Monday, May 28, 2012

Encana O&G: Notice of Alleged Violation - Arsenic levels exceed...

Date Received: 12/12/2011

Mesa County, Colorado

Operator:ENCANA OIL & GAS (USA) INCOper. No.100185
Address:370 17TH ST STE 1700 ATTN: DIANE BILESZNER  DENVER , CO 80202-5632

Alleged Violation:
Date of Alleged Violation:  12/5/2011Approx. time of violation:  
 On December 5, 2011, a Form19 for a spill which occurred on 11/20/2011 included three background samples (reportedly not in the 11/20/2011 spill path) collected from the disturbed area of the pad. Two of the samples had arsenic levels of 25 mg/kg and 15 mg/kg. These arsenic concentrations are above the Table 910-1 level (0.39 mg/kg) and above background soil arsenic concentrations in Colorado for Native Grassland, Rangeland, or Agriculture of 3-14 mg/kg, according to the Colorado Department of Public Health and Environment (CDPHE) �Risk Management Guidance for Evaluating Arsenic Concentrations in Soil� (June 2010). The other background sample, not in the spill path, had an arsenic level of 5.5 mg/kg, indicating non-impacted material. The sample results indicate a previous spill on this pad which was not reported and was not remediated to meet Table 910-1 levels.

Act, Order, Regulation, Permit Conditions Cited:
 324.A.a, 906.a, 906.e.2, 907.a (1), 909.b.5

Abatement or Corrective Action Required to be Performed by Operator
 1. Review operational history at pad to identify possible previous releases and potential sources of elevated arsenic. 2. Prepare a Form 27 Site Investigation and Remediation Workplan for COGCC approval prior to implementation. The plan shall include a sampling program to delineate the vertical and horizontal extent of soil concentrations above Table 910-1 levels for full Table 910-1 constituents. 3. Provide written description and diagrams of surface geology and soils present at this location. 4. Perform a background study at this location. Background samples must be collected from undisturbed, native materials. 5. Prepare an interpretive report including the results of tasks 1 through 4 and the "background" samples reported for the 11/20/2011 spill. A one month extension has been granted from 1/20/2012 until 2/20/2012 on LSO 1/20/2012


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