According to a new Extraction permit posted on March 29 on the COGCC site, Extraction applied for a Modular Large Volume Tank (MLVT) Facility with 4 large freshwater storage tanks in Broomfield. The Form 2A permit shows that the facility is located just north of 160th and west of I-25 on the Weber H Unit 1 Well Pad with a surface use agreement with McWhinney. The size of one tank is noted as “Size/Volume: 42,000 bbl, 12 ft tall, 157 ft across.” You can view the permit here. Comments are due to the COGCC by April 28 and can be submitted here.
The City confirmed on March 31 that this is the “Approved Water Storage Site” referenced in the 10/24/17 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 April 2, the City has posted a notice of the permit and stated that the pad can be discussed at the next Council Oil and Gas Update Report.
These are a few of the oversight questions for the City which come to mind when reviewing Extraction’s COGCC permit and the 10/24/17 Operator Agreement:
1) Access Road: 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) No previously published maps from the City show any pipelines or access roads coming from this MLVT Facility area. The Extraction permit drawing below shows a planned access road.
2) Berming: There is no berming mentioned in the Extraction permit. The Operator Agreement does not list any requirements.
3) BMPs: The Extraction permit lists 10 BMPs for the tanks but the Operator Agreement does have any required by the City.
4) Emergency Response: The Extraction 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. A 2014 policy by the COGCC refers to catastrophic failures of these tanks for a variety of reasons.
5) Visual Mitigation: There are no visual mitigation requirements for the tanks in the Operator Agreement and there is nothing indicated in the Extraction permit.
6) Construction Timing: On page 2 of the Form 2A, 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.” This water would be needed for hydraulic fracturing and completion on the Interchange B Pad which is shown on Extraction’s March Project Schedule to begin in July. Comments to the COGCC are not due until 4/18/19.
7) Reclamation: The Extraction permit states a date of 12/15/19 for possible interim reclamation of this 6 acre pad but does not specify 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.”