2015-11-06_PERMIT FILE - C1981022 ‎(2)‎

• Permit No: C1981022
• IBM Index Class Name: Permit File
• Doc Date: 11/6/2015
• Doc Name: Colorado Oil And Gas Conservation Commission
• Media Type: D
• Archive: No

STATE OF
COLORADO
O1
DEPARTMENT OF NATURAL RESOURCES
BM Ritter, Jr., Governor
1120 Lincoln St_ Suite 8ol
/
Denver, CO 80203
*v' /� S
CC!;
Phone: [phone]
x,'„7/"1
FAX: [phone]f 09
CONSERVATION COMMISSION
www•colorado.gov/oogcc
Notice Concerning Operating Requirements for Wildlife
Protection
In December 2008 the COGCC adopted several new and amended rules intended to minimize
adverse impacts to wildlife resources in Colorado from oil and gas activities. Beginning July 1,
2009 on federal land and April 1, 2009 on all other land, these rules will apply to all oil and gas
exploration and development operations in the state.
This notice is intended to inform operators of these wildlife protection rules and to provide a
reminder so company staff and contractors may become familiar with certain new and existing
operating requirements. While some of these practices were required under conditions of
approval attached to permits submitted between January 5, 2009 and June 2009, operators should
be aware that they will apply automatically to all permits and operations going forward.
If you have any questions about the following rules, please contact the COGCC at 303-894-2100
or dnr.ogcc(a-1,state.co.us.
PITS AND WASTE MANAGEMENT
The COGCC Rules have long had waste management requirements to protect wildlife, and the
rules in this regard have not changed significantly.
Pits pose a hazard to people and animals because they are difficult to exit if one falls in.
Accordingly, COGCC Rule 604.c.(3) continues to require pits to be fenced in order to prevent
accidental entry when the site is easily accessible and poses a hazard. The most common and
significant problem with pits and wildlife arises when waterfowl land in a pit, get oil on their
wings, and are unable to fly or otherwise get out of the pit. This is likely a violation of COGCC
Rule 902.c and may also violate the federal Migratory Bird Treaty Act (MBTA). While the U.S.
Fish and Wildlife Service (USF&WS) may enforce for the loss of life by migratory birds under
the MBTA, operators should be aware that the COGCC will enforce where pits are not
maintained to be free of oil and condensate, unless the pit is permitted as a skim pit and is
properly lined, fenced, and netted. Additionally, COGCC Rule 902A continues to require
operators to install appropriate netting or fencing where necessary to prevent significant adverse
environmental impacts resulting from access to a pit by wildlife, including migratory birds.
Failure to comply with COGCC Rules could result in penalties or revocation of the pit permit,
Form 15.
The text of these provisions regarding waste management for wildlife protection follows:
COGCC Rule 902. PITS- GENERAL AND SPECIAL RULES (Excerpt)
C. Any accumulation of oil or condensate in a pit shall be removed within twenty-
four (24) hours of discovery. Operators shalt use skimming, steam cleaning of
exposed liners, or other safe and legal methods as necessary to maintain pits in
clean condition and to control hydrocarbon odors. Only de minimis amounts of
hydrocarbons may be present unless the pit is specifically permitted for oil or
condensate recovery or disposal use. A Form 15 pit permit may be revoked by
DEPARTMENT OF NATURAL RESOURCES Hama Sim mm, Exew" Dtrecw
COGCC COMMISSION Ridw AMard -Thanes L Compton - OeAnn Crag - Mark Cur4it - %d" Dm&V _ Joshua 8 Epef - Trbsi Houpt - Jun Madm - Hams Sherman
COOCC STAFF Dared NeMn, Dneaor - Deus "drnn, Envxardn MM Manages - DmW K Dillon, Erpmeenng Manager