A 44-page report describing the lessons learned from the September 2013 flood was released by the Colorado Oil and Gas Conservation Commission on Monday, and the importance of communicating with the players in the industry is a key component.
Recommendations in the report from the COGCC to the oil and gas industry will be discussed by the commission in the near future at a public hearing, as it decides whether to modify its regulations and policies.
COGCC — which oversees the responsible development of oil and gas in Colorado and regulates the industry to protect public health, safety, welfare and the environment, as well as oversees wells, tank batteries, and other oil and gas equipment located, in some cases, near streams throughout the state — said the flood along the Front Range and Eastern Plains of Colorado impacted many oil and gas facilities. Production equipment and oil and gas facilities were damaged by rushing floodwaters and debris. According to the commission, Colorado experienced spills of oil, condensate and produced water.
The report, “Lessons Learned in the Front Range Flood of September 2013” describes the commission’s investigation and conclusions following its flood response so far.
The commission has completed more than 3,400 individual inspections of oil and gas facilities affected by floodwaters. It has discussed flood observations and lessons learned with the oil and gas industry, first responders, federal, state and local government agencies, conservation groups, and many other interested parties. On Feb. 6, the commission held a workshop in Denver to support a wide-ranging public discussion.
Tisha Schuller, president and CEO of the Colorado Oil & Gas Association, which is the trade association that represents Colorado drilling companies, said: “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 disaster 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.”
The report describes recommendations for changes to Colorado’s oil and gas program.
COGCC spokesman Alan Gilbert said part of the equipment like the wellheads held up really well during the flood, but other parts such as the tanks didn’t.
“Also, other equipment did not fare so well. Some of the suggestions in the report are directed at making sure the equipment holds up better the next time,” Gilbert said.
Gilbert said some of the key safety recommendations from the report are:
» Anchor with engineered cables.
“We require anchors already, but we saw some that were too lightweight, not engineered enough to hold the equipment. We want to continue to anchor, but we want engineered anchors so they’re robust enough to hold up better,” Gilbert said. “A lot of the equipment was that way, and it wouldn’t have to be changed or altered in the future, but some of it was not.”
» Require metal fencing-type secondary containment around well pads.
“We found that those metal fences that a lot of the companies use already held up much better than earth and berms,” Gilbert said. “These secondary containment postings keep spilled materials at the site, but they also protect against flood from outside. We just found the metal ones held up much, much better.”
» Require the ability to do remote shut-in for every well located near streams and drainages. (Shut-in is closing the main valve at a wellhead that’s located at ground level and it separates the pressurized underground formation — oil and gas materials — from the surface.)
“You can either do that by remote means or some wells do not have that capacity and you have to send a crew out to shut them off,” Gilbert said. “What we found is it’s much safer to have a well shut-in prior to an emergency like this. If there’s damage at the surface, there won’t be pressurized material spilling because the well’s shut.”
» Require each operator to maintain a current inventory of its wells that are located close to drainages.
“That way they would know what wells they’d have to deal with before a flood happens,” Gilbert said.
» Locate tanks’ batteries production equipment as far from water ways as practical.
COGA’s Schuller said the industry was very transparent following the flood.
“Despite days of hyperbole and misinformation about oil and gas releases, the industry was committed to providing around the clock, transparent information about incidents and responses,” Schuller said. “This report also confirms that samples collected by the Colorado Department of Public Health and Environment and United States Geological Survey detected no oil and gas contaminants, while E-coli was identified in 14 samples above state standards.”
Schuller said 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,” 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.”
Gilbert said the report also contains a set of internal recommendations geared toward the COGCC as to how it can do better in the next emergency such as react faster and give better information.
“It’s important that this gets done and not just talked about, and that’s what we’re trying to do,” Gilbert said of the recommendations in the report.