On April 9, Extraction notified the City and the Colorado Oil and Gas Conservation Commission (COGCC) that they found historical contamination (accumulated over time) from produced water while plugging and abandoning the Weber H Unit 1 Well Pad, a legacy well site located just north of 160th and west of I-25 that contained tanks and a separator (see blue square on the map). This is the future site for the Modular Large Volume Tank (MLVT) Facility with 4 large freshwater storage tanks to be used to store the water needed for hydraulic fracturing of all 84 wells in the Extraction project. The City’s announcement states, “A Broomfield inspector is in the process of acquiring additional information and will conduct a site investigation to further evaluate site conditions and review Extracton’s plan for remediation.”
Extraction has already spudded 10 wells on the Interchange B Pad and their schedule shows fracking when water would be needed to begin in July 2019. This MLVT Facility on the former Weber Pad is the “Approved Water Storage Site” referenced in the Operator Agreement (p. 8, number 11). The fresh water will then “be transported via pipeline from the Approved Water Storage Site to each of the Well Sites for use during hydraulic fracturing and completions operations.” On page 2 of the COGCC Form 2A for the MLVT Facility, it states that construction will begin on 05/15/2019. However, in the comments on page 7 of the Form 2A, it states, “Anticipated timeframe on location: Initial construction of the MLVTs is planned to begin June 2019.” Those dates are not internally consistent and the City’s announcement did not speculate how long it expected remediation to take.
On March 29, the COGCC posted Extraction’s permit for the MLVT facility. The size of the tank is noted as “Size/Volume: 42,000 bbl, 12 ft tall, 157 ft across.” You can view the permit here http://cogcc.state.co.us/weblink/results.aspx?id=401631392 . Comments are due to the COGCC by April 28 and can be submitted here https://cogcc.state.co.us/publicComment/?doc_num=401631392
The City has indicated that lay flat pipes will come from a nearby ditch to bring the water to the MLVT Facility. Lay flat pipes will also be used from the MLVT to the Extraction pads. According to the Operator Agreement, “The Operator will submit a traffic plan to the City that includes detailed descriptions of all proposed access routes for equipment, water, sand, waste fluids, waste solids, mixed waste, and all other material to be hauled on the public streets and roads of the City.” (p. 41, number 40) The map at the right was published with today’s announcement and does not seem to have been published previously.
There are other oversight questions which come to mind when reviewing the permit and the 10/24/17 Operator Agreement:
1) Berming: There is no berming mentioned in the permit. The Operator Agreement does not list any requirements. There is evidence in COGCC documents of a history of leakage from tanks.
2) BMPs: The permit lists 10 BMPs for the tanks but the Operator Agreement does have any required by the City.
3) Emergency Response: The permit states, “Operator has developed a contingency plan/emergency response plan associated with the MLVT and it is on file at their office.” It is not clear why the operator would not give that plan to the City and conduct conversations with the City about its adequacy.
4) Visual Mitigation: There are no visual mitigation requirements in the Operator Agreement and there is nothing indicated in the permit.
5) Reclamation: The permit states a date of 12/15/19 for possible interim reclamation of this 6 acre pad but does not list what that will look like. In the Operator Agreement, it states, “At the completion of Operator’s plan of development, Operator will remove the water tanks and plug and reclaim the existing well at the Approved Water Storage Site in accordance with state law and regulations and the Broomfield Municipal Code.”