DOGM Explains Drilling Approval Policies to County

By Sun Advocate

The associate director of the Utah Division of Oil, Gas and Mining visited the area last week to explain state policies for approving drilling projects to the Carbon County Commission.
The visit followed up a couple of weeks of investigation by the county, DOGM and personnel from a private exploration company in connection with wells proposed by Prima Oil in the Jump Creek area.
“I am here to be sure you are comfortable with what we do when we are looking at approving well sites,” said the division’s John Baza. “We don’t want to interfere with your processes, but would like you to know that we are a resource you can use should you need it.”
Baza gave the commission a handout which explains the kinds of steps a company must go through to get a well approved.
“The application for a permit to drill includes four parts,” Baza told the commission. “First there is a pre-drill on site evaluation, then an administrative review, an engineering review and finally a geology/ground water review.”
Baza went on to explain those various stages and what tasks the division performs during those stages of review.
During the on site evaluation, the potential drill site is ranked for applicability of reserve pit lining or even exclusion of pit use.
Drainage, erosion control, and sedimentation issues are addressed at this time.
All runoff is diverted away from drill pad. If surface water or drainages are near, pads are burmed to keep potential spills and runoff on the pad itself.
Access roads are evaluated for runoff, erosion and sedimentation issues. Recommendations for change and/or approval conditions are recommended at this time as well.
The administrative review comes next. This portion of the process is mostly geared toward assuring that all required information is included. Such things as bonding, well siting and spacing, water use approval, surface agreements, lease type and number verification, and wildcat or field status are all part of this review.
Next comes the engineering review. This is a technical review of the drilling program, well control, safety concerns, casing/cementing design, and other related information. This along with the geology review looks at well design to adequately protect ground waters.
Finally comes the geology/ground water review. This is a technical review of the application for protection of resources including ground water. A search and review of all wells in the vicinity (within a one-mile radius) including water wells is performed.
Relevant well files and histories and technical publications are reviewed so that all available information on resources or geological features are taken into consideration.
Conditions of approval are developed, often in conjunction with the engineer, for protection of resources. The conditions often involve casing and/or cementing requirements, berming, sediment control, closed mud systems or other things that go beyond what was proposed. A brief statement of basis is written to support the approval conditions as developed.
Individual applications for permit to drill usually involve construction of short access roads.
If the proposed drilling involves construction of many pads, extensive roads and facilities, it is part of a larger project and will involve various land and lease ownership, including federal, so the National Environmental Protection Act process is applicable.
The result is, environmental protection measures and such things as road designs are applied throughout the project, which lessens the need to address them on a well by well application basis.
Commissioner Bill Krompel, however, was concerned about what might happen after wells are drilled and how those operations might be monitored.
“Over the years, we’ve noticed a few places where agreements were not held up and there was a lack of compliance,” stated Krompel. “We worry about your ability to monitor operations after the permits are issued.”
Baza explained that the division does inspections during critical operations (construction, actual drilling, etc.) and then that inspections become routine with officials visiting each site a couple of times a year.”
“Protecting ground water is one of the key things we go after,” explained Baza. “We look at the formations and design the casings for the well to protect that water. We not only want to protect it from oil or gas residues, but also from salt water, which is what is often found in water that is taken from deep under the ground. We often sample water from wells and springs to make sure that there is no contamination.”
Well site reclamation was also on the mind of the commissioners. One of the original complaints by a local land owner in the area where the wells are proposed was that one site was not properly reclaimed many years ago.
“We matched up the coordinates with the well site and the one that was reported to have been not reclaimed properly,” said Mark Jones, a field representative for DOGM and one of those who went to the actual sites. “It happens to be a well on a SITLA (state institutional trust land) site, and it appears to be reclaimed correctly. We found intermediate wheat grass which had to be planted there. One side of the reclamation has a cut side slope from operations, but it isn’t steep or high.”
Jones went on to explain that according to the records the well was drilled in 1992 and was plugged and abandoned in 1993. The bond was released in 1994.”
County officials, who also went out on the investigation concurred with Jones’ findings. Commissioners also wanted to know about the bonding rules that are presently being followed.
“We are now requiring a higher level of bonding that we did even a year ago,” explained Baza. “If we see problems, the bond can be requested for as much as it would take to totally reclaim the area. At present our bonding requirements are more stringent than almost any of the other rocky mountain states.
County commissioners also wanted to know where the conditional use permits they issue fit into the scheme of things.
“Do you guys even see these permits or even care about them?” Commissioner Steve Burge asked Baza.
“We see that as an important, local, independent process,” answered Baza.
Craig Stay, who owns a cabin in the area and brought up the problems of reclamation and deforestation attended the commission meeting, but offered little input about the situation as the officials presented the reports.
Rex Sacco, the county’s lands and access coordinator, at one point in the meeting told commissioners that the closet proposed well to Stay’s cabin could not be seen from his dwelling.
Stay asked Sacco if that would be true if the trees were removed and Sacco answered no.
Stay had also voiced concerns about deforestation in the area by private land owners who were selling off timber.
After a discussion about the various well sites along with the presentation of the county staff’s report, the commissioners decided to approve the zone change for the proposed wells. The lawmakers also approved the conditional use permit for their operation.