Were Seismic Operations Illegally Conducted by the Oil and Gas Industry in Boulder County? Supporting Documents May Reveal Answers

It appears three oil and gas operators conducted seismic operations in Boulder County in 2013 and 2014. According to documents and mapping maintained by the Colorado Oil and Gas Conservation Commission, (COGCC), Extraction Oil and Gas Inc., Encana Oil and Gas and Anadarko Petroleum Corporation have conducted 3D seismic testing operations in Boulder County. 

CLICK IMAGE TO ENLARGE

1.) Extraction Oil and Gas Inc., filed a Form 20 (Notice of intent to Conduct Seismic Operations) on December 8 2014. With the signatures of COGCC Director, Matt Lepore and Permit Technician and project manager, John Krull approved Extraction’s approximate 41 square mile seismic testing for shale in Larimer, Weld and Boulder Counties.

On the Form 20, Extraction indicated that their start date for seismic testing would occur one month prior to the authorization of the permit with an estimated date of completion of Feb 15 2015.

The type of seismic shale testing conducted is listed as 3-D – Vibroseis.  It is a truck-mounted or buggy-mounted device that is capable of injecting low-frequency vibrations into the earth.

Vibroseis trucks conduction seismic shale operations. Image Wikipedia

Extraction hired Houston Texas contracting company, Geokinetics USA Inc. to conduct the seismic testing with RLI Insurance holding the bond for the operations.

COGCC FORM 20 - Extraction Oil and Gas authorized permit to conduct
seismic activities in Boulder County. Click  image to enlarge.

Extraction's 3D mapping indicating Boulder County in 3N 69W.
Note the bottom right of map indicating Larimer, Boulder and Weld Counties
are the area of seismic testing interest. Click map to enlarge.

Green area illustrates Extraction's seismic operations in Boulder County.

Reviewing the legend on the bottom right indicates the green areas are listed by Extraction as
'Good to Go.' Could this mean seismic permitting authorization has been approved or the
shale is viable for drilling?

LINK TO DOWNLOAD EXTRACTION DOCUMENTS


2.) Encana Oil and Gas Inc., filed a COGCC Form 20A - Completion Report for Seismic Operations on April 18 2013. Notice of intent Form 20 is missing from the COGCC's database.

Encana's seismic operations contracted by Lockhart Geophysical Crew #4 out of Montana consisted of 5,438 square miles of 3-D Vibroseis methodology in Weld and Boulder Counties starting on March 15 2013 with a stated completion date of March 24 2013.

It seems odd that seismic operations for 5,438 square miles could be completed in a mere nine days  by Encana when in-fact, it took Extraction almost three months to conduct seismic testing on much smaller 41 square miles.

Encana Oil and Gas Inc Form 20A Completion report for Seismic Operations.
Click to enlarge

Longmont, CO map indicating Encana's seismic activities. Red diagram - left side

Encana's seismic operations mapping - possibly indicating select areas in Boulder County
(left side of map - red areas).

LINK TO DOWNLOAD ENCANA'S SEISMIC DOCUMENTS


3.) Anadarko Petroleum Corporation filed a Completion report for Seismic Operations on April 27 2015. 

Yet another out-of state contractor was hired. Dawson Geophysical Company from Midland, Texas conducted the seismic operations on 70-100 square miles. (The Form 20A has both 70 square miles and 100 square miles listed.)

The start date of seismic activities on November 5 2014 with a completion date of December 15 2014. 

Anadarko's FORM 20A Completion report for Seismic Activities April 27 2015

On the left side of the map you'll notice 1N 69W and 2N 69W (Boulder County Sections) where
Anadarko seimic operations took place in 2014.

Anadarko's Seismic Identifier is listed as #8750, however in the file cache, this document is listed as #8055 with information of seismic activities in Boulder County. There is more than one Identifier listed in the COGCC's database. 

There is much more to discover about Anadarko's seismic operations in Boulder County and there are many missing documents that need to be found to provide public transparency.

According to the COGCC, one of the three seismic contractors described above, Geokinetics USA Inc., conducted illegal seismic testing operations in Weld County without prior submittal and approval of a  COGCC Form 20 - Notice of Intent to Conduct Seismic Activity.

Geokinetcs USA Inc, Houston Texas was issued a ‘Notice of Alleged Violation by the COGCC and was fined $10,000 for illegal seismic testing operations for 196 days. The fines imposed were $1,000 per day of the violation, up to ten days for a maximum fine of $10,000 for ten days of illegal operations. Geokintetics was not fined for the additional 186 days of illegal operations.

Download documents here

One more time: Geokintetics was not fined for the additional 186 days of illegal operations.

This is a clear demonstration of ineffective, unfair and unbalanced, arbitrary and capricious COGCC oil and gas rules and regulations to issue a fine that is in no way, a deterrent. The COGCC should be fined for allowing these illegal activities to occur unnoticed for any length of time, let alone 196 continuous days.

The COGCC and the industry both know it’s clearly cheaper to operate without rules and regulations and pay a fine (also known as a fee) rather than have a single day of down-time. The COGCC rules and regulations were created with the interest of ‘time’ in mind to not fairly penalize the fracking industry for not following the suggestions in the COGCC rules and regulations handbook.  

After all, it’s the COGCC’s job to foster oil and gas development and not slow the industry down.  

      

Do not be fooled however, there are no fines that currently exist in the COGCCs Rules and Regulations that would deter an operator or contractor from practicing illegal activities if it saves them money long-term. 

In-fact, many of the violations have fines that are a positive economical avenue for the industry to take and the cost of a fine is nothing when it comes to ‘down -time’ operators would face waiting for public comments, notifications, permitting, signatures etc. - so much down time wasted on paperwork.  

The fines are designed as a public pacifier to create the appearance of penalties in action. Wait, isn't that called 'fake news?'

COGCC rules and regulations are an annoyance.  If a person got a ticket for running a stop sign or red light 196 times in a single year what would be the imposed fines and penalties? Would the operator still have a license to operate?

How could Geokinetcs USA conduct seismic operations for 196 days without the state regulators even knowing? The answer is simple; there are not enough inspectors, and the COGCC Rules and Regulations penalties and fines are insufficiently assessed and imposed.

On the Colorado Oil and Gas Conservation Commission’s website it states: ‘The Commission provides rules and regulations to establish operational standards and requirements for industry activity in the state.’ The COGCC rules and regulations are not effective or adequately enforced, but rather suggestions like a speed sign on the Autobahn. 

Operate as fast as you want, wherever you want, and don’t worry about reading the regulations, the fines are so small it does not matter and there are no police to enforce your illegal activities anyway.

This case also demonstrates the lack of enforcement of formal processes within the fracking industry and state regulators to ensure accountability of all procedures of operations. Both the COGCC and the fracking industry are not fully accountable.

Any novice review of the state’s online oil and gas database illuminates the COGCC’s and the oil and gas industry’s operations as grossly incomplete, incompetent and in shameful disarray, thus harming public health, safety and environment.

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