After eleven days of remediation work by Extraction, the City announced on April 29 that the “soil contamination has remediated to the satisfaction of COGCC” at the future site of the Modular Large Volume Tank (MLVT) Facility containing 4 large freshwater storage tanks to be used to store the water for hydraulic fracturing of all 84 wells in the Extraction project. On April 9, Extraction had notified the City and the Colorado Oil and Gas Conservation Commission (COGCC) that they had found historical contamination (accumulated over time) from produced water while plugging and abandoning the Weber H Unit 1 Well Pad located just north of 160th and west of I-25, a legacy well site that contained tanks and a separator (see blue square on the map below). The permit for the MLVT site is still pending at the COGCC.
The City’s April 9 announcement had stated that, “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.” The City’s April 29 announcement does not state if that investigation by the Broomfield inspector has occurred.
On the COGCC Form 27, it states that, “Based on the information presented, it appears that no further action is necessary at this time and the COGCC approves the closure request. However, should future conditions at the site indicate contaminant concentrations in soils exceeding COGCC standards or if groundwater is found to be impacted, then further investigation and/or remediation activities may be required. In addition, the surface area disturbed by the remediation activity shall be reclaimed in accordance with the 1000 Series Reclamation Rules.”
The Form 27 states that, “Soil samples were collected and analyzed for organic (TPH and BTEX) and inorganic constituents (SAR, EC and pH) until the horizontal and vertical extents of the excavation were within COGCC Table 910-1 allowable limits.” (See COGCC Table 910-1 below.) In the 2180 square foot contamination area, there were 4 soil samples taken during the remediation process where the BTEX (benzene, toluene, ethylbenzene and xylene) concentrations were above the COGCC limits. The vertical extent of the contamination with the concerning BTEX levels was marked as 10 feet and there were no groundwater samples taken. 1073 cubic yards of soil were removed and dumped in the Front Range Landfill in Erie. You can read the entire Form 27 here.
Extraction has already begun drilling 10 wells on the Interchange B Pad and their schedule shows water would be needed for fracking 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.”
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.” The City did not submit any comments before the April 28 deadline but two residents did.
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 City has not published this traffic plan.
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.”
If you have questions about the remediation or permit, you can email COGCC Environmental Protection Special Chris Canfield at firstname.lastname@example.org, COGCC Permit Manager Jane Stanczyk at email@example.com, Council at firstname.lastname@example.org , or Broomfield Oil and Gas Staff at email@example.com
CONCENTRATION LEVELS 1
Contaminant of Concern Concentrations
Organic Compounds in Soil
TPH (total volatile and extractable petroleum hydrocarbons) 500 mg/kg
Benzene 0.17 mg/kg2
Toluene 85 mg/kg2
Ethylbenzene 100 mg/kg2
Xylenes (total) 175 mg/kg2
Acenaphthene 1,000 mg/kg2
Anthracene 1,000 mg/kg2
Benz(a)anthracene 0.22 mg/kg2
Benzo(b)fluoranthene 0.22 mg/kg2
Benzo(k)fluoranthene 2.2 mg/kg2
Benzo(a)pyrene 0.022 mg/kg2
Chrysene 22 mg/kg2
Dibenzo(a,h)anthracene 0.022 mg/kg2
Fluoranthene 1,000 mg/kg2
Fluorene 1,000 mg/kg2
Indeno(1,2,3,c,d)pyrene 0.22 mg/kg2
Naphthalene 23 mg/kg2
Pyrene 1,000 mg/kg2
Organic Compounds in Ground Water
Benzene 5 g/l3
Toluene 560 to 1,000 g/l3
Ethylbenzene 700 g/l3
Xylenes (Total) 1,400 to 10,000 g/l3,4
Inorganics in Soils
Electrical Conductivity (EC) <4 mmhos/cm or 2x background
Sodium Adsorption Ratio (SAR) <125