|Week Sixty-Nine January 12 - January 18|
...and still no ground water sampling of the 2008 seep site, despite thermogenic (produced, formation gas) detected in relatively nearby ground water at the time the seep was discovered; and despite a large area of vegetation die-off (suggestive of methane seep) and persistent iron-reducing bacteria near beaver house (also where paralyzed frog was found). Ground water has also begun upwelling again.
A new, vast area of grass die-off emanating form the Schwartz pad was reported 12-12-08, and yet no soil/gas monitors have been installed. No sampling of flammable gas in the creek bed either - despite its continuous accumulation.
Probable reason for such delay and obfuscation: The COGCC doesn't want to know what's really occurring in this geology with the kinds of drilling procedures they are allowing without adequate oversight.
And so, long reigns the mantle of carefully structured and preserved ignorance (and the policies that benefit those that further it).
Take a gander at the big nasty erected on Schwartz. This place was vacant for months, but "Holy crap!" EnCana execs must have said, "The elk and eagles and deer are moving in to eat what little grass hasn't been killed off. Damn, boys, fire up the rig and move 'er in!" Never fails. This is the reason the DOW needs to limit these fools to certain times of the year. They obviously don't have enough sense or compassion to do it themselves. The morning this picture was taken, a pair of eagles were buzzing the tower, trying to drive this mess away from a nearby nesting site. They finally exhausted themselves and flew away. I got a little video of it, but it's pretty shaky. I'll try to get a better film tomorrow. [01-15-09]
A Damnable Cover-up Finally Exposed
In the summer of 2006, my family was told that the two ground water monitors and our domestic well would be removed from the COGCC-mandated water sampling program for West Divide Creek. We were told this by both EnCana and their surrogate environmental compliance firm, Cordilleran.
After that time, we saw no evidence of further sampling from either ground water monitors: MW-23 and MW-27. And no sampling records were provided. Sampling of our domestic water well was conducted only periodically when we were able to negotiate with EnCana privately, or as a part of a base-line test prior to EnCana establishing a new pad within a mile of our water well. The very best we were able to secure was annual sampling while the 2004 seep remained active (that event continues to release benzene into the ground water upstream of our domestic water well). During such sampling efforts, we were typically not notified of sampling dates, nor was sampling data shared making it very difficult for us to determine the health of our water quality.
In the summer of 2008, we learned from COGCC that Cordilleran had in fact been sampling MW-23 and MW-27; yet, we were unable to obtain those records, even after repeated requests to EnCana, Cordilleran and the COGCC.
Finally, on December 04, 2008, Cordilleran delivered a three page historical summary of ground water monitoring.
In those documents it was revealed that thermogenic methane -- that is, formation gas, produced through drilling operations had been detected on five different quarterly occasions in the ground water on our property.
Several of these occurrences were in MW-23, located a very short distance from our domestic water well.
The other lone event occurred in MW-27, located a hundred yards or so from the site of the 2008 seep and at the same time as the seep - June, 2008.
We were not notified of the presence of thermogenic methane in any of these occasions.
The sudden presence of thermogenic methane proves a direct link between renewed drilling operations and yet another communication of produced gas with shallow ground water in West Divide Creek. Without a doubt, this should inspire the COGCC to conduct a full investigation - including the tests we've requested which have been denied.- The COGCC should prudently exercise an abundance of caution and re-institute the moratorium until the cause of the communication can be determined - and subsequently corrected. Only in this way can continued and future damages be prevented.
COGCC environmental and engineering departments as well as the Interim Director (who has recently, together with EnCana, become the subject of a public safety lawsuit) continue to deny the existence of a natural gas seep or any adverse impacts related to drilling activities.
We believe that there is no excuse for the mismanagement of such vital public health and environmental data.
We also believe there can be no excuse for the continued irresponsible development of minerals at the continued and clear expense of pubic health, safety and the environment. To do so is more than outrageous. It is criminal.
Given the revelation of formation gas in the ground water and COGCC's steadfast denial of any impacts related to drilling, we have no choice but to perceive this ongoing and blatant action as an overt act to protect the interests of industry to the exclusion of pubic welfare.
The COGCC's response to their sampling
efforts conducted in the fall of 2008 are summarized in the 9-page letter
which immediately follows the fracing link below.
To better understand the dynamics of
Summary Letter from COGCC on Sampling Efforts Conducted Fall, 2008
Date: December 31, 2008 [added]
The Colorado Oil and Gas Conservation Commission (COGCC) has investigated the various issues and concerns you have submitted to the COGCC dating to June 2008. The issues, concerns and complaints raised, the investigative actions taken and results of analytical testing are summarized in this letter.
The main issue appears to be a concern that petroleum hydrocarbons and or other materials
related to oil and gas operations have impacted your property and that an active methane gas seep is occurring. This concern is based on your review of engineering reports, observations made of gas bubbles in the West Divide Creek and other surface water features including beaver ponds and other areas of standing water, white precipitate material observed on the ground surface, black material that seeps from creek banks, various odors, the appearance of orange and purple films/sheens on surface water features and areas of stressed vegetation.
To investigate these issues multiple members of the COGCC environmental staff made a total of four site visits to your property from June 2008 to December 2008 to collect samples from assorted media including plant, soil, surface water, a ground water seep and a permitted water well for laboratory analysis. A summary of the field investigations including a discussion of the analytical data is provided below.
COGCC environmental staff visited the site and collected three surface water samples for analysis of benzene, toluene, ethyl benzene, and total xylenes (BTEX) and biological activity reactive tests (BART). The surface water features sampled included West Divide Creek and two areas of standing water. Additionally, one sample of the black "seep" material was collected and analyzed for diesel range organics (DRO). The analysis was conducted by TestAmerica, Inc. (TA) in Arvada, Colorado. The analytical data report for the June 30,2008 sampling is included as Attachment 1.
No BTEX compounds were detected in the three water samples.
The BART analysis was conducted onsite and tested the water for Iron-Related Bacteria (IRB), Sulfate-Reducing'Bacteria (SRB) and slime forming bacteria (SLYME). The test results indicate a high activity level of IRB and SRB bacteria. Iron-related bacteria are oxidizing agents that use iron and or manganese to generate brown slime and can produce unpleasant odors and can be corrosive. IRB are also known to generate strong smells that can resemble fuel odors and can generate yellow, orange and red-colored water. Sulfate-reducing bacteria live in oxygendeficient environments and break down sulfur compounds producing hydrogen sulfide which smells like rotten eggs.
A pamphlet prepared by the Colorado Department of Public Health and Environment that describes the affects and issues that IRB and SRB bacteria can generate is included as Attachment 2.
Soil (Black Seep Material)
Diesel range organics were detected at a concentration of 9.9 milligrams per kilogram (mg/kg) in the "black seep" material which is slightly above the reporting limit of 5.6 mg/kg. Review of the gas chromatograph indicates that this detection is not indicative of a diesel fuel or a biodiesel material. Diesel would show a hump or bell-shaped curve (usually with many sharp spikes) on the Chromatogram, centered on the "Diesel Range Organics" flag. The pattern for Bio-diesel would show several large peaks in the kerosene boiling range.
September 25. 2008
On September 25,2008 COGCC environmental staff visited your property and spent approximately four hours walking the site, taking notes and photographs of the areas of concern and collecting analytical samples. Soil and water samples were submitted for environmental analysis. The environmental samples were submitted to TestAmerica in Arvada, Colorado. The laboratory reports are included as Attachment 3. Two sand samples were collected and submitted for analysis using x-ray diffraction (XRD) and optical microscopy.
One surface water sample was collected from an area of standing water (Area 2) on the east side of the West Divide Creek. Your concern or issue was that it was not normal for water to pond or collect in this area. The sample was analyzed for volatile organic compounds (VOG), semi-volatile organic compounds (SVOC), dissolved methane, total metals, anions and general water chemistry. The water was relatively clear, colorless and had no odor. No VOC or SVOG were detected. The vac and svac results are summarized in Tables 1 and 2, respectively. Dissolved methane was detected at 43 micrograms per liter (ug/l), or parts per billion, as noted in Table 3.
3. General water chemistry parameters indicate the water quality is relatively good (Table 4).
The total dissolved solids concentration was 520 milligrams per liter (mg/L) and the pH 7.6. No nitrates or nitrites were detected. The chloride concentration was 7.1 mg/L. The calcium concentration was 77,000 ug/L, which is 77 mg/L, sodium 53,000 ug/L (53 mg/I), magnesium 41,000 ug/L (41 mg/L), barium 190 ug/L (0.190 mg/L), iron 610 ug/L (0.61 mg/L), and bicarbonate 440 mg/L. An additional sample of the water from Area 2 was collected on October 14, 2008 and submitted for analysis of dissolved metals. Concentrations were: calcium 88,000 ug/L (88 mg/L); sodium 64,000 ug/L (64 mg/L), magnesium 50,000 ug/L (50 mg/l) and barium at 0.190 mg/L. The inorganic results from both sampling events are summarized in Table 4 and the laboratory reports are included in Attachment 3.
Seven soil samples were collected from areas throughout the property. A brief summary of the samples collected, issues for each area and the analytical parameters tested is provided below.
Additionally, a sample of frac sand was obtained from EnCana Oil & Gas USA Inc. (EnCana) and submitted with the two soil samples for optical microscopy and XRD. Please note that the frac sample was labeled as Area 15 and not as trac sand to ensure that the laboratory was not biased before analytical work was conducted.
SEPTEMBER 25, 2008
SOIL SAMPLING SUMMARY
Sample Issue/Concern Analysis
Area 1 Landowner concerned frac sand has been intruded into BTEX GRO/ORO SAR, pH, Optical microscopy, subsurface and onto surface causing distressed Sc, XRO vegetation.
Area 3 Orange biofilm, dark/black to gray soils, with decay odor BTEX GRO/ORO landowner concerned that gas or oil seep is occurring.
Area 4 Orange biofilm, black soils, with decay odor, also near BTEX GRO/ORO area where fluid seeped from creek bank: landowner concerned that gas or oil seep is occurring.
Area 5 Landowner had previously observed black material GRO/ORO bubbling up.
Area 5 Sandy area on creek bank between areas 4 and 5. Optical microscopy Concerned about stressed vegetation and that more sand analysis, XRD was present than in past. Concerned that frac sand had been intruded into area.
Area 8 Black soil. GAO/ORO
Area 9 Orange and purple biofilm. GAO/ORO
Area 10 Stressed vegetation and white/orange precipitate materi. SAR, pH, Sc, total metals.
"Area 15" Frac sand sample obtained from EnCana for comparisor Optical microscopy analysis, XRD
No BTEX or GRO compounds were detected in the soil samples. ORO were detected in the Area 4 sample at a concentration of 6.4 milligrams per kilogram (mg/kg) with a reporting limit of 5.4 mg/kg and in the Area 8 sample at a concentration of 8.1 mg/kg (Table 5) with a reporting limit of 4.8 mg/kg. TestAmerica was contacted to determine if naphthalene, a common component of diesel fuel had been tested during the ORO analysis and if so to provide reports summarizing the results. These results were received on December 5, 2008. Naphthalene was not detected in either sample. Reviews of the gas chromatographs indicate that these detections are not indicative of a diesel fuel. Diesel would show a hump or bell-shaped curve (usually with many sharp spikes) on the chromatogram, centered on the "Diesel Range Organics" flag. The pattern for bio-diesel would show several large peaks in the kerosene boiling range.
A sample of the white and orange precipitate material observed on the surface was collected in Area 10 for chemical analysis. Results indicate the material contains calcium at 13,000 mg/kg, magnesium at 3,800 mg/kg, iron at 11,000 mg/kg, potassium at 2,400 mg/kg and sodium at 12,000 mg/kg. The sodium adsorption ratio was 1,800 and the pH 11 as summarized on Table 6. These results indicate that the material is an evaporative deposit. Sodium, calcium, and magnesium were also detected in the standing water sampled in Area 2, see Table 4 for reference. It is not uncommon for salts of this type to be deposited on the ground surface as standing water evaporates and or infiltrates into the subsurface. There are no indications that this material is related to an oil and gas activity.
The comparison of the sand samples from Areas 1 and 5 to frac sand was conducted by OCM Science Laboratory, Inc. (OCMS) in Wheat Ridge, Colorado. The Area 5 sample was described by OCMS as: consisting primarily of quartz with lesser amounts of feldspar, mica and trace minerals. Grain size varied from 10 um to approximately 500 um. The morphology is angular to sub-round. Quartz grains resembling frac sand were not identified.
The Area 1 sample was described as: being similar to Area 5 but with a finer grain size. It is composed primarily of quartz with lesser amounts of feldspar, mica, carbonate, and some hematite and possibly trace amounts of clay. Grain size ranged from 10 um to 250 um and grain morphology in angular to sub-rounded. The "Area 15" sample was described as: representing frac sand with quartz being the sole component. The grains range from 600 um to 1. 1 um and exhibit a high degree of roundness and sphericity. Grains of this type were not identified in the previous two sand samples. The OCMS report is included as Attachment 4.
October 14, 2008
A sample was collected from the Eicher-Bracken water well on October 14, 2008. Samples were submitted to TestAmerica for analysis of dissolved methane, BTEX, GRO/ORO, SVOCs, metals (total and dissolved) and general water chemistry. No BTEX, GRO, ORO or SVOC compounds were detected (Table 7). The inorganic water chemistry was similar to water quality from the Area 2 sample (see Tables 8 and 9). The water contained sodium at a concentration of 78,000 ug/L (78 mg/L), calcium at 77,000 ug/L (77 mg/L), magnesium at 3,800 ug/L (3.8 mg/L) and bicarbonate 470 mg/L.
A soil sample was collected by the Creek Filter House (CFH). The sample was submitted for BTEX, GRO and DRO analysis. No BTEX or GRO compounds were detected. DRO at a concentration of 12 mg/kg were detected (Table 10). The laboratory reports for samples collected on October 14, 2008 are included as Attachment 5. Review of the gas chromatograph indicates that this detection is not indicative of a diesel fuel or a biodiesel material. Diesel would show a hump or bell-shaped curve (usually with many sharp spikes) on the chromatogram, centered on the "Diesel Range Organics" flag and the pattern for bio-diesel would show several large peaks in the kerosene boiling range.
A sample of grass near the Creek Filter House (CFH) and leaves from a stand of oak trees were collected on October 14, 2008. The stressed grass was black, very dry and corresponded to an area of black to dark brown soil located near the CFH. The oak trees appeared to be distressed with dry brown leaves with black spots/patches.
The samples were submitted to the Colorado State University Plant Laboratory for analysis. The report from the CSU observed that the oak trees were exhibiting natural senescence. According to the plant laboratory the grass appeared to have been dead for sometime and that it had been colonized with fungi. The report is included as Attachment 6. No impacts from oil and gas activities were detected.
December 4, 2008
Water Sampling and Site Visit
On December 4, 2008 COGCC Acting Director [name retracted], COGCC [name retracted] EPS and COGCC Engineer [name retracted] met with you and staff from Cordilleran Compliance and EnCana on site to discuss the historic sampling of the Eicher-Bracken water well and the two monitoring wells (MW23, and MW27) located on your property. A report that provided historical laboratory data, maps and responses to questions about past sampling reports was discussed.
COGCC staff collected a sample of water seeping out of a terrace deposit immediately above the creek bank. The sample was submitted for inorganic analysis, total and dissolved metals, BTEX, DRO/GRO and dissolved methane to Evergreen Analytical, Inc. in Wheat Ridge, Colorado on December 5, 2008.
BTEX, GRO-DRO and dissolved methane were not detected (Table 11). Inorganic analysis as summarized in Table 12 indicates that the water is similar to the water in the Eicher-Bracken water well which accesses shallow groundwater and surface water. Laboratory data reports are included as Attachment 7.
Grass and Hayfields
On December 3, 2008 you sent an email indicating concern that pasture land near the Schwartz well pads exhibited signs of distressed vegetation related to a methane gas seep(s). Photographs of stressed fields and other fields as a comparison were provided. On December 4, 2008 during the onsite meeting you provided additional photographs and a map of the area of concern. Follow-up emails and telephone calls have been made. This complaint is being addressed under COGCC complaint #200200082.
On December 4, 2008 [COGCCC names retracted] toured the area in question and made observations of the various fields. There are noticeable differences with the various fields. However, the differences appear to be based on land use and agricultural practices. One field is an irrigated. cultivated hay-field while the areas of concern are un-improved pasture or rangeland that do not appear to be irrigated and in some cases appear to have been used for cattle grazing. There are no indications of an ongoing methane gas seep. The Garfield County Extension Office has been contacted and the Extension Agent Patrick McCarty has agreed to review these issues. Photographs and maps have been submitted for his review and if necessary COGCC environmental staff will meet with him to review the condition of these fields.
COGCC staff researched the drilling and completion records of all wells drilled to date from the Schwartz (EnCana designation 02) and the Juniper (EnCana designation M1 E) well pads. Since the original problem in the Divide Creek area was caused by a high bradenhead pressure acting against surface casing set at a shallow depth in the Schwartz 2-158 wellbore, we reviewed bradenhead pressures and surface casing setting depths for the area in detail. We also reviewed our records for any gas kicks that were reported during the drilling phase of these wells.
Our review of casing design in this area shows all surface casing (excluding the Schwartz 215B) to be set at a depth greater than 1000 feet. Four of the wells on the Juniper well pad have casing set deeper than 1500 feet and three of the wells in the area also have intermediate casing set below 2800 feet. These deeper casing strings insure that gas produced from the Williams Fork formation remains in the well bore and will not escape into shallower zones.
EnCana also monitors bradenhead pressure (this is the pressure acting against the surface casing shoe) on a regular basis. The COGCC allows EnCana to vent the bradenhead of any well showing a pressure increase in weIIbore annulus. By allowing EnCana to vent this excess pressure, any natural gas entering the annulus cannot increase to a level of pressure sufficient to bypass the surface casing. This eliminates the possibility of gas migrating from the well bore into shallower sands. Also, wells that have the bradenheads vented will eventually show lower bradenhead pressures. EnCana is currently venting the bradenheads on nine wells in the area and these pressures have decreased from an average pressure of 216 psi to 74 psi measured when the bradenhead is not vented.
We find two wells have a record of gas kicks in the area (excluding the Schwartz 2-15B). The Schwartz 11-2A had surface casing set at 1024 feet and encountered a gas kick at a depth of 4186 feet. The shut-in casing pressure recorded at the time of the kick was 500 psi and the kick was immediately killed by increasing the mud weight from 9.2 to 11 pounds per gallon.
The Juniper 2-16A well had surface casing set at 1527 feet and had a gas kick occur at 4305 feet. The shut-in casing pressure recorded at the time of the kick was 325 psi and the kick was immediately killed by increasing the mud weight from 10.6 to 11.7 pounds per gallon.
Based on this information, we do not have any reason to believe there is contamination of ground water due to faulty well bore construction.
GAS SEEP SAMPLING REQUESTS
During the 2008 complaints you have requested that gas bubbling from surface water features be sampled. However, the gas has not been sampled for various reasons as outlined below.
1. COGCC staff did not observe gas bubbling during the September or October site visits. During the December 2008 only possible traces of bubbles were noted in West Divide Creek. Most observers' onsite did not observe any gas bubbling.
2. Two groundwater samples and one surface water sample have been analyzed for dissolved methane concentrations since June 2008. Only trace levels of dissolved methane have been detected.
3. A detailed review of engineering data does not support the theory that a thermogenic methane gas seep is occurring on your property.
4. Previous Gas Sampling Events:
In 2004 COGCC staff collected four gas samples from various surface water features on your property. The laboratory data, including isotopic analysis, showed that the gas was of biogenic origin.
In 2007 COGCC staff collected gas samples from two ponds on your property. The analysis showed that the methane was of biogenic origin. The laboratory data was provided in a letter report dated January 10, 2008.
In 2007 EnCana retained a third party contractor to collect samples of gas bubbling from surface water features on your property. The gas analysis showed that the methane was clearly of biogenic origin.
5. West Divide Creek, as it runs through your property, is surrounded by wetlands and areas of standing water such as beaver ponds and water retained behind flood debris. The presence of gas bubbles from wetlands and other stagnant surface water bodies is a natural phenomena and is not an indication of impact from oil and gas operations. Methane seepage from wetlands is one of the largest sources of naturally occurring methane emitted to atmosphere.
6. The Colorado Division of Wildlife (CDOW) completed biological and chemical sampling of West Divide Creek on the Bracken and Langegger private properties on July 10, 2008. Electrofishing was conducted in a 445 foot stream reach (average stream width of 13.5 feet) that encompassed multiple microhabitats (riffles, runs, pools). According to CDOW staff multiple age classes of all species were observed including and three species that displayed spawning colors and/or spawning tubercles. Macroinvertebrate and water quality samples were also collected. The presence of the multiple age classes and reproducing species could be considered positive indicators for the overall health of the stream. The final report is pending at this time, however, the CDOW has raised no issues or concerns with COGCC staff.
In addressing the issues and concerns you have raised this summer and fall the eOGCC has conducted four site visits, has collected eight soil, four surface water, two groundwater and two plant media samples for laboratory analysis. At this time no indication of a petroleum hydrocarbon impact or ongoing methane seep related to oil and gas activities has been identified.
No voe, SVOC, or GRO hydrocarbons were detected in the numerous samples collected. Inorganic analysis of surface water and ground water are comparable and show no indications of impact from oil and gas activities.
The DRO detections are not consistent with a diesel fuel and are more indicative of naturally occurring hydrocarbon material such as terpenes from pine needles and wood, tannic acids from leaves, humic acids from decaying grass, roots, and leaves and or aromatic oils from sage and similar plants.
The sand samples collected from Areas 1 and 5 are not similar to frac sand. Areas 1 and 5 were different in composition, texture and grain size from the frac sand ("Area 15" sample).
Biofilms: The orange and purple films and sheens are naturally occurring biofilm; BART testing shows that IRB and SRB bacteria exist in the surface water. Laboratory testing (Tables 4,6,8) indicates that the surface water, ground water and soils contain iron and also manganese which are used in the oxidizing process by IRB. A side effect of this process is the generation of brown slime and orange and red colored water. The presence of these purple and orange films in a wetland environment is a natural occurrence and is not indicative of an ongoing or past impact from oil and gas operations. No biofilms were noted during the December 2008 site visit.
The black "seep" material appears to be an organic sandy soil generated by the decomposition of plant materials in wetland environment. No vac, svoe or GRO compounds were detected and the ORO detections are outside of the pattern that a diesel fuel would generate.
Odors: One of the issues cited as an indication that an ongoing gas seep was occurring was the foul odors described as the odor you get when you light a gas stove. Methane however is an odorless gas. The odor noticed when a gas distribution system leaks or a gas stove is being lit is an odorant purposely placed into the gas prior to retail sale. The odorant used is frequently a mercaptan. Mercaptans are flammable compounds which are commonly known in the gas processing industry has stench or skunk gas.
The Colorado Oil and Gas Conservation Commission staff take all complaints from surface owners and concerned citizens seriously and welcomes citizen involvement and input. However, due to overwhelming evidence from the current and past investigations, the COGCC finds no indication of an ongoing thermogenic methane seep or other impacts from oil and gas operations and our investigation in to your complaint is complete at this time.
cc: [names retracted]
My Letter in Response to the letter above and sent to the COGCC Interim Director and two COGCC Commissioners on January, 12 2009
Re: "Reply alleged gas seep investigation COGCC # 200191771 and # 200200082 Garfield County Colorado" dated December 21, 2008
Thank you for submitting the summary report and data records associated with sampling efforts conducted on our property during the fall of 2008. I appreciate the efforts conducted to date on our behalf insofar as their limited scope, application and interpreted revelation of conditions.
I have responded to the COGCC's various assertions in their letter, noted above, by categorical reference. This letter is not exhaustive, and is meant to be a brief overview of our summary perspective on these issues.
THE PRESENCE OF KEROSENE IN SOILS
Kerosene is a component of natural gas, and is a strong indicator of the presence of a natural gas seep in the two areas where kerosene compounds were detected.
You may recall that in June of 2008 DROs (or organics in the diesel range) were also detected in a sampled, nearby location. Also a strong indicator of the presence of a seep.
THE PRESENCE OF REDUCING BACTERIA
I agree with COGCC environmental staff that the iron and sulfate reducing microbes, which were the subject of the sampling effort, can be normally found in a wetlands environment, and further agree that they are abundant under oxygen deficient conditions. What the environmental staff habitually fails to point out, however, is that methane depletes oxygen and creates a favorable environment within which these microbes can and will flourish. In the areas of the 2008 seep, we have seen and documented such flourishing. Despite the COGCC environmental staff's belief that the presence of such microbes is 'normal', most of the scientific community will concur and the sampling results validate, that such concentrations are typically encouraged and supported by a methane-saturated environment, causing it to become reductive.
This is strongly suggestive of the presence of a natural gas seep.
The COGCC environmental staff seems to have asserted, in the reply letter noted above, that the odors I smelled and likened to a gas stove must be from the odorant added to a gas stove which may have been hidden in the nearby weeds. I confess I cannot rule out the presence of a gas stove anywhere beyond the confines of our property; but, as I pointed out to the environmental manager on a conference call with Garfield County, and as she herself pointed out to Commissioner McCown at that time, other chemical constituents are present in raw natural gas, such as any number of "anes", that do indeed possess an odor. The odor is akin to that which we continue to smell around our home as EnCana continues to flare nine different wells in the vicinity. This is a strong indicator of the presence of a natural gas seep.
In the COGCC's reply letter noted above, the environmental staff requested that Colorado State University's plant pathology lab analyze the blackened forbs collected at a sample site. CSU made the determination that the plant matter had been dead for a long time. In fact, I also suspect this, since when we found it, it appeared to be quite dead. The COGCC's delayed investigation of the matter provided even greater opportunity for the plant matter to continue to be dead. The plant lab noted that the plant matter hosted an advanced colony of fungus. Because this is also in the area where kerosene-range hydrocarbons were found, I suspect that the forbs were infested with what is known as a "kerosene fungus". Unfortunately, however and despite the unusual presence of the plant's condition, I did not see an identification of the fungus in the report.
The oak leaf analysis does not surprise me, since the original sample - in an unusual blackened state like the forbs - was crushed in transport to Denver. The second specimen was collected long after frost and may well have been a normal specimen.
The unusual state of this isolated plant forb and its pathology in the presence of kerosene soils strongly suggests the presence of a natural gas seep.
LIFE IN DIVIDE CREEK
The COGCC environmental staff point to an electro-fishing study conducted by the CDOW, as an indicator that the aquatic life in West Divide Creek is suggestive of a normal riparian environment. While it is true that the DOW found several native species within the creek, there was a conspicuous absence of trout, a regular inhabitant of Divide Creek and an indicator of less than healthy aquatic conditions.
Further, the COGCC failed to discuss the dead wildlife such as crawdads in the immediate vicinity of the seep, nor did the COGCC discuss the presence of a paralyzed frog also found in the immediate area of the seep and the site of continued gas accumulation in the creek bed. These combined factors strongly suggest the presence of a natural gas seep.
ACCUMULATING GAS IN THE CREEK (BUBBLES)
The COGCC environmental staff does not feel that sampling the flammable bubbles in West Divide Creek is important for several reasons.
The COGCC asserts that these are the same bubbles the staff witnessed and sampled in 2004. It is entirely possible that four years have slipped by without the good folks in the environmental department noticing, so I will again reassert that these particular bubbles correspond to a different event - one which I identified and reported in June, 2008.
The COGCC staff also asserts that they did not see the bubbles in the creek on any of their visits. I will remind the staff that I offered to demonstrate the bubbles' location to them on more than one occasion - the last of which was December 04, 2008. On all occasions, my offer was declined, which perhaps explains why the environmental staff did not see them. It is indeed difficult to see what one will not look at. Despite my asking at least twice to bring apparatus to sample the bubbles on December 04th, no apparatus was brought to do so.
Another reason given for not sampling the bubbles nor the ground water at the 2008 seep site is because the bubbles are believed by COGCC's environmental staff to exist in stagnant water or a beaver pond. Actually, this is not the case, and I'm surprised by this assertion given that I have physically pointed to the area where the bubbles actually are. To my knowledge, COGCC environmental staff was looking when I pointed. The bubbles are in neither stagnant water nor a beaver pond. The bubbles are accumulating in a specific area near the bank in situ - that is, in the creek bed itself where the waters of West Divide Creek flow unencumbered.
I actually expect sand to be present with water in a creek bed, and pointed out to COGCC staff and the Garfield County Commissioners who requested sand testing, that my worry that the sand bar may have been frac sand was very probably the psychological result of the aggregate effects of the other impacts noted in association with the seep, and was, therefore, quite probably without basis. I even suggested to the COGCC, on a site visit, that the sampling of the sand be suspended in the interest of conserving state funds. But, the COGCC tested the sand anyway, even after obtaining a sample of frac sand from EnCana - where visual observation suggested that the two were different in characteristic. Thank you for your immensely detailed analysis of the sand. It is very likely, as we all suspected, not suggestive of a natural gas seep.
In the reply letter noted above, the COGCC environmental staff addressed the distressed vegetation which is situated near the area of accumulating bubbles in the creek, and noted that I felt it was the result of sand incursion into the area. This is not accurate. I do not believe that sand has encumbered vegetative growth in this dead zone. Rather, I believe methane underground is suffocating or dehydrating the root systems of those plants that endeavor to grow there. Due to the tendency of methane to displace oxygen in the environment, this dead zone - and others around and on our property - is strongly suggestive of a natural gas seep.
ENGINEERING RECORDS and GAS KICKS
The well which I believe is responsible for the 2008 gas seep is the Schwartz 11-2A which encountered a kick resulting in bradenhead pressures of 500 psi. This is the exact amount of pressure that resulted in the 2004 well blow-out and subsequent seep event. The one apparent difference is that the 2004 event did not "immediately blow down", and this one did. The damage incurred, however, is clearly similar, and both events required remediation of the respective wells.
Further, at the time of the Schwartz blow-out of 2004, the bradenhead pressure in the Brown 11-2C well was approximately 300 psi. Recently, the bradenhead pressure in the Juniper Group well (situated just above the seep site) reached 325 psi. Either of these events alone or combined represents the smoking gun… at least for this event, and perhaps, by now, even others.
Subterranean pressures of this magnitude in this very fractured and fragile geology are sufficient to degrade the formation and introduce gas migration along fracture pathways and into the surface environment - in this case, both terrestrial and riparian. We have seen this occur in the past, and it is occurring again - with the endorsement of the COGCC.
EnCana continues to vent nine wells in the vicinity in order to maintain what is only assumed to be a "safe" level of pressure on the respective bradenheads.
It is clear, that well casings are insufficient in their depth; the pressures encountered are too great; and, the geology and hydrology is too fragile - even beyond the moratorium area and quite specific to the outcrop creek areas.
These kicks - with or without the need to remediate - strongly suggest the presence of a natural gas seep.
DEAD VEGETATION Re" Complaint # 20020082
The COGCC environmental staff, in the letter noted above has attributed vegetation die-off to the fact that land around the Schwartz and extending across our property and that of Juniper Group, Griffin and Thompson is un-irrigated.
In it's assumption that a lack of water is the cause of the die-off, the COGCC environmental staff has decided to compare irrigated hay fields over a mile away with the un-irrigated fields which are the subject of my concern.
While it is true these fields are not irrigated, they have always maintained an abundance of dry-land plantings and native vegetation. This vegetation has only been impacted one other time, during the 2004 seep. After the Schwartz well was remediated in 2004, the grass recovered. Now, however, the impacts are back. These impacts can be clearly detected by comparing different areas of the same properties - all of which share similar land management history - that is, no irrigation and deer/elk grazing. Only the Schwartz has ever grazed cattle and then only rarely.
Let us not confuse these parcels of impacted lands the way the COGCC environmental staff has attempted to confuse the 2004 seep event with the 2008 seep event. I possess video and photographs posted on-line of these fields - at the website www.journeyoftheforsaken.com.
The recent and widespread vegetation die-off that has occurred over the summer in the valley which was neither acknowledged nor addressed by the COGCC, and finally a couple of months later, massive vegetation die-off 200 feet higher in elevation are clear indications of a natural gas seep.
THERMOGENIC METHANE CONTAMINATION IN GROUND WATER
Despite our many requests directed toward EnCana, Cordilleran and even the COGCC, we have long been unable to ascertain the sampling activity on the two ground water monitors on our property, which are: the MW23 (south - and nearer to our domestic water well) and the MW 27 (north - and about 100 yards from the 2008 seep site). We were in fact informed by both EnCana and Cordilleran that any monitoring of these two wells would cease back in the summer of 2006.
Upon a visit by the COGCC environmental staff this fall, we learned that in fact these two wells have been being monitored. And on December 04, 2008 COGCC environmental staff and Cordilleran delivered a packet of documentation relative to those sample results.
After review of that documentation we discovered that there have been five different occurrences of thermogenic (formation) gas detected in one or both of those wells. Two of those instances have been negated due to what Cordilleran and COGCC deem inappropriate sampling methods. COGCC and EnCana through their surrogate, Cordilleran have long favored a method of water analysis which minimizes the detection of thermogenic methane and inaccurately describe it as biogenic when in fact, it can be otherwise classified as thermogenic using a more appropriate, refined and accurate means of analysis - such as that recommended by Dr. Geoffrey Thyne, contracted by Garfield County to analyze the effects of drilling operations on the methane contamination of water wells and other water sources.
Even in negating those two readings from 12-06-06 and 03-13-07, there are still three remaining occurrences where formation gas was detected in ground water on our property.
MW23 (south - and nearer to our domestic water well)
12-05-06 - negated
03-12-07 - negated
MW 27 (north - and about 100 yards from 2008 seep site)
06-17-08 (14 days prior to the 2008 seep discovery a hundred +/- yards away.)
Over the course of 4 years and over 56 samples, thermogenic methane only became present on our property in ground water after the moratorium was lifted and drilling operations resumed in this area.
Since 2004, thermogenic gas has only be detected once, in M-27 - in association with the 2008 seep discovery approximately a hundred yards away.
The findings above, summarized by Cordilleran in a document titled: "Summary of Historical Ground Water Analysis Results - EnCana West Divide Creek Seep" are counter to Cordilleran's' claims in a letter dated December 02, 2008 to COGCC environmental staff that "no thermogenic gas has ever been observed in MW23.".
The presence of thermogenic gas in the ground water monitors - particularly MW 27 nearer to the 2008 seep site and detected the month of that discovery, is clear evidence of a natural gas seep.
OUR CONCLUSIONS AND REQUESTS
Despite the COGCC environmental staff's best efforts to delay investigative findings and select methods of analysis which endeavor to minimize the appearance of impacts, the impacts of renewed drilling in this area are overwhelming and undeniable.
To allow continued and destructive industrial operations under these conditions is an egregious affront to the COGCC's duties and responsibility to the public's health and environment.
Again, we respectfully request:
1) The COGCC conduct on-going ground water monitoring in the vicinity of the 2008 seep - in all suspect locations, the area of which comprises approximately 3 acres.
2) We further request monthly sampling of the MW23 and MW 27 ground water monitors and the re-inclusion of our domestic water well into EnCana's quarterly sampling program, from which it was indiscriminately cut in 2006.
3) We further request sampling of the gas accumulating in the creek bed.
4) We further request soil/gas monitoring at sites suspected of methane impacts around the Schwartz and Juniper Group well pads - which includes approximately 6 acres of our upper meadow and a portion of the valley seep area.
In light of the totality of impacts the COGCC has thus far failed to embrace, our requests are reasonable and appropriate.
Because of a disproportionate number of inspectors to the crushing development currently permitted by the COGCC, this agency has admitted on more than one occasion that it depends almost solely upon the public to raise the alarm when drilling operations are believed to have impacted an area. And I have done so. Yet, despite this, the COGCC has continually disregarded our alarms, and, when finally acknowledged, has acted upon our complaints in an either incomplete or grossly delayed manner - by a carefully considered strategy, I am left to surmise.
The latest example of this scurrilous behavior is the COGCC's response to the dead vegetation around the Schwartz pad and which extends across our property and two neighbor's properties. Here, the COGCC has had an opportunity to immediately assess the situation using appropriate monitoring measures such as the installation of a soil gas monitor, but the agency refuses to do so. Even in the face of clear indications of a kick and continuously elevated bradenheads that are affecting the terrestrial and aquatic environs. But… as expected… the agency steadfastly refuses. Again, it is indeed difficult to see what one will not look at.
This agency, through its habitual failure to act in a procedurally predictable and responsible manner not only neglects its duty, but creates the accurate public perception that it is not science that matters, it is revenue generated by the recovery of natural gas at the expense of every other value or human concern.
Therefore, it is my view that the COGCC's investigation into this complex and geographically far-ranging issue is far from complete, nor should it conclude.
My complaints are not ethereal delusion. They are based on rational, logical and empirical evidence gathered by first hand and relatively continued observation over the past twenty-one years. But all I can do is present the dots. It is up to the COGCC to connect them. And unfortunately, try as the agency might to distort facts and subjugate science, a clear picture is emerging. A picture which is distinct and in opposition to the COGCC's long-standing legislative mandate to protect the environment and public health in addition to regulating the development of oil and gas resources. That picture clearly shows this agency's favor toward industry at the sacrifice of public health and safety and environmental protections.
If this agency wishes to push science out in front of this secret mandate, and have it be believed, then do not make so obvious the efforts to derail and frustrate genuine scientific inquiry. At least do me the favor of simply stating that this agency is interested in conducting only those activities which advance an industrial agenda. The poor disguise of science worn as a thin and tattered veil only betrays the apparently true role of this agency - whether or not it is intended.
I spoke with the environmental department today and learned that I misinterpreted their Kerosene finding referenced in my letter above. Evidently, the spike that showed up on the gas chromatograph was neither diesel nor kerosene nor in the gasoline hydrocarbon range. It apparently is a heavier hydrocarbon. While I can accept that I misinterpreted this information, I cannot accept the time frame that was allowed to lapse before sampling was conducted. The area was also described by the COGCC as a stagnant area. It was not. It was a ponded area where Divide Creek flows through and into which the newly upwelling ground water slowly seeps. It was also very close to the area where diesel organics were found previously.
I was told by the environmental department that they are "pretty sure" the spike is plant matter. That may in fact be. But as I said, so much time was allowed to pass, and so many influencing variables have been continually and routinely dismissed that it is difficult to accept results such as this one on its face - something COGCC would love me and others to do. It is much easier to hide the truth when methods and assumptions are confused and frustrated.
Think of this situation like a paint-by-number painting. If all the little numbered components were separated from the whole, you'd have no idea what each revealed, nor how they were relevant overall. They must be taken together as a part of the whole to determine any kind of clarity at all. But, inspiring the COGCC to consider collective impact, let alone act in any timely and thorough manner all at the same time is like pulling hen's teeth. They have proven that it is simply not going to happen, regardless of evidence that impacts are and continue to occur.
So, while any traces of lighter hydrocarbons may have evaporated or deteriorated in the time allowed to pass before COGCC became interested in collecting samples, the vegetation was likely impacted by whatever had manifest itself during the earlier period. But, it was confirmed by the environmental department that no identification of the colonizing fungus had been made. Of course, if it had, we might know what led to its colonization of the plant matter - given that it attacked in isolated areas relative to other vegetative dead zones and other aspects collectively reflective of seep activity.
THERMOGENIC METHANE IN GROUND WATER
I asked the department why they still deny any impacts are occurring which are associated with drilling operations. Operations which have incurred gas kicks of extremely high pressure. Kicks which - identical to 2004 - resulted in a blow-out. I asked how they could deny it, particularly when thermogenic methane had been detected in ground water monitors. Here is the answer I got: The data is wrong.
The thermogenic detections aren't something I just pulled out of the air (although you could probably do that, with EnCana venting nine wells in the area to keep blow-out pressures down). But these aren't my numbers. This is information provided by Cordilleran - EnCana's surrogate environmental compliance people.
This must be the COGCC's "false positive" argument they always use when thermogenic methane is detected. They jump up and down and defend their methods squawking like a parrot:" It's biogenic! It's biogenic!".
You know what? Bull-feathers.
Thank goodness Dr; Thyne has exposed this sorry ruse for what it is.
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
The fact and my whole point is that drilling cannot be safely conducted in this geology. Period. But when you subjugate science to political will, you will never hear the truth.
Instead industry hides behind regulators - both of whom thrust the environment out in front, much like a terrorist uses women and children. These two try to take what nature does to defend itself and uses it against nature - all the while continuing to harm it.
Remember that gross black gunk that was in the ponded areas? Well, as of December, it had became pretty much non-detectable with the naked eye. And that's presumably a very good thing. Nature will kick into gear all kinds of bugs to wolf down the intruding pollutant. This is why biofilm and orange gunk show up when methane saturates wetlands. Industry ilk and their regulatory cohorts count on nature's efforts to cleanse itself to defend against adverse environmental impacts. It's a pretty reprehensible tactic. But it's also pretty effective. Nature will immediately do what it can to correct harm done to it and make itself sustainable once again. If you let enough time pass, and sunlight, wind, water and bugs go to work, who can tell what has been going on?
If you dropped a cup of chocolate milk on the kitchen floor, and didn't clean it up, would you expect to be able to find any easy evidence of it a month later? Certainly not if you had dogs running around... and grape juice-dropping kids... and high traffic... you get the idea.
Thermogenic Methane in Ground Water
-- Bernard Madoff, on the topic of Wall Street - October, 2007
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