Residential development near historic oil and gas toxic waste pit. Hazmat response docx

CASE: Lafayette, CO historic toxic waste pit v. residential development.



 Click on documents to enlarge

Another letter from concerned citizen regarding the Parachute Gas Plant toxic waste spill

From: Matt Lepore - DNR <matt.lepore@state.co.us> 
Date: 
To: Jodee Brekke <Jodee.Brekke@cort.com> 
Subject: RE: Emailing: 536433_497576430298431_203489034_n.jpg 

Ms. Brekke:

No regulatory regime can prevent every spill; no regulatory agency can be on-site 24 hours, 7 days a week, 365 days a year to monitor an operator’s every action.  It appears Williams reported the impacts to soil and, subsequently, groundwater, to COGCC as soon as they learned of those impacts.  The Spill Report attached to your email was submitted to COGCC by Williams as required by our Rules.  That is evidence of a regulatory system working.  COGCC staff, including our Environmental Manager, our Rifle Office Manager, and several Environmental Protection Specialists, have been on site nearly every working day since the groundwater impacts were reported to us.  The companies involved have been taking action to respond to the contamination since it was discovered.  We have issued a Cease and Desist Order and Notices of Alleged Violations to the Parties, and are actively monitoring and overseeing the on-going response actions.  The responsible party or parties will be obligated to remediate the environmental impacts.  Fines and other remedies will be considered by the Commission at the appropriate time, consistent with the Commission’s statutory authority and our Rules. 

Sincerely,

Matt

Matthew Lepore

Director

Colorado Oil and Gas Conservation Commission

From: Jodee Brekke [mailto:Jodee.Brekke@cort.com]
Sent: Tuesday, March 26, 2013 4:39 PM
To: Matt.Lepore@state.co.us
Subject: Emailing: 536433_497576430298431_203489034_n.jpg

Mr. Lepore,

In regard to the accident in Parachute CO (attached), the COGCC has once again failed to prevent adverse impacts and the industry operator should be held accountable for all reclamation costs, fines and punitive damages.

Jodee Brekke

Concerned citizen letter to COGCC Director and response regarding the recent Parachute gas plant spill

Mr. Lepore,

Once again COGCC has failed to protect the public.

It is disappointing that the filed spill documents are absent of water contamination results.

I assume they are in the process of being conducted?  COGCC documents appear

misleading because they indicate groundwater and surface water were 'not' contaminated.

It's highly likely that both ground and surface waters were contaminated due to the volume

and proximity of release!

We citizens hold you personally accountable to notify the public of the BTEX results.  In particular, 

all down stream recipients must be immediately notified.  Once again, COGCC has failed to prevent adverse

impacts and the industry operator should be held accountable for all reclamation costs, fines and punitive damages.

Sincerely,

NR

...............

COGCC Director, Matt Lepore's response

Sent: Wednesday, March 20, 2013 7:51 PM

Subject: RE: Parachute Spill

Ms. Rosa:

The Form 19 is for the limited purpose or reporting the fact of a spill.  Subsequent to reporting the release, the operator responsible for the release of hydrocarbons will submit a Form 27, which describes the sampling and other work that will be done to characterize the extent and nature of adverse impacts to the environment and describe the remediation work that will be done to remediate environmental impacts.  All of those plans will be reviewed and approved by COGCC. 

The COGCC’s primary concern regarding protecting the public was and is to prevent contamination reaching Parachute Creek; to that end we issued a cease and desist order on Friday, March 15 directing the companies to take all appropriate measures to prevent the hydrocarbons from migrating to the Creek.  Those efforts appear to have been successful thus far. 

I am not sure what documents you interpret as saying groundwater has not been contaminated.  That is clearly not the case:  hydrocarbons have contaminated both soil and groundwater near the pipeline right of way associated with the gas processing plant operated by Williams.  The Form 19s clearly indicate those facts.  With respect to surface water (Parachute Creek), as noted, we have no data at this time indicating hydrocarbon impacts to the creek.  The companies involved, as well as COGCC, are collecting groundwater and soil samples which will be analyzed to determine the scope and nature of contamination. 

Finally, the COGCC has directed the companies involved to “Identify and evaluate all potential receptors of both surface water and ground water within a one-mile radius of the interceptor trenches” on the site.  Thus, any users of surface or ground water within one mile will be assured their water supplies have not been impacted by the incident in question.  Furthermore, in the event hydrocarbon impacts are detected in Parachute Creek, we will immediately notify the Town of Parachute, Garfield County officials, and the Parachute Municipal Water District. 

I and my colleagues at COGCC care deeply about Colorado’s environment.  Releases like this are not acceptable, and the responsible party or parties will be obligated to remediate the environmental impacts.  Fines and other remedies will be considered by the Commission at the appropriate time, consistent with the Commission’s statutory authority and our Rules.   

Thank you for sharing your concerns with me.

Sincerely,

Matthew Lepore

Director

Colorado Oil and Gas Conservation Commission

Parachute Creek Gas Plant Spill - UPDATE - Ground water found contaminated, possible emergency to city drinking water

- FORM 19 - Spill incident report indicates ground water contaminated
- Notice of alleged violation issued to operator
- CEASE & DESIST ordered
- Town of Parachute municipal water possibly at risk of contamination

My take--> Surface water (Parachute Creek) is likely contaminated from this spill with Benzene, Toluene, Xylene, and Ethylbenzene but if test are not conducted immediately, trace amounts might be found. The longer water testing is delayed, the more diluted the sample results.  The 'unknown' volume that was released can be in the hundreds of thousands of gallons.

Who are the downstream recipients?  Who and what will be affected? I will report all chemical analytical results as they occur. Stay tuned.


CLICK DOCUMENTS TO ENLARGE

.......... ...........

Parachute Creek Gas Plant Spill - document dump. Some never seen before

Spill documents are absent of water contamination results as they are yet to be conducted.  COGCC documents appear misleading because they indicate groundwater and surface water were 'not' contaminated.  It's highly likely that both ground and surface waters were contaminated due to the volume and proximity of release. 

Hold COGCC Director Matt Lepore accountable to notify the public of the BTEX results immediately to all down stream recipients.

Email Matt --> Matt.Lepore@state.co.us

Let him know that the COGCC has failed to prevent adverse impacts and the industry operator should be held accountable for all reclamation costs, fines and punitive damages.


...Shane

.............................................
Click documents to enlarge

Source: http://cogcc.state.co.us/

Description of the spill/release incident:

Hydro-excavation work was being done in an existing pipeline right]of]way (ROW) to locate existing
piping as part of a project to install a new pipeline. During the course of that work late on March 8th,
impacted soils and an unknown hydrocarbon were encountered in the excavation. Notification was
provided at that time to both COGCC and the landowner. The location of the incident has been given as
39‹29'2.53"N, ]108‹ 6'40.57"W (legal description of Section 33, Township 6 South, Range 96 West; North
., NE .). The area where the release was discovered is outside of the fenced Parachute Creek Gas Plant
area, on the west side of the facility, within the pipeline ROW, and just to the east of Parachute Creek.
At the time of discovery, there was no alarm, malfunction or other indication of equipment failure
within the Parachute Creek Gas Plant, or related piping infrastructure. The Parachute Creek Gas Plant is
located approximately 4 miles NW of the town of Parachute, Colorado on Garfield County Road 215, and
is being used as a command post for this incident.

Description of immediate response (how stopped, contained and recovered):

Upon discovery of the release, vacuum (evacf) trucks were dispatched to the site to recover any free
liquids. The vac trucks have been continuously kept onsite, manned and operating; and as of the
morning of March 17th have recovered a total of 903]bbls of liquid, which when subsequently allowed to
settle out in tankage appears to contain approximately 57]bbls of an as]yet unknown hydrocarbon
material. As the source of the release could not immediately be ascertained, Williams also shut]down
and removed from service its 4h Natural Gas Liquids (NGL) product line which is one of a number of
pipelines within the ROW corridor. The NGL line was subsequently purged of NGL product, and hydrotested

to assess the line integrity. This line is, and will remain out of service until Williams has fully
assessed the results of the integrity testing. Visual field inspections of the waters in Parachute Creek
were conducted, and subsequently analytical water samples were taken to assess the creek waters.
Based on this information, no impact to the creek waters has been identified.

Concurrently, exploratory excavations were made in the area around the initial point of discovery in an
effort to assess the extent and source of the release. Excavations were initially made with hydroexcavation
equipment both as the equipment was immediately available; and, due to the close

proximity of multiple pipeline, to avoid the potential for line impact or damage. This investigation
showed evidence of hydrocarbon impact up]gradient from the initial point of discovery. From these
investigative excavations, it was also determined that the vertical extent of the release reached to the
free groundwater surface. As a result of this discovery, additional notification was provided to CDPHE
(Incident No. 2013]0161).

To provide better assurance of protection from any released hydrocarbon entering Parachute Creek, an
interception trench was jointly constructed by Williams and the landowner on the east bank of
Parachute Creek between the creek waters and the point where the hydrocarbons were discovered.
The trench extends parallel to the creek, some distance upstream and downstream of where
hydrocarbons have been found; with the outer ends of the trench angled up]gradient and away from
the creek to capture of any flow which might occur around the release area toward Parachute Creek.
The landowner for the pipeline ROW and surrounding area has been involved with any work outside of
Williamsf ROW.

As yet, a specific source or cause of the release has not been determined. Work crews are continuing to
investigate potential causes / sources of the release. Work crews are also visually inspecting the waters
in Parachute Creek in approximately 30 minute intervals, and samples of the water are being taken on a
daily basis to assess any water quality concerns. The evacf trucks have (and will) remain onsite,
operating continuously to recover any free liquids that enter the interception trench; and are also
poised to recover water from Parachute Creek were there to be any observation of impacted waters. As
an additional protective measure, the landowner has placed diversionary and absorbent booms across
Parachute Creek downstream from the incident location. Contact has been made with various township
and county officials to advise them of this incident; and in particular, Williams has spoken with the
Water Treatment Manager for the Town of Parachute so that he could be immediately advised if there
were to be a discovery of any impact to the waters of Parachute Creek.

In addition to required notifications which are identified on Form 19 to COGCC (Colorado Oil and Gas
Conservation Commission), CDPHE (Colorado Department of Public Health and Environment) and the
land owner; additional contacts have been made with:

Entity Contact Phone Comments
EPA Region 8 Tien Nguyen 303]312]6820 Onsite field inspection
Garfield County Kirby Wynn 970]625]5905 Onsite field inspection
Town of Parachute Bob Knight 970]285]7630 Town Administrator
Parachute Water
Treatment Manager
Mark King 970]986]1821 Potential emergency contact
Colorado Parks & Wildlife Mike Porras 970]210]3768 Courtesy notification
Army Corps of Engineers South Pacific
Division
916]557]6911 Courtesy notification

Describe any emergency pits constructed:

In addition to the interception trench described above, any recovered liquids are being stored in tankage
(nearby, but offsite from the incident location) for volume measurement, further analysis and
characterization. Williams will appropriately manage or dispose of these liquids once appropriate
characterization is complete. A lined containment area has also been constructed on a nearby piping
laydown area to similarly receive and stage impacted soils until they can be managed for proper
disposal. In addition, best storm water management practices have been implemented both onsite
around the incident area, and for these areas where liquids and soils are being temporarily managed

How was the extent of contamination determined:

As the source of the release remains under investigation, work has not yet progressed to a delineation
phase where the full extent of the release plume can be accurately determined. Based on preliminary
field observations made to date, it appears the impacted area extends approximately 200 ft along the
ROW, 170 ft perpendicular across and beyond the ROW boundaries; and to a depth of approximately 14
ft; which in some areas reaches to groundwater. Further evaluation and sampling is ongoing to
determine the boundaries of the release plume.

Further remediation activities proposed:

As the source of the release has not yet been determined, Williams will maintain its current response
efforts to contain and recover any available hydrocarbons, as well as continuing its investigation to
identify the source. Once a source of the release has been ascertained, updates with an additional work
plan for appropriate remediation activities will be prepared.

Describe measures taken to prevent problem from reoccurring:

As the source of the release has not yet been determined, Williams will maintain its current response
efforts to contain and recover any available hydrocarbons, as well as continuing its investigation to
identify the source. Once a source of the release has been ascertained, Williams expects that measures
to prevent similar reoccurrence can be identified.

Click image to enlarge

http://cogcc.state.co.us/