ECMC engineering unit details life-cycle forms, integrity inspections and UIC primacy plans
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Summary
ECMC engineering staff described the unit’s oversight across the life cycle of wells—permit reviews (Form 2), completion reporting (Form 5), plug-and-abandon (Form 6), flow line reporting (Form 44), UIC permits (Forms 31/33)—and outlined inspection, audit, and risk-modeling work, plus pursuit of class-6 UIC primacy for carbon sequestration.
At the Jan. 14 Energy and Carbon Management Commission meeting, the ECMC engineering unit described technical reviews and enforcement tools used to protect groundwater and ensure well integrity from permitting through plug-and-abandon.
Diana Byrne, engineering manager, and engineering supervisors Diane McCoy and Elise Whittington summarized how the unit applies a life-cycle approach: area engineers review Form 2 applications (permit to drill) for casing, cementing and surface-casing depth to isolate groundwater; Form 5 completion reports verify construction and COA fulfillment; Form 6 documents plug-and-abandon notices and subsequent reports; Form 21 documents mechanical integrity tests; and Form 44 captures off-location flow line activities. "The form 6 subsequent report of abandonment documents how the PA was executed," McCoy said.
Whittington outlined integrity and flow-line programs: the integrity group inspects and audits operators, witnesses tests, reviews Form 12 (gas facility reports) and Form 19 (spill/release reports), and compiles annual summaries of spills and releases. She explained the UIC program’s role under the Safe Drinking Water Act and the department’s long-standing primacy of class 2 wells (since 1984) and noted staff are pursuing primacy for class 6 wells for carbon sequestration.
Presenters emphasized protections used in permitting and oversight: offset-well evaluations (policy originating in 2012 and incorporated into rulemaking in 2020) and conditions of approval applied to ensure older wells meet current isolation standards; a requirement to repair or plug wells within six months of discovery of an integrity issue; step-rate tests and volumetric/pressure limits for injection permits; and cross-agency consultation (Division of Water Resources, EPA, CDPHE and CPW) when appropriate. The engineering group also described ongoing work with the Colorado School of Mines to develop a quantitative, machine-learning risk model for flow lines and efforts to rectify discovered reporting discrepancies through QA/QC and auditing.
