The Energy and Carbon Management Commission (ECMC) on June 26 said it has issued a notice of alleged violation to Noble Energy Inc., the operator of the Bishop A 18-742 well, after a well-control blowout on April 6 that led to evacuations and an ongoing, multi-parcel remediation effort near Galeton in Weld County.

At a special online hearing, Greg Duranello, deputy director of operations for ECMC, told commissioners: "This morning, ECMC issued a notice of alleged violation, also called an NOAV, to Noble Energy." He said the NOAV alleges violations of multiple ECMC rules and includes staff-established corrective actions; the NOAV document number is 404256913 and was posted to the COGIS database and ECMC’s Bishop incident web page the same day.

The NOAV begins a formal enforcement process that, under ECMC procedure, requires the operator to file an answer; ECMC staff then may seek adjudication before the commission, and penalties are calculated under the agency’s administrative rules. Chair Jeff Robbins emphasized the separation between staff enforcement and the commission’s adjudicatory role, saying the NOAV “comes to commission for final decision.”

Why it matters

ECMC staff said the blowout released formation fluids and required an immediate unified response from local and federal agencies. Kyle Wagoner, ECMC’s Eastern Environmental Supervisor, summarized the scale of sampling and site work that staff are overseeing: "As of June 13 ... 730 surface water samples have been collected, 2,203 soil samples have been collected, 475 air samples have been collected ... on the ag properties, 4,957 acres have been covered, which encompasses 115 properties, and for residential, approximately 297 acres have been covered, which encompasses 107 properties." Wagoner also said 29 monitor wells have been installed near the Bishop pad and that remediation work has been divided into roughly 300 parcel-level investigations to manage a roughly 1.5-mile radius assessment area (about 4,500 acres).

What investigators found and operator’s analysis

Chevron (which owns Noble Energy Inc.) submitted a supplemental accident report (Form 22) on June 10 that included a root cause analysis. ECMC staff reviewed the analysis and said they do not dispute its technical findings. According to the operator’s submitted diagrams and ECMC’s presentation, the root cause identified by Chevron was improper assembly of key components of the tubing hanger/running-tool assembly during the transition to install the production tree after hydraulic fracturing. That improper assembly, the operator reported, allowed the tubing hanger to unseat when the production tree was being set; the unseating permitted pressurized fluids to escape and started the blowout. ECMC staff said one person was struck by the falling wellhead and sustained a broken leg.

Chevron’s proposed corrective measures reported in its Form 22 — as summarized by ECMC staff — include assembling the tubing hanger components in a shop to specified torque rather than assembling them in the field and using downhole packers as a secondary barrier during future wellhead transitions. ECMC framed those measures as steps intended to prevent recurrence while noting that broader industry discussions about on-site protocols and barrier redundancy are underway.

Regulatory and investigatory steps to date

ECMC staff provided a timeline for regulatory activity: the blowout occurred April 6; contractors stopped the flow April 10 and the response team declared the well secured on April 11. ECMC posted its review of Chevron’s environmental sampling and analysis plan (ESAP) on April 17 and issued a notice to operators (NTO) on April 25 that asked operators to review post-stimulation wellhead procedures; 52 submissions were received in response to the NTO, and ECMC flagged several for follow-up. Chevron has submitted thousands of laboratory reports and site forms as remediation and sampling continue.

Staff said remediation is being conducted under ECMC oversight and that the operator is responsible for cleanup. Mike Leonard, ECMC’s QA/QC manager, described the NTO as an industry communication tool: "They’re a message to the operating community that ECMC has identified something that needs to be addressed or clarified to the operators." He said most operators responded and that ECMC followed up where submissions were incomplete.

Enforcement and next steps

ECMC staff said the NOAV alleges violations of six ECMC rules spanning safety and impact standards; those specific rule citations are included in the NOAV posted to COGIS. The NOAV also lists corrective actions the staff seeks to abate the alleged violations and prevent recurrence. ECMC described the NOAV as the start of an administrative enforcement process: the operator may file an answer and may contest allegations, and the matter may proceed to an adjudicatory hearing before the commission.

During the hearing commissioners and staff emphasized transparency and community outreach. Duranello noted ECMC’s fourth update to the commission on the incident and pointed commissioners and the public to a dedicated web page with plain-language summaries, data links, and contact information. He thanked ECMC community liaison Kristen Kemp and the array of state and federal partners involved in the response, including the U.S. Environmental Protection Agency, OSHA, the Colorado Department of Public Health and Environment, Colorado Parks and Wildlife, the Colorado Department of Agriculture, Weld County agencies and Galeton Fire Rescue.

What remains unresolved

Staff said sampling and parcel-level investigations will determine when individual parcels can receive a "no further action" determination; timelines vary by parcel and are data dependent. Staff also said the total volume of fluids released remains uncertain. As Duranello put it during the hearing, "we still don't quite know" the total volumes released. The enforcement process under Rule 5 23 and the commission’s administrative procedures will govern how alleged violations are adjudicated.

The commission did not take a vote during the special hearing; ECMC staff issued the NOAV and described next steps in oversight, remediation and enforcement, and the matter will return to the commission if adjudication proceeds to a hearing.