Entry - 11-06-2010

In October, 2010, a document titled “Gasland Correction Document 10-29-2010” was issued by the Colorado Oil and gas Conservation Commission. The document is prefaced on the COGCC homepage with this lead-in: "Because an informed public debate requires accurate information, the COGCC has corrected several errors in Gasland''s portrayal of Colorado incidents."

In this document the COGCC refutes accounts of contamination in Colorado, which is quite aligned with the difficulty we’ve had all along in the agency's failure to properly regulate aggressive natural gas development. The Commission, similar to its industry, spends a good deal of time defending its failures instead of simply acknowledging and correcting them.

  • Following are the COGCC's excerpted comments relative to West Divide Creek, then some "other information" from the COGCC.
     

  • Following that are a few key points I'll make relative to the COGCC's perspective of West Divide Creek
     

  • Finally, you can find a link to the full document.

First, the COGCC's comments on West Divide Creek

The West Divide Creek Seeps

Gasland also addresses complaints about oil and gas activity in the West Divide Creek area of the Piceance Basin in Garfield County, though it again confuses issues related to biogenic gas with those related to thermogenic gas. The film focuses on two seeps that are in close geographic proximity but derive from different origins. One of the seeps occurs in a wetland on property owned by Lisa Bracken, who appears in the film; it contains biogenic methane. The other seep, which the COGCC terms the West Divide Creek gas seep, is about 1,500 feet to the south on property owned by a neighbor; it contains thermogenic methane caused by EnCana’s failure to properly cement a natural gas well.

Gasland adopts the claim that the West Divide Creek gas seep was caused by hydraulic fracturing. After investigating the matter thoroughly in 2004, COGCC staff concluded the seep was caused by gas migrating up a gas well borehole that had not been properly cemented and in which the upper portion of the gas bearing Williams Fork Formation had not been isolated. On August 16, 2004, following a public hearing, the COGCC commissioners approved an enforcement order (Order 1V-276) that incorporated the staff’s causation conclusions and assessed a substantial fine against the operator.

In investigating the West Divide gas seep, the COGCC determined that it contains thermogenic methane. The gas composition and stable isotope signature of the gas closely matched that of the gas being produced from the Williams Fork Formation. The gas from both the West Divide Creek seep and the Williams Fork Formation is composed primarily of methane, but it also contains ethane, propane, butane, pentane, and hexanes. In addition, BTEX compounds were detected in ground and surface water in the vicinity of the West Divide Creek seep, which indicates that the gas is related to oil and gas activities and not of biogenic origin.

In contrast, the laboratory results for the gas samples collected from the seep on Ms. Bracken’s property have demonstrated that the gas is biogenic. The COGCC has collected nine gas samples on six different occasions during 2004, 2007, 2009, and 2010. With respect to each sample, the gas composition was found to be 100 percent methane, no heavier hydrocarbon compound was detected, and the stable isotope ratio indicated that the gas is biogenic. The COGCC has 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 from Ms. Bracken’s property. BTEX compounds and/or other hydrocarbons associated with oil and gas operations were not detected in any of these samples. Based on these results, the COGCC has concluded that the gas seep on Ms. Bracken’s property resulted from the fermentation of organic matter by methanogenic bacteria. This is not uncommon in wetland areas, such as those that exist along West Divide Creek.

Other Information

Oil and gas development is an industrial activity, and property owners sometimes complain that it has contaminated their water well. The COGCC investigates all such complaints and reports the results individually to the complainant and collectively to the Colorado Water Quality Control Division. In some cases, the COGCC has found that the well contains thermogenic methane linked to oil and gas development. In most cases, however, the COGCC has found that contamination is not present or that the methane comes from biogenic sources and is not attributable to oil and gas production. The following excerpt from a report summarizing the COGCC’s investigation following the contamination of the Ellsworth water well is illustrative:

In response to concerns regarding the presence of methane gas in water wells completed in the Laramie/Fox Hills Aquifer, COGCC, Noble Energy, and Anadarko/Kerr McGee sampled a total of 28 water wells between March 25, 2009 and April 7, 2009 across an approximately 170 square mile area. Sample results show that these wells contained either no methane gas or biogenic (biological generated) methane gas. None of these wells, other than the Ellsworth water well, contained thermogenic methane gas. The sample results along with letters discussing the results were sent by COGCC staff to the 28 well owners [who had requested testing].

Nevertheless, it remains important to establish prudent regulations to ensure that other resources, such as groundwater, are protected. Producing oil and gas formations in much of Colorado, including the Denver-Julesburg and Piceance Basins, lie at depths of up to 8,000 feet below the ground surface, while the aquifers that sustain domestic water wells are generally less than 1,000 feet below the ground surface. COGCC regulations establish casing and cementing standards to ensure that gas being produced from 8,000 feet down does not leak into the shallower aquifers. These regulations require wells to be cased with steel pipe and the casing to be surrounded by cement to create a hydraulic seal within the annular space between the wall of the well bore and the steel pipe. In addition, a number of recent amendments to the COGCC regulations address concerns raised about hydraulic fracturing:

• Rule 205 requires operators to inventory chemicals, including fracturing fluids, and to provide this information upon request to the COGCC and certain health care professionals;

• Rule 317 requires cement bond logs to confirm that aquifers are protected;

• Rule 317B imposes mandatory setbacks and enhanced environmental precautions on oil and gas development occurring near public drinking water sources;

• Rule 341 requires well pressures to be monitored during hydraulic fracturing;

• Rule 608 mandates additional pressure testing and water well sampling for coalbed methane wells; and

• Rules 903 , 904 , and 906 impose enhanced requirements for pit permitting, lining, monitoring, and secondary containment to ensure that pit fluids, including hydraulic fracturing flowback, do not leak.

Finally, it should be understood that the COGCC Director, Dave Neslin, offered to speak with Gasland’s producer, Josh Fox, on camera during the filming of the movie. Because the issues are technical and complex and arouse concerns in many people, Director Neslin asked that he be allowed to review any material from the interview that would be included in the final film. Unfortunately, Mr. Fox declined. Such a discussion might have prevented the inaccuracies noted above.

Now, for a few of my points relative to the COGCC's very skewed perspective on this issue

Key Points

 

  • Despite overwhelming evidence of hydrocarbon impact on our property which emerged in 2008, and included the presence of diesel range organics in a black ooze which smelled of propane, the COGCC failed to properly investigate it – never looking for signature BTEX and delaying any meaningful level of inquiry for months after its discovery. When I asked why BTEX weren’t tested for, and I inquired as to testing protocol, I learned – lo and behold, the COGCC has no testing protocol. It was left up to the visiting field inspector to decide what to test for. Incidentally, this seep emerged after EnCana began drilling on the same Schwartz pad of the notorious well found responsible for the 2004 seep (which continues). Once some level of COGCC inquiry did occur, it was relative to surface examination (already degraded by environmental conditions) and failed to include a correlative engineering review. Also, by the way, the COGCC has finally undertaken an investigation, including an engineering review, and lo and behold – right at the same time, intermediate casing was remediated on one of the Schwartz wells.

 

  • Methane - The distinction between biogenic and thermogenic methane is much less clear than the COGCC would have you believe. Methane is believed to be the product of degraded organic matter, period. Nearer the surface of the earth, biologic forces together with surface environmental conditions, such as sunlight and oxygen, affect methane’s ‘signature’ mix of compounds. Deeper underground, the heat of the earth’s core, lack of oxygen, pressure, and biologic mix affect the signature of that methane source. Complicating the matter even further is the introduction of a wetlands environment – Divide Creek. What is fascinating to me is that neither the COGCC nor the Colorado Department of Public Health and Environment have a wetlands department. In fact, I think the COGCC folks are mostly geologists with little specialized training in the way of hydrology, chemistry, biology, biochemistry, physics, fluid or thermal mechanics – all of which are involved in the generation of methane and production seeps. When I once asked the COGCC to explain the disconnected dynamics of biogenic gas in association with surface impacts, I was forwarded a link from a university in Michigan about how to recognize pollution. I’m just sayin’.

 

  • The COGCC also helpfully notes in this document that propane is a component of thermogenic methane. Yes, I would buy that. Of course, according to the USGS, so, usually, is ethane. Again, I find it fascinating that ethane and propane have been found in a very suspect monitor well on our property… the same well which has experts differing over the methane source. Oh, and the COGCC failed to note that the monitoring well is very near an area of the 2004 seep which the COGCC refused to acknowledge, even though the field inspector first noted it in that location. This appeared to be an effort to minimize the appearance of what was in reality a very large seep expressing in areas both aquatic and terrestrial all along Divide Creek. This was during the G.W. Bush days, and the inadequate investigation did make the seep appear minimized. After all, it’s not that hard to simply ignore something or fail to report it. But it still begs the question… why on earth is this methane, ethane and propane showing up in monitor well 23? I can’t possibly imagine… could it be from the unreported, uninvestigated seep that emerged nearby, back in 2004?

This page from the 'Journey' site discusses the biogenic / thermogenic situation in greater detail and provides links to the monitoring well results that show the presence of propane and ethane in MW23. http://journeyoftheforsaken.com/week76.htm

  

  • Did I mention the acknowledged area of the Schwartz seep from 2004 persists? Even after re-cementing “corrected it”? That makes me wonder – ‘what the heck?’ Did frac’ing cause the seep by causing or interconnecting faults which cannot be closed – some…. six, almost seven years later? Me thinks maybe so…

 

  • Interestingly, a frac company lobbyist had dropped off a packet of ‘information’ to Congressman Salazar’s DC office ahead of myself and a few others who had made an appointment to discuss potential perils of the practice relative to ground water sources. This was back in 2009, I think. That visit was too pathetic to even talk about. I’ll leave it to your imagination to guess why. But interestingly, while the frac company had taken the time to detail their dispute of claims from the situations noted in the COGCC document as well as others, the Divide Creek situation - conspicuously - was not addressed. Is that because maybe it cannot be disproven that hydraulic fracturing contributed to that ongoing situation? Maybe? Hmm? Be good to get the EPA out here to have a look-see. And I've certainly asked them to.

 

The bottom line here is that I have no interest in lying or spinning select components of fact. I have one interest and one interest alone. Find out what the heck is occurring here to decimate plants and wildlife. It doesn’t take a friggin’ genius to determine a general link between intense drilling and the coincident collapse of environment. Any attempt to dilute this truth will only entangle those who engage in it within their own web of deceit… which would be as dumb as say… destroying groundwater resources in the pursuit of gas in the first place. It may work for while, but sooner or later, the truth bubbles up. And that’s what is occurring. This is also why I believe there exists so vehement a backlash against a film that raises serious questions about the casual habits of a multi-billion dollar industry.

 

It is unfortunate this industry can’t hunker down and figure out the problem and fix it rather than continually deny it… even as a much more broadly emerging set of circumstances literally surfaces.

 

Seriously, COGCC, such a rebuttal would be preciously naive if it weren’t so indicative of this agency’s debilitating level of denial and justification, which makes it downright concerning.

 

Despite the COGCC's vehement denials of contamination on our property along  West Divide Creek due to drilling activities, whether in connection with the 2004 or 2008 seeps, in September of 2010 a soil gas survey was finally conducted in the area of the bubbles still expressing in the creek. Lo' and behold. Production gas was discovered which revealed propane, ethane, pentane and butane expressing into the surface waters.

It's easy to deny anything exists when you refuse to look for it.

“Informed pubic debate… accurate information”? Give me a break.

Here’s the COGCC’s take on Gasland:  http://cogcc.state.co.us/library/GASLAND%20DOC.pdf

 

  

 

 

 

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