Monday, May 28, 2012

BP AMERICA PRODUCTION: Notice of Alleged Violation, Fumes, 2,4-D, Frac Fluids, Soil Kill




Date received: 9/06/2011
La Plata County, Colorado


DocNum:200319999Date Rec'd:9/6/2011
Operator:BP AMERICA PRODUCTION COMPANYOper. No.10000
Address:501 WESTLAKE PARK BLVD ATTN: JACKSON COOLEY  HOUSTON , TX 77079
Company Rep.DANIEL FAUTH
Well Name/No.HESTER GAS UNIT  1
LocationSESE  11 T34N  R9W  M
Fac.ID:215434 Fac.Type:WELL  
API number:05-067 -07039CountyLA PLATA  
COGCC Rep:STEVE  LABOWSKIEPhone:(970 ) 259-0945
.........


Alleged Violation:




Date of Alleged Violation:  8/30/2011




Approx. time of violation:  
 Public complaint # 200319674 alleged over application of weed control chemicals on 8/30/2011 caused adjacent landowner to be affected by fumes. In addition complainant alleged repeated application and uncontrolled runoff has caused vegetation kill extending beyond operator leased area since prior to 2008. 


Telephone conversation with complainant had concerns of mishandling of fracturing fluids on pad.


 Field inspection on 8/31/2011 found areas of soil kill extending beyond pad, uncontrolled storm water runoff and excessive weeds on location. Inspector also noted chemical (probable herbicide) smell present on pad.

Act, Order, Regulation, Permit Conditions Cited:
 324 A. (a), 603 j, 1002 f (2&3), 1003 f

Abatement or Corrective Action Required to be Performed by Operator
Provide history of herbicide application on the pad since 2008, to include all chemicals used, quantities and MSDS's and show weed control measures have been conducted in compliance with Colorado Noxious Weed Act. Provide history of all downhole well activities, to include frac jobs, well cleanings, well maintenance, etc. for a period of 7 years. Provide list of chemicals used, including quantities and MSDS's. 


Submit a Form 27 Site Assessment & Remediation Plan detailing a sampling and analysis plan (SAP) to assess potential soil impacts on the pad, at the point(s) of flow exit from the pad and onto the adjacent properties. Initial SAP needs to address soil sampling to include all COGCC Table 910-1 constituents, plus herbicides and chemicals identified in items 1 & 2. Upon COGCC approval, implement plan. Submit a copy of the Post-Construction Stormwater Program for this site to the COGCC for review and comment. Eliminate stormwater flow onto the adjacent property. Remove and control weeds. Provide and implement a weed control plan that eliminates spray and fumes from leaving pad.



click on image to enlarge





LINK TO LAB TEST DOCX FULL 100 PAGE REPORT









Sampling Screening Level Comparison Report

Tier 1 Assessment Document

BP response to Notice of Alleged Violation



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