American Oil and Gas Reporter - March 2018 - 22

intended to "prohibit the dumping of
'fracking' chemicals and other
dangerous waste fluids into the Gulf
unless (EPA) adequately studies and
discloses the risks."
The National Ocean Industries
Association says the lawsuit challenges
the National Pollutant Discharge
Elimination System permit issued by
EPA in September for oil and gas
platforms operating in federal waters
off Texas and Louisiana. "NOIA,
alongside the American Petroleum
Institute and the Offshore Operators
Committee, worked with EPA to
ensure the new general permit provided
a workable framework for offshore
operations while still maintaining
environmental integrity," the
association remarks.
The environmental groups contend
EPA's analysis failed to comply with the
Clean Water Act and the National
Environmental Policy Act. A notice of
intent to sue that the groups filed in
December also suggests the discharge
permit imperils loggerhead sea turtles,
whales and fish in violation of the
Endangered Species Act. r

Integrity Management
Added To Requirements
For Colorado Flowlines
DENVER-In February, the Colorado
Oil & Gas Conservation Commission
expanded regulations to include regular
integrity management surveys of onand off-location flowlines, crude oil
transfer lines and produced water lines.
The commission also increased a mill
levy on production to help fill its
looming budget gap.
The regulations were prompted by an
April 2017 tragedy in which
investigators determined that
accumulated, untreated natural gas
caused an explosion in a house in
Firestone, Co. Findings indicated the
gas flowed from a nearby well to the
house through a line that was recorded
as inactive but inadvertently left tied to
the well (AOGR, June 2017, pg. 32).
Under the rules, Colorado flowline
integrity management requires
operators of:
* Lines in service after May 1 to
conduct maximum operating pressure
tests according to ASME, ASTM or API
standards;
* Existing, aboveground, onlocation lines to conduct monthly audio,
visual and olfactory (AVO) test of the
entire line;
22 THE AMERICAN OIL & GAS REPORTER

* Existing, below-ground, onlocation lines to choose between
pressure testing or smart pigging every
three years, continuous pressure
monitoring, or annual AVO alternative
tests, which include use of an instrument
monitor capable of detecting line failure,
leaks, spills, releases or signs thereof;
* Existing, off-location, flowline
and crude transfer lines to choose
between annual pressure tests, smart
pigging every three years, continuous
pressure monitoring, or annual AVO
alternative tests; and
* Existing, below-ground, offlocation, produced water flowlines to
pressure test annually, conduct
continuous pressure monitoring and
smart pig every three years.
Expanding the state's Series 1104
regulations to include flowline integrity
management pushes Colorado's oil and
gas oversight back to the national
forefront, assesses Dan Haley, president
and chief executive officer of the
Colorado Oil and Gas Association. He
says COGA supports the rules,
suggesting "these tough, new
regulations will further enhance the
safety and integrity of pipeline
infrastructure."
He adds that flowline endpoint
mapping and a required top-level
participation in the state's one-call
system by all operators is unprecedented
for any Colorado industry. In addition to
the flowline integrity management
assessments, the expanded rules also
require companies to report injuries to
workers and others if they are caused by
operational accidents.
Under the rules, any OSHA
reportable accident that injures a worker
or results in a medical treatment for a
member of the public must be reported
to the commission. The event is
reportable by Form 22 within three days
and an injury report not later than six
days.
According to a statement from
Governor John Hickenlooper, COGCC
staff is empaneling a stakeholder group
to review current instrument-based
technology "for detecting leaks or spills
from flowlines." The panel, to consist of
industry, local governments, experts and
COGCC staff, will provide a report,
with possible recommendations for
rules revisions, within a year.
On the day before the flowline
hearing, the commission also approved
an increase in the production mill levy
to 0.11 cents on the dollar, up from 0.07
cents. The increase is estimated to raise
an additional $4.8 million to fund
COGCC operations, which faces a

projected budget shortfall of $5.6
million, a department spokesman
indicates.
Commissioners and COGCC Director
Matt Lapore discussed but did not act on
requests to hike the mill levy to the full
0.17 cents state law allows. Lapore has
said a future mill levy increase or
voluntary program may be needed to
deal with the state's orphaned wells. r

Gas Storage Levels
Decrease By 515 Bcf
WASHINGTON-Underground
natural gas storage in the United States
stood at 1.682 trillion cubic feet on Feb.
23, 18.1 percent below the five year
average, according to the U.S. Energy
Information Administration. That was
down 515 billion cubic feet from the
2.197 Tcf in storage on Jan. 26, which
was 16.2 percent below the five-year
average. The Feb. 23 storage number
was 680 Bcf less than a year ago, when
gas storage stood at 2.362 Tcf.
According to EIA, gas storage in the
East Region was 382 Bcf on Feb. 23,
7.5 percent below the five-year average
and 143 Bcf less than on Jan. 26, when
storage stood at 525 Bcf, which was
11.5 percent below the five-year
average. East Region gas storage on
Feb. 23 was 41 Bcf less than it was a
year ago.
Gas storage in the Midwest Region
stood at 398 Bcf on Feb. 23, 18.4
percent below the five-year average and
198 Bcf less than the 596 Bcf in storage
on Jan. 26, which was 12.6 percent
below the five year average. Feb. 23 gas
storage in the Midwest Region was 211
Bcf less than a year ago.
In the Mountain Region, EIA says,
gas storage was 102 Bcf on Feb. 23,
23.3 percent below the five-year
average and 35 Bcf less than the 137
Bcf stored on Jan. 26, which was 11.6
percent below the five year-average.
Gas storage in the Mountain Region
was 44 Bcf less than a year ago.
Gas storage in the Pacific Region was
189 Bcf on Feb. 23, 15.6 percent below
the five-year average and 31 Bcf less than
the 220 Bcf stored on Jan. 26, which was
12.4 percent below the five-year average.
Pacific Region gas storage on Feb. 23
was down 16 Bcf from a year ago.
In the South-Central Region, gas
storage levels on Feb. 23 were 611 Bcf,
23.1 percent below the five-year
average and down 108 Bcf from the 719
Bcf in storage on Jan. 26, which was
23.6 percent below the five-year
average. r
American Oil and Gas Reporter - March 2018

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