In response to public comment made during their October 29th meeting, Ellice Devine, ECMC UIC Program Coordinator gave an update on data issues discovered in produced water reporting.
In Summary:
- Reporting inconsistencies discovered: While reviewing Form 7 produced water reports (required since September 2023), staff found operators reporting disposal at closed facilities, abandoned locations, spill/release IDs, and lease IDs, none of which are appropriate disposal locations.
- Root cause identified: The errors appear most common among operators using commercial UIC facilities, likely because commercial operators reroute produced water based on logistics without communicating changes back to the producing operators.
- No safety concerns: The misreported volumes represent “a minute fraction of total disposal volumes”, and this is “purely a data reporting problem”.
- Corrective actions planned: ECMC will modify business rules to alert or prevent submission of incorrect facility IDs, update guidance documentation, contact operators to request corrections to existing data, and may pursue enforcement action for non-compliance.
- Quality assurance success: Commissioner Messner praised this as an example of effective quality control for Colorado’s relatively new (less than 2 years old) and potentially nation-leading produced water reporting requirements.