The report, “Lessons Learned” in the Front Range Flood of September 2013 is the result of a COGCC workshop held in Denver on February 6, the first public discussion of the flood damage in the gasfields.
According the report:
Energy companies shut down 2,658 wells, with about 89 percent of those, or 2,360 wells, returned to operation as of March 14.
All but five of the 1,614 wells in the COGCC’s designated flood zone were shut down. Those five wells, three of them owned by small companies, didn’t have remote shut-down capability — but none of those five wells were the source of flood-related spills.
The COGCC staff has made more than 3,400 on-site inspections related to the floods that swept through communities north of Denver between the foothills and the state line.
Spills resulting from the flood:
- About 48,250 gallons (1,150 barrels) of oil and condensate (a mixture of natural gas and water).
- More than 43,478 gallons (1,035 barrels) of produced water (a mixture of water and fluids used in hydraulic fracturing that flows out of a well).
Citing test results from samples taken by the Colorado Department of Public Health and Environment and the U.S. Geological Survey the report states: “These spilled materials were greatly diluted by the flood waters [and] … are now undetectable.”
Here are some suggestions which would only apply to wells and operations near waterways.
- Inventories of wells and equipment.
- Automatic shut-in valves for wells within a designated distance of the normal high-water mark. These were very effective during the September flood.
- No pits allowed within a designated distance of the high water mark.
- Secondary containment constructed of steel berms and synthetic liners around wells and tanks. No earthen berms.
- Tanks and equipment must be secured to the ground with anchors and cables.
- Structural fencing must be located upstream to protect the well site.
- Tanks and production equipment should be located as far from waterways as possible.
- COGCC should upgrade its emergency management procedures.
However Colorado has more than 5,900 oil and gas wells within 500 feet of named rivers and streams, and the number grows to 20,850 wells with the inclusion of dry drainage ditches that flood during heavy rains. Noticeably missing from the report are any suggestions to require greater setbacks from our waterways.
Which is why some conservationists are crying foul.
“This doesn’t go far enough,” said Bill Dvorak, a public lands organizer for the National Wildlife Federation. “We really need riparian setbacks to keep oil and gas operations away from streams.”
Laura Belanger, a water resources and environmental engineer with the Western Resources Advocates conservation group, said the only waterway setback rules in place now are designed to protect municipal water supplies, cold-water trout fisheries, and designated Gold Medal fishing waters. She hopes the issue of setbacks will be looked at when flooding regulations are considered. “Just having these important protections as recommendations is not sufficient,” she said. “I definitely think it’s very complicated and complex and needs to be looked at on a situational basis. But I think we need to remember that the waters of the state are a public resource and they need to be properly protected.”
Commission spokesman Alan Gilbert said commissioners will discuss the report’s findings at their next meeting April 28 and decide which, if any, new regulations are needed. “New rules typically take six months to a year or more to promulgate. In this instance, the commission said … that it understands the need to move as quickly as reasonably possible with this process.”
“We are sure there will be vigorous discussion about the best ways to proceed with industry and others,” Gilbert said. “But we welcome that vigorous discussion. It always makes the regulation or policy better.”
Of course, any new regulations will only be considered as long as the oil & gas industry doesn’t mind too very much.
And boy howdy, do they ever mind.
In a statement also released on Monday, Colorado Oil and Gas Association (COGA) President and Chief Executive Tisha Schuller said, “The floods were a difficult and trying event for everyone, and we are proud at our ability to engage meaningfully in the response and recovery of our Colorado communities. The flood report reiterated facts supporting that Colorado’s oil and gas industry was extraordinarily well prepared, responded in real time, and is committed to Colorado’s recovery.
“Our industry prepares for all sorts of disasters with emergency response plans and drills; in this case, we were quick to respond with remote and manual shut-in of wells, deployment of thousands of employees, and implementation of 24-hour emergency operations centers.
“COGA does not believe any legislative or statutory changes are necessary. We will continue to work with the commission to share lessons learned and continually improve best management practices.”
Denver Business Journal: Colorado issues oil & gas recommendations after historic 2013 flood
Northern Colorado Business Report: Report recommends changes to oil/gas regs
Daily Sentinel [subscribers only]: New rules needed for well safety, report says