Completions Starting on Interchange B: Are There Tier 4 Engines and a Complete Freshwater System?

Extraction is set to begin fracking in the completions phase on the Interchange B Pad as early as July 13, according to an announcement by the City and County of Broomfield (CCOB).  At around 7 pm on July 12, the photo shows just a few of the many Liberty Fleet trucks rolling inside the walls of the Interchange B Pad.  This was happening as residents were still asking questions if the freshwater layflat piping system was in place and if Tier 4 engines were being used to protect air quality instead of Tier 2.

It was not clear until mid-afternoon on July12 that a partial freshwater piping system was in place to be used for fracking.  As late as the July 8 Oil and Gas Update, CCOB had stated that “Modular Large Volume Tanks (MLVTs) are being constructed and lay flat pipe to all six well pads will be placed in the near future.” In a mid-afternoon July 12 email from Staff in response to a resident’s inquiry, the response stated that, “The layflat to the Interchange B Pad is in place and will run water directly from the Frico Community Ditch to the Interchange B Pad.  The Large Volume Tanks are under construction and are currently estimated to be complete in two weeks.”

Another resident wrote a subsequent email to Staff to ask if the use of the Frico Ditch would “short its agricultural allocation to sell to fracking.”  The resident also added, “although principally used for irrigation, it is also a valuable resource for protecting and enhancing riparian corridors that are used by nesting birds, and as migration corridors for wildlife. Waterfowl and amphibians also use these ditches and the ecosystems they create.”

The hydraulic fracturing of each well can take several million gallons of freshwater, so the Operator Agreement required that this be piped in to save “130,000 truck trips from area roads during the completions phase of operations,” according an earlier Extraction announcement.  The original plan was to store water in the tanks at the Webber H-1 MLVT facility north of 160th and east of Huron to feed into the pipes, but the MLVT had to first be remediated due to a leak that was discovered in cleaning up a legacy well.  That remediation was completed and the COGCC approved the permit at the end of May.

There are also concerns if Extraction is using Tier 4 engines to protect air quality in line with the Operator Agreement.  At 3 pm on July 12, a resident wrote the following email to CCOB but did not receive a reply from Staff:

“Well completions must not commence using Tier 2 Frac Pumps on Interchange B as this is a violation of the BMPs included in the City agreement with Extraction:

  • Air Quality BMP 20(A)(2) requires that if Tier 4 fracking pumps become commonly available, the Operator will begin using Tier 4 fracking pumps.
  • Per Section L of the CDP, the Operator will be using Cummins QSK 50L engines which are now commonly available per a Cummins technical expert.

Note: Cummins Tier 4 engines were designed to fit the same specifications as the Tier 2 engines to allow for retrofit on existing systems.

Per CDP Section (L) Facility Emissions for a 29 well site, the Frac Pump engines are the major contributor to the overall emissions during well completions with 191 tons/year NOx, 1.3 tons/year PM10, 226 tons/year CO, 209 tons/year VOC, and 0.21 tons/year benzene. Switching to Tier 4 engines will result in a 45% reduction in NOx and an 80% reduction in PM. As a reminder, an APEN would typically be required for annual emissions above 2 tons/year VOCs and 5 tons/year NOx for our region. These emissions are significant, which is why the EPA has required manufacturers to reduce emissions through Tier 4 standards for non-road engines.

Per the Broomfield Charter, it is a requirement that the City protect the health and safety of the residents. Certainly, the use of Tier 2 engines which were an EPA requirement in 2006 should not be utilized. Tier 4 technology is readily available. At this point in time, all Cummins needs in the frac pump engine serial numbers to provide the process of switching out the Tier 2 engines for Tier 4 engines.”

You can read Extraction’s basic description of completions operations here.  It also will likely raise resident concerns about the increase in the number of trucks carrying sand and chemicals going to the site.  It is also well known that operators engage in flaring operations during overflow conditions in flowback operations, resulting in the release of emissions dangerous to residents’ health and the climate.  Residents have been questioning if CCOB Air Quality monitoring data will be used in a timely manner to prevent this.

Extraction’s announcement has the following description of the completions phase:

  • “Hydraulic Fracturing – Pumping water and sand at a high pressure and rate to create a flow channel between the wellbore and formation. Depth ranging from 7,000 to 25,000 feet.
  • Coiled Tubing – Coiled tubing is commonly used to mill out plugs that are set during the plug and perforation process during hydraulic fracturing.
  • Work over rig – The work over rig will be on site after coiled tubing has milled out plugs in order to install a smaller diameter tubing in the wellbore to help flow the well.
  • Flowback – After the wells have been fractured, milled, and have production tubing installed the flowback process begins. Initially most of the fluid that flows back is water.”

The drilling of twelve wells on Interchange B was completed over the period from April 20 to the end of June, despite many health and safety complaints from nearby residents to CCOB, the Colorado Oil and Gas Conservation Commission (COGCC) and the Colorado Department of Public Health and Environment (CDPHE).  These complaints centered on the usage of odorous, carcinogenic drilling mud Gibson D822 as residents suffered from short-term health impacts like sore throats, nosebleeds, and asthmatic complications and also questioned long-term health risks.  After numerous complaints as drilling began on the Livingston Pad, Neoflo 4366 is now being used as the drilling mud there.  There were also numerous Extraction truck traffic violations reported during that period at Interchange B that did not result in any fines.

Additionally, Extraction has not secured all the mineral rights for the Interchange B Pad.  COGCC Docket Number 190400292 is a forced pooling protest for Huron South, a spacing unit for the Interchange B Pad.  This forced pooling protest hearing has not yet been held at the COGCC as most hearings have been delayed.  Under interim COGCC guidelines following the passage of SB19-181, the operator must prove that they have secured 45% of the mineral interests in a spacing unit and made reasonable lease offers in good faith before a forced pooling order can be considered by the COGCC.  However, even though the hearing has not yet been held, current COGCC rules do not prohibit the operator from taking unleased minerals in fracking operations before securing them in forced pooling, at the operator’s own risk of incurring civil suits by mineral owners.