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2008 Divide Creek Seep 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
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Contents - this page The COGCC responds to my protest, approving EnCana's request A chronology of Cluster-cluckism in the news
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| Entry 08-29-10
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Since December 2008, lots of stuff has been going on in the
way of our efforts to inspire the COGCC to do its job. It's been an uphill
battle. August 29, 2010 Importantly, Summerhawk Valley continues to try to recover from impacts; and, as of this writing, I'd guestimate that, on balance, it has recovered by perhaps 70%. This is presumably because conditions that contributed to the seep have been corrected. Problem is, without a proper investigation, we don't know what went wrong, nor how and to what degree it was 'fixed'. That means this land is likely to experience yet another pummeling once drilling commences in earnest on the canyon rim of Summerhawk Valley - already begun August 20, 2010 (see photo below which shows the rig's proximity to the main 2008 seep area). Part of the slow recovery is due to the fact that probably 20% included vegetation which was killed and will not recover, the remainder continues experiencing impact, both in West Divide Creek and on the land around it. Of the wildlife species, some have returned, but this part of the process takes quite a while, as we learned during the 2004 seep. The area had experienced, at that time, a complete exodus of wildlife and had yet to fully recover when another seep emerged in 2008 and resulted in an almost duplicate experience. Here it is mid-2010 and some species have, again, returned in lower numbers, but EnCana installed a rig on the rim of the canyon above the 2008 seep, and the noise has once again driven away some of the wildlife that had twice returned. We expect the new rig on the East side of the canyon will result (together with the anticipated installation of another rig to the south, adjacent to and beneath the 2004 seep areas) in impacts that will completely destroy whatever remains of Summerhawk Valley. Sadly, this could have been prevented.
[08-16-10] This area is maybe fifteen feet East of our water well. You can still see a very active area generating biofilm (the oily looking stuff which is actually a bacterial mat); and iron-reducing bacteria (the rusty looking stuff). This is, I believe sourcing from a spring to the East which surged in output at the time of the 2008 seep. The output of water continues to be high, saturating the ground with water that may have elevated salt and hydrocarbons such as methane in it. The little bacteria that make the ground look so yucky eat methane and other hydrocarbons. We are assured from the COGCC that this is fine. However, and finally, a soil gas survey is scheduled to begin for this area this month. Whatever is shown - I expect the COGCC to shout "Biogenic!"; but, certainly, if there is evidence of methane there is reason aplenty to prompt the COGCC to look further. If we had the money, we'd do it ourselves.
[08-16-10] an area to the East of Turkey Point - where ethane had been found expressing to the surface in the creek just left (North) of here.
This is a soggy area closer to the spring mentioned above. I have no idea what the pool of red stuff and trailing black/green stuff are. My guess is some type of bacteria (the red is probably iron-reducing) - the vegetation probably also holds clues as to what water and soil chemistry qualities are supporting these conditions. Now, let's go back a bit and look at what else has
transpired March 16, 2009 I ask Garfield County to ask the COGCC to reinstate the drilling
moratorium April 20, 2009 I ask again... Again, in a letter to Garfield County and the COGCC I ask for a reinstatement of the drilling moratorium ahead of EnCana's plans to frac a series of nine wells on the Brown pad - implicated in the 2004 seep. No dice. Dr. Thyne reviews the 2008 West Divide Creek Seep Dr Thyne finds limited public data due in part to inaccessibility. We have shared that same frustration... no data available to us or no access. Dr. Thyne's cursory review indicates that my observations are in accordance with those associated with a reductive environment - that is, an environment saturated with methane and bacteria are acting to try and reduce it to more neutral levels. He recommends that Garfield County take specific actions relative to the obtainment and review of data. The County languishes despite promises for immediate action. You can see excerpts of his report here July 14 - 15, 2009 Dr. Thyne evidently suspected through this and perhaps also through his analysis of the Divide Creek Seep of 2008, and maybe from a few other data sources, that methane may, possibly, it appears, be finding its way into domestic water wells, illuminating a potential pattern of possible contamination for which those in a position to be concerned for such matters, may wish to be concerned. What a second... "What was that?!" industry raised its mono-brow in a collective grunt heard round the country. That's right sports fans, methane may be migrating into domestic water wells. "And from WHAT SOURCE?!" industry bangs their forearms on the ground and demands to know... maybe...FROM DRILLING! PR firms are alerted, attorneys are summoned, politicians are speed-dialed and industry huddles... hummuna, hummuna, hummuna... experts whip out their compasses, rulers and lined paper. In what appears to be a poorly considered and totally reactionary fit of frustrated placation, the COGCC decrees it will hold forth a "hearing" in which no one will have standing to speak or intervene... but a goodly many and several of industries' heavies will pontificate in great measure against Dr. Thyne's reasonable supposition. In order to appear fair-minded and formal, Garfield County is allowed to present also. This is a "hearing" after all, and the COGCC Commissioners are gathered, it may be presumed, to hear. Here then, (trumpets sound and the scroll is rolled out) are the terms of the "hearing": Garfield County shall proceed first. Garfield County will have no knowledge of an opportunity for rebuttal. But, Garfield County will be allowed limited rebuttal if it so requests. Industry will have benefit of full knowledge of Dr. Thyne's conclusions, while Garfield County will have no knowledge of the contents of industries' presentations. What followed was a total sham of a "hearing" and what amounted to a psheudo-intellectual dog-pile upon Dr. Thyne's professional, indeed, papered reputation. But industry, being industry, and the COGCC being, well, the COGCC, failed utterly to see the crass shallowness in their own contrived display. To see the agenda for and listen to the full transcript of this ludicrous
event click here "Silt-area
drilling report contentious" November 16, 2009 We drive to Glenwood - again - and in person - again - implore Garfield County to ask the COGCC for a moratorium. The country says no way; but, when reminded of the County's promises of "immediate" response (now months later) based on Dr. Tyne's findings, the County does agree to follow through with Dr. Thyne's recommendations (below)
March 30, 2010 Methane appears in two domestic water wells in the near area. We ask again for a moratorium. Sometime at the end of 2009... beginning of 2010 methane shows up in the Moon (old Dietrich's place) domestic water well. [EnCana bought this property from Dietrich when high levels of methane showed up in the their water at the time of the 2004 seep]. Methane also showed up in Miller's domestic water well. The seeps from 2004 and 2008 lie between these two Easterly and Westerly points along a pretty straight line - which also happens to coincide with the 2004 Arbaney (Magic P3) gas kick, explosion and fault disturbance. In an amazing turn of events and counter to a long-standing patter of behavior, the COGCC orders a soil gas survey for the area around the Arbaney and the Schwartz pads. The Arbaney survey, completed in the summer of 2010, reveals a good deal of methane saturation in the area which appears to be of the same or similar origin to the gas found around the P3 pad in 2004. This gas harkens to wells put in place prior to the new stipulations which resulted in the lifting of the moratorium. This appears to focus concern then on the older structural integrity of wells installed pre-stipulations (of which there are only a few). There appears then to be a resurgence of gas in this area. Which narrows the range of questions, but also encompasses risks of hydraulic fracturing in this unique hydro-geology. Before the Schwartz well is surveyed at the end of August, EnCana, in a further, astonishing move, volunteers to survey our property as well. When the COGCC ordered EnCana to conduct a soil gas survey of the nine-mile moratorium area in 2004, our property was inexplicably excised. Now, I wonder how that could have happened, especially when we raised nine kinds of heck about it. In March, we bring the issue of hydrocarbons infiltrating domestic wells to the attention of Garfield County via a letter. Apparently, the county forwarded it to the COGCC. In our letter, we asked again for the moratorium to be reinstated. To not do so is, we feel, egregious negligence of the sort that led to the Gulf oil disaster. June 07, 2010 I presented a packet demonstrating the background of this situation: its geology, hydrology, soil surveys, risks to groundwater, etc. Garfield County's Oil and gas Liaison also presented and expressed frustration at the Country's inability to work with the COGCC environmental supervisor to gain access to data and resolve professional disagreement regarding theories relative to ongoing seeps in the area. Garfield County's environmental consultant also presented a summation of his findings from the Phase I study, Phase II study and Analysis of the 2008 Divide Creek Seep. Commissioner Mike Samson agreed to my request that Dr. Thyne follow-up with his review of circumstances surrounding West Divide Creek and the seep of 2008. He stopped short of recommending a moratorium. As expected, Commission Martin noted the importance of jobs over public health. While there is little hope I will ever see eye-to-eye with Commissioner Martin, and certainly, I fail to appreciate unquestioning adherence to party-line positions from any political representative, I deeply appreciate Commissioner Samson's common-sense and open-minded approach to this complicated issue. Since he first heard our appeal for Garfield County to request the COGCC to reinstate the moratorium, he has appeared to sincerely endeavor to embrace the comprehensive nature of this public health issue, going so far as to pick up the phone himself and request a sit-down conference between the COGCC's environmental supervisor and Garfield County's Oil and gas Liaison and retained environmental consultant. To date that has not occurred. The minutes from our June 7th presentation to the County are here - but fail to account for a majority portion of dialogue. August, 29 2010 Investigation into symptoms which increasingly avail themselves in the former moratorium area On the 31st of August (eleven days after putting up a rig on the rim of Summerhawk Valley) EnCana's subcontractors are to embark on a soil gas survey for parts of our property. In the 2004 soil gas survey, our property was excluded, despite there having been symptoms of a seep across it and hydrocarbons detected in the soil on either side of it. Quite unexpectedly, there appears to be a sudden and concerted effort by the COGCC to figure out what is occurring in this former moratorium area. Appointed to the task is who appears to be a truly competent, conscientious, objective and capable individual conducting what I would call a reasonable and logical investigation - albeit a bit late in the game. At this point, I expect this person could well be being positioned in a way which attempts to insulate from culpability those who have botched or intentionally blocked nearly every inquiry into investigation thus far. Why would I think that, when some could argue the renewed expression of gas in the Moon well is basis enough for such an investigation? Because we would argue that 1) the 2008 seep which is ongoing; 2) impacts to monitor wells; 3) impacts to another neighbor's domestic well; and, 4) EnCana's failure to explain the continued expression of the 2004 seep - also ongoing - should have provided that basis long before now. Any reasonable person would also argue that to impact an investigation at this stage with very nearby drilling activities - as from the newly positioned O1EB - will only 'muddy the waters'. Are muddy waters being summoned? Does the COGCC need a 'fall-guy'... someone to put forth a credentialed, heroic but ultimately futile effort, and yield an inconclusive summary only to have drilling commence as if best efforts had long led the way? Maybe this protracted struggle with an all-too political regulatory agency, that has heretofore appeared more interested in stonewalling than fact-finding, has me a bit jaded. I'd like to believe all this is an innocent or even logical coincidence. And maybe, in part, I will believe that. But, after all these long, difficult years, the theory of benign inattention just doesn't quite add up. Curiously, this representative launches an investigation (and seemingly very sincerely so) over two years after the 2008 seep emerged and continues to persist, and in concert with a newly engaged and massive drilling assault set to assume on Summerhawk Valley begun a little over a week ago. I give full credit to this representative's manner and methodology. But I fear, in the face of the destruction surely to come, the effort - and whatever reason that propels it - is simply too late. |
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June 08, 2010 Letter sent to EPA re: Hydraulic Fracturing Study I live in the West Divide Creek area of Garfield County, Colorado. This area was impacted in 2004 from drilling activities which led to a methane seep of an estimated 115 million cubic feet into the surrounding terrestrial and aquatic environment. That event continues in one area of the region. This event was foreshadowed by a massive kick (or blowout) to a well three weeks prior to the seep. This event was discounted by both the operator (EnCana Oil and Gas, USA) and the Colorado Oil and Gas Conservation Commission as having any effect and was therefore never investigated. Also during that time, cement was lost down two well bores which were in production. Hydraulic fracturing commenced on one of those wells (despite lost cement circulation) and it was soon targeted as the source of contamination. The operator contested any wrongdoing, but naturally paid a fine – the largest in the state of Colorado. From a regulatory perspective, the matter was quickly and officially settled.New procedural (cementing) stipulations were promulgated and drilling continued. The behavior of this seep – and why it continues, even after re-cementing took place – remains unexplained by either EnCana’s models or those of the COGCC.Since that time (specifically in 2008) new impacts have been documented through surface observation. The COGCC waited three months to investigate these matters and to this day refuses to order groundwater sampling to determine the cause and scope of these impacts. While largely uninvestigated, the impacts continue. Dr. Geoffrey Thyne, a hydro-geologic consultant for Garfield County has concurred that surface observations are coincident with characteristics of a reductive, methane saturated environment. Yet, we have been unable to muster the COGCC to investigate nor EnCana to acknowledge what is observable and obvious. EnCana has now proposed to drill ten new wells adjacent to this active seeping zone and directly beneath it as well as within the general vicinity of both the 2004 seep and the 2008 seep. They have argued all along that there is no impact from their activities and the COGCC has concurred. However measurable impacts continue. Currently, within our domestic (shallow water in situ well) salinity and other dissolved solids are dramatically on the rise. Propane and ethane have been detected in nearby shallow monitor wells. Other water wells in the vicinity have recently become contaminated with higher methane counts and traces of other hydrocarbons. Our geology is comprised of fluvial tight sands and coal seams. The surface is comprised of Wasatch formation outcrop, aquifers, springs and creeks. To my knowledge, no other area of on-going hydraulic fracturing activity possesses this unique profile. Given the GOGCC’s reluctance and inability to ascertain sources of impact and EnCana’s refusal to acknowledge them, impacts are continuing. We’ve asked for revised stipulations from the COGCC, but without what it considers proof of impacts, none – not even an engineering and tandem environmental review has occurred. It is a catch-22 situation. I’d like, then, for the EPA to consider this area for inclusion in its 2010 hydraulic fracturing study. Increasingly, other fluvial zones are being drilled, but none which are supported by over half a decade of existing data.There is a large body of water-sampling data as well as a three-phase and on-going hydro-geologic study, commissioned by Garfield County, available relative to this area. Some of this data, however (that collected by EnCana subcontractors) appears incomplete and at times inconsistent in its availability. Nonetheless, it would doubtless be useful as backgrounder should this region be considered for inclusion in the EPA’s fracturing study. It would also negate duplicity and conserve funds. Dr. Thyne is intimately familiar with this area as he designed the Phase I hydro-geologic study. He would doubtless be a potentially valuable resource also.
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[Given the Board of Garfield County Commissioner's (BOCC) ability to intervene in the protest of new wells drilled into the 2004 seep geology, I filed a protest/intervention below with the COGCC and shared it with the BOCC.] Protest/intervention to deny drilling of these specific wells until an impact study and determination of 2004 seep cause can be determined. Colorado Oil and Gas Conservation
Commission May 14, 2010 Mr. Neslin, in accordance with rule 509, this letter (5 pages) is a formal notice of protest relative to the following: Cause No. 191 / Docket No. 1006-EX-03 (Twin Creek well #12-5A2). This well is relative to the anticipated installation of the Twin Creek F12E pad. Please distribute the enclosed copies to the COGCC Commissioners. Thank you. COGCC Commissioners, in considering whether to allow EnCana’s request for location exceptions for the above-mentioned applications, please recognize that the region in which the target formation lies is known to be highly, deeply, vertically faulted, over-pressurized and the subject of multiple incidents involving documented, significant adverse impacts to public health and safety as well as environmental resources. Underlying formation conditions combined with known and in some cases catastrophic drilling-related accidents acknowledged by the COGCC have collectively made this region a very unstable operational environment. Events include: 1) A protracted January, 2004 (Twin Creeks) plug-induced pressure; 2) a massive March, 2004 (Arbany) blow-out; 3) March/April, 2004 (Brown / Schwartz) cementing failures and a 500 psi pressure kick; 4) high braden head pressures in two Bill Barrett wells (2006); 5) an October, 2007 500 psi pressure kick (Schwartz); and, 6) December 2008 / January 2009 cementing problems (Brown). These issues have led to series of adverse impacts including: 1) a massive and on-going regional gas seep in 2004; 2) a temporary moratorium; 3) the promulgation of new drilling stipulations; and, 4) a second regional seep event in June, 2008 which remains largely uninvestigated by the COGCC. Recently, various compounds including increased methane, other hydrocarbons, salts and other dissolved solids have been detected in the region’s domestic water wells, including ours. To date, EnCana’s reasoning behind the emergence of the 2004 seep has been inconsistent with the seep’s continued behavior. This should dictate a renewed and temporary cessation of any further drilling activity as well as a prudent and timely re-examination of cause. The aforementioned events (leading up to April 01, 2004) were completely ignored as contributors to the 2004 seep; however, it is likely they established the conditions for and/or contributed directly to it. Another seep emerged in 2008. Despite the COGCC’s failure to explain its emergence contrary to new stipulations presumed to prevent it, the new seep was verified by Garfield County’s hydrogeologic consultant, Dr. Thyne, as consistent with documented surface, landowner observations indicating the presence of hydrocarbons in the surface environment indicative of a deeper source. This continuing seep and its cause(s) remain largely uninvestigated by the COGCC. Though the COGCC Commission finally requested that EnCana address ground water monitoring relative to this seep at a special hearing in July, 2009, to our knowledge no efforts have been made in that direction by either EnCana or the COGCC staff. Although EnCana was directed to work with us relative to such monitoring, our good faith efforts were ignored, communication was severed and, according to EnCana, all coordination was redirected between EnCana and COGCC staff, where it has remained – to our complete exclusion – undisclosed and presumably curtailed. An increase in irresponsible drilling activity can be reasonably suspected of causing or contributing to these degraded environmental conditions. The COGCC is mandated to respond to these impacts, yet has grossly failed to thoroughly and therefore adequately address them. Despite these lingering and unexplored impacts which are completely within the COGCC’s purview and ability to forestall, the COGCC has been heretofore unwilling to exercise prudent restraint in the issuance of permitting which facilitates continued adverse impacts to residents and the environment of this region. We believe the COGCC is fundamentally conflicted and therefore unable to adequately ensure dual mandates of public health and welfare protection as well as the profitable extraction of gas. We feel there is no compelling need to pursue gas in this manner, which clearly possesses the likelihood of contributing further damage to the formation, resulting in significant adverse impacts to the public’s health, safety and welfare in addition to environmental and wildlife resources. Our ownership in mineral interests implicated in this location exception request does not change our views on this matter. There can be no compelling reason to pursue minerals in a manner which necessitates further weakening of existing COGCC rules, particularly to the highly likely, significant and irreversible detriment of public health and safety and further environmental degradation. Additionally, the faulted nature of this formation increases the likelihood of unnecessarily interfering with and impeding the productivity of nearby wells. Clearly, stipulations established as a condition of lifting the moratorium and allowing further drilling have proven grossly inadequate. Current COGCC rules and procedures have failed to safeguard domestic water supplies and human health and safety. EnCana has failed to adequately address potential impacts in its herein mentioned applications and proposed plans for location exceptions to proposed drilling. As landowners and mineral owners, we have exhausted every available avenue to urge an abundance of caution, responsible development, inquiry into failed policy and practice and accountability for known but officially unexamined impacts. Any further drilling of this region, without a thorough investigation into causes of degraded water and terrestrial environments and a means of mitigating further damages would be egregiously negligent and we contest and protest the COGCC’s approval of and EnCana’s pursuit of such development. We hereby, then, request that the COGCC deny approval of EnCana’s location exception applications. Due to physical disability and economic hardship, we are unable to attend the two-day pre-conference hearing relative to this application. Our inability to physically appear should in no way be deemed a voluntary waiver of our bonafide protest in this contested matter. Nor should our inability to appear be deemed a concurrence to any agreement reached, nor to any order or ruling made at the prehearing conference or thereafter. I acknowledge this presents a deviation from procedure and therefore appreciate the COGCC’s efforts to accommodate such need as noted in the COGCC’s May 05, 2010 “Notice of Hearing”. The COGCC’s inherent opportunity, ability and authority to hear and decide these matters in accordance with the public’s health and welfare interests should have resulted in the temporary reinstatement of a moratorium in this region in 2008. Such a reasonable action would have provided for an opportunity to investigate on-going impacts, negating the imposition to address these requests for spacing orders and the presumed, associated installation of a new well pad adjacent to and aligned with the still active seep areas. It is appropriate then, under these continued and aggravated circumstances to locate all hearing matters relative to continued drilling in this region to this region. A failure to do so unfairly excludes impacted parties and unduly favors the operator in this case. If relocating such matters is not an acceptable proposal, perhaps a combination of document submission and teleconference would be. Such an arrangement, for these applications would be agreeable to me, and may be more cost effective and expeditious for all parties. Regards,
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The COGCC says 'Drill, baby drill - right into the 2004 seep!' Back in June of 2010, we asked Garfield County to intervene to prevent the COGCC from permitting EnCana to drill into the geology underlying the 2004 seep. You may recall this seep continues despite re-cementing efforts, which points strongly to hydraulic fracturing as a cause. Encana and the COGCC like to say that benzene is decreasing in the shallow groundwater's of West Divide Creek, so re-cementing must be working. Naturally, they fail to note that EnCana is constantly forcing air into the groundwater (sparging) in an effort to rip up and degrade benzene molecules. While this is a good thing in order to minimize the impact of the seep on the environment, it alters the characteristics of the gas expression and compromises data collection. This produces skewed results and presents a false picture of corrective action. But, you know what? I find that when presented with facts, these folks reliably mischaracterize. The amazing nature of science enables this type of approach. This is because anytime you try to measure anything, there are untold numbers of implicating variables - both accounted for and unaccounted for - which allow for interpretation. Interpretation leads to conflict and argument and, sometimes... convenient regulation. The ability to interpret science is one of the greatest frustrations of any investigation - presentations and testimony by 'experts' who have skewed findings due to poorly considered variables and associated interpretations for the benefit of their clients. Sorry, got off course... the county refused to intervene. The state eventually concluded its investigation (that time, anyway) and gave the thumbs up to EnCana... but with new stipulations, you know... new engineering procedures supposed to better protect the groundwater. Which... makes me wonder if there were no problems before, why the change?
From the: DEPARTMENT OF NATURAL RESOURCES: Mike King, Executive Director January 31, 2011 Re: Protest/Intervention 510 Statement Re: Form 2A Twin Creek #12-6C1 (F12E) Dear Lisa, The Colorado Oil and Gas Conservation Commission (COGCC) has carefully considered your May 26, 2010 email regarding Protest/Intervention 510 Statement Re: Form 2A Twin Creek #12-6C1 (F12E), including your concerns regarding prior impacts in that area. In addition to previous investigations and studies in the area, COGCC engineering and environmental staff are currently conducting the East Mamm Creek Area Investigation which has included: 1. Retaining a third-party consultant to evaluate natural gas wells in this area, including but not limited to drilling, cementing, and completion records and logs, 2. Incorporating recommendations made by the consultant into the conditions of approval that are placed on the permits, 3. Evaluating water well data from the area, including data from your well, 4. Reviewing geologic data for the area, and 5. Meeting with the Environmental Protection Agency, Garfield County, and their respective consultants to discuss geologic, environmental, and engineering matters. The COGCC currently does not have evidence to support enacting a temporary moratorium on drilling in the F12E area. Thus, the APDs for the wells on the F12E well pad will be approved. EnCana’s proposed well construction methods for F12E pad wells are more protective than are required by the Mamm Creek Notice To Operators (NTO), revised in 2007. Further, COGCC engineering and environmental staff has required additional precautionary construction measures and monitoring in the form of: - additional surface hole logging and data collection from the first well drilled on the pad; - additional open hole logs from one production hole drilled on the pad;- additional cementing and lost circulation procedures for all wells on the pad;- a higher top of cement above gas-bearing formations;- surface casing to be set 50 feet below the Molina members of the Wasatch Formation;- additional notifications in advance of various activities to allow COGCC inspectors and engineers to witness the activity; - using fresh water drilling mud for the surface casing borehole;- using well casing centralizers;- running cement evaluation tools on all casing strings before drilling out the casing shoe;- defining criteria that will be used to determine when intermediate casing will be required to be run in the well;- submitting additional field reports to the COGCC;- sampling of domestic water wells within ½ mile of the well pad, including your domestic water well, pre and post drilling of the wells on the F12E pad;- documented visual monitoring of West Divide Creek and other surface water bodies during the drilling of the five gas wells with trajectories passing beneath West Divide Creek, with increased focus as the well bore passes under West Divide Creek; and- collecting samples and submitting chemical inventories if increased bubbling in West Divide Creek or other surface water body is observed during monitoring.- The full list of conditions of approval can be viewed on our website ( http://cogcc.state.co.us/) associated with the Form 2, Application for Permit to Drill. The professional opinion of the COGCC staff involved is that these measures will fully protect areas of previous documented impact. In addition, the Garfield County (GARCO) Board of County Commissioners has asked to have the findings and recommendations of the East Mamm Creek Area Investigation presented to them and the COGCC staff will work with the GARCO to accommodate this request.Over the years, the COGCC has dedicated a significant amount of time, manpower and resources towards investigating the cause of the West Divide Creek Seep, and therefore we respectfully disagree with your statement that the “seep remains largely uninvestigated by the COGCC”. We collected nine gas samples on six different occasions during 2004, 2007, 2007, 2009, and 2010. We also collected six water samples on four different occasions during 2004, 2007, and 2009 and ten soil samples on multiple occasions during 2008 and 2009. We believe that residual thermogenic impacts, if present, would have been identifiable when at least some of these samples were collected. However, no such impacts were identified. We also believe that the Mamm Creek Notice to Operators (NTO), including the East Mamm Creek area requirements, which were revised February 9, 2007, has proven to be protective of the drinking water aquifers in the area. No instances have been identified to date where a gas well drilled in the East Mamm Creek area after the NTO originally went into effect, July 23, 2004, has been identified as the source of an impact to a domestic water well. The COGCC is continuing its investigation into the source of the Moon water well impact, but has not discovered any indicators of contribution from the nearby F11E pad wells. Encana’s soil gas survey did identify the source of the Moon water well impact as natural gas well(s) drilled on the P3 well pad. Both the P3 pad and the F11E pad are located above the crest of the Divide Creek Anticline. The P3 pad natural gas wells were all drilled prior to the issuance of the NTO. Nine out of ten natural gas wells on the nearby F11E pad were drilled after the NTO went into effect. The soil gas survey conducted by EnCana, on their property, including the F11E pad itself, did not identify any gas seeps originating at the F11E pad as it did on the P3 pad. These results are evidence that the East Mamm Creek NTO well construction requirements are sufficient to prevent the unintended migration of gas. The soil gas survey did not identify any seeps on or near the F11E pad nor did it identify any contribution from the F11E pad wells to the thermogenic gas identified in or near the Moon water well. This data supports our belief that the requirements in the NTO provide protection for public health, safety and the environment, including regional groundwater aquifers. As noted above, these requirements have been supplemented with additional conditions of approval for the wells proposed on the F12E well pad. Our engineering and environmental staff believe that the NTO requirements, together with the additional conditions of approval, will protect ground water resources in the area. I can assure you that the protection of public health, safety, welfare and the environment is taken very seriously by everyone at the COGCC. Thank you for your input on these issues. Regards, Colorado Oil and Gas Conservation Commission
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A chronology of cluster-cluckism in the news This mess since 2004 has been a royal clustercluck and I'm pretty sure I now suffer from an affliction recently identified by fellow embattled Rick Roles as "SCRSA" (sickarza): Serious Can't Remember S--- Anymore". In trying to get a list of relevant dates together without having to root through piles of poo, I found this awesome archive feature the Post Independent maintains: Thank you Independent! There is also an article from the Daily Sentinel, so thanks Sentinel for that too! Here then, for researchers and myself is a pretty decent chronology of the crap and crap shooters from 2004 forward. Somewhere in all this stuff is a really dorky picture of me I ask you to forgive. I consented to it on request of a reporter who, for whatever the heck reason, just wanted one. That was the context. It wasn't meant to go with any article, so imagine my surprise when my face pops up looking like an escapee from a happy farm -- "just give me a balloon and I'll be skipping friggin' happily away!" Anyway.. such is media. Post Independent and Daily Sentinel reporters have tracked much of our efforts with the COGCC and Garfield County through relevant articles linked here through online archives... www.postindependent.com The most recent articles occur first
in this list. 06/14/10
http://www.gjsentinel.com/news/articles/siltarea_drilling_report_conte/
County unwilling to endorse new ...
"County unwilling to endorese new Divide Creek drilling moratorium But Commissioners want state agency to pay closer attention to water concerns"
West Divide Creek resident says ...
"West Divide Creek resident says water contamination continues: Lisa Bracken asked the BOCC to support her in calling for a renewal of a drilling moratorium
EnCana, commission defend invest...
"EnCana, commission defend investigation of seep near Silt: Dispute landowner's claims they haven't done enough"
Garfield County agrees to help w...
"Garfield County agrees to help woman resolve water case: Will seek disclosure of details of Divide Creek Seep investigations"
No help for Bracken from COGCC o...
"No help for Bracken from COGCC officials: Woman who filed complaint concerning the West Divide Creek Seep in 2004 believes there is a new one, EnCana disagrees"
Oil and gas commission meets in ...
Oil and gas commission meets in Glenwood today, Wednesday: Two-day meeting to cover locally controversial topics
Garfield County commissioners co...
"Garfield County commissioners concerned about meeting agenda: Want to make sure three items will be discussed in July by the Colorado Oil and gas Conservation Commission" 06/02/2009 Garfield County commissioners OK Barrett water storage facility south of Silt (this is an area just over the ridge from us and within the former moratorium area - brilliant no?) 04/21/2009 Officials nix temporary injunction on fracturing near Silt
04/17/2009
Well fracturing prohibition sought near Silt
08/19/2009 Commissioners agree to ask for soil sampling near alleged seep south of Silt
07/04/2008
Landowner alerts authorities to ‘gunk’ seeping out of ground in Silt
11/28/2007 Testing finds no link between gas bubbling and drilling south of Silt
11/14/2007
Drilling's cumulative impacts on habitat south of Silt are worrying DOW
06/05/2006 Commission defends its lifting of the drilling moratorium south of Silt 04/26/2006 COGCC lifts drilling moratorium south of Silt
COGCC puts off moratorium decisi...
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All set to muddy the waters |
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[08-29-10] EnCana puts up a rig overlooking and adjacent to the 2008 seep still largely uninvestigated. |
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The term biogenic (meaning from fermenting or decomposing sources) is the battle cry of both the COGCC and the natural gas industry. "Biogenic" methane gas is also known as 'swamp gas'; that is, gas that is very active at the near surface and even deeper environments. "Thermogenic" methane gas is formation or produced gas. It comes from a production target thousands of feet below the surface. Here's the problem... the two gases can mix even in varying ratios far down into the earth. Near the surface, and in the presence of other gases - like oxygen - little microbes go to work on thermogenic gas to eat it up - it's their food supply. When the little microbes digest, they off-gas and poop out biogenic gas. Blurp... up comes a bubble in a pond. Scientists look for distinguishing features of the ratio to help them ascertain what type of gas and, therefore, its source they are looking at. It is an imperfect science, but the presence or absence of other gases like hydrocarbons and CO2 help them better determine the origins. ------------------------------------------------------------------------ Dr. Thyne's Analysis of West Divide Creek Seep 2008 (Excerpt from "Appendix 3" segment of report) "Appendix 3. Specific Complaints by Lisa Bracken with Current answers in italics. On five different occasions thermogenic methane has been detected in groundwater on our property. Those dates are: January 05, 2006 (MW23) / March 12, 2007 (MW23) / June 17,2008 (MW27) / September 30,2008 (MW23) / October 14,2008 (MW23). Thermogenic methane is identified by isotopic content. The only data publicly-available on the Bracken/Eicher property is for well MW23. Two samples from the COGCC website are available, September 2008 and December 2008. Additional pre-2006 analyses were available from the 2006 URS Phase 1 report. Both samples had isotopic signatures consistent with carbon dioxide reduction. This source of methane is biogenic, however, is not associated with fermentation, the common form of biogenic methane generation. The data do not currently support thermogenic sources for this gas. However, CO2-reduction processes are only significant in reducing environments which are consistent with spatial proximity to hydrocarbon seeps. However, the sample from December 8, 2008 had both ethane and propane detected. While ethane is rarely detected in biogenic samples, the presence of propane supports a thermogenic component."(end excerpt portion of report) ------------------------------------------------------------------------- (Excerpt from "Recommendations" segment of report) Recommendations Garfield County should ask COGCC to supply all the data from the seep monitoring program, associated reports, and post-seep complaints and responses for the County to archive and for future review and analysis. Garfield County should ask COGCC staff to prepare an evaluation of the continued seepage of methane and associated hydrocarbons to either estimate the likely duration of continued seepage if the source is the original discharge from the Schwartz 2-l5b well or identify the additional source(s) of hydrocarbons and provide appropriate remediation. Garfield County should ask impacted homeowners in the area to voluntarily provide data from their water wells that have been sampled by the State or gas producers to supplement the State data for future review and analysis. (End excerpt of report) ---------------------------------------------------------------------------- This report in full can be found via Garfield County's website here: Analysis of the West Divide Creek Seep
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The COGCC's official minutes form the 'special' hearing follow
A HEARING AGENDA Devereux Room Tuesday, July 14, 2009 and Wednesday July 15, 2009
1:00 p.m. Review of Report Prepared by Dr. Geoffrey Thyne on Hydrogeologic Study in Garfield County COGCC Industry – Bill Barrett Corp./ EnCana Oil & Gas/Williams Production Public Comments Garfield County 3:00 p.m. West Divide Creek Seep presentation COGCC Garfield County – Dr. Geoffrey Thyne Industry – EnCana Oil & Gas Public Comments -------------------------------------------------------------------------------- Review of Report Prepared By Dr. Geoffrey Thyne on a Hydrogeologic Study for Garfield County. Director Neslin gave a statement to set the stage for the presentation of technical evidence in support of, and countering, Dr. Thyne’s study. Dr. Geoffrey Thyne, Ph.D., consultant for Garfield County, gave a presentation on his hydrogeologic study for Garfield County and the associated impact on that hydrogeology by oil and gas activities. Dr. Peter Gintautus, Ph.D., COGCC Environmental Specialist, gave a presentation on the COGCC Staff analysis of Dr. Thyne’s Hydrogeologic Study for Garfield County. Brian Grigsby, COGCC Consultant for S.S. Papadopulos & Associates, Inc., gave a presentation on his analysis of Dr. Thyne’s Hydrogeologic Study for Garfield County. Mike Paules, Environmental and Safety Manager for Williams RMT Production Co. ("Williams"), and Mark Leverson, URS Consultant for Williams, gave a presentation on Williams’ analysis of Dr. Thyne’s Hydrogeologic Study for Garfield County. Scot Donato, Environmental and Safety Manager for Bill Barrett Corporation ("BBC") and Robert Sterret, Consulting Hydrogeologist for BBC, gave a presentation on BBC’s analysis of Dr. Thyne’s Hydrogeologic Study for Garfield County. Dr. Anthony Gorody, Ph.D., Consultant for EnCana Oil and Gas (USA) Inc., gave a presentation on his analysis of Dr. Thyne’s Hydrogeologic Study for Garfield County. Dr. Thyne gave rebutted some of the points brought out in counter-presentations and requested, on behalf of the Garfield County, a continuing and enhanced monitoring well program. Pepie Lahgegger, resident of West Divide Creek, Lisa Bracken, resident of West Divide Creek, and Hermann Staufer, resident of West Divide Creek, gave statements regarding their concerns surrounding the West Divide Creek and the impact oil and gas activity has on their lives. West Divide Creek Seep. David Andrews, COGCC Engineering Supervisor, and Margaret Ash, COGCC Environmental Supervisor, made presentations on the complaint and investigation of a gas seep in the West Divide Creek alleged to be associated by oil and gas activities. Dr. Geoffrey Thyne, Ph.D., consultant for Garfield County, gave a presentation on his hydrogeologic study for Garfield County and the associated impact on that hydrogeology by oil and gas activities in the area of West Divide Creek. Lisa Bracken, Silt, gave a statement to the Commission regarding her concerns surrounding an alleged gas seep associated with oil and gas activities near West Divide Creek. Tim Baer and Chris Williams, employees for EnCana, gave a presentation regarding the West Divide Gas Seep and efforts made by EnCana to conform with COGCC rules. The hearing adjourned at approximately 6:00 p.m. on July 14, 2009, subject to recall at or around 9:00 a.m. on July 15, 2009. To hear the audio recordings of the agenda items above
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Official
Minutes from Our June 7th Appeal to
a. Divide Creek Update – Judy Jordan Judy Jordan submitted the in-depth information on the Divide Creek Seep stating it is still a concern for county residents. New applications for permits to drill have arrived and Lisa Bracken has requested assistance with opposing them. Her concern is that natural gas continues to propagate through the subsurface, threatening water quality and additional production activities will only contribute more problems and potential sources of contamination. In the summer of 2009, COGCC staff arranged for a multi-attack on Dr. Geoffrey Thyne work. Then following the most recent appeal to the Board, Commissioner Samson arranged for a conference call with Dave Neslin, Debbie Baldwin and me, Judy Jordan. The outcome of that call was that COGCC determined the Dr. Thyne was wrong in his conclusions about water quality condition. Therefore, whatever the Board decides to do regarding Ms. Bracken’s request, I would recommend that the County encourage COGCC to investigate and remediate the improperly constructed wells noted in the URS and Papadopoulos in Phase I and Phase II studies back in 2004 that was connected to the Schwartz, Dietrich, Magic 10-1 well on EnCana P3pad. She encouraged the Board to support Dr. Thyme’s presentation to the scientific community as many regions of the country are in need of a greater factual understanding of the effects of natural gas development. Many need to know whether facing causes contamination and it is important for them to understand that our studies have not implicated facing. It would benefit the communities and the industry to understand areas of disagreement within our studies so they can apply lessons and elevate the overall level of knowledge about the issues.
Update on COGCC Commissioner Houpt – This is a topic that I need to recuse myself from the County Commissioner due to having discussed this as an Oil and Gas Commissioner but gave an update on the discussion held last Tuesday at COGCC hearing. She made the request that the staff come back to us with a presentation on how they’re approaching APD’s in this area and to analysis the activity that has occurred in the area from the Divide Creek seep, the study in place, to the concerns that were brought out a couple of years ago and the current contamination of a couple of wells, they are preparing something to bring back to the Oil and Gas Commission for the July meeting and then our COGCC chair asked if it would make sense for COGCC staff to meet with Jeff Thyne to talk about their various theories in this area. That is the direction given. Lisa thanked Tresi for doing this, these were outstanding directives and looking forward to the presentation, and when the staff sits, they will determine discrepancies and theories or approach and some clarification through this process, as there are some gaping holes in the data. a. Divide Creek Update – Judy Jordan Judy Jordan submitted the in-depth information on the Divide Creek Seep stating it is still a concern for county residents. New applications for permits to drill have arrived and Lisa Bracken has requested assistance with opposing them. Her concern is that natural gas continues to propagate through the subsurface, threatening water quality and additional production activities will only contribute more problems and potential sources of contamination. In the summer of 2009, COGCC staff arranged for a multi-attack on Dr. Geoffrey Thyne work. Then following the most recent appeal to the Board, Commissioner Samson arranged for a conference call with Dave Neslin, Debbie Baldwin and me, Judy Jordan. The outcome of that call was that COGCC determined the Dr. Thyne was wrong in his conclusions about water quality condition. Therefore, whatever the Board decides to do regarding Ms. Bracken’s request, I would recommend that the County encourage COGCC to investigate and remediate the improperly constructed wells noted in the URS and Papadopoulos in Phase I and Phase II studies back in 2004 that was connected to the Schwartz, Dietrich, Magic 10-1 well on EnCana P3pad. She encouraged the Board to support Dr. Thyne’s presentation to the scientific community as many regions of the country are in need of a greater factual understanding of the effects of natural gas development. Many need to know whether facing causes contamination and it is important for them to understand that our studies have not implicated facing. It would benefit the communities and the industry to understand areas of disagreement within our studies so they can apply lessons and elevate the overall level of knowledge about the issues. Dr. Thyne’s submitted his report and a power point presentation explaining the present day geography and subsurface geology. We need the state’s information. · F12E pad – Lisa Bracken Lisa Bracken submitted the following a detailed report. She stated that she appreciates the County asking the COGCC for their cooperation in this matter. Lisa requested the County for a temporary moratorium until this has been reviewed and corrected. Chairman Martin stated there is a problem and we understand that there are people living with this situation everyday and Judy does the reviews and we will move forward with a request to review and intervene on the F12E pad. Commissioner Samson agreed we need to go forward with this and commented to Lisa on the admirable job she has done and put in many hours on this issue. What is frustrating is the COGCC since Lisa has highlighted but it seems like their unwillingness to stonewall on certain things and this is a struggle for me. Judy pointed out that I called David Neslin, Debbie Baldwin the environmental manager and James Dillon their engineer and read into the record that “following Lisa Bracken’s most recent appeal to the BOCC for support in opposing any further APD’s in the Divide Creek area, Mike Samson arranged for a conference between COGCC staff, Dave Neslin, Debbie Baldwin and the engineer, Debbie described the activity that COGCC staff is taking to investigate Divide Creek issues and Dave Neslin stated that three heavy hitters showed up last summer and Mr. Thyne was wrong in his conclusions about water quality conditions. I explained that I thought Mr. Thyne’s reports maybe partly responsible for residents continued concerns and that perhaps a discussion between Debbie, Mr. Thyne to resolve disagreements over technical interpretations might help us to develop a common view of the situation that would make it more amenable to resolution. Debbie rejected this proposition out of hand and cited her busy schedule and higher priorities dealing with real problems as the reason. Clearly COGCC staff has no intention of working with us constructively to investigate and resolve the Divide Creek issues raised by your consultant and constituents, it is important to recognize that any additional effort the BOCC may decide to invest in this issue could be fruitless.” We are trying to help and I am not saying who is right or who is wrong, I am not an expert and I do not have all the answers but there are some questions that need to be answered that seems to me that the COGCC staff/commission have not done their part. With those four points that Lisa brought forward to the Board we need to go forward. Once we do this then we have done it and we cannot keep going with this issue. Lisa stated she understands that the County has limitations on priorities on budget and resources. Ed stated there are two things going on here, a request to intervene on the F-12 E Pad and then Judy’s request to encourage the COGCC to investigate. Chairman Martin – Following the recommendations of Judy Jordan, reviewing the information of Dr. Thyne presented on another basis to also review the 97 wells in reference to information and issues brought forth by Lisa Bracken, review the possible adjustment of field rules in reference to the Divide Creek Seep area as well set a workshop with Garfield County and Judy put all this together in a letter addressing it the Department of Natural Resources, that would be my motion. Commissioner Samson – Should we also have a copy go to the Chairman of the COGCC? Chairman Martin – Agreed and that should come from the Board of County Commissioners signed by the Chair. Commissioner Samson – Second. Don clarified there is no direction to request a hearing regarding the permit applications on the 12F pad. Chairman Martin did not include that and felt we would not have a chance and how much information we would have to present in reference to evidence to request that other than having all of this reviewed. Lisa appreciates all that Commissioner Samson has done, listened to and positive attitude. In favor: Martin – aye Samson – aye Houpt - recued
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Gas Well Saturation in Garfield County,
CO |
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The map above (though it's hard to tell it) is a portion of Garfield County, CO. The blight you see that is generally redish/purple... is all the wells (red and green dots) and pipelines (purple lines). The sky-bluish squiggly line generally arcing downward across the length-wise middle of the image is the Colorado River. Along that arc, you might notice big blotches of bright yellow... there is one in the lower left section (town of Parachute); one to the right of middle and a little towards the top (town of Rifle); and another smaller one just to the right of that - but barely visible (town of Silt). We're generally in the lower right area of this image - just on the Eastern edge of this pile of crap. Lots of folks in Rifle and Glenwood Springs think they're immune to the effects of all this drilling, but the winds blow West to East - that is, from left to right on this map, right on up-valley. This map, in its entirety can be accessed via Garfield County's website here (click "Gas Wells In Garfield County") http://garfield-county.com/Index.aspx?page=594 The "Gas Wells" link on the same page, under the header: "Explore Live County GIS Data" is very helpful also in finding well information.
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Other Relevant Links |
Compare the 2004 Seep with the 2008 Seep with video (scroll down to Video section) Divide Creek Then - 2004 [Seep photos and information] Divide Creek 'Now' - 2007 [Prior to the seep event of June 28, 2008] Timeline of events [From January 2004 to present]
COGCC 2004 Divide Creek Seep Order (judgment) and Vital
Exhibit showing faulting. (in
particular, you may find paragraphs 10, 20, 30 and 73 of interest).
Dr. Geoffrey Thyne's (of Science Based
Solutions) presentation to Garfield County
Re: "Sumary of PI and PII Hydrogeologic Characterization Studies - Mamm Creek
Area, Garfield County, CO" This key
PowerPoint presentation and its companion conclusive report provide an outstanding perspective of the dynamics
at play between the hydrology and the geology of this area in particular as
it specifically relates to drilling operations and risks to water supplies.
Please look for these links at the following addresses: Conclusions - http://garfield-county.com/Index.aspx?page=1149
Garfield County
Incomplete List of Hydraulic Fracturing Constituents (with MSDS sheets)
Garfield County Gas Wells and Pipelines
COGCC Quarterly Complaint Reports Analysis of the West Divide
Creek Seep
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