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Frequently Asked Questions About the Parachute Creek Natural Gas Liquids Release 2013

 

The leak of natural gas liquids, or hydrocarbons, was initially discovered and stopped on January 3, 2013. An investigation by Bargath LLC, owner and operator of the pipeline, determined that a failed pressure gauge, located on a four-inch natural gas liquid pipeline, was the source of leaking hydrocarbons. According to Bargath, that pipeline transports natural gas liquids removed from natural gas within the Parachute Creek Natural Gas Plant to accumulation bulk-storage tanks across Parachute Creek. The failed pressure gauge was replaced on January 3, which stopped the leak, and the pipeline was returned to service. Based on visual observations on January 3, Bargath initially believed that only approximately 25 gallons of natural gas liquids had been released. Bargath did not notify the state or the U. S. Environmental Protection Agency (EPA) of the release on January 3 because a 25-gallon release is less than the required reporting threshold.

 

On March 8, 2013, Bargath was conducting hydro-excavation activities to locate existing piping as part of a project to install a new pipeline. During these activities, hydrocarbon-impacted soils and unknown hydrocarbon liquids were discovered. Bargath immediately ceased using the four-inch pipe, which has remained out of service as of the date of this Frequently Asked Question.

 

An in-depth investigation of the leak included analysis of meter data, from which Bargath determined that the leak resulting from the failed pressure gauge began on December 20, 2012 and ended on January 3, 2013.

 

 

Once Bargath determined on March 8 that a significant release of hydrocarbons had occurred, it conducted additional investigations into the source and duration of the leak. Bargath reported a revised total estimate that 1,150 barrels of natural gas liquids had leaked over a period of 14 days. An analysis of the chemical properties of the natural gas liquid suggests that approximately 80 percent of the leaked liquids evaporated before entering the soil, leading Bargath to conclude that by January 3, up to 241 barrels of natural gas liquids had entered the soil at the leak location.

 

Based on data from the many ground water monitoring wells spread widely throughout the area, natural gas liquids have traveled approximately 900 feet southeast of the release point, while trace amounts in ground water have been detected approximately 1,500 feet southeast of the release point. As of June 4, 2013, the ground water contamination plume was stabile, meaning not increasing in size by any dimension, and was estimated to be 462,000 square feet in area (approximately 10.6 acres). Trace amounts of contamination were detected in surface water of Parachute Creek early on, but contamination readings have been non-detect (less than 1.0 part per billion) in all but one location since the last week of May 2013. Benzene is still occasionally detected at low concentrations (<2 ppb) in the surface water adjacent to where contaminated groundwater enters the creek.

 

Benzene is a highly volatile chemical, meaning that it would prefer to be in a vapor state rather than in liquid form. This property of benzene is very important for the remediation of benzene-contaminated ground water and surface water. Any activity that adds air to the ground water or surface water will allow benzene to evaporate to the air. Please note that all treatment processes at the Parachute Creek site that result in releases of benzene to the air are conducted in accordance with the Colorado Air Pollution Control regulations.

 

 

Data collection focuses on the amount of hydrocarbons in the area’s soil, groundwater and surface water. The data is used to monitor or improve cleanup efforts, and to keep track of the extent of contamination. All data collection activities are being performed in accordance with work plans and quality assurance project plans approved by both the U. S. Environmental Protection Agency (EPA) and the Colorado Department of Public Health and Environment.

 

Monitoring efforts include daily sampling of surface water and monitoring wells for groundwater. Surface water monitoring has been conducted from upstream of the natural gas plant downstream to the confluence of Parachute Creek and the Colorado River. Residents of the area also have been able to request tests for contamination of their domestic wells or irrigation water intakes. To date there has been no contamination detected in private supply wells or public or private irrigation water supplies.

 

 

Remediation activities have been ongoing at the site since the release to groundwater was first discovered in March 2013. Trenches were dug down to the groundwater table to allow for the skimming of liquid hydrocarbons from the groundwater surface. Liquid hydrocarbon recovery via specifically-designed recovery wells will continue at the site until removal is complete. As of May 31, 2013, over 7,000 gallons (165 barrels) of liquid hydrocarbon have been recovered. The final disposition of the recovered hydrocarbon has not been determined but it very likely may be recycled back through the Parachute Creek Gas Plant. 

 

Bargath is also actively treating dissolved-phase benzene in groundwater via an aeration trench and vertical aeration wells. Compressed air is introduced into the contaminated ground water where it literally strips the benzene from the ground water. Benzene-contaminated air is captured and monitored to ensure compliance with air pollution control laws.

 

The cleanup process does not have a timeline because many factors could speed up or slow down the process. At a typical spill site, a large proportion of the cleanup can be completed within a few years, but complete remediation of the residual contamination, bound up in the soil or aquifer material, may take many years. It is very important to note that the Hazardous Materials and Waste Management Division of the Colorado Department of Public Health and Environment (state health department) will have an enforceable mechanism in-place by the end of June 2013 that will require Bargath to completely delineate the extent of contamination and fully remediate the release of natural gas liquids due to the pipeline release. The cleanup requirement for the natural gas liquids release will be drinking water standards for all groundwater, surface water and residential/unrestricted use for soil contamination. 

 

The enforceable mechanism for cleanup will be either a hazardous waste corrective action Compliance Order on Consent or a Unilateral Compliance Order. In either case, if Bargath fails to fulfill the requirements of the order, the state health department can and will conduct enforcement actions with penalties to ensure compliance.

 

 

Natural gas, the source of natural gas liquids, is a naturally occurring mixture of gaseous hydrocarbons found in the ground. Its composition varies in different parts of the world but the chief component, methane, usually makes up 80 percent to 95 percent of it. The balance is composed of varying amounts of ethane (35 percent-55 percent), propane (20 percent-30 percent), butane (10 percent-15 percent), isobutane (4 percent -8 percent) and natural gasoline (pentanes; 10 percent-15 percent). Natural gas liquids are produced by refrigeration and distillation processes in gas plants and refineries.

 

During this pipeline leak, the lighter part of the natural gas liquids (ethane, propane, butane, and isobutane) evaporated, leaving the heavier part (natural gasoline) to reach the ground and sink beneath the soil surface. Natural gasoline includes the chemical compounds benzene, toluene, ethylbenzene and xylenes (typically referred to as “BTEX constituents”). While all of the BTEX constituents have been detected in groundwater at the site, the focus has been on benzene, which is the most mobile constituent and poses the greatest hazard because it has the lowest standards.

 

Benzene is a toxic chemical that occurs naturally in the environment, as well as in a wide variety of man-made products. Exposure to this chemical can result in a wide range of side effects and ailments from acute (from short-term exposure) to chronic (from long-term exposure), and can be deadly. Effects of exposure, depending on the dosage, can range from dizziness, nausea and headaches to major bone marrow troubles, immune system deficiency, cancer or death. Benzene has been labeled a “Class A Carcinogen” by the U. S. Environmental Protection Agency (EPA).

 

A fact sheet prepared by the Agency for Toxic Substances and Disease Registry (ATSDR) answers the most frequently asked health questions about benzene. It can be found at http://www.atsdr.cdc.gov/tfacts3.pdf.

 

 

No member of the public has been exposed to contamination related to the Parachute Creek pipeline release, since all contamination is limited to private property owned by natural gas production or treatment companies. Although current and future exposure is unlikely, people could be exposed by drinking contaminated surface water or groundwater. People also could be exposed by direct contact with, and breathing of, contaminated water, through bathing, swimming or wading. To date, only a few of the Parachute Creek surface water samples have shown contamination levels slightly above the state drinking water standard – 5 parts per billion – and none of these detections have been in areas accessible to the general public. Please remember that the 5 ppb drinking water standard for benzene is considered safe for a lifetime of exposure to benzene via direct contact, breathing and drinking. No person could ever be exposed to the benzene released from the Parachute Creek Gas Plant for even a small fraction of a lifetime.

 

Surface water samples have been collected daily at the town of Parachute’s irrigation water diversion and a private owner’s irrigation diversion since the release was found. All samples from the irrigation water diversions have been non-detect for benzene. The surface water of Parachute Creek is not used as a drinking water source. However, there are private well owners that draw groundwater from the Parachute Creek alluvial groundwater. Private supply wells have been sampled and no contamination has been detected. Vapors from remedial activities have been captured and treated. Unless residents of Parachute have come into direct contact with these hydrocarbons, they are not otherwise exposed as a result of this leak.

 

 

Colorado hazardous waste laws and regulations require any environmental liabilities to be addressed by the owner and operator. Bargath, as the owner and operator of the Parachute Creek Natural Gas Plant, is strictly liable to pay for the investigation and entire cleanup. Bargath also will be responsible for reimbursing the Colorado Department of Public Health and Environment (state health department) for its employees’ time spent directing and overseeing the cleanup. If Bargath cannot complete the cleanup, then the property owner, WPX, will be financially responsible. Currently, state health department staff have every indication that Bargath will cover all cleanup costs resulting from the leak, as the company has been fully compliant so far.

 

 

Any air emissions that may be generated during the cleanup process will be controlled and permitted through the Colorado Department of Public Health and Environment's Air Pollution Control Division, not the Hazardous Materials and Waste Management Division.

 

 

The State of Colorado surface water standard for Parachute Creek for benzene is 5,300 parts per billion. This standard is called an “aquatic life” standard and is intended to be protective of the fish and other organisms that live in the creek. No surface water readings for this contaminant in Parachute Creek have exceeded 10 parts per billion. There is a chance that wildlife may be harmed during remediation efforts due only to the disturbance of their original habitat.

 

Although benzene is harmful to animals, health risks would only be incurred through direct exposure or drinking water directly from the contaminated portion of the creek. There are no standards for protection of wildlife drinking contaminated water, but it is unlikely that wildlife has been harmed due to drinking contaminated surface water due to the low concentrations and the short period of time that surface water was actually impacted. 

 

For extended health risks of benzene exposure, a fact sheet prepared by the Agency for Toxic Substances and Disease Registry (ATSDR) answers the most frequently asked health questions about benzene. It can be found at http://www.atsdr.cdc.gov/tfacts3.pdf.

 

 

 

Based on information provided by Bargath, the release of natural gas liquids occurred due to the failure of a pressure gauge attached to a four- (4) inch pipeline that is used to transport natural gas liquids from the gas plant to storage tanks, prior to sale as a product. The release occurred due to the fracture of a small diameter (about the size of your pinky finger) behind the face/dial of a gauge that was about four inches in diameter. There are no regular maintenance requirements for the inside of a gauge so the failure of the gauge was not the result of poor maintenance or negligence. After determining that the source of the leak, Bargath immediately replaced all gauges of that same model on their pipelines.

 

The leak in the pressure gauge was discovered just after midnight on January 3, 2013 by maintenance workers responding to reset a valve that had closed automatically due to the cold weather. The maintenance workers noticed the leak coming from the pressure gauge and closed the valve that turned off flow to the gauge, which stopped the leak. The maintenance workers believed that the broken gauge had occurred due to a pressure spike that happened when the automatic valve closed. The maintenance workers shoveled up all of the snow and unfrozen soil that appeared to be impacted by the release and restarted the pipeline.

 

As noted above, the natural gas liquids leak occurred through a very small diameter pipe at a rate of less than three (3) gallons per minute. The pressure drop and volume reduction caused by the release was not a large enough magnitude to trigger alarms in the automatic sensors that monitor each pipeline at the plant. It was not until after the actual significance of the release was realized, and further investigation of product inventories in March that Bargath realized the failure in the pressure gauge had actually begun on December 20, 2012 and was stopped on January 3, 2013. Again, the Colorado Department of Public Health and Environment (state health department) has no reason to believe that the initial lack of release discovery was due to negligence on the part of Bargath. 

 

The determination that Bargath was not negligent in the cause and non-discovery of the natural gas liquids leak is very important because the state health department does not have any authority to regulate the natural gas liquids in the pipeline (because they are product) or the pipeline itself. The state health department’s authority only begins once the natural gas liquids have reached the ground as a result of a spill, because once a product hits the soil and groundwater it becomes classified as a waste. Disposal of waste without a permit is a violation of Colorado’s solid waste laws, and in this case, also the hazardous waste laws. If the state health department had determined that Bargath intentionally released (disposed) of natural gas liquids, or that significant negligence on Bargath’s part had resulted in the release (disposal), then the state health department would have sought to assign significant fines to Bargath. However, in this case, the natural gas liquids released had a significant value to Bargath that was lost as a result of the release. There would never be a reason for Bargath to intentionally release natural gas liquids – their product – or ignore a known leak.

 

To date, Bargath staff have done everything possible and required by authorities to contain the leak. Immediately upon receiving direction from appropriate experts, staff began removing hydrocarbons from the soil and groundwater. The ongoing remediation efforts have caused the company to spend a very large amount of money and it will continue to do so until the cleanup is complete. State health department, the Colorado Oil and Gas Conservation Commission (COGCC) and the U. S. Environmental Protection Agency (EPA) staff have overseen every action Bargath has taken to ensure the leak is cleaned up as quickly, efficiently and completely as possible.

 

Considering the present information, the Hazardous Materials and Waste Management Division of the state health department (the division) itself does not plan to assess Bargath any penalties for the leak. If subsequent information changes, penalties would be reconsidered. Fines could be levied if Bargath does not follow the division’s orders requiring the company to clean up the environment. The division’s decision not to assess penalties under its enforcement authority does not prevent the Water Quality Control Division or the Air Pollution Control Division from independently from imposing penalties. The possibility of fining the company is still under consideration.