-
producing wells. A total of seven wells in the section have been plugged and
abandoned and five of the plugged wells are located less than 100 feet from existing
structures. The Waters’ Edge project specifically has three producing wells and two
nonproducing wells located within its boundaries.
Fig 3 – Waters’ Edge Subdivision in relation to Fort Collins oil and gas field.
Boundary of Waters’ Edge PUD.
(See enlargement, Fig 4)
Boundary of Fort Collins Field.
Active well
Plugged well
Inactive well
Water Injection well
Undrilled Well Location
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Section 30 also contains six domestic water wells varying in depth from 20 feet to
350 feet. The shortest distance between any of these water wells and one of the
existing oil and gas wells within the Waters’ Edge property is 741 feet. This is a
greater distance than either the distance between a water well and a producing oil
well (minimum 573’) or the distance between a water well and a plugged oil well
(minimum 450’) within Section 30 as a whole. A complete list of oil and gas wells
located in Section 30 is shown below in Figure 5.
Fig 4 - Waters Edge in relation to oil and gas wells located in Section 30.
Boundary of Waters’ Edge
Subdivision.
Small blue dots denote
permitted domestic
water wells.
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Facility Name Status Status Date
WHITTAKER-BLUNK 3 DA 12/11/1926
MSSU 30-11 IJ 10/27/2014
MSSU 30-14 IJ 10/27/2014
MSSU 30-19 IJ 10/27/2014
MSSU 31-3 IJ 10/27/2014
MESSERSCHMITT 1 PA 1/1/1999
BLUNCK 2 PA 9/17/1946
WHITAKER 1 PA 2/18/1969
WHITAKER BLUNK 4 PA 12/19/1991
MUDDY SANDSTONE UNIT 30-3 PA 11/17/1992
HAWKINS 1 PA 9/3/1958
WHITAKER BLUNK (MUDDY UNIT) 1 PR 4/2/2012
MUDDY SANDSTONE UNIT 30-13 PR 3/30/1994
FT. COLLINS MUDDY UNIT 30-4 PR 9/20/2006
MUDDY SANDSTONE UNIT 30-1 PR 3/30/1994
MUDDY SANDSTONE UNIT 30-6 PR 6/1/2014
MSSU 30-8 PR 10/1/2011
HEARTHFIRE 1 PR 11/13/2012
MSSU 30-5 PR 9/20/2006
MUDDY SANDSTONE UNIT 30-2 PR 9/1/2011
MSSU 30-18 PR 2/14/2013
MSSU 30-17 SI 10/27/2014
MSSU 30-7 SI 10/27/2014
MSSU 30-10 SI 1/1/2013
MSSU 30-12 SI 10/27/2014
MSSU 30-15 SI 6/13/2013
MSSU 30-16 SI 7/15/2015
MSSU 31-1 SI 3/7/2008
MSSU 31-2 SI 7/15/2015
WATER SUPPLY 1 TA 2/9/1925
Fig 5 – Oil and gas wells located in Section 30. Wells located within Waters’ Edge are shown in red font.
Plugged and abandoned wells located less than 100 feet from a residential structure are shown in blue font.
PR=Producing Well SI and TA=Non Producing Well DA and PA= Plugged Well IJ=Injection Well
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P&A Process:
The ground water protection council has described the plugging process as follows:
“The purpose of well plugging is to permanently seal the inside of the well
and wellbore so that fluid cannot migrate from deeper to shallower zones or
create reservoir problems through downward drainage. The process involves
the placement of cement and other materials such as gels inside the well or
wellbore in a manner that prevents the upward or downward migration of
formation fluids.” (“State Oil and Natural Gas Regulations Designed to
Protect Water Resources” - Page 26)
According to the COGCC, more than 33,000 wells have been plugged in Colorado,
(Colorado Oil and Gas Conservation Commission “Final Reclamation Inspection and
Implementation Program: A Status Report to the Commission” Dec 2015. This
information is shown in detail in Appendix “A”). The few wells plugged in Colorado that
have experienced problems are distinguishable from the Waters’ Edge wells because
they were older wells, often abandoned prior to 1952 when the COGCC was formed. In
addition, the COGCC plugging procedures are now more rigorous, and the COGCC
inspection staff often witnesses plugging operations in the field. None of the seven
plugged and abandoned wells located in Section 30, including the five wells located
within 100 feet of residential structures, have caused environmental harm or have
required re-plugging.
The COGCC has strict requirements concerning the plugging and abandonment of oil
and gas wells and they require that plugging procedures be reviewed and approved by
COGCC staff before plugging operations take place. COGCC inspectors must be given
48 hours’ notice prior to plugging so they may be on site to witness plugging operations
as they are performed.
COGCC regulations include requirements to:
1) Set a cement or mechanical plug above any perforated interval in the well.
2) Set a cement or mechanical plug above any unperforated hydrocarbon zones
that are generally produced in the nearby vicinity.
3) Set a cement plug across the casing stub if casing is cut and pulled.
4) Set a cement or mechanical plug above any repaired casing leaks or
cementing stage tools.
5) Set a cement plug across any fresh water aquifers not covered by surface
casing or production casing cement.
6) Set a cement plug across the surface casing shoe (½ below the shoe to ½
above the shoe).
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7) Set a cement plug at surface 50 feet in length.
8) Remediation of surface terrain.
Figures 6 and 7 below show a typical oil and gas well before and after plugging. After a
well has been plugged the surface location must be reclaimed per COGCC reclamation
regulations. Figure 8 below shows a picture of a well site after the well has been
plugged and the surface restored. The full text of the COGCC’s plugging regulations
are included in this report as Appendix “B”. An excerpt from the White Paper published
by the COGCC Oct 16, 2012 which summarizes the COGCC plugging process is
included as Appendix “C”.
Surface Casing - A short string of steel casing set to protect fresh water zones.
Shoe - The bottom of the casing string.
Production Casing - Steel casing set through the producing formation.
Perforations - Holes shot through the steel production casing and cement to allow
hydrocarbons to flow into the well.
Fig 6 – Showing wellbore prior to plugging. Fig 7 – Showing wellbore after plugging. Note casing
has been cut off and free casing pulled from the well.
WATER OR OTHER
FLUID PLACED
BETWEEN PLUGS.
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Special plugging procedures maybe required if fresh water aquifers are not covered by
surface casing or production casing cement. All wells within Waters’ Edge can be
plugged in a normal manner with the exception of the Muddy Sand Stone Unit 30-4 and
the Muddy Sand Stone Unit 30-5. Because the surface casing in these wells is set
above the depth of the deepest water well in the area, these wells will need additional
cement coverage to isolate the exposed aquifers. Figure 7 below list the five wells
located within Waters’ Edge with casing depths, the top of the production casing cement
and comments concerning special plugging procedures. Each of the three Waters’
Edge wells that are plugged in the normal manner will have a total of cement or
mechanical plugs, ranging from the surface to 4500 feet below ground surface. The two
wells that require additional cement coverage will also have a total of four cement or
mechanical plugs, with shoe plugs of additional length to cover exposed fresh water
aquifers. Plugging procedures for producing oil and gas wells or water injection wells
will be the same.
Fig 8 – Reclaimed well site.
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Well Name
(Date Drilled):
Surface
Casing:
Production
Casing:
Top of
Production
Casing
Cement: Comments:
MSSU 30-4 (1979) 8⅝" @ 284' 5½" @ 4852' 3750' Calc This well will need an
additional cement plug
to cover exposed
aquifer.
MSSU 30-1 (1978) 8⅝" @ 471' 5½" @ 4613' 3218' Calc No comment.
MSSU 30-5 (1979) 8⅝" @ 251' 5½" @ 4765' 3344' Bond Log This well will need an
additional cement plug
to cover exposed
aquifer.
MSSU 30-15 (1991) 9⅝" @ 455' 5½" @ 5095' 255'-720';
1000'-1630';
3598' Bond Log
No comment.
MSSU 30-16 (1992) 9⅝" @ 505' 5½" @ 5450' 4196' Bond Log No comment.
The COGCC has no requirements or recommendations regarding set backs from
plugged and abandoned wells. A more conservative approach has been taken by the
Alberta Energy Regulator (Alberta, Canada’s equivalent to the COGCC). Alberta
specifically prohibits the construction of any structures over plugged and abandoned
wells and requires a five meter (16.5 foot) setback radius around the plugged well in
case the well should need remedial work. Appendix “D” is an excerpt from the Alberta
Directive 079 regarding setback requirements from plugged and abandoned wells.
Although a 350 foot setback requirement is appropriate for producing oil and gas wells,
it should not be required for plugged and abandoned wells. Even a 100-foot setback is
larger than what would be required to access a plugged and abandoned well in the
unlikely event that future repair work is required. Insofar as the 350-foot setback is
based upon the setback from new wells that are being drilled or existing wells that are
producing oil and gas, a plugged and abandoned well would not raise similar concerns.
It will not require a drilling rig or special trucks and other well equipment that can be
required to maintain a well in producing condition. Wells that are plugged and
abandoned under the current COGCC requirements should never required additional
work of any type and a 350 foot setback from a plugged and abandoned well is not
necessary as a safety precaution.
Fig 9 – A table showing casing and cementing information for wells located within the Waters Edge PUD
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In the highly unlikely event that a plugged well needs to be replugged, a truck mounted
well surfacing unit will need to access the well site. Additional equipment would include
steel tanks to capture fluid from the well and truck mounted pumping equipment to mix
and pump new cement plugs.
Conclusion:
All oil and gas wells will eventually be plugged and abandoned. Records indicate the
State of Colorado currently has over 33,000 plugged and abandoned wells with less
than six of these wells (all older wells) showing a record of environmental problems.
The Colorado Oil and Gas regulations regarding the plugging of wells have been in
place for many years and ensure oil and gas wells will be plugged in a manner that
prohibits the movement of fluids through the wellbore. The regulations requiring cement
plugs to be set above producing perforations, at casing cut off points, special plugs
covering exposed aquifers, and cement plugs at the surface casing shoe are all
requirements that provide multiple layers of protection for both ground water and
surface occupants.
Although the COGCC does not require setbacks of any kind for a plugged and
abandoned well, the 100 and 150 foot setbacks proposed by WEW is a conservative
and appropriate method to ensure residents of Waters’ Edge are provided with a safe
buffer from any plugged wells within the development. This setback will be just as
protective of public health, safety and the environment as the existing 350-foot setback.
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Appendices:
Appendix “A”: Plugged and Abandoned Wells from COGCC “Final Reclamation
Inspection and Implementation Program: A Status Report to the Commission” Dec
2015.
Total number of abandoned wells totals 33,185.
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Appendix B - State Regulations:
319. ABANDONMENT
The requirements for abandoning a well shall be as follows:
a. Plugging
(1) A dry or abandoned well, seismic, core, or other exploratory hole, must be
plugged in such a manner that oil, gas, water, or other substance shall be
confined to the reservoir in which it originally occurred. If the wellbore is not static
before setting a plug in an open hole or after casing is removed from the
wellbore, then any Produced Fluids must be circulated from the wellbore and the
wellbore shall be filled with wellbore fluids sufficient to maintain a balance or
overbalance of the producing formation. Wellbore fluids shall be in a static state
prior to pumping balanced cement plugs, unless the cement plug is being placed
as a preliminary step to counteract a high pressure or a lost circulation zone
before establishing a static state. Intervals between plugs shall be filled with
wellbore fluids of sufficient density to exert hydrostatic pressure exceeding the
greatest formation pressure encountered while drilling such interval. If mud is
necessary to maintain wellbore fluids in a static state prior to setting plugs, a
minimum mud weight of 9 pounds per gallon shall be used. Water spacers shall
be used both ahead of and behind balanced plug cement slurry to minimize
cement contamination by any wellbore fluids that are incompatible with the
cement slurry. Any cement plug shall be a minimum of 100 feet in length and
shall extend a minimum of 100 feet above each zone to be protected. The
material used in plugging, whether cement, mechanical plug, or some other
equivalent method approved in writing by the Director, must be placed in the well
in a manner to permanently prevent migration of oil, gas, water, or other
substance from the formation or horizon in which it originally occurred. The
preferred plugging cement slurry is that recommended by the American
Petroleum Institute (API) Environmental Guidance Document: Well Abandonment
and Inactive Well Practices for U.S. Exploration and Production Operations, i.e.,
a neat cement slurry mixed to API standards. However, pozzolan, salt-
compatible cements, gel, high-temperature additives, extenders, accelerators,
retarders, dispersants, water loss control additives, lost circulation material, and
other additives may be used, as appropriate for the well being plugged, if the
operator can document to the Director's satisfaction that the slurry design will
achieve a minimum compressive strength of 300 psi after 24 hours and 800 psi
after 72 hours measured at 95 degrees Fahrenheit (95 °F) and at 800 psi
confining pressure.
(2) The operator shall have the option as to the method of placing cement in the hole
by (a) dump bailer, (b) pumping a balanced cement plug through tubing or drill
pipe, (c) pump and plug, or (d) equivalent method approved by the Director prior
to plugging. Unless prior approval is given, all wellbores shall have water, mud or
other approved fluid between all plugs.
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(3) No substance of any nature or description other than normally used in plugging
operations shall be placed in any well at any time during plugging operations. All
final reports of plugging and abandonment shall be submitted on a Well
Abandonment Report, Form 6, and accompanied by a job log or cement
verification report from the plugging contractor specifying the type of fluid used to
fill the wellbore, type and slurry volume of API Class cement used, date of work,
and depth the plugs were placed.
(4) In order to protect the fresh water strata, no surface casing shall be pulled from
any well unless authorized by the Director.
(5) All abandoned wells shall have a plug or seal placed in the casing and all open
annuli from a depth of 50 feet to the surface of the ground or the bottom of the
cellar in the hole in such manner as not to interfere with soil cultivation or other
surface use. For below-grade markers, the top of the casing must be fitted with a
screw cap or a steel plate welded in place with a weep hole. For above-grade
markers, the top of the casing must be fitted with a screw cap or a steel plate
welded in place with a weep hole, and a permanent monument shall be a pipe
not less than four inches in diameter and not less than 10 feet in length, of which
four feet shall be above ground level and the remainder embedded in cement or
welded to the surface casing. Whether a below-grade or an above-grade marker
is used, the marker shall be inscribed with the well’s legal location, well name
and number, and API Number.
(6) The operator must obtain approval from the Director of the plugging method prior
to plugging, and shall notify the Director of the estimated time and date the
plugging operation of any well is to commence, and identify the depth and
thickness of all known sources of groundwater. For good cause shown, the
Director may require that a cement plug be tagged if a cement retainer or bridge
plug is not used. If requested by the operator, the Director shall furnish written
follow-up documentation for a requirement to tag cement plugs.
(7) Wells Used for Fresh Water. When the well, seismic, core, or other exploratory
hole to be plugged may safely be used as a fresh water well, and such utilization
is desired by the landowner, the well need not be filled above the required
sealing plug set below fresh water; provided that written authority for such use is
secured from the landowner and, in such written authority, the landowner
assumes the responsibility to plug the well upon its abandonment as a water well
in accordance with these rules. Such written authority and assumption of
responsibility shall be filed with the Commission, provided further that the
landowner furnish a copy of the permit for a water well approved by the Division
of Water Resources.
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Appendix “C” - State White Paper Published by the COGCC:
Except from Wellbore Integrity White Paper (October 16, 2012) Page 15:
Wellbore Abandonment Review:
The following is a summary of the Engineering Staff review process for well
abandonment, which begins with an operator submitted request to abandon, a Notice of
Intent to Abandon. The Notice of Intent to Abandon is reviewed and approved with any
necessary changes. Upon completion of the approved abandonment procedure the
operator must submit a Subsequent of Abandonment Report, including contractor
plugging verification reports, which document materials used and work performed.
The engineer reviews the operator’s Notice of Intent to Abandon, with specific
consideration given to fresh water aquifers and hydrocarbon producing zones to
determine where plugs should be set in the well. Evaluation of these zones is similar to
the evaluation described above for casing and cement program reviews for new oil or
gas wells. Engineers require that plugs be set above the perforations for each
hydrocarbon formation completed in the well. We also require plugs above hydrocarbon
zones that are generally produced in the nearby vicinity even if not perforated in the
particular well being plugged and abandoned. In dry holes, we require plugs to be set
above drill stem tests (DST’s) or other significant oil & gas shows observed while
drilling. Shows are typically reported on the Form 5 or on a mud log. A stub plug is
required if casing is to be cut and recovered. Plugs are required across previously
repaired casing leaks and cementing stage tools. Plugs are required below and/or
above fresh water aquifers (if any) that are not covered by surface casing or stage
cement. A plug is required across the surface casing shoe, and another plug is required
from 50’ to surface.
Engineers consider the operator’s proposed procedures, zones in need of isolation and
documentation of existing cemented intervals in the wellbore. The engineer reviews
important wellbore conditions as disclosed in the well record or on the Notice of Intent to
Abandon, such as holes in casing (wellbore integrity), stuck tubing, packers, or other
fish in the hole, previously undocumented perforations and cemented intervals (cement
squeezes, casing repairs, or recompletions), and information from past workover
operations, etc.
If the operator’s Notice of Intent to Abandon, as submitted, is not adequate or the
engineer has other questions, the engineer contacts the operator to resolve issues and
make changes before approving the Notice of Intent to Abandon.
Subsequent Report of Abandonment:
After plugging the operator is required to provide a Subsequent Report of Abandonment
of the well, including contractor plugging verification reports, which document materials
used and work performed. Engineers review the submittal to confirm that plugs were set
as required on the approved Notice of Intent to Abandon. If the job was not carried out
substantially in accordance with the approved Notice of Intent to Abandon or it did not
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result in adequate isolation because of unanticipated changes in the field, necessary
corrective action such as re-entry and replugging of the well, is required.
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Appendix “D” - Alberta Directive (excerpt):
Except from Directive 079, Alberta Energy Regulator, Pages 4, 5 and 6:
Setback Requirements for Abandoned Wells:
In support of the SDR [Subdivision and Development Regulations], the AER has
established minimum setback requirements in this directive to address public safety
issues that could result from an abandoned well. While the likelihood is low that future
access to an abandoned well for repairs will be needed, establishing and maintaining a
greater setback than is required should be considered between the abandoned well and
surface structures to
• allow well access with minimal disruption to surface structures and
• prevent accidental contact of the construction equipment with the well.
Applicants are strongly encouraged to address the need for a greater setback with the
licensee before submitting their application to the municipality.
The SDR requires the municipality to ensure that applicants seeking subdivision or
development approval have appropriately identified and considered locations of
abandoned wells, including any prescribed setback area, when making planning,
development, and construction decisions. The municipality may require a larger setback
than the minimum requirement set out in this directive.
Surface structures on top of an abandoned well are not permitted and a minimum 5 m
setback radius around the well must be maintained.
However, some very shallow abandoned wells that were drilled for geological evaluation
or did not penetrate hydrocarbon-bearing formations may not require a setback.
Specifically, wells drilled and abandoned to a depth of less than 150 m do not require a
setback and are exempt from the requirements set out in this directive. In other limited
circumstances, the AER may determine that a setback distance can be reduced or is
not required at all (e.g., for oil sands evaluation wells and certain stratigraphic test
wells). If it is determined by the licensee in consultation with the AER that there is no
need for a setback, the applicant for subdivision or development approval should obtain
a letter from the AER confirming its support of the decision by the municipal approving
authority to grant an exemption from the setback requirement and submit this letter with
its application.
Provision of an access route should be discussed between the applicant for subdivision
or development approval and the licensee. The licensee of the well is expected to
determine whether there are any existing well integrity issues that need to be addressed
prior to surface development taking place and whether the well was abandoned to an
acceptable standard. In order to minimize the chance that a well may leak once surface
development occurs in proximity to the well, the licensee is strongly encouraged to
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consider reabandoning the well to current standards prior to surface development taking
place.
The applicant for subdivision or development approval and the licensee of any
abandoned wells in the area are strongly encouraged to discuss whether the 5 m
setback is sufficient. Legislation administered by the AER provides that the licensee of
an abandoned well remains responsible for the well indefinitely. Therefore, licensees
should ensure that they maintain abandoned wells in a condition that minimizes the
chance of a leak.
The SDR requires applicants seeking subdivision or development approval to comply
with this directive. As a result, applicants must incorporate the 5 m setback radius into
their subdivision and/or development. Applicants are strongly encouraged to also
incorporate any additional area recommended by the licensee, including an access
route. Early identification of abandoned wells and consultation with the municipality and
licensee will help in determining an effective subdivision design, the location of surface
structures, the siting of underground utilities, and the land grading. It is strongly
recommended that the applicant for subdivision or development approval, the licensee,
and the municipality discuss early in the planning stages possible land use around
abandoned wells, including land contouring that may require an abandoned well to be
cut and capped at a greater depth below the surface.
Should there be lack of agreement between the licensee and applicant for subdivision
or development approval with the licensee recommending a setback greater than the
requirements of this directive, the parties should consider third-party mediation.
While the SDR amendments and this directive do not apply retroactively, it is strongly
recommended that parties that have received approval for but have not yet constructed
a proposed subdivision or development take steps to determine if abandoned wells exist
within the project area and, if so, ensure that an appropriate setback area is
incorporated.
Applications for Subdivision or Development
Before completing an application for subdivision or development, applicants should
search for abandoned wells in the proposed development area using the viewer or
request the information from the Information Management Branch, as mentioned above.
The SDR requires that applicants include in their application information from the AER
identifying the locations or confirming the absence of any abandoned wells within the
proposed project area. The information is to consist of the following:
• a map of the search area from the viewer and a statement that there are no wells in
the project area or
• a list and map identifying the locations of abandoned wells within the search area,
including the surface coordinates, as provided by the viewer or the Information
Management Branch, and
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• written confirmation from the applicant for subdivision or development approval that
the licensee responsible for each well has been contacted and the exact well location
confirmed (any additional information discussed with the licensee that may have led to a
change in the setback area should also be included),
• a sketch of the proposed development incorporating the necessary setback area for
each well, and
• if the development will result in construction activity within the setback area, a
statement confirming that the abandoned wells will be temporarily marked with on-site
identification to prevent contact during construction.
If applicants find abandoned wells within the project development area, the SDR
requires them to contact the licensee.
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Appendix “E” :
CURRICULUM VITAE
David K. Dillon, PE
6230 E. Jamison Circle South
Centennial, CO 80112
Education: BS Civil Engineering from the University of Colorado at Boulder
Professional Affiliations: Member of Society of Petroleum Engineers
Licensed Professional Engineer in Colorado #19171
Licensed Professional Engineer in Wyoming #12530
(Licensed as a Petroleum Engineer in both states)
Work Experience:
1975 – 1978 Amoco Production Company (Powell, WY and Denver, CO)
Performed production engineering, drilling engineering and operations engineering. As a
drilling engineer I prepared AFE’s, designed and implemented optimized drilling plans
and I supervised drilling rigs. As a production engineer I designed and recommended
workovers, prepared AFE’s for workovers and I performed economic evaluation for
various farmin / farmout type projects. Areas of experience include the Williston Basin
and various basins in Wyoming.
1979 – 1981 Ladd Petroleum (Denver, CO)
Drilling engineer and later drilling supervisor for Ladd Petroleum. I designed and
implemented optimized drilling programs, estimated drilling costs (AFE’s), negotiated
contracts with drilling companies and other drilling vendors. I also supervised drilling rigs
in the field. Areas of experience include the Williston Basin, the San Juan Basin, and the
Permian Basin.
1982 – 1983 Dome Petroleum (Denver, CO)
Drilling engineer for Dome Petroleum. I designed and implemented optimized drilling
programs, estimated drilling costs (AFE’s) and negotiated contracts with drilling
companies and other drilling vendors. I also supervised drilling rigs in the field. Area of
experience includes the Williston Basin.
1984 – 1984 Davis Oil (Denver, CO)
Senior Production Engineer for Davis Oil. I designed well completions, hydraulic
fracturing procedures and optimized pumping systems. Area of experience includes
Powder River Basin of Wyoming.
1985 – 1994 Coastal Oil and Gas (Denver, CO)
Drilling Engineer and Senior Production Engineer for Coastal Oil and Gas performing all
of the duties shown above. I also testified on Coastal’s behalf as an expert witness before
the Utah Oil and Gas Commission (DOGM) and the Wyoming Oil and Gas Commission.
These testimonies required reservoir engineering analysis and included calculations on
reserve recovery and drainage areas. The testimony required analysis of reservoir
pressure data and fluid flow through the reservoir.
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Curriculum Vitae
David K. Dillon
Page 2
1994 - 2010 Colorado Oil and Gas Conservation Commission (Denver, CO)
Engineering Supervisor and Engineering Manager. Prior to the reorganization of the
Commission, I supervised 17 technical positions including engineers and engineering
technicians. Prior to retirement, I supervised nine employees. I was responsible for the
interviewing and hiring of qualified people for all engineering positions, their performance
evaluations and the organizational structure and mentoring of the engineering group. Due
to competition for qualified people, we initiated a program to hire engineers with a
minimum of petroleum experience and train them for engineering positions. As
Engineering Manager I gave expert testimony to the Commission on almost a monthly
basis concerning reservoir behavior, oil and gas operational issues, and spacing issues.
The COGCC also spends over $220,000 per year to plug and abandon old wells in the
state. I approved and/or personally supervised preparation of the plugging procedures,
cost estimates, the scheduling of contractors, and the field supervision of this work.
Presently: Principle of David K. Dillon PE, LLC, a petroleum engineering consulting firm.
Testimony: East Cheyenne Gas Storage (Colorado OGCC Unitization Hearing)
Cause 5 Docket No. 1011-UP-60
November 29, 2010
Fornstrom Field Waterflood Application (Wyoming OGCC Unitization Hearing)
Docket No. 120-2013
March 12, 2013
Publications: David K. Dillon et al., Induced Seismicity Potential in Energy Technologies, The National
Academies Press, 2012
David K. Dillon et al., Pavillion Field Well Integrity Review, Wyoming Oil and Gas
Conservation Commission, 2014
Presentations: 3 hour presentation on hydraulic fracturing for EUCI’s conference entitled, “Hydraulic
Fracturing: Regulatory Perspectives and Achieving more ROI.” Denver, Colorado -
February 8th & 9th, 2012
30 minute presentation on “Noise Regulations Impacting Hydraulic Fracturing” for EUCI’s
conference entitled, “Hydraulic Fracturing: Regulatory Perspectives and Achieving more
ROI.” Denver, Colorado - February 8th & 9th, 2012
12 hour presentation on hydraulic fracturing for EUCI’s course “In-Depth Introduction to
Hydraulic Fracturing”. Pittsburgh, Pennsylvania – August 27th & 28th, 2012.
Presentations to various groups concerning Induced “Seismicity Potential in Energy
Technologies” for the National Academies of Science.
Contact Information: Office Phone: 720-347-5925
Web Site: www.DavidDillonPE.com