Analytical Results of the 2008 Seep
COGCC staff e-mailed me the results of the seep
sampling on Tuesday night, but it took awhile to obtain permission to speak
to the lab about the results. Once that was secured, I was able to understand what data
represented controls and what data was relative to our samples.
From my discussion with the lab I learned that essentially
the water from the orange gunk was tested for BTEX (benzene, ethyl benzene,
toluene and zylene) and there were none detected.
According to the COGCC, their staff has analyzed the
orange “gunk” but I have not been provided those results – though I have a
call in.
The results of the BTEX analysis are not
surprising given what we believe are the same environmental symptoms
currently seen on Langegger’s property, and there are no surface BTEX hits
there either – however, in a ground water
monitor nearby there have been. These reports are apparently available on
the COGCC website, though I've not yet looked for them.
The soil from the black seep was also tested.
This soil was tested only for “Diesel Range Organics ["DRO”] – and these
oil-related hydrocarbon compounds were detected. The detectable level
is 5.6 mg/kg, and the results were 9.9 mg/kg.
Whoever ordered the analysis had to have made
certain preliminary conclusions in order to request what to test for. Given
that the test was for Diesel Range Organics (oil-related hydrocarbons), I am
disappointed that neither the water nor the gas associated with this aspect
of the seep was tested for BTEX.
In other states, this is
considered a serious concern and BTEX testing for soil and ground water is a matter
of course. Further, if any levels of Diesel Range Organics are noted in
soils - particularly where inhalation of vapors may have occurred (remember
me hanging over the damned thing sucking it up while I filmed it belching
away?) naphthalenes are also tested for. Ditto in the ground water. None of
that, however and to my knowledge, was tested by the COGCC. A DOW employee
was also exposed to those potential vapors as were two COGCC staffers, a
neighbor and other family members.
In fact, this was the extent of
their response to us that accompanied the sampling results:
"Here are the analytical results from the 7/3/08
sampling conducted by [name removed]. There are no contamination concerns
from the sample results. The COGCC is continuing to evaluate your concerns
regarding West Divide Creek."
When you consider that there appears to be a
new underground upwelling feeding these seeps, and the symptoms of it
(orange gunk on the banks) are familiar to events in 2004, and diesel
hydrocarbons – a component of oil - were found in the soil – the source of
which could be from heavy equipment or even drilling fluids, I think an
abundance of caution is called for and further investigation should occur
immediately.
In discussing the circulation of
drilling fluids during the drilling process,
a tutorial on naturalgas.org notes the following
under the header "Circulating Systems": “Typically, liquid drilling
fluids are used. The most common liquid drilling fluid, known as 'mud', may
contain clay, chemicals, weighting materials, water, oil, or gases.” The
link to that quote follows.
http://www.naturalgas.org/naturalgas/extraction_rotary.asp
Oil-related hydrocarbons - or
Diesel Range Organics were detected in the soil sample - significantly above
detectable limits. These types of things are normally associated with oil
spills, refined petroleum products or even home heating oil. Further, due to
their oily nature, Diesel Range Organics tend to separate from water and
adhere to soil structures leaving the water to hold onto associated BTEX,
like benzene. So, the finding of these organics in the soil should provide a
significant clue as to what may be in the ground water. Given the
circumstances that surround its detection, we are highly suspicious of its
origin and apparent introduction into the environment.
If, as we suspect, this seep is the result of
nearby drilling activities which were occurring at the time we first began
to notice bubbling in the creek (or perhaps occurred some time previous),
and if these oil/hydrocarbon components can be found in drilling fluids, and
if - as the results suggest - these same or similar oil-related hydrocarbons
were found in the soil sample tested that was associated with the seep, we
are left deeply concerned for the health of the environment. And of course,
we want the COGCC to act responsibly and properly investigate.
Plus, this also raises a serious question
about injection wells – and pit waste fluids that may have been injected.
We know
some of the characteristics of
some of the surface – but what
is underground? We have no idea.
What
flowed across or from beneath the sandstone boulders and caused it to
deteriorate? This substance also has yet to be sampled.
On Langegger’s place near the “main seep” we
know BTEX have been present underground – and are still being treated with
sparging equipment. But here, we have no idea, and our water well draws
water from this shallow aquifer. The aquifer charges the creek and the whole
thing flows downstream to the Colorado River and on to Silt and Rifle.
For a year, we have had to
encourage inch by painful inch, the COGCC toward an investigation of this
area despite conditions worsening which have finally culminated in the
revelation that Diesel Range Organics are present in the surface soil. And
yet, still, they continue to "evaluate" our concerns. With no COGCC-initiated
communication and no active interest when we raise concerns - I'm not sure
that is being accomplished.
One cannot and should not draw
conclusions from a single data point or observation. Here - we have a suite
of observations and finally a little sampling which should under reasonable
circumstances lead to deeper inquiry in order to rule-out the extent of
potential contamination, not disregard and minimize that possibility by
failing to inquire where it is clearly suspected at least by us - only
because we've see it before, and it is still occurring on Langegger's
property.
I think these results, coupled with obvious surface
observations, should compel a responsible regulatory body to thoroughly
investigate. In other states, that is exactly what happens. The
industry says that Colorado rules are currently some of the most conducive
to profitable operations. If this is the case -and I am beginning to see
that it is - no wonder industry is lobbying so hard for better rules - like
the disclosure of chemicals. In other states, regulatory environmental
officials would be looking into what is present on the surface and
underground - but here, there appears to be less a pursuit of truth and far
more the preservation of carefully structured ignorance.
In the least, a ground water
monitor (a ten or fifteen foot hole in the ground about as big around as a
coffee cup) should be installed behind this seep and sampled. This is a
significant area that is impacted – probably 30-40 yards square and the
sampling results collected from a seep indicate a subsurface source -
significant enough to remain present in shallow surface soils.
Despite the still active
seep which began in 2004, the COGCC (lobbied by EnCana) lifted the
moratorium on drilling in this area. (We happen to live at one of the
shallowest points in the gas bearing formation - so we are the low-hanging
fruit. The gas beneath our home is cheapest to reach for, so the profits are
presumably higher). In lifting that moratorium, the COGCC instituted a set
of drilling stipulations which presumed to prevent such an environmental
catastrophe from happening again. But it was a crap shoot. A guessing game.
An experiment and everyone knew it What we are observing, we believe, are
the effects of an experimental framework insufficient to safeguard public
safety, the environment and specifically, the public waters of Divide Creek.
If drilling is to occur here,
the COGCC and EnCana have a public responsibility to ensure it is done
safely. If it cannot be done safely, then it must not occur at all -
because the cost to families, our home and the environment is too great to
bear. People worry about ANWR. I worry about ANWR. Look what is
happening here, right under our noses. Clearly, these issues point to the
potential need to bolster the stipulations - though we do not want to endure
another failed experiment. This geology should be a model - what is
happening here, along this canyon outcrop - should be a model for similar
areas, in order to avoid destroying them.
We are certain what we are observing is a
seep, but we are deeply concerned and disappointed that the COGCC appears
reluctant to uncover its source.
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