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Home My WebLink About20240455.tiffFREDERICK. 401 Locust Street • P.O. Box 435 • Frederick, CO 80530-0435 Phone: (720) 382-5500 frederickco.gov Weld County Board of Commissioners do Karla Ford, BOCC Office Manager Email: kford@weld.gov RE: KP Kauffman's ongoing spills and failed mediation Dear Weld County Commissioners, February 14, 2024 RECEIVED FEB 2 a 2024 WELD COUNTY COMMISSIONERS KP Kauffman ("KPK") oil and gas wells within the Town of Frederick have become an ongoing concern to public health and the environment. We are asking you to join the Town of Frederick to request action from the Energy and Carbon Management Commission (`ECMC") to shut in all wells within the Town of Frederick until (1) all flowlines can be inspected and tested for integrity, and (2) KPK has successfully remediated every open spill location within the Town. KPK currently has 107 wells within Frederick. 94 of those wells are considered "low producing" because they have generated less than two barrels of oil per day for the past three years. Of those low producing wells, 15 of KPK's wells have been completely inactive (shut-in) since 2021. More than 80 of KPK's wells are producing under one barrel of oil a day. At this point, the vast majority of KPK wells are not profitable. It appears KPK is saving money by refiising to conduct adequate maintenance of their equipment or to remediate their spills. Over the past 18 months, the Town of Fredrick has been tracking 22 KPK spills and flowline leaks within the Town limits. These are listed on Exhibit 1 and on the enclosed map. Some of those remediation projects have been open since 2018 — for more than five years. Over the past 18 months, KPK has successfully remediated only four sites within Frederick. In that same time period, there have been 15 new spills. KPK's operations are causing four new leaks for every leak they successfully remediate. Since January 3, 2024, there have been five new KPK leaks reported within the Frederick town limits. A review of the ongoing remediation efforts indicates that KPK has stopped making any effort to address remediation requirements on some of these locations. For example, the Form 27 remediation plan for the Grant Tank Battery, just outside of Frederick's Legacy Elementary School, was rejected by the ECMC in March of 2023. There has been no action on this location for almost a year. The "Morgan 1A" and "Facility #4 West A Consolidation Flowline Release" Form 27 remediation plans were also rejected in March of 2023. Nothing has happened on these remediation projects for eleven months. In some cases, KPK has stopped even attempting to comply with ECMC rules and direct orders to clean up these locations. For example, Town staff discovered the "Guadagnoli Consolidated Co-sMVn, ©2/26/29 Built on What Matters. Gc:o&(5M), chtet) Bocc(xe/KR) o/2o/ay 2024-0455 [Weld County Board of Commissioners] February 14, 2024 Page 2 of 2 Flowline leak" on March 16, 2023. KPK's Environmental Director wrote to the ECMC, "Considering the current State of Affairs at KPK with the Final Order issued by the COGCC and our inability to retain contractors to conduct environmental site assessment work, we have no current plans to conduct a subsurface site assessment but will keep you both informed should that change hopefully in the very near future." Email from Craig Meis on March 27, 2023. As of today, there still has been no site investigation or remediation of the location. In late January, after there were four leaks reported in less than two weeks, the Town staff reached out to ECMC to demand immediate action. In response to our concerns, ECMC issued a letter requesting KPK to shut in one of its flowline systems that extends throughout much of Frederick and into Dacono. KPK was asked to depressurize and shut in the flowline system by .February 6, to complete a root cause analysis to determine the cause of the numerous leaks, to repair leaks within the system, and pressure test the entire system before restarting production. As of today, ECMC does not know if KPK has taken any action in response to the letter. While we appreciate the quick response from ECMC, the time for letters encouraging compliance with health and safety rules has passed. We are requesting that ECMC order all flowlines within the Town be depressurized and tested. We are also asking that ECMC take action within its Rule 901.a authority to order all KPK wells within the Town be shut in until all locations with open remediations are addressed and given a "no further action" designation by ECMC staff. We hope you agree that, if KPK is not willing to live within the rules of the ECMC, they cannot be allowed to operate. We would greatly appreciate the ongoing support of the Weld County Board of Commissioners not only in amplifying our concerns but also in securing the necessary financial assistance required for successful oil and gas remediation in the Town of Frederick. Thank you for your consideration of our requests, as it is imperative that we partner to safeguard public health and the safety of our community. I welcome the opportunity to further discuss this matter and can he contacted at tcrites@frederickco.gov. Si rarely, \(0&61C-SV Tracie Crites, Mayor of the Town of Frederick cc: Governor Jared Polis Barbara Kirkmeycr, Colorado Senate Jennifer Parenti, Colorado House of Representatives FRe E icig Oil Spill and Release Locations 2023 - 2024 Eut t')n What Ma:tecs Y� Map HD Name + FacitnylU DiscoverDate RemedtatInnProjedt•lo StMWs StatusDate ' MapjD Name RettablydlvnProjixstio Status;tatusDate 0' Grant T;ink Battery 446608 11/14/2018 12158 Remediation Not Complete 2/6,2024 12 UPRR 42 par; Am AE 2 Manifold 480151 7/2/2021 Remetheitiun Not Complete 2,6/2024 02 Facility #4 North Consolidation 463820 4/12/2319 13445 Remedianon Nnt Complete 2/612024 13 State 14-2 a 483070 1017/2022 i Remediation Not Compete 2/6/2024 03 Jillson A #1 478617 6/16/2021 18950 • Rerriedia:ior: Complete P 7/19'2021 14 PAcDnnald #2 Flowline Release 483i22 :?:1912022 Rrrriedieaun Not Complete ? 6'2^24 04 Longmont Farms Unit #5 Flowline - 479267 6/16/2021 18932 Remediatiun Complete 7/1912021 15 Goadagnck Consolidated Flowline 484039 3/17/2023 Remediation Not Complete 2/6/2024 05 Facility #4 West A Cunsokoation Flowhne Release 459299 7/24/2020 15829 Rernectation Net Complete 2/6/2024 16 Facility 4 Flowline at Brozovicn 464634 6/20/2023 Remediation Nut Comotese 2'6/2024 06 Motel/ #1 479484 2/23/2021 Remedialion Complete 6/15/2021 17 Hingley #2 Flowline 484760 7/11/2023 Remediation Not Complete 2'6/2024 J , ._ PRP 42 Pan Am AE Manifold 2 Facility 4 AE 2 479311 5'232022 23366 Remediallon Not Complete 2/6/202» :8 Wilson #2 Bultpfug Hist Release 435797 1'2/2024 Pemedial;un Not Complete 2/6/2024 08 Rogers #1 Flowline • 482755 8/12/2022 Remedialion Complete 8/25/2022 19 Faciity 4 at Citlev Cl 485898 1;17/2024 Remediation Nol Complete 216/2024 09 Morgan A#' »51051 1011U2021 2.2D32 Re'redianon No Complete 2'5!2Q24 2C Pan Am 3 4.6 10,12 445939 1124/2624 Remediation Nal Complete 216'2024 09 Morgan Al Header 482224 5/18/2022 22032 Remediation Not Complete 2/6/2024 21 Johnson 1 Flowline 485936 1/23/2024 Remediation Not Cornptta 2/6/2024 1 S'cnm±uici 4A 482194 5/15/2022 2560E Rtsrnediaacr 'Vol Complete 2'6x2024 2 F3c4*y 4 at UPRR 43 Par Am AE 485940 1;25/2024 Remediation No: Complete 2)6/2024 11 Milton Nelson 481725 3/3/2022 23610 Remediation Not Complete 2/6/2024 Town Boundary Remediation Complete • Not Complete 1 I I It j I I i 1 0 025 0.5 baps llwvw.hotJencwcc govRcrmaotLse S Q i 3 Ajrr.natra haw Tani Arco • ncy ciandGas Miles Exhibit 1 - List of KPK Remediation Locations Within the Town of Frederick 1. Grant Tank Battery (Remediation Project No. 12158) - only 800 feet from Legacy Elementary School. Remediation project is dated 11/14/2018 more than five years ago!! c Latitude: 40.116700 Longitude: -104.967740 c Approval to backfill on October 26th, will remediate in -situ, site investigation is complete - no threats to human health or adjacent creek identified with assessment activities. STILL NOT COMPLETE AS OF 2/06/24. Form 27 remediation plan was denied on 3/13/23. o Three NOAVs including failure to report spills to COGCC or local government 905 Closure of Pits, and Buried or Partially Buried Produced Water Vessels; 906.b Spill Reporting; and 906.6. (1) Spill Reporting -Report to Director -Threat of Impact 2. Facility #4 North Consolidation (Remediation Project No. 13446; Spill/Release ID 477605 Spill/Release ID 463820)- Oil actively surfacing on Tipple Pkwy across from Frederick High School from two separate leaks (4/12/2019). u Latitude: 40.102329 Longitude: -104.944888 .T Groundwater investigation complete and data submitted to COGCC. Six groundwater monitoring wells have been installed. Form review of analytical data is in process by the COGCC. Hydrocarbon impacts are naturally attenuating. Excavation is filled and flowline repairs have been completed. o STILL NOT COMPLETE AS OF 2/06/24. Form 27 remediation plan was approved on 6/26/23. o Five NOAVs including failure to report spills to landowner, local government, or COGCC: 906.6 Spill Reporting; 906.c Remediation of spills/releases: and 906.6 Spill Reporting 3. Jillson A #1 (Remediation Project No. 18950) - Produced water bubbling out of surface casing. Latitude: 40.118760 Longitude: -105.005970 o COMPLETED. Excavation has been backfilled and no further remedial excavation is planned. Groundwater investigation started 11/15/22. 4. Longmont Farms Unit #5 Flowline (Remediation Project No. 18932) - Surface staining along pipeline path a Latitude: 40.105497 Longitude: -104.994215 c} COMPLETED. Approval to backfill. Backfill conducted the week of 11/7/23. Flowline integrity testing witnessed and complete. Additional Form 27s have been requested 2/21/23 5. Facility #4 West A Consolidation Flowline Release (Remediation Project No. 15829) - Historical release discovered by third party on 7/24/2020. c Latitude: 40.124127 Longitude: -105.008090 o NOT COMPLETED AS OF 2/06/24. Form 27s submitted in January and still in process. Proposing additional excavation. ECMC denied Form 27 remediation plan on 3/1/23. 6. Wooley #1 (Spill ID 402607886) - Pipeline strike. Contaminated soil o Latitude: 40.100834 Longitude: -104.982908 o COMPLETED. Spill closed under Form 19 on 5/27/2021. No further action anticipated. 7. UPRR 42 Pan Am AE Manifold 2, Facility 4 AE 2 (Remediation Project No. 23366) - Historic Pipeline leak near homes found by developer. a Latitude: 40.094020 Longitude: -104.925690 o NOT COMPLETED AS OF 2/06/24. Soil contaminant removal complete. Backfill conducted. Move into groundwater monitoring program. Groundwater investigation schedule TBD following landowner approval. Form 27 remediation approved on 2/28/23. ECMC denied Form 27 remediation plan on 11/14/23. "Operator has continued to fail at comply with their approved sampling plan." 8. Rodgers #1 Flowline (Spill ID 403135067) - on 8/12/2022, homeowner discovered oil leaking out of the ground, called the Fire Dept. who contacted KPK who shut in the well and fenced off the area. t Latitude: 40.094913 Longitude: -104.993423 o COMPLETED. Excavation and backfill is complete. Form 19 closure request was submitted and in process by the COGCC. KPK was in contact with the local HOA. Flowline integrity testing witnessed and complete. Backfill of repair excavation will be completed. Reclamation ongoing. Five NOAVs including failure to take reasonable actions to prevent spills, report spills: Rule 912.b.Reporting Spills or Releases of E&P Waste, Gas, or Produced Fluids; 1702 Operations, Maintenance, and Repair; 602 General Safety Requirements; 902. Pollution; and 912.a. Spills and Releases - General 9. Morgan A #1 (Remediation Project No. 22032) - On 10/15/2021, homeowner noticed oil pooling on the ground, called the Frederick Fire Dept., who contacted K.P.K.. Latitude: 40.097260 Longitude: -104.986950 o STILL NOT COMPLETED AS OF 2/06/24. Excavation completed and backfilled. Site investigation data and a reclamation plan submitted to COGCC. Form 27 still in process with the COGCC. Background soil sample test trenches to be backfilled this week or next. COGCC denied Form 27 remediation plan on 3/1/23. o Six NOAVs including failure to prevent pollution; failure to take reasonable actions to prevent spills: Rule 7002.f Stormwater Management; 902. Pollution; 7102 Operations, Maintenance, and Repair; 972.b. Reporting Spills or Releases of E&P Waste, Gas, or Produced Fluids; 913. Site Investigation, Remediation, and Closure; and 913. failure to fence or cover open excavation. Morgan Al Header (Spill Report 403055337) - on 5/18/2022, while collecting background samples for remediation project 22032, MarCom discovered another historical release. c Same site as Morgan A #1. Combined under 1 remediation project. 10. Stromquist 4A (Spill report 403050091; Remediation no. 25606) - On 5/15/2022, Landowner discovered product at surface on his property and notified KPK. c Latitude: 40.123447 Longitude: -105.013035 o STILL NOT COMPLETED AS OF 2/06/24. A Form 27 to evaluate groundwater impacts has been approved and the site investigation was con610ducted on11/14/22. Analytical results are pending. Field screening indicates additional remedial excavation may be needed. ECMC denied Form 27 remediation plan on 1/05/24. 11. Milton Nelson (Remediation Project No. 23610) - Flowline was broken, leaking oil. c Latitude: 40.124020 Longitude: -105.009606 o STILL NOT COMPLETED AS OF 2/06/24. Background soil sampling has been completed in preparation for a backfill request. No additional source removal is proposed. Groundwater monitoring program to be implemented post backfill. Form 27 remediation plan was approved on 12/05/22. 2 12. UPRR 42 Pan Am AE 2 manifold (Remediation project 20310) KPK was notified about an active flowline release on 7/2/2021. Flowline was immediately shut in and controlled. Small volume of fluids misted at surface. o Latitude: 40.092035 Longitude: -104.924641 o STILL NOT COMPLETED AS OF 2/06/24. Source removal has been conducted, additional sampling for confirmation is planned. Landowner has been notified. ECMC denied Form 27 remediation plan on 10/03/23. 13. State 14 -2 (Spill ID 483070) - located in field behind Fredrick High School. o Latitude: 40.096158 Longitude: -104.945565 o STILL NOT COMPLETED AS OF 2/06/24. Occidental Petroleum (Oxy) line strike reported by KPK under a Form 19. Background sampling conducted week of 11/7 to request closure once analytical results are received. Excavation backfilled by Oxy. No further action requested but not yet approved. ECMC denied Form 19 closure on 2/10/23. 14. McDonald #2 Flowline Release (Spill ID # 403234873) o Latitude: 40.105410 Longitude: -104.958190 o Surface/Business Owner contacted KPK about liquid surfacing in storage yard. KPK responded and isolated segment of flowline between McDonald #2 well and flowline manifold just south of McDonald #1 well. Liquid pooled within lot space no. 6 approximately 30 sq ft of surface impact. NOT COMPLETED AS OF 2/06/24. 15. Guadagnoli Consolidated Flowline (Spill ID 403349253) — o Latitude: 40.102367 Longitude: -104.941582 o In Tipple Parkway right of way. Smith Environmental (Smith) was installing a monitoring well for the Town of Frederick and discovered potential historical impacted soils on 3/16/2023. o NOT COMPLETED AS OF 2/06/24. COGCC required submittal of Form 27 remediation because ground water was impacted. Craig Meis (KPK Environmental Director) wrote to the COGCC... "Considering the current State of Affairs at KPK with the Final Order issued by the COGCC and our inability to retain contractors to conduct environmental site assessment work, we have no current plans to conduct a subsurface site assessment but will keep you both informed should that change hopefully in the very near future." Email March 27, 2023. (K-2) "As of 11/29/2023 Spill ID #484039 has been open for 258 days - No site investigation/remediation has been reported to date." 16. Facility 4 Flowline @ Brozovich (Spill ID 403439412) o Latitude: 40.112380 Longitude: -104.957600 o NOT COMPLETED AS OF 2/06/24. The Lease operator found stained soil by the lease road and notified KPK. Crews were sent to isolate and blow down the flow line and excavate the impacted soils. The crew was able to uncover the flow line and locate the damaged steel pipe. Corrosion of the steel pipe is the reason of the failure. Further investigation is ongoing. "ECMC has not granted approval for excavation backfill; the last approved Supplemental Form 19 for this spill was received on June 30, 2023 (Doc # 403450984). On 09/28/23 "No analytical data has been provided by Operator for this location." 17. Hingley #2 Flowline (Spill ID 40346092) o Latitude: 40.114788 Longitude: -105.001046 o NOT COMPLETED AS OF 2/06/24. Release detected on the south side of the Hingley #1 wellsite. The spill was discovered by the pumper based on oil observed at the ground surface. The surface staining/oil area is approximately 400 sf. Surface staining and oil has been scraped at the surface in the areas downgradient of the release point and transported offsite for disposal. 18. Jillson #2 Bullplug Hist. Release (Spill ID 403643088) Latitude: 40.115327 Longitude: -104.991037 o NOT COMPLETED AS OF 2/06/24. Discovered on 1/2/24 Historical impacts beneath the newly identified leak, leading to the generation of more than 10 cubic yards of waste during the removal of impacted soil on 12/29/23 and 1/2/23 19. Facility 4 @ Ditlev Cl (Spill ID 403661051) o Latitude: 40.093323 Longitude: -104.935819 o NOT COMPLETED AS OF 2/06/24. a KPK employee discovered the presence of oil surfacing at near the Ditlev-Simonson C1 well. Discovered on 01/17/2024 20. Pan Am B 4,6,10,12 (Spill ID 403666721) o Latitude: 40.080693 Longitude: -104.989311 o NOT COMPLETED AS OF 2/06/24. The tenants in the industrial park northeast of the spill heard unusual noises and investigated the sound to see oil at the ground surface. Discovered on 01/24/2024 21. Johnson 1 Flowline (Spill ID 403666525) c Latitude: 40.103217 Longitude: -104.968156 o NOT COMPLETED AS OF 2/06/24. On 1/23/24 a KPK pumper noticed oil coming out at the ground surface. 22. Facility 4 @ UPRR 43 PAN AM AE (Spill ID 403667163) o Latitude: 40.093916 Longitude: -104.924281 o NOT COMPLETED AS OF 2/06/24. This spill reported on 1/25/2024 was identified on the same flowline approximately 3300 feet east of the 485898 spill. 4 Esther Gesick From: Sent: To: Cc: Subject: Kevin Ross Thursday, February 22, 2024 3:49 PM tcrites@frederickco.gov Bruce Barker; Commissioners; Jason Maxey; Esther Gesick RE; Letter request Mayor Crites Thank you for reaching out to the Weld County Board of Commissioners regarding a letter of support in regards to your complaint letter towards KPK. Weld County's legal authority ends at our unincorporated boundary. Additionally, none of the KPK well sites are permitted through Weld County's WOGLA process. We feel it would be inappropriate to comment on the matter at this time as a board. Regards Kevin Ross , ewin §rovb Chairman of the Board Weld County Commissioner -at -Large 970-381-5172(cell) Hello