Council Members Ms. Bette Erickson and Mr. Kevin Kreeger, and Local Government Designee Ms. Pat Gilbert,
Ms. Gilbert, Would you please forward this to the Oil and Gas Comprehensive Plan Update Committee? Thank you.
This email is limited to the legality and safety of Extraction installing Local Gathering Lines in our community.
It is heavily influenced by Mr. Josh Joswick and his Pipeline presentation which includes the referenced GRI report and Pipeline Safety Trust. His presentation details the reasons for local governments to exercise their land use authority over the siting of gathering lines. Mr. Joswick was mayor of Bayfield, from 1988-1993, and La Plata County commissioner from 1993-2005. In the Bowen-Edwards case, La Plata County established the precedent in the Colorado Supreme Court for local government to exercise their land use authority over oil and gas. When COGA and COGCC sued La Plata County, this precedent was upheld and strengthened. I believe that Mr. Joswick’s information and perspective on the siting of gathering lines by Broomfield would be important for the Council and Study Team to see and hear.
This is a matter of public safety. Fortunately, Extraction cannot proceed without your approval of these lines.
Existing and Proposed lines
From Extraction Oil and Gas, Inc. Development Plan January 10, 2017, Page 11
Extraction requests approval of all City ROW segments and easements to allow for pipeline infrastructure
The City needs to start with the known:
How many pipelines are existing, and what are their pressures and diameters in the County Parcels Pipeline Right Of Way (ROW) and the City and County Owned Parcels Pipeline ROW?
Then add the following:
What is the pressure and diameter of Extraction’s Proposed Pipeline?
Are any of these pipelines “looped”? (defined later)”
From Pipeline Safety Trust
National Pipeline Mapping System
The National Pipeline Mapping System (NPMS) is a geographic information system (GIS) created by the U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS) in cooperation with other federal and state governmental agencies and the pipeline industry. The NPMS consists of geospatial data, attribute data, public contact information, and metadata pertaining to the interstate and intrastate gas and hazardous liquid transmission pipelines, liquefied natural gas (LNG) facilities, and hazardous liquid breakout tanks jurisdictional to PHMSA. These GIS layers are available to local governments.
Side note: The GIS layers are not available to the public because Homeland Security deemed the pipelines as potential targets.
From U.S. Energy Information Administration
Many of the larger mainline transmission routes are what is generally referred to as "looped." Looping is when one pipeline is laid parallel to another and is often used as a way to increase capacity along a right-of-way beyond what is possible on one line, or an expansion of an existing pipeline(s). These lines are connected to move a larger flow along a single segment of the pipeline system. Some very large pipeline systems have 5 or 6 large diameter pipes laid along the same right-of-way. Looped pipes may extend the distance between compressor stations, where they can transfer part of their flow, or the looping may be limited to only a portion of the line between stations. In the latter case, the looping often serves as essentially a storage device, where natural gas can be line-packed as a way to increase deliveries to local customers during certain peak periods.
The Natural Gas Gathering System
The principal hydrocarbons normally contained in the natural gas mixture are methane, ethane, propane, butane, and pentane. Typical non-hydrocarbon gases that may be present in reservoir natural gas are water vapor, carbon dioxide, helium, and nitrogen.
A MODEL FOR SIZING HIGH CONSEQUENCE AREAS ASSOCIATED WITH NATURAL GAS PIPELINES pages 10-11 (.pdf 15-16)
Equation 2.8 (defined later) can be used to estimate the radius of a circular area surrounding the assumed point of line failure within which the impact on people and property would be expected to be consistent with the adopted definition of a high consequence area.
Hazard area radii … are plotted in Figure 2.4 as a function of line diameter and operating pressure. The figure shows that, for pipelines operating at pressure levels in the range of 600 to 1,200 psi, the calculated hazard area radius ranges from under 100 ft for small diameter lines to over 1,100 ft for large diameter lines.
High Consequence Area is where both damage to property and the chance of serious or fatal injury is expected to be significant.
Class 1 = any buildings within 660 feet
Class 2 = 10 or more buildings within 660 feet (either side) per mile
Class 3 = well-defined outside area (such as a playground, recreation area, outdoor theater, or other place of public assembly) within 100 yards and regularly used.
High Consequence Area Definition:
Any area in a Class 1 or Class 2 location where the potential impact radius is greater than 660 feet (200 meters), and the area within a potential impact circle contains 20 or more buildings intended for human occupancy per linear pipeline mile, and any area in Class 3.
Figure 12 Page 19 from the U.S. Pipeline Risk Report showed 23% of the serious incidents were caused by Excavation Damage.
Are you sure you want Extraction or their subcontractor to be digging around existing pipelines?
Safety and Legality:
From Briefing Paper March 24, 2011 Onshore Gas Gathering Advisory Committee
Recent developments in the field of gas exploration and production indicate that the framework for regulating gas gathering lines may no longer be appropriate. The gathering lines being constructed to transport “shale” gas typically range in diameter from 12” – 36” with a maximum allowable operating pressure (MAOP) of 1480 psig, far exceeding the historical operating parameters of such lines.
Production Peak Flows, Pressure and Pipe Size Estimations:
From U.S. Energy Information Administration Drilling Productivity Report March 2017 (Page 7 Niobrara)
And Table 2 -- Percentage Natural Gas Decline By Year(Depletion Rate)pdf page 13
And modeling Extractions January 2017 plan (page10) of 55 wells (Lowell and Sheridan) followed by 8 month drilling hiatus followed by 84 wells (Union and Huron) for a total of 139 wells.
Please see attached spreadsheet.
I calculate the following production peaks in these Local Gathering Lines:
29 wells at 1,173 million Standard Cubic Feet per month (mmSCF/m), 55 wells at 1,850 mmSCF/m, 84 wells at 2,375 mmSCF/m, 139 wells at 3,013 mmSCF/m. To balance the flows at 1200 psig, a 12 inch line from Lowell (29 wells) to Lowell-Sheridan Wye, 12 inch line from Sheridan (26 wells) to Lowell-Sheridan Wye, 16 inch line from Lowell-Sheridan Wye (55 wells) to Sheridan-Union Wye, 18 inch line Union to Sheridan-Union Wye (84 wells) , 14 inch line (42 wells) Huron to Union Wye, and 20 inch line Sheridan-Union Wye North to the Gathering Facility (139 wells). And that brings up the question: What is the line that goes south from the Union-Huron Wye? Is there something Extraction is not telling us? Is Extraction planning a pad south-east of Huron?
These are reasonable size options and pressures but there could be others. There could even be a different flow path than I built but that would move the question to What is North of the Sheridan-Union Wye.
We need actual flows, paths, pressures, and pipe sizes from Extraction.
Hazard Area Calculations:
Using the GRI-00/0189 formula: hazard area radius = 0.685 sqrt(p*d^2); where p is psig and d is pipe diameter inches and hazard area radius is feet and my best estimate of pressure and pipe sizes the following is the recommended high consequence hazard area setbacks:
From google maps the following are near Extraction’s proposed pipeline:
The following are examples where the hazard area radius exceeds the actual setback.W152nd Ave & Lowell Boulevard homes less than now actual 200 feet => minimum should be 283 feet
Since several areas along the proposed pipeline fall into the High Consequence Area definition, I recommend a minimum standard setback of 660 feet for the entire pipeline.
From A Regulatory Review of Liquid and Natural Gas Pipelines in Colorado
Interstate transmission pipelines are Federally controlled (page 6)
Congress created the Office of Pipeline Safety (OPS) in 1968 to oversee and implement pipeline safety regulations. OPS is housed in the U.S. Department of Transportation (DOT), originally under the Research and Special Programs Administration (RSPA) and now under the Pipeline and Hazardous Materials Safety Administration (PHMSA). OPS oversees interstate pipelines while states are responsible for intrastate pipelines. The Hazardous Liquid Pipeline Safety Act of 1979 was enacted on November 30, 1979. The PHMSA-OPS oversees interstate pipelines.
Intrastate transmission pipelines are State controlled (pages 6 and 8)
States are responsible for intrastate pipelines, via an interagency agreement with PHMSA. The statutes under which PHMSA operates provide for state assumption of all, or part of, the intrastate regulatory and enforcement responsibility through annual “certification agreements.” This cooperative, collaborative relationship between federal and state governments forms the cornerstone of our country’s pipeline safety program.
The Colorado Public Utilities Commission (COPUC) Gas Pipeline Safety Section is charged with confirming compliance with and enforcing the State's intrastate gas pipeline safety regulations in order to provide public safety to the citizens of Colorado.
Wells are State controlled (page 7)
Since the basic element to oil and gas development is an underlying mineral right, and mineral rights are state-specific, the Federal government does not have overarching authority as with pipeline safety or environmental protection.
Gathering lines are locally controlled (page 5, 8 and 12)
The midstream gathering and processing (G&P) segment collects hydrocarbons starting at a meter point near the well site for processing (page 5)
The COPUC does not have jurisdiction over pipelines not engaged in transport (i.e. pipelines directly associated with gas production, and gas piping within a home or business that is the responsibility of the customer and is regulated by the city or county building codes). (page 8)
County Commissions and Land Use Review
Location Regulation (Local) (page 12)
Local governments exercise land use authority to provide certain regulation on natural gas and petroleum pipelines. It should be noted that regulations vary based on the county; however, the pipeline approval process usually falls into two permitting categories.
Special use permit – May be subject to approval by the Board of County Commissioners (BCC). If the diameter of the pipeline is less than 10”, the hoop stress is less than 20%, and the pipeline is not in proximity to residences or other sensitive areas it is considered, by some counties, a “minor facility”. If the pipeline is deemed a minor facility then the permit can be determined administratively, without BCC review, once the pipeline company submits the proper information to the planning commission.
Conditional use permit - Must be approved by the Board of County Commissioners. Some counties consider conditional use permits for “major facilities”. Pipelines determined to be a “major facility” typically have a diameter greater than 10”, a hoop stress greater than 20%, and are in proximity to residences or other sensitive areas. Requirements include notification to adjacent landowners, legal notification in a public newspaper, and a public hearing. Some counties use their authority to identify, designate, and regulate areas and activities of state interest through their local permitting process prior to their decision (commonly referred as 1041 powers).
Legality and Safety:
Extraction can’t declare their gathering lines as transmission lines because the product contains liquid hydrocarbons, water vapor, carbon dioxide, helium, and nitrogen. The nearest Gathering Facility the proposed pipeline is in Dacono and a Processing Plant is north of Dacono towards Greeley.
Since Extraction did NOT request approval of the County Parcels Pipeline Right Of Way, I suspect they feel they already have rights. But do they have rights to add new piping? They are asking for City ROW segments and easements to allow for pipeline infrastructure. With the current housing offsets, estimated pipelines, and proposed route, you can block Extraction’s Sheridan, and United pads with the City and County Owned Parcels Pipeline Right Of Way. The Lowell and Huron pads are blocked as well if they go with the proposed piping plan without the City and County Owned Parcels Pipeline Right Of Way.
The safety limits from GRI-00/0189 are minimum recommendations. I believe you have the authority to make the limits as large as you want. I hope you can place the well pads in an industrial areas, lower the well count and keep the properties and people outside the Local Gathering Pipeline High Consequence Area setback minimum of 660 feet.
The calculations for flows, pressures, and pipeline sizes for Extraction’s proposal are mine. Believe them with a good dose of caution.
I repeat: We need actual flows, paths, pressures, and pipe sizes from Extraction and an independent verification.
This is a matter of public safety.
cc: Josh Joswick