Residents living near the Livingston Pad reported hearing loud noises and seeing a white plume coming from the Livingston Pad in recent days as the drilling phase began. The reports were posted on social media and, most importantly, filed to the City and County of Broomfield (CCOB) and State complaint systems. Various descriptions of the noises included a regular jet propeller-type sound, a mechanical whine and loud clanging sounds. An Anthem Ranch resident sent CCOB a video taken from her house on Saturday night of the white plume coming from the Livingston Pad and blowing east. CCOB is investigating as described in further detail below.
It is very important to file a complaint for anything that is annoying since drilling on Livingston will last 22 weeks, followed by about nine months of completions (actual “fracking”). See the most recent June timeline here. https://www.broomfield.org/DocumentCenter/View/29674/Current-Broomfield-Project-Schedule?bidId= Please file a complaint with the City, COGCC and CDPHE. You can find the links here and further filing information described below. http://broomfieldconcerned.org/register-your-concerns/
Even if Extraction is compliant with the Operator Agreement, there should be a robust audit trail at CCOB and the State to show any impact this drilling activity is having on resident health and quality of life, in what even the COGCC referred to as an unprecedented oil and gas development near so many residents.
“Thank you for submitting your odor-related concern to the Broomfield complaint management system. The following summarizes the response to your concern:
1. Broomfield Oil and Gas Division staff contacted the Extraction drilling supervisor to confirm drilling operations that were transpiring at the time specified in the complaint. It was determined that Extraction was filling bins with dry cement in preparation for cementing operations. The bins are now full and should not need to be filled for several days.
2. Extraction was also ‘tripping into the hole’ which means they were connecting pipe and lowering it back down to the bottom of the borehole. During this process, there is no drilling occurring. In addition, during ‘tripping downhole’ operations, Extraction was not circulating any of the drilling mud and no drill cuttings were being brought to the surface.
3. Broomfield Oil and Gas Division staff continue to inspect and monitor Extraction operations at all sites, including Livingston. To date, Extraction has been in compliance with the requirements of the Operator Agreement. As a result of this complaint, Broomfield Oil and Gas Division staff will further investigate what transpired when Extraction filled the cement bins, including potential fugitive dust emissions, and work with Extraction to determine if there are methods for mitigation
Laura Davis, Assistant Director of Strategic Initiatives
City Manager’s Office”
One resident reported using the following Apple App as a simple sound level meter, but it is not essential to attempt any individual measurement before filing a complaint. https://apps.apple.com/us/app/gauges/id1056649790?fbclid=IwAR2JP0ax-e-ICf9WckANzluLiETxZK-PT5g7VW0UZyvoQfEhLAdynyQkdxI
Section 31 of the Operator Agreement details allowable noise levels and is described in detail below. In part, it states, “The Operator shall comply with all provisions of COGCC Rule 802 on Noise Abatement with respect to the Well Sites; provided, however, that the Operator and City agree that the maximum permissible noise levels to be applied under Rule 802 shall be, other than during pad construction at the Well Sites, the greater of (i) the levels set forth for the land use type of “Residential/Agricultural/Rural” under Rule 802 if measurements are taken at 1,000 feet from the sound walls at the Well Site and (ii) 4 dB(A) higher than baseline ambient sound measured at 1,000 feet from the sound walls at the Well Site.”
Since CCOB has three noise monitors around the Livingston Pad as of June 1, residents should be as accurate as possible in reporting the time of the loud noise(s). CCOB contracted with Vibra-Tech Engineers on February 21 to provide continuous noise monitoring equipment at the Interchange B and Livingston Pads. Making complaints at the time of the occurrence is best, but they can also be filed later with notes like “last night I couldn’t sleep due to the constant clanging of pipes throughout the night.”
HOW TO FILE A COMPLAINT
Residents should file a complaint with both CCOB and the State. Make sure to include name and contact information (phone number, email address) so that you get a response from both CCOB and the Colorado Oil and Gas Conservation Commission (COGCC).
File a complaint with the City here:
File a complaint with the COGCC here:
When you file a complaint at COGCC, use the Livingston Pad Facility ID as #455317 and name the Pad as Livingston Pad. There is a spot in the complaint form for that.
A resident provided an example of the information that you can expect to be asked to provide, as written in the acknowledgement response that you will receive from the COGCC. The resident took out any personal identifying information and added a few comments for filing either a noise or odor complaint, the most common problems reported for Interchange Pad drilling.
“COGCC received your complaint
|Date of Complaint||Date of complaint|
|Your Name||Your Name|
|Your Address||Your address|
|Your City and State||Broomfield CO|
|Your Zip Code||800XX|
|Your Phone (Used only to follow up)||XXX-XXX-XXXX|
|Type of Complaint (Click all that apply)||Select the appropriate complaint|
|Location of Concern||Put your address or, if you are driving, include the cross streets.|
|Detailed description of the issue or issues.||Noise – Describe what it sounds like. State that it is coming from the Livingston Pad (assuming you can determine that). Include the time of the incident and any impact it is having on your health (e.g. loss of sleep). If odor/air quality, note the direction of the wind and if the wind is variable, high, low, air inversions, etc. Be as specific as possible. Note if this is having any impact on your health, e.g. throat/eye irritation, difficulty breathing. If an odor, what exactly does it smell like? Is it oil, solvent, not sure, rotten eggs, etc?|
|Do you know who the oil and gas company is? If so, please specify and if you contacted them already please indicate that and who you talked with.||Extraction|
|Well or facility name and number (If known).||455317 <–this is the Livingston Pad Facility ID|
|Have you contacted any other agencies or local governments related to this issue or issues? If so, please provide details.||Broomfield complaint portal|
|What is your preferred method for the COGCC to communicate with you throughout the investigation? (Select all that apply)||e-mail This allows the COGCC to email you the final report and for the inspector to call you
|Would you like to answer additional optional questions related to the issues you are experiencing? If so, click the appropriate issue from the below list. If not, click “NO”. Then click “Continue”.||NO — I JUST WANT TO SUBMIT NOW|
PERTINENT REGULATIONS TO NOISE PROBLEMS
Exhibit B – Best Management Practices
“31. Noise Mitigation.
Noise mitigation measures shall be constructed along any edge of any Well Site if such edge is in proximity to existing residential development. The noise mitigation measures shall use the most current equipment to minimize noise impact during the Drilling and Completion Phases, including those measures set forth in Sections 2 and 18. Operator shall comply with the sound limitation regulations set forth in COGCC 800 Series Aesthetic and Noise Control Regulations. The Operator shall not unload pipe between 8:00 p.m. and 7:00 a.m. The Operator will complete a baseline noise mitigation study at each Well Site that demonstrates that noise is expected to be mitigated to the extent practicable and a copy will be provided to the City. A noise mitigation study has been completed that demonstrated that noise is expected to be mitigated to the extent practicable and to levels acceptable to the City. The Operator shall address C scale noise/vibration through berming and other associated BMPs. During the Drilling and Completion Phases, the operator shall construct a perimeter wall and/or use hay bales to mitigate noise as appropriate on a case-by-case or modeled basis. If Operator uses any engines that are not electrically operated, Operator shall use quiet design mufflers (also referred to as hospital grade or dual dissipative) or equivalent and shall use acoustically insulated housing or covers to enclose the engines.
The Operator shall comply with all provisions of COGCC Rule 802 on Noise Abatement with respect to the Well Sites; provided, however, that the Operator and City agree that the maximum permissible noise levels to be applied under Rule 802 shall be, other than during pad construction at the Well Sites, the greater of (i) the levels set forth for the land use type of “Residential/Agricultural/Rural” under Rule 802 if measurements are taken at 1,000 feet from the sound walls at the Well Site and (ii) 4 dB(A) higher than baseline ambient sound measured at 1,000 feet from the sound walls at the Well Site. During pad construction at the Well Sites, the Operator agrees that noise levels shall not exceed those produced by the construction of a typical residential or commercial development. All measurements considered for compliance with this Section 3 1 shall be taken by a third party contractor using industry standard equipment and practices.”
“802. NOISE ABATEMENT
a. The goal of this rule is to identify noise sources related to oil and gas operations that impact surrounding landowners and to implement cost-effective and technicallyfeasible mitigation measures to bring oil and gas facilities into compliance with the allowable noise levels identified in subsection c. Operators should be aware that noise control is most effectively addressed at the siting and design phase, especially with respect to centralized compression and other downstream “gas facilities” (see definition in the 100 Series of these rules).
b. Oil and gas operations at any well site, production facility, or gas facility shall comply with
the following maximum permissible noise levels.
ZONE 7:00 am to next 7:00 pm 7:00 pm to next 7:00 am
Residential/Agricultural/Rural 55 db(A) 50 db(A)
Commercial 60 db(A) 55 db(A)
Light industrial 70 db(A) 65 db(A)
Industrial 80 db(A) 75 db(A)
The type of land use of the surrounding area shall be determined by the Director in consultation with the Local Governmental Designee taking into consideration any applicable zoning or other local land use designation. In the hours between 7:00 a.m. and the next 7:00 the noise levels permitted above may be increased ten (10) dB(A) for a period not to exceed fifteen (15) minutes in any one (1) hour period. The allowable noise level for periodic, impulsive or shrill noises is reduced by five (5) dB (A) from the levels shown.
(1) Except as required pursuant to Rule 604.c.(2)A., operations involving pipeline or gas facility installation or maintenance, the use of a drilling rig, completion rig, workover rig, or stimulation is subject to the maximum permissible noise levels for industrial zones.”