From September 9 through September 13, 2013, a series of heavy storms settled over parts of Colorado, bringing flash floods and widespread destruction. Over the five-day period, parts of Boulder County received over 17 inches of rain, with an unprecedented 12 inches of rain occurring in one day. Rain totals in numerous Denver suburbs exceeded 20 inches, compounding the havoc from the storms. The catastrophic event created swollen rivers and flash flooding that cut off towns, destroyed homes, crumbled transportation infrastructures, ravaged sewer lines, and damaged oil and gas production facilities.
As a result of the flooding, the local oil and gas industry was forced into flood disaster management mode. Many oil and gas wells and facilities were shut-in to reduce potential impact to the environment, however the force of the flooding caused thousands of gallons of oil to be spilled. According to The Colorado Department of Natural Resources’ October 8th report, the agency was tracking 13 notable releases caused by the extensive flood waters, with oil releases totaling 43,134 gallons or 1,072 barrels.
Experts believe the release totals are likely to rise, as state oil and gas commission inspectors evaluate additional areas affected by flooding. The agency developed “flood impact zone” mapping which expanded its initial flood assessment area. The report states, “This is not due to an increase in impacted locations, but is an exercise designed to use an excess of caution in ensuring any location potentially affected receives an assessment and evaluation by Colorado Oil and Gas Conservation Commission (COGCC) personnel.”
The flood impact presents an opportunity for governments agencies, LEPC’s, and companies to review response plans, assess response procedures, and identify what lessons can be learned from the disaster. Alan Gilbert, a director at the Colorado Department of Natural Resources, stated that regulators were examining their response to the disasters. "We are going to have a formal review. We'll look at what worked and what didn't work."
However, the extent of the flooding has highlighted effective mitigation measures. Doug Hock, spokesman for Encana, a North American energy producer, identified a lessons’ learned concept from their Front Range operations. Hock told The Daily Sentinel that fences are typically installed on well pads when operations are located in densely populated areas. While Encana did sustain damage from the flooding, the damage was limited at the Front Range facility because the fences kept out floating debris. “It was kind of an ah-ha, light-bulb moment to say, going forward we should do this because it helped protect those pads,” Hock said.
On October 4, 2013, the COGCC released a notice stating that Level 1 and Level 2 facilities in the flood impact zone shall be subject to a Compliance Plan. The Compliance Plan includes start-up procedures, certification that the procedures have been completed, and submission of a Notice of Start-up.
The following COGCC recommended start-up procedures could be utilized as a guide for restoring operations after a flooding incident has occurred. (Note: Site-specific operations may dictate specialized start-up procedures and applicable regulatory compliance requirements).
- A status report shall include fluid inventory assessment to compare pre-flood volumes to post-flood volumes.
- Inventory list shall include review of tank gauging records and or remote monitoring data.
- The inventory assessment shall occur before facility is restarted or before tanks are moved from the location and reported on a status report.
- Inconsistent volumes may trigger spill reporting.
Flowlines and Pipelines
- Pressure test and document the integrity of flowlines. Submit pressure test results of any segment that fails integrity test and include plans for repair or replacement.
- Pressure test all pipeline segments and onsite production equipment.
- Pressure test flow lines to the maximum anticipated operating pressure
- Stabilize tanks
- Check all valves and piping on the drain, and all inlet and tank load valves
- Pressure test oil dump line(s) to tanks to the maximum anticipated operating pressure.
- Each oilfield tank must be inspected to ensure integrity. If damage is known or suspected (the tank, flanges and/or any other fitting), additional integrity testing such as Magnetic/Flux Leakage (MFL), ultrasonic thickness, or weld inspections may be required or replace tanks as necessary.
- All oilfield tanks shall be labeled with the following:
- Name of operator
- Operator’s emergency contact telephone number
- Tank capacity
- Tank contents
- National Fire Protection Association (NFPA) Label
- Information shall be on tanks and legible from 100 feet
- All equipment including buried vessels and sumps shall be anchored
- Each buried or partially buried sump, vault, vessel shall be tested to ensure integrity using static level test methods.
- Shall be installed at tanks, sumps, and partially buried vessels.
- Where secondary containment has been damaged and will be replaced/repaired, the containment shall be constructed of metal, concrete or other armored material such as compacted earth with gravel protective covering. Material must be sufficiently impervious to contain released fluids and resist damage from floodwaters.
- Tanks shall be anchored using an engineered design.
- Submit Form 4 with GPS coordinates for all tank batteries taken from southeast corner of battery. Include listing of all wells producing to the battery.
- Storm water management BMPs shall be installed.
- Visually inspect all equipment.
- Check for separator stabilization on pad.
- Check regulators; connections on separator inlet and outlet to meter; and high/low valves to ensure that they are functioning correctly.
- Check flame arrestors and fire tubes for debris.
- Integrity testing to the maximum anticipated operating pressure shall be conducted for the following equipment:
- Separator equipment
- Heater treaters
- Integrity testing shall be conducted according to industry standards and documented in final compliance certification.
- All separator equipment shall have general secondary containment. It shall consist of metal, concrete, or earthen material that is sufficiently impervious to contain released fluids and to resist damage from wind and water erosion.
- All separators shall have NFPA Hazard Diamond label.
- Check stability of emission control device. Inspect pilot light(s), ignition control equipment and flame arrestor. As necessary, disassemble and clean affected parts. Clear line from production tanks to emission control device
- Check stability of Vapor Recovery Unit and that the unit is operating safely and efficiently.
- Check suction and discharge lines.
- Safely remove debris from all equipment in order to provide unrestricted access.
- Repair damaged fencing around equipment as needed
- Ensure onsite gathering equipment has integrity