According to an August 1 announcement from the City and County of Broomfield (CCOB), CCOB will hold a special Council meeting on August 13 to consider whether to sell water to Extraction for usage in mixing cement for drilling operations. The announcement claims that Extraction needs clean water in order to “assure their [well casings] physical integrity” and that “the ditch water they [Extraction] have purchased from others for use in their Broomfield operations does not provide the consistency of water quality necessary for the drilling and the cement to be used in constructing the well casing.” The announcement did not state the amount of water that Extraction is requesting.
The CCOB announcement states that “Extraction has been trucking in clean water for the drilling phase.” Residents near the Interchange B Pad raised questions about the number of trucks coming in during the drilling phase, but their concerns were not addressed during the drilling of 12 wells there from April 20 to the end of June. Extraction started drilling 16 wells on the Livingston Pad in mid-July and drilling is scheduled to continue there through November. Since trucking is “the greatest risk to the community’s health and safety through the drilling and development phases,” CCOB proposes “to eliminate 690 truck trips to the site” by selling Extraction the water and then “the water will be delivered to each well pad site using lay-flat hose.”
In drilling operations, the quality of the cement is important to long-term well integrity over the lifespan of the well. The State of Colorado does not currently test the quality of cement used in drilling operations, but there are proposals to increase cement monitoring through the SB19-181 COGCC rulemaking process for well integrity beginning in the fall.
Residents can write to Council at email@example.com to express their opinions on this matter. The phases of oil and gas development are pad construction, drilling, completion and production, as found in Extraction’s timeline here. Here are relevant excerpts from the Operator Agreement:
Exhibit B: BMPs
BMP #3 p. 24
“3. Use of Pipelines. The Operator agrees to build pipelines for the transport of oil, gas, and produced water from the Well Sites to the specifications set forth in Exhibit D and to utilize such pipelines at the Well Sites before the Production Phase commences. During the Completion Phase, the Operator will use pipelines for produced water for flowback to the maximum extent feasible. All fresh water shall be transported to the Well Sites by means other than by truck. The Operator’s obligation to build and utilize such pipelines is subject to the City granting Operator all necessary right-of-way and the City issuing Operator the necessary Public/Private Improvement Permits. Operator shall be permitted to utilize temporary tanks during drilling, flowback, workover, completion, hydraulic fracturing and maintenance operations. If requested by the City, Operator will conduct a risk analysis to identify potential risks associated with pipelines and the measures implemented that are intended to mitigate such risks.”
BMP #9 p. 25 “…Other than for irrigating landscape material, Operator shall not use City water for any of its oil and gas operations…”
BMP #40 p. 41
“40. Transportation and Circulation. The Operator will comply with all Transportation and required by the City’s Traffic Engineer and will comply with all applicable hazardous material regulations. 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.”
BMP #42 p. 42
“42. Water Supply. The Operator agrees to comply with applicable State of Colorado, Department of Natural Resources and other applicable State regulations concerning the source(s) of water used in the Drilling Phase and Completions Phase. The Operator shall notify the City, upon its request, of the source(s) of water to be used at Well Sites during the Drilling Phase and Completion Phase and will provide the City with an estimate of the volumes of water to be utilized, with such estimates subject to change. All water volumes actually used by Operator shall be reported by the Operator to the State of Colorado in accordance with its regulations.”
Body of Agreement #11 p. 8
“11. Approved Water Storage Site. “Approved Water Storage Site” means the Weber H Unit 1 Well Pad, which was approved by the City on February 12, 2013 for a use by special review permit by Resolution No. 2013-22. Operator is permitted to use the Approved Water Storage Site for fresh water storage. Fresh water will be transported via pipeline from the Approved Water Storage Site to each of the Well Sites for use during hydraulic fracturing and completions operations. The City will grant underground and surface pipeline right-of-way or licenses as necessary for the transportation of water to and from the Approved Water Storage Site. 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.”
The Weber Unit 1 Well Pad needed remediation from historical contamination (accumulated over time) from produced water found while plugging and abandoning the legacy well there.