On June 15, I sent a letter with several attachments to Mr. Joe Malloy, who is Chief of Pipeline Safety for the Colorado Public Utilities Commission (COPUC). The purpose of my letter was to outline my concerns about Ursa’s pipeline proposal within the Battlement Mesa PUD. I also copied Matt Lepore at the COGCC.
To begin with, the design of the pipeline showed a lack of awareness that gathering lines are subject to PHMSA regulations that are supposed to be enforced by the COPUC. For instance, homes and apartment buildings are considered High Consequence Areas (HCA) under existing PHMSA rules. Pipelines that will be built near HCAs, like Ursa’s proposed pipeline in Battlement Mesa, are subject to more specific requirements.
Garfield County did not include the COPUC among the agencies that were notified [pg 10 of PDF] about Ursa’s pipeline proposal. However, the ultimate responsibility of compliance and Integrity Maintenance (IM) falls on the operator. Wherein the operator and landowner entered into negotiations over final pipeline locations and were either unaware or unmindful of these increasing hazards, by reducing distance mitigations resulted in even more buildings being in Potential Impact Radius (PIR) or Zone (PIZ). It would seem qualified designers would advise those using the pipeline and land owners of such actions and the Operator would need to be cognizant of the added responsibility they are acquiring. The County should also be made cognizant that operators not observing increased IM may have greater chances of disasters they will have to respond to and have disaster/evacuation plans.
According to the Engineer Certification that was on the Site Plan, it basically certified compliance to certain county land use regulations and added a disclaimer to any “construction means and methodologies” which could include engineering, design, materials, or construction requirements. It is not a submittal to demonstrate the construction of a pipeline, it is only a placement and landscape guide (grade plan) as needed for county regulations. In my review of these submittals, I did not find operating specifications, corrosion protection, standards, inspections, or testing to use for determination of pipeline integrity or soundness.
Moreover, two Steel Bore Details [pg 9 of PDF] do not show the presence of the two 8” water lines and are either incorrect or notes on the plan that imply the water lines are in casing are incorrect. However, if the two water lines are fitted inside the 24” steel bore casing with the 12” gas pipe, the spacers/skids would be totally different in configuration and could seriously reduce friction holding inner pipes in place. Pipe-to-pipe contact can create corrosion problems and future full inspection could be near impossible. Construction assembly would be critically pressed not to damage pipes.
In the Geologic Hazard Report prepared by Olsson Associates [pg 15 of PDF], the Executive Summary identified the following geologic hazards:
- The soils in the vicinity of the Site are corrosive to steel and moderately corrosive to concrete due to high salt content.
- According to the Preliminary Geologic Map of the Grand Valley Quadrangle, Garfield County, the proposed Site is located on Quaternary age (Holocene) mud flow and fan gravel deposits.
- The Site is not mapped as being in an Alluvial Fan Hazard area, but is located on alluvial fan deposits associated with Battlement Creek and unnamed intermittent drainages.
- The Site is not mapped within the FEMA 100-year flood plain, but is located within 650 feet of the Colorado River. There is an unnamed drainage 520 feet to the northeast and another unnamed drainage 760 feet southwest of the BMC D Pad. The areas immediately adjacent to the banks of these drainages are prone to flash floods.
The downhill section of Ursa’s proposed pipeline cuts under many drainage channels including “D pad” drainage and the access road runoff as a means to minimize slope to the last point of drop-off. In March 2014, around the bend of the Colorado River upstream from the town of Parachute, close to the north end of the Battlement Mesa golf course, WPX experienced the failure of a down-the-hill 16” gathering gas line caused by a land slump after some heavy rainfalls. The pipeline was of the same type of design, in the same type of soils and geologic profile as the proposed Ursa pipeline. The WPX line did not have two 8” water lies to further disrupt integrity, but all it took was water from a heavy rain.
Furthermore, the construction on the proposed Ursa pipeline would add disturbance and load within the hillside, actually increasing the likelihood of slope failure. Slope failure can create water supply problems for the nearby Battlement water treatment plant intake.
A Mountain Cross Engineering review [pg 3 of PDF] of Ursa’s pipeline application generated the following comments which echo some of my same concerns (Ursa is the Applicant):
- The Applicant should identify what will be used to pressure test the pipeline and also the associated filling, emptying, and disposal.
- The application materials have Kahuna Ventures as the engineer on the application. The plan sheets were prepared by River Valley Survey Inc. The “Engineer’s Certification” was by Matrix Design Group. The Applicant should clarify who the design engineer is for the project.
- The trench detail should be revised to be congruent with the “Conditions to all Pipeline Grading and Installation Permits” of Garfield County.
- The plans show that silt fence is placed continually along the edges of disturbance. This BMP may not be appropriate for concentrated flows. The plans should be revised to show a more appropriate BMP where the pipe trench crosses areas of concentrated flows.
- It is unclear from the plans if the waterlines are also to be bored. The Applicant should clarify and add details as necessary.
From what I could determine there is no indication or evidence that Ursa has addressed any of these recommendations.
The purpose of regulation is to provide for situations that demand extra inspection, record keeping, and Integrity Maintenance. Regulations do not address alternative planning. However in the case of Ursa’s proposed pipeline:
1) the operator should be informed of the HCA requirements that must be met;
2) any approvals sanctioning the plan of the bored pipeline down the bluff (Sheet 3) should be reviewed by competent 3rd party; and
3) if any preapprovals from the COPUC are needed, they should be involved with this plan.
The choice of Colorado regulators to allow drilling in urban areas, and not invoke mandatory alternate use wherever possible, means that an agency such as COPUC must make sure those elements of their regulation are not allowed to fall through the cracks of “we don’t regulate that” porosity of regulatory responsibilities.
As of this posting, I have yet to receive any acknowledgement or reply to my letter.
*Bob Arrington, P.E., is the Battlement Mesa citizen representative on Garfield County’s Energy Advisory Board (EAB), and he represents the Grand Valley Citizens Alliance and the Battlement Concerned Citizens. He is also a Director-at-Large for Western Colorado Congress.