The relentless pursuit of natural gas under West Divide Creek... and the question of pending impact
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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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The relentless pursuit of natural gas under West Divide Creek... and the question of pending impact
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Here we are looking to the South. The context map above is not meant to reflect pin-point accuracy or scale. It is intended to give a general idea of downhole well locations (five of which generally align at equal intervals North/South beneath West Divide Creek, beginning South from within the main seep area) and seep locations. The wells will originate from the F12E pad (under construction above in the photo. Drilling is scheduled to begin in December 2011 - conveniently ahead of the COGCC's new fracking regulations and as always just in time to totally disturb the wintering elk population). The illustration of the rig is just that - an illustration... the real rig is supposed to be up in a few weeks. This photo was taken on 09-22-11. Our domestic water well draws from the creek and sits between the still seeping 2008 seep (further north outside the scope of this photo) and just downstream of this mess.
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| Now, we turn around and look to the North. The context map below shows locations of the monitor
wells associated with the West Divide Creek seep of 2004. As noted in the map (top right) the entire 2008 main seep area has never been acknowledged by the COGCC (nor has the area below it, which is where the COGCC's own field inspector first identified massive fizzing associated with the 2004 seep event). Neither of these areas have monitor wells associated with them, despite detecting the presence of production gas in the areas by other, more transient means.
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| What? Me worry?
Also, if that were the case, I wonder why Geoffrey Thyne noted correlations to contaminants in water wells coincident with an increase in drilling in his published summary of Garfield County's Hydrogeologic study (which West Divide Creek was excluded from at industry's request)? Of course, he was professionally attacked by the industry and the COGCC for even postulating such suppositions. The EPA was going to include Divide Creek in its new study plan and settle the matter once and for all, but its Science Advisory Board (the subject of controversy itself given its ties to industry) and the Department of Energy (pursuing an aggressive pro-development plan) didn't want the EPA focusing on case studies which could generate "negative outcomes". Now, see... it's that kind of thing right there that makes me think maybe I'm getting paranoid. But, you know what? It's probably just me. I'm sure I'm wrong about the risks of fracking, despite the research I've collected from the oil and gas industry themselves, the US government and respected scientists and posted here to back up my perspectives. I'm sure I'll be wrong about the looming final devastation of West Divide Creek when EnCana commences drilling into the seep hydro-geology. I do come down pretty hard on the COGCC and EnCana, and maybe that's just insensitive. Let's see... here's my record... in 2003 I warned the COGCC that continued operations as they stood would devastate the valley. And I was... wait... I was right about that. Okay, well... the COGCC issued some more modifications for EnCana to follow - and predictably, I raised cane because the modifications were without correct scope or basis, and I predicted that once the moratorium was lifted and drilling commenced, again, additional problems would arise. Well, turned out I was... wait... I was right about that too. Gosh... remember the 2008 seep? (Click here for the Powerpoint) And the COGCC scrambled to put in place even more modifications for drilling and fracking. No wonder the COGCC must think I'm such a smart ass. But, you know what? I'm not so smart. I'm just putting two and two together. The COGCC on the other hand, inappropriately denies, delays, ignores and isolates variables, depends upon skewed or missing data.... oh - and serves a mandate which compels them to advance a production agenda (as well as - as an incidental inclusion decades after the agency's founding - protect public health and safety). No conflict there. Nope. So, once again, I predict that once EnCana drills thousands of feet into the seep hydo-geology, there will again be seeps... more seeps. More seeps on top of all the other seeps in a gargantuan cluster cluck of jacked up destruction no one in a thousand years could sort out let alone contain or stop. The COGCC must think I'm a friggin' genius by now. I mean, who could see that coming? No one could predict total frigging annihilation of the environment from such a move. Right? But, wait... if you think about it from a corporate point of view... let's see... multiple millions in pure profits... and, what? Maybe a few bucks thrown at a settlement or two, later... hey, that's like... a hundred-thousand percent profit! Whooohooo! Drill baby drill! But, hold on... that was a "forward-looking statement". I'm only advancing one scenario of profit potential, and I could be wrong on that. After all, the COGCC and EnCana are confident all will be okay. And since the EPA excluded this region from its totally unbiased new fracking study, all will proceed unhindered by scientific scrutiny. Too bad I don't feel comforted by that. We'll see who gets it right. Problem is, if the COGCC and EnCana are wrong, history has shown there to be very little consequence. Since the industry is worried more about "messaging" than the reality of risks, and since the EPA has their head up their... er... in the sand... fracking is probably heading for your neighborhood next. But I'm going to go out on a limb here and predict the new EPA study (just like the EPA study from 2004) will show fracking to be perfectly safe... so, like me, you probably don't need to worry.
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Here are COGCC's latest round of modifications to drilling/fracking practices based upon third party review of some truly valid, but also inappropriately narrowed issues upon which to focus and which would seem totally unnecessary given there 'have never been any problems back here'. If you have natural gas wells in your area, you might want to pay attention to these findings which include very serious issues with hydraulic fracturing. Think your gas is 'different' or you live somewhere else, so you don't need to understand what's happening in West Divide Creek? Think again. The industry likes to label natural gas wells as "shale gas" or "tight sands" or "coal bed methane" - as if they are vastly different. As if screw up in a "tight sands" formation surely won't apply to a "shale gas" formation. Well, guess what? These wells and their unmet challenges are drilled into similar geology because predictably, industry targets vertically faulted anticlines, sedimentary basins and hydro-geologically fragile watersheds within which to pursue natural gas derived from coal seams at differing depths. Divide Creek Area Joint Study Summary Report (Geology) Divide Creek Area Joint Study Summary Presentation (Geology) COGCC Cementing and Bradenhead Pressure Monitoring Practices (Engineering) East Mamm Creek Project Drilling and Cementing Study (Engineering) The same reports and others as Accessed from the COGCC website: http://cogcc.state.co.us/ Note: If the links below do not work for you here, you can find them by following this trail from the COGCC's homepage: "Library" / "Area Reports/Data" / "Piceance Basin" / "Piceance Basin Reports/Data" / "East Mamm Area Evaluation". Incidentally, you can find a lot of other scientific information on this area there too.
East Mamm Creek Area
Evaluation EMC
Study Response Memo (09/19/2011)
COGCC
Cementing and Bradenhead Pressure Monitoring Practices
(09/19/2011)
Divide
Creek Area Joint Study Summary Report
(09/08/2011)
Divide
Creek Area Joint Study Summary Presentation
(09/07/2011)
EAST
MAMM CREEK PROJECT DRILLING AND CEMENTING STUDY
(06/20/2011)
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| Written Statement, Re: Vulnerabilities of the Review Following is my "510" statement relative to the review and decision based upon it to move forward with drilling from the F12E pad. It was offered to the COGCC at the time an interpretation of the final engineering report was made to the COGCC Commissioners (at a COGCC hearing held in Broomfield, CO on September 19, 2011. Colorado Oil and Gas Conservation
Commission September 10, 2011 Re: September 19th, 2011 COGCC meeting/hearing and presentation of the East Mamm Area Investigation; specifically, third-party engineering review. I am a landowner in the East Mamm Area (West Divide Creek), and have personally experienced impacts from EnCana’s oil and gas operations since 2003. Those impacts have been broad, persistent, damaging, and often contested by the COGCC. Impacts include those relative to environmental degradation; trespass; destruction of private property; and health. There are approximately 60 actively producing natural gas wells within an approximate mile of my home. Many wells are openly venting without benefit of measured or chemically disclosed release and are the subject of this report. I consider the fate of my and my family’s health likewise the subject of this report. I would like my 510 comments entered into the official record of this September 19th meeting/hearing. I did not receive proper notice of this presentation; and because a standard presentation inclusive of relevant findings does not appear to exist, I may not be apprised of the same details as the Commission. Therefore, please consider my comments within that context. In my review of Mr. Andrew’s Power Point distillation, the engineering review appears to have revealed some alarming and potentially useful insight into failures associated with past and current exploration and production practices. However; I strongly recommend the COGCC Commissioners review findings from the actual report, as well as the COGCC staff’s subsequent interpretation, mindful of the following: Contamination found in the Dietrich/Moon wells and found in apparent association with the Magic 10-2 and the Arbaney 3-15C well, reflects concurrent contamination similar in constituent and quantity found in Monitor Well 23 (MW23) as well as at the site of the 2008 seep in West Divide Creek (detected September 2010 – and still persisting). Neither MW23 nor the presence of these contaminants in West Divide Creek are referenced in, nor appear included in, either the original report or COGCC’s presentation. The two pressure buildups noted on the formerly mentioned Magic and Arbaney wells appear to have implicated a degraded geologic area far greater than estimated. The eruption of massive seeps in 2004 and 2008, somewhat attenuating, but currently persisting certainly suggest so. It is unclear whether or how greatly the Schwartz 215B well (found responsible for the 2004 seep) or the Juniper M1E pad (inclusive of all wells) were considered within this report, but both of these facilities appear to have experienced significant problems including: high pressure gas kicks and influxes; losses of circulating cement and/or drilling mud; well bore failures to seal; bradenhead issues, interception of ground water; and, the necessity to vent gas in perpetuity. It is not surprising these problems coincided with the emergence of the 2008 natural gas seep which remains unacknowledged and contested by the COGCC and, again, does not appear to find relevant inclusion associated with these findings, despite groundwater and surface impacts discovered and quantified on a number of separate occasions beginning at early as June, 2008. Those findings have included soil, water and gas samples which have shown elevated diesel organics in the soils as well as thermogenic gas inclusive of elevated (6.6%) methane and attendant propane; butane; ethane and pentane hydrocarbons, as well as a suite of noble gases. These results were coincident with widespread loss of mixed-species fauna and flora. Despite COGCC assurances to the contrary, there is still no shallow groundwater monitor installed at this location. The report also appears to utterly fail to account for the implication of hydraulic fracturing and failure of remedial cementing to stop the 2004 natural gas seep associated with the Schwartz 2-15B well, which continues (over 7 years later) to release benzene into the shallow ground water of West Divide Creek, without greater mitigation or explanation. DOE and other documents suggest this area may have been the early target of experimental deep coalbed methane extraction without benefit of safety standards. Hydraulic fracturing within and/or above coal seams, and water production raises even further questions. Because all of these issues are material to conditions, failures and impacts; but, have found no meaningful inclusion within the review, the findings of the review should be considered incomplete in their scope, since such exclusion certainly diminishes the suspected degree of impact relative to known operational failures, whether pertaining to drilling or hydraulic fracturing practices and resultant environmental impacts. Astonishingly, yet, consistent with past COGCC failures in investigative methods, the COGCC has not produced a written scope of work or even a plan of action relative to the East Mamm Area Investigation. The author of the third-party engineering review has not been publicly credited, nor their work revealed, leaving the public to ascertain and infer from the COGCC’s potentially biased and/or improperly selective interpretation of the report. Without a plan, there has been no stated purpose of the investigation, or acknowledged and prompting impact associated with stated concerns. There is no stated intent; no identified timeline; no scope of inclusion in considering relevant findings toward a reasoned and structured conclusion, and therefore… once again, relatively limited accountability and credibility. Given EnCana’s recently permitted plans to proceed with drilling 19 new wells from the Twin Creeks F12E pad into the ambiguous 2004 hydro-geologic seep structure highly proximal to, or within a coalbed methane unit, it appears the narrow intent of this investigative component may be to advance a production agenda upon a thinly contrived, narrowly framed and inappropriately segregated inquiry into obvious issues while damning the consequences of premature and slanted conclusion. This is made more evident by the COGCC’s reliance on EnCana’s ‘proprietarily’ edited geologic data, which appears to have greatly influenced the basis of such decision. The glaring absence of a third-party hydro-geologic and environmental impact component from the investigation is also notable, and I suspect may never occur. The 2004 seep continues; yet, for all their expertise, neither the COGCC nor EPA can seem to figure out why. Despite its documented contribution, neither agency will consider the role of hydraulic fracturing. Why hasn’t remedial cementing fixed the problem? What is there to fear from a proper investigation? It is appropriate to vet these important issues before a concerned public in Rifle, Colorado at the next Forum. An unwillingness to do so demonstrates the COGCC’s continuing and unproductive commitment to failing policy and the furtherance of self- and industry interests to the detriment of human health, safety and welfare. Indeed, problems first arising here which are reluctantly, selectively investigated by the COGCC within an inner-agency cocoon of near-exclusive jurisdiction, mission to produce, and quiet adjustment made without publicly acknowledged failures generate modified practices applied to other areas of the state. Where investigation is steered short, impacts to date have been shown to transcend West Divide Creek and extend to other areas of targeted development. I and many others do not appreciate the apparently presumed and assigned role of guinea pig within the COGCC’s bastion of development and denial which has resulted in one preventable catastrophic failure after another and strongly demonstrates a gravely unsettling level of destructive, trial and error experimentation with the environment and its reciprocal human population. Lisa Bracken
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Other Relevant Links |
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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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