January 29, 2014 Director Matt Lepore Colorado Oil and Gas Conservation Commission 1120 Lincoln Street, Suite 801 Denver, Colorado 80203 Submitted via email to: [email protected] Director Lepore, Please accept this letter from Western Resource Advocates (WRA) commenting on the Colorado Oil and Gas Conservation Commission’s (COGCC) January 3, 2014 draft Policy on the Use of Modular Large Volume Tanks in Colorado. WRA appreciates that the COGCC recognizes the growing use of modular large volume tanks (MLVTs) and the potential hazard they may pose to public safety, health and the environment without heightened attention to their proper design, siting, installation and oversight. We also appreciate the opportunity to comment on the draft policy. WRA supports the COGCC’s draft policy and strongly believes that MLVTs should only be used to store fresh water. Founded in 1989, Western Resource Advocates (WRA) is a non-profit environmental law and policy organization with a mission to protect the West’s land, air and water. We have a long history of involvement with the COGCC with the goal of ensuring public health, our air and water, and the environment are protected. Our interest in MLVTs is to ensure that the COGCC policy is sufficiently protective of these same resources. As stated in the draft policy, MLVT technology is emerging. The five catastrophic failures identified by the COGCC illustrate that both the construction and use of MLVTs is not yet tried and true. Per the draft policy the cause of failures have been wide-ranging and include: • Liner seam failure • Improper liner installation • Steel weld failure • Poor MLVT placement (one MLVT failed and caused an adjacent MLVT to fail) and • Unsuitable or underprepared substrate. According to data (Table 1) provided by Greg Deranleau, COGCC Oil and Gas Location Assessment Supervisor, in a January 17, 2014 email, the volumes of fresh water released in the MLVT failures were very large, more than three million gallons (nearly 10 acre-feet) in one failure. That is a tremendous volume to be released over a very short period of time. To put it in perspective, that’s enough water to cover the typical residential use (indoor and outdoor) of 20 Colorado families for an entire year – released over just minutes. The impacts of such a rapid release of fresh water are extreme and would be greatly exacerbated were MLVTs allowed to contain E&P waste or other potentially hazardous fluids. Not only would physical safety and stream erosion and sedimentation be major concerns, but contamination of soils, surface waters and groundwater resources would likely occur, requiring significant mitigation and potentially impacting municipal and agriculture water supplies. To clarify that MLVTs should be used only for fresh water storage WRA suggests slightly modifying the draft policy language as follows (proposed additional text is underlined): Appropriate Use of MLVT Technology When used in accordance with this policy, COGCC considers a MLVT to be appropriate technology to store fresh water to support Oil and Gas Operations. Storing or handling E&P Wastes, including treated E&P Wastes and flowback during hydraulic fracturing operations, or other non-fresh water fluids in a MLVT does not comply with Rule 907.a.(1) & (2). Table 1: Catastrophic Modular Large Volume Tank Failures in Colorado * Reported as barrels (bbls). Converted to gallons and acre-feet by Western Resource Advocates. These five failures illustrate that extreme caution is necessary when using MLVTs. The draft policy developed by the COGCC addresses the causes of these failures, encompassing design criteria, site preparation and installation, and operations and contingency planning. Though MLVTs have failed repeatedly, rather than limiting the use of MLVTs the COGCC is seeking to ensure that reasonable, responsible and protective policies are in place to ensure their integrity. Because these tanks are utilized multiple times, requiring them to be dissembled and reassembled at different locations, and because of the magnitude of potential impacts, it is imperative that the structural integrity of the tanks and liners is assured each time a tank is reassembled. We believe the draft COGCC policy is well thought out towards this end, ensuring that MLVTs (including liners) are consistently engineered, installed, and operated throughout the state - rather than haphazardly as would likely occur without this guidance. 2 WRA hopes the COGCC will adopt the draft policy as written (with the minor modification we’ve suggested). Given recent catastrophic failures, we are especially supportive of the policy that MLVTs be used only to store fresh water. Again, we thank the COGCC for their thoughtful and comprehensive attention to this matter. Sincerely, Laura Belanger, P.E. Water Resources Engineer Western Resource Advocates 2260 Baseline Road, Suite 200 Boulder, CO 80302 720-763-3718 [email protected] www.westernresources.org 3
© Copyright 2024 ExpyDoc
