COGCC approves comprehensive new flowline regulations

Graphic credit: Anadarko

Here’s the release from Governor Hickenlooper’s office:

The Colorado Oil and Gas Conservation Commission (COGCC) today approved comprehensive new regulations addressing oversight of flowlines and related infrastructure associated with oil and gas development.

The nine-member commission unanimously approved the updated regulations following three days of testimony from the public, local governments, homebuilders, citizen groups, trade associations and members of the oil and gas industry on more than 20 pages of proposed new and amended rules.

“We believe these new rules are another important step in the aftermath of the Firestone tragedy,” said Governor John Hickenlooper. “State government and local municipalities depend on the commitment that industry is doing everything to to keep our communities safe.”

The flowline rules take numerous steps to strengthen requirements for design, installation, maintenance, testing, tracking and abandoning flowlines. Flowlines describe the kinds of pipelines that most typically move fluids around specific oil and gas development locations from wells to separators to storage tanks or to larger pipelines.

The new rules include dozens of changes and improvements to flowline oversight, including:

Requirements for more detailed tracking, location data and record-keeping for flowlines that carry fluids away from a specific oil and gas location, such as lines that may travel from a well to a storage tank not co-located on the same wellpad, or to a gathering line. The rule permits COGCC to share resulting, more specific geospatial information with local governments through a confidentiality agreement.

Requirements that any flowlines not in use – but not yet abandoned – are locked and marked. All such lines must continue to undergo integrity testing under the same standards as active lines until abandonment. Any risers associated with abandoned flowlines must be cut below grade. This rule change makes permanent the post-Firestone order to eliminate above-ground risers connected to abandoned flowlines.

More detailed requirements for operators to demonstrate flowline integrity, including updated standards for integrity-testing lines, more testing options that align with newer technology, and the elimination of pressure-testing exemptions for low pressure lines.

Requirements for full operator participation in the Utility Notification Center of Colorado’s “one-call” program to ensure a centralized home for all data on flowline locations and access to that information through the established 811 “call-before-you-dig” system.

The new flowline rules and enhanced participation by operators in 811 include three key components of state actions outlined by Gov. Hickenlooper following a three-month review of oil and gas operations last year. The review followed the home explosion in Firestone last April that killed two people and injured a third.

“Our work with operators last spring and summer to identify, quantify and test all flowlines near residential areas was a significant start,” said COGCC director Matt Lepore. “These rules – and additional actions ordered by the Governor that are still unfolding – continue to keep our focus on this work.”

The final draft of the proposed rules can be found here, and an overview of the COGCC’s basis and purpose for the rules here. The latter provides context and analysis for the rulemaking. All documents associated with the rulemaking, including formal statements from parties to the hearing, are housed here.

The Commission also directed COGCC staff to empanel a stakeholder group representing a cross-section of interests to review current and developing instrument-based technologies and methods for preventing or detecting leaks and spills from flowlines. COGCC staff will present to the Commission quarterly on the group’s progress with a final presentation of the results of the stakeholder group’s study, along with any associated recommendations for changes to COGCC’s policies or rules, within a year.

The flowline rulemaking is the latest in a consistent and long-running effort to strengthen the regulatory oversight of the COGCC, dating to 2008.

The COGCC, under the Hickenlooper Administration, has crafted rules to increase distances between drilling and neighborhoods; reduce the effects of light, noise and odors; protect groundwater; reduce air emissions in partnership with the Colorado Department of Public Health and Environment; disclose hydraulic fracturing chemicals; tighten requirements for spill reporting; significantly elevate penalties for operators violating Commission rules; toughen requirements for operating in floodplains; and amplify the role of local governments in siting large operations near communities.

The Commission has also significantly expanded inspection, engineering, reclamation, and environmental staff; increased ease of access and the volume of data available to the public; intensified collaboration with local governments; sponsored ongoing studies to increase understanding of impacts to air and water; and adopted several formal policies to address health, safety, and environmental issues brought about by new technologies, all while experiencing an unprecedented increase in oil and gas development in Colorado.

Firestone April, 2017 photo credit: 9News.com

From the Associated Press (Dan Elliott):

The rules are intended to prevent a repeat of the April 17 explosion that killed two people, injured a third and destroyed a house in the town of Firestone, about 30 miles (50 kilometers) north of Denver. Investigators said the explosion was caused by odorless, unrefined natural gas from a severed flow line.

The line was believed to be abandoned but was still connected to an operating well with the valve turned to the open position, investigators said.

The flow line was severed about 10 feet (3 meters) from the house, and gas seeped into the home’s basement, investigators said. The well and pipeline were in place several years before the house was built.

Colorado has nearly 129,000 flow lines within about 1,000 feet (300 meters) of occupied buildings, according to energy company reports submitted to the state last year.

The proximity of oil and gas wells to homes and schools is a contentious issue in Colorado, especially in the fast-growing Front Range urban corrido, which overlaps with an oil and gas field. Firestone is in the midst of the growth area.

The new regulations says flow lines that are permanently taken out of service must be disconnected, drained and sealed at both ends and any above-ground portion must be removed. The rules also allow energy companies to simply remove the lines.

The proposal also requires energy companies to provide information on the location of flow lines to the Call 811 program, which marks the site of underground utilities at a property owner’s request. That’s meant to help homeowners and construction companies avoid inadvertently severing a line.

Directional drilling from one well site via the National Science Foundation

#Snowpack news: Wanted — more snowfall *and* a #MiracleMay #drought

Westwide SNOTEL basin-filled map February 14, 2018 via the NRCS.

From the Craig Daily Press (Eleanor C. Hasenbeck):

According to the Natural Resources Conservation Service, the Yampa River basin has received 73 percent of the average amount of snow it typically receives by this time of year. The Little Snake River basin has received 72 percent. In river basins in the southwest and south central part of the state, this number is in the 30s.

The drastic difference in snowpack between the northern and southern parts of the state is thanks to the La Niña winter. La Niña is a weather phase that cools the waters of the Pacific.

A La Niña year influences weather patterns around the globe, but in the United States, it creates a ridge of high pressure in the West. Storms develop in the moist air of the Pacific Northwest, then ride the jet stream on the northern edge of this high-pressure ridge.

National Weather Service meteorologist Megan Stackhouse calls these storms “northern clippers.” They typically hit only the northern edge of Colorado.

According to the U.S. Drought Monitor, all of Colorado (except a sliver at the northern edge, containing Larimer and Jackson counties) is facing drought or near-drought conditions.

Eastern Moffat County is abnormally dry, which is a pre-cursor to a drought designation. West of Maybell, the county is in a moderate drought. Steamboat Springs is also in a moderate drought, which could have implications for Moffat County, as snowpack in the Park Range melts into Moffat’s water supply.

Stackhouse said it would take 40 to 60 inches of snow for the Yampa/White River basin to reach an average level of precipitation for this water year. Receiving that much snow is not out of the question, though it’s unlikely.

With this in mind, Tom Gray, Moffat County’s representative to the Colorado River District, cautions the public not to panic before it’s warranted. In 2015, he said, Northwest Colorado faced a similar light snow year. Then, there was a “miracle May.” Mountain storms dumped snow late in the season and brought the basin back up to the average…

Gray and others at the Colorado River District are worried about meeting obligations under the Colorado River Compact. Under the agreement, the state of Colorado is required to contribute a 10-year rolling average amount of water downstream to the Colorado River system to help fill reservoirs such as Lake Powell.

So far, Colorado is set to contribute about 40 percent of its average annual contribution, according to Jim Pokrandt, director of community affairs at the Colorado River District.

That puts Colorado on track to send the smallest amount of water downstream to Lake Powell in the past 10 years, according to data from the Colorado Basin River Forecast Center. This could cause shortages to water users in parts of California, Utah, Arizona and New Mexico.,,

Closer to home, the Stagecoach and Elkhead reservoirs are on track to be filled. These reservoirs are relatively small, however, which makes them easier to fill.

But unless more snow comes, rural Moffat County is likely to feel the impact.

“If you start the spring with not-very-good soil moisture levels, and then, through April and May, if we don’t get rain to get some soil moisture, you’re that much drier,” Gray said.

For farmers, this could mean a weaker hay crop, as water to irrigate isn’t there. Dry soil also means dry grasses, which are better fuel for wildfire.

For now, residents of Northwest Colorado can kick off their snowshoes and hope to receive more moisture to avoid a drought. The weekend snowstorms helped.

“Statewide snowpack for Colorado approximately went up 5 percent with this last storm,” Stackhouse said in an email. “But that is very preliminary, since we are still collecting and receiving reports with this storm.”

Colorado Drought Monitor February 6, 2018.

The winter newsletter from the #Colorado Ag Water Alliance is hot off the presses

Lake Powell April 12, 2017. Photo credit Patti Weeks via Earth Science Picture of the day.

Click here to read the newsletter. Here’s an excerpt:

Should Coloradoans Care about Water Levels in Lake Powell?

We occasionally hear about declining lake levels in Lake Powell or Lake Mead, but – apart from being nice places to boat and fish – what is the relevance of these water bodies to Colorado agricultural producers and rural residents? To understand this, we need to go back almost 100 years to the signing of the Colorado River Compact.

Under the 1922 Compact, Colorado and the rest of the Upper Basin states – Utah, Wyoming, New Mexico – have a shared obligation “not to deplete” the river by more than 7.5 MAF (million acre-feet) per year on average, or 75 MAF over a 10-year period. The three lower basin states – Arizona, Nevada and California – also have an allocation of 7.5 MAF per year, and Mexico gets 1.5 MAF. The Compact essentially obligated the river to supply up to 16.5 MAF per year, which was thought to roughly represent the long-term annual average flow of the Colorado River based on an estimate made at the time.

The problem – as it turned out – was that the original estimate was high. The period 1905-1922, which was used to estimate water production allocated under the 1922 Compact had the highest long-term annual flow volume in the 20th century, averaging 16.1 M acre-feet per year at Lee’s Ferry, AZ. Since then, the average flow has been about 13.9 MAF.

The collective water use of the four Upper Basin states is still well below the 7.5 million acre-feet annual average depletion allowance. U.S. Bureau of Reclamation 5-year retrospective “Consumptive Use and Loss” reports indicate that the Upper Basin water use averaged 4.4 MAF between 2000 and 2015. The highest use among these years was 4.9 MAF.

The Lower Basin states, with greater population and higher evapotranspiration, have a more difficult time managing water demands within the limitations of the Compact. For the last several years, annual releases from Lake Mead have averaged about 9 MAF to meet lower basin water demands. However, Lower Basin water users receive credits for unused return flows. Lake Mead also loses about 1.2 MAF in evaporative and system losses, so the total annual outflow from Lake Mead has been about 10.2 MAF.

The imbalance between Lake Mead’s long-term inflows and outflows is called the “structural deficit.” This volume is estimated to be approximately 1.2 MAF annually. Lower Basin water users, including Mexico, are developing a Drought Contingency Plan (DCP) to address this imbalance by using a comprehensive demand management system that will better match deliveries to variable, and generally diminishing inflows into Lake Mead.

Lake Powell stores water that flows from the Upper Colorado River basin and is used to buffer declines in Lake Mead. Glen Canyon Dam – which creates Lake Powell – also has turbines that generate 5 Billion kilowatt-hours of hydroelectric power annually. The Western Area Power Administration (WAPA) distributes this electricity to Colorado and six other states at cost-effective rates. The total value of the electricity produced is about $120 M annually. A small but important portion of the annual power revenue is used to fund salinity control programs that help pay for irrigation infrastructure upgrades on the western slope, and provide funding for the Colorado River and San Juan River endangered species recovery programs.

In 1970, formal “Operating Criteria” were agreed upon by the seven states and the Bureau of Reclamation to provide for the coordinated operation of reservoirs in the Upper and Lower basins and set conditions for water releases from Lake Powell and Lake Mead.6 In 2007, interim criteria were established to specifically enable coordinated operation of Lake Powell and Lake Mead that would “minimize shortages in the Lower Basin and help avoid the risk of curtailments in the Upper Basin.” These interim criteria are based on specified reservoir conditions.

Operating Criteria allow the Secretary of the Interior to make releases from Lake Powell to raise the water level in Lake Mead so that the stored volume of the two reservoirs is roughly equal. The upshot is that Lake Powell declines when Lake Mead declines, even if ample flow is entering Lake Powell from the upper basin states.

Since 2000, the two reservoirs have fallen to approximately half of their combined capacity in response to hydrological conditions and to meet Lower Basin water needs and Upper Basin power needs. The current water level of Lake Mead – 1,087 feet above sea level – remains above the “Tier 1 Shortage level” of 1,075 feet, which is the point where water allocations to Arizona and Nevada are reduced under the Interim Operating Guidelines. These reductions become increasingly severe at Tier 2 and Tier 3 levels.

The current level of Lake Powell is about 3,619 feet above sea level. The concern for the Upper Basin states is that if the structural deficit continues and/or a drought returns, Lake Powell could fall to a level below 3,490 feet, which is the minimum level needed to generate electricity (ie. the “power pool”).

The Lower Basin states and Mexico have implemented conservation measures that have saved about 1.2 million acre-feet in Lake Mead since 2014. This has resulted in the lake level being 14 feet higher than it would have been otherwise.

For Colorado and the other upper basin states, the challenge isn’t complying with the depletion limit spelled out in the 1922 Compact. Instead, it is simply how to deal with snowpack variability and potential water supply shortages over a multi-year period. Since many Front Range cities and east-slope irrigation districts rely on Colorado River Basin water via trans-mountain diversions, runoff shortages on the western slope also directly affect eastern slope residents and farmers. And of course, multiple years of drought in the upper basin could result in lowering of Lake Powell to the power pool level simply because of inadequate runoff. When the 2002-2003 drought began, Lake Powell was full. Today it is about 56 percent of its capacity.

In 2015, a program was created to determine whether voluntary, compensated reductions in consumptive use in the upper basin states could be a useful tool to put water into Lake Powell and minimize lake-level declines during drought periods. The System Conservation Pilot Program (SCPP) is funded by southern California’s Metropolitan Water District, Central Arizona Project, Southern Nevada Water Authority, Denver Water, US Bureau of Reclamation, and NGOs. About $4.5 M has been spent on the program through 2017 and approximately 22,000 acre-feet of consumptive use water has been conserved through fallow and deficit irrigation, alternative cropping and a municipal water savings program. The program is being continued in 2018.

Lake Powell and Lake Mead tie the Upper and Lower Basin states together. Sustaining a pool level in Lake Powell above the “power band” is in the best interests of Coloradoans due in part to the inexpensive electricity and revenue that the hydroelectric plant generates. Additionally, severe drought in Lower Basin cities could have unexpected and undesirable implications for water and power users in both the Eastern and Western slopes of Colorado. Establishing strategies now that enable structured yet nimble responses to future water shortages downstream will help lessen negative impacts to Colorado agricultural producers.

Get lost, frost – News on TAP

The first in a series of throwback photos to honor Denver Water’s 100th anniversary shows off ground-thawing operations in 1896.

Source: Get lost, frost – News on TAP

@ColoradoClimate: Weekly Climate, Water and #Drought Assessment of the Intermountain West

Water Year 2018 precipitation as a percent of normal through January 31, 2018.

Click here to read the current assessment. Click here to go to the NIDIS website hosted by the Colorado Climate Center.

South Platte Roundtable meeting recap

Illustration shows water availability, in blue circles, compared with demand at various places along the South Platte River. The yellow area is the study area. (Illustration by Stantec).

From The Greeley Tribune (Tyler Silvy):

A yearlong study centered on a decades-long trend of Colorado sending too much water to Nebraska via the South Platte River yielded dozens of potential storage projects.

But high costs, potential environmental impacts, and bureaucratic and regulatory hurdles could doom the road ahead for any of those possibilities, according to a study presented Tuesday night at the South Platte Basin Roundtable meeting in Longmont.

Further, even if several of the identified projects happen, they would barely put a dent in what’s expected to be a Front Range water needs gap of 500,000 acre feet per year.

The $200,000 study, ordered by the Colorado State Legislature and paid for by the Colorado Water Conservation Board, looked at the South Platte from Greeley to the state line and identifyed potential storage solutions along the way.

Putting any of those solutions — with costs estimates ranging from $190 million to $1 billion — to work most likely will take more time, money and study…

Consultants from Stantec Consulting Services and Leonard Rice Engineers completed the study in December and have toured the state making presentations. The Legislature has yet to get a presentation, but here are the key points legislators will hear:

A large amount of water is physically and legally available but only during wet years and during short periods.

Mainstream options have the most benefit but likely are not permittable and have significant social impacts.

Many off-channel options appear to be feasible and could be combined in different concepts.

Even multiple projects won’t make a big dent in the supply gap.

One reason for the lack of impact is how the South Platte works. When farmers divert water from the South Platte to irrigate crops, some of that water soaks underground and slowly moves back to the river. That’s called a return flow, and return flows feed the South Platte to allow it to flow long after snowmelt water is gone for the season.

That’s why the Sterling No. 1 ditch can completely dry out the river with a diversion and then a mile downriver it’s flowing again.

That’s why the best possible place for a reservoir would be near the Colorado-Nebraska border, and the best solution for keeping as much water as possible — a mainstream reservoir — is the solution that likely never will happen.

A mainstream reservoir along the South Platte essentially would be a lake on the South Platte, with the western portion feeding into the lake and the eastern portion running when the lake releases water.

Water experts agree that would be nearly impossible to get approved.

But the consultants did identify storage options away from the river, including old gravel pits.

Still, building ditches or pipes to fill those gravel pits would prove costly.

The consultants also talked about the 2013 flood and high flows in 2015, which ended up sending 1.9 million acre feet of water to Nebraska — exponentially more water than Nebraska is entitled to via the 1923 compact with Colorado.

But managing or diverting water during a flood event like that would take technology water experts said just doesn’t exist. Instead, ditch companies did everything they could to keep the flood water out of their ditches, lest they get damaged by the torrent.

Groundwater storage also was touched on, but concerns were raised about water losses and the co-mingling of other water rights. Once the water flows under another landowner’s property, for example, they would have the right to pump that water to irrigate crops.

The conversation circled back to the reason for the study. Essentially, lawmakers on the Western Slope long have pointed to the excess water the Front Range sends to Nebraska. Rather than divert more water from the Western Slope, the argument goes, Front Range farmers and municipalities need to figure out how to keep what they have.

Mike Schimmin, a water rights attorney on the roundtable, said his fear is the study will reinforce those feelings and that people will ignore the high cost to capture the extra water.

@CSUtilities may offer water to outlying communities in El Paso County

The new north outlet works at Pueblo Dam — Photo/MWH Global

From The Colorado Springs Independent (Pam Zubeck):

Should the city be a good neighbor and share its water with those who don’t live within its boundaries?

Yes, says the Colorado Springs Utilities Policy Advisory Committee, which after a year of study has formed draft recommendations that call for removing barriers for bedroom communities to hook up to city water and wastewater systems. The recommendations — due for delivery to the Utilities Board, composed of City Council members, on March 21 — would lower the cost of hookups by up to 26 percent while opening the door to long-term agreements.

So what’s in it for city ratepayers? Plenty, according to Dave Grossman, Utilities strategic planning and government supervisor. New sales could help pay off debt for the $825 million Southern Delivery System (SDS) pipeline from Pueblo Reservoir, erase headlines that give the city a bad name and help outside water providers’ groundwater supplies last longer…

Still, the move raises a lot of questions. Why should city ratepayers share their resources with those who chose to live outside city limits, didn’t pay the costs of major Utilities projects and don’t pay city property taxes? Why allow outsiders to become dependent on city water, when the city will likely need that water for its own population in the future? And, at a time when the city is trying to attract more development within city limits, why give away one of the city’s best bargaining chips?

[…]

Until 2010, the city didn’t sell water outside its limits. The policy changed to accommodate sales for three years or less to districts that experienced water shortages or other problems. But they paid 150 percent of city customer charges. There are 11 water districts, six water and wastewater districts and four wastewater districts in El Paso County. Not all would necessarily want to buy city services, but some would.

Many rely largely on groundwater from the Denver Basin, which is rapidly depleting. Despite state and county measures to assure supplies last, the water table continues to drop.

Utilities has had outside deals with Cherokee Metropolitan District east of Powers Boulevard and Donala Water & Sanitation District east of the Air Force Academy. Cherokee needed water temporarily after court decisions prevented its use of some wells, while Donala uses the city’s pipes to convey water it obtained from Pueblo Board of Water Works.

Water districts form such a patchwork that Sean Chambers, who’s worked for several districts and now runs Chambers Econ & Analytics, has teamed with Peak Spatial Enterprises to create an online tool to compile district information in seven counties from Denver to Pueblo. Funded in part by the Colorado Water Conservation Board, it will feature maps, water rates, sources, conservation practices, water quality reports, consumption and the like, listed by address, for use by the public and the real estate industry.

But what if those districts had access to Springs Utilities’ supply? The city’s roughly 140,000 water customers use about 40 million gallons a day during the winter and more than 100 million gallons a day in the summer, Grossman says. If pressed, the city could provide well over that amount short term, he says.

Besides completing SDS in 2016, which increased the city’s water supply by a third, the city’s abundant supply is linked to conservation measures taken since 2001 that reduced per-person consumption from 130 gallons a day to 82. The city’s system also has capacity; the Bailey Water Treatment Plant, part of SDS, runs at about 10 percent capacity.

As for wastewater, the city has plenty of capacity, Grossman reports, for the next 30-plus years.

More than a year ago, Utilities began looking into whether extending service could benefit everyone. For one thing, the Advisory Committee found, water issues anywhere in the Pikes Peak region impact the city’s reputation and the region’s economy.

For example, in 2016, it was found that groundwater wells had been contaminated with perfluorinated chemicals (PFCs) from firefighting foam at Peterson Air Force Base. The chemicals fouled wells serving Fountain, Widefield/Security and other areas…

Under the committee’s recommendation, outside users would still pay more than city customers — 120 percent of the normal charge for water and 110 percent for wastewater. Currently, the city charges 150 percent for both…

Districts aren’t apt to buy their entire supplies from the city, however, Chambers says. That’s because their goal is conjunctive use — a combination of wells and surface water; if districts can buy water during wet years and pump from their wells in dry years, the aquifer gets a rest and a chance to recharge, he says.

That’s the concept behind WISE (Water, Infrastructure and Supply Efficiency), a coalition of 12 entities, including Denver Water, Aurora Water and the South Metro Water Supply Authority created after the 2002 drought.

Chambers notes that outside sales could help the city retire debt and fund maintenance and operations. Having attended most of the committee’s meetings, Chambers attests the city’s top goal is to serve existing customers. “Utilities has been very protective,” he says, “saying regionalization will not happen unless it’s a benefit to the citizen owners and ratepayers.”

For example, Grossman notes the committee wants to include options for conveying and treating water, but that no outside contracts would be executed if they’d erode the city’s targeted storage benchmarks.