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Baseline Water Frequently Asked Questions

How will the voluntary program apply in areas where the Colorado Oil and Gas Conservation Commission (COGCC) currently has Area Rules, Well Rules, or Fieldwide Orders which already require the collection of groundwater samples?

Participation in COGCC’s Greater Wattenburg Area Rule 318A.e.(4), COGCC’s Coalbed Methane Well Rule 608.b, or existing fieldwide orders will supersede COGA’s Program within the applicable geographic areas.

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Will the public be able to view the data?

Generally, yes.  The COGCC will post the data to its database which is currently under development.

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As a landowner, may I refuse participation in the program?

Yes. Sampling will only be conducted on private property with landowner permission granted in writing.  Participation in the program will grant the operator permission to provide copies of the laboratory results to the COGCC which will then be available for public review.

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Will landowners be provided with the testing results?

Yes. Within three months of collecting a sample, the landowner will be provided with a letter explaining the testing and analyses completed and a copy of the laboratory analytical report.  At the same time, the results will be provided to the COGCC.

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What tests will be run on the collected samples?

Samples will be analyzed for the following constituents:  major cations and anion; total dissolved solids; iron, manganese, and selenium; nutrients (nitrates, nitrites, and phosphates); dissolved methane; pH; specific conductance; and benzene, toluene, ethylbenzene, and xylene (BTEX).  Field observations at the time of sampling such as temperature, odor, water color, sediment, bubbles, and effervescence will also be recorded.

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What should operators do if elevated hydrocarbons or other indicator compounds are detected in a baseline sample that was collected prior to drilling?

With landowner approval, the operator will notify COGCC of potentially anomalous data and submit the data to COGCC for follow-up. Operators are not responsible for conducting follow-up testing, investigation, or remediation at such locations unless additional evidence implicates the operator as the responsible party for the identified alleged impact.

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Can baseline samples be collected while a well is being drilled?

Baseline samples must be collected before the well’s conductor casing has been set.

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Can operators use baseline data they have already collected?

Existing baseline sampling data that is less than three years old may be use in lieu of collecting new data, provided the data were collected in manner consistent with or equivalent to the guidelines outlined in the Program Sampling and Analysis Plan (SAP).

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Will operators need to go back and collect samples for existing wells/well pads?

This program applies to newly developed or new expansions of wells or pads, not existing wells or pads.

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How do I sign my company up for the program?

COGA is striving for 100 percent participation and we welcome all operators to join our program.  Please send an email to Andrew Casper, COGA Regulatory Counsel, at Andrew@coga.org.

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Can companies that are not COGA members participate in the program?

Yes.  Any company can participate provided that they meet program standards.  For example,  all companies that participate in the program will be required to annually confirm with COGA that they are meeting the program conditions.

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