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RESPONSE BY STATE:
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2.
February 27, 2012
Ms. Tisha Schuller
Colorado Oil and Gas Association
1660 Lincoln Street, Suite 2710
Denver, CO 80264
Colorado Oil and Gas Association
1660 Lincoln Street, Suite 2710
Denver, CO 80264
Dear Ms. Schuller,
It has recently come to our attention that your Association
has paid for and is airing a radio advertisement about drilling and fracking in
Colorado. The ad is here: http://www.coga.org/audio/Gov_Hickenlooper_HF_Rule_30sec.mp3
This ad contains this sentence: “Since then [2008] we have not had one
instance of groundwater contamination association with drilling and hydraulic
fracturing.”
This sentence is not correct.
Specifically, our organizations have analyzed the 615 “Incident
Spill Reports” for oil and gas drilling and fracking reported to the Colorado
Oil and Gas Conservation Commission (COGCC) in just one Colorado County (Weld)
from 1/3/2008 – 1/5/2012. These publicly
searchable reports (Table 1 below)available on COGCC’s website reveal that:
1.
44% of spills have contaminated groundwater.
2.
2.8% of spills have contaminated surface water.
3.
40% of spills have resulted in or been caused by
berm failures.
Further, we have also reviewed the 1,000 Incident Spill
Reports available on COGCC’s website for Weld County, dated 8/28/2003 –
1/05/2012 (the COGCC website only lists the 1,000 most recent reports). Those reports (table 2 below) reveal that:
1.
43% of spills have contaminated groundwater.
2.
3.1% of spills have contaminated surface water.
3.
43% of spills have resulted in or been caused by
berm failures.
These reports are available for each the 40 oil and gas
companies operating in Weld County, revealing that bulk of the spills and
contamination are due to a handful of companies.
Further yet, we randomly sampled 60 of the 1,000 Spill
Incident Reports and extrapolated those results to generate an estimate of
fluid contamination. Those results
(Table 3 below) reveal that:
1.
Up to 824,600 gallons of oil have been spilled
and “unrecovered” in Weld County.
2.
Up to 383,600 gallons of produced water has been
spilled and “unrecovered” in Weld County.
3.
Up to 547,400 gallons of “Other” fluid has been
spilled and “unrecovered in Weld County.
(“Other” may include fracking fluids.)
The results above are just for one County, Weld, and do not
reflect spills and groundwater contamination in the 41 other Colorado counties in which oil and
gas drilling and fracking occur.
Because the statement in your radio ad is incorrect, we
request that you correct the ad or remove it from the airwaves.
Respectfully,
Shane Davis, Chair, Poudre Canyon Group of the Sierra Club, shane.davis@rmc.sierraclub.org,
509-570-4422
Gary Wockner, PhD, Colorado Program Director, Clean Water
Action, gwockner@cleanwater.org,
970-218-8310
1/3/2008 - 1/5/2012
|
271 YES
|
17 YES
|
246 YES
|
344 NO
|
598 NO
|
369 NO
|
|
GW CONTAM
|
44.0%
|
YES
|
|
GW CONTAM
|
56.0%
|
NO
|
|
SURFACE H2O CONTAM
|
2.8%
|
YES
|
|
SURFACE H2O CONTAM
|
97.2%
|
NO
|
|
BERM CONTAINED
|
40.0%
|
YES
|
|
BERM CONTAINED
|
60.0%
|
NO
|
Table 1
INCIDENT SPILL REPORTS
|
|||||
271 YES
|
17 YES
|
246 YES
|
|||
2008
|
GW CONTAM
|
44.0%
|
YES
|
||
GW CONTAM
|
56.0%
|
NO
|
|||
SURFACE H2O CONTAM
|
2.8%
|
YES
|
|||
SURFACE H2O CONTAM
|
97.2%
|
NO
|
|||
BERM CONTAINED
|
40.0%
|
YES
|
|||
BERM CONTAINED
|
60.0%
|
NO
|
Table 2:
Company Name
|
Ground Water
|
Surface Water
|
Berm Contained
|
TOTAL
1000 SPILL INCIDENT REPORTS
|
427
YES
|
31
YES
|
429
YES
|
40
OPERATORS –WELD COUNTY
|
563
NO
|
969
NO
|
571
NO
|
TOTAL
PERCENTAGE FROM 1000 SPILL REPORTS
|
GW
CONTAM
|
42.7%
|
YES
|
GW
CONTAM
|
56.3%
|
NO
|
|
SURFACE
H2O CONTAM
|
3.1%
|
YES
|
|
SURFACE
H2O CONTAM
|
96.9%
|
NO
|
|
BERM
CONTAINED
|
42.9%
|
YES
|
|
BERM
CONTAINED
|
57.1%
|
NO
|
|
Company Name
|
Ground Water Contamination
|
Surface Water Contamination
|
Berm Not Contained
|
BAYSWATER
EXPL AND PROD LLC * 1
reported
|
0.0%
|
0.0%
|
100.0%
|
BLUE
CHIP * 2 reported
|
50.0%
|
0.0%
|
100.0%
|
BONANZA
CREEK * 21 reported
|
16.0%
|
11.0%
|
63%
|
CDM
* 1 reported
|
0.0%
|
100.0%
|
100%
|
CHESAPEAKE
* 4 reported
|
0.0%
|
0.0%
|
0%
|
COLTON
* 1 reported
|
0.0%
|
0.0%
|
0.0%
|
CONQUEST
* 5 reported
|
0.0%
|
0.0%
|
20.0%
|
DIAMOND
* 1 reported
|
0.0%
|
0.0%
|
100.0%
|
DUKE
* 1 reported
|
0.0%
|
0.0%
|
100.0%
|
EDDY
* 3 reported
|
67.0%
|
0.0%
|
100.0%
|
ENCANA
* 46 reported
|
44.0%
|
4.0%
|
61.0%
|
ENERVEST
* 1 reported
|
0.0%
|
0.0%
|
100.0%
|
EOG
* 4 reported
|
0.0%
|
0.0%
|
0.0%
|
FOUNDATION
* 1 reported
|
0.0%
|
0.0%
|
0.0%
|
FOUNTAINHEAD
* 3 reported
|
100.0%
|
0.0%
|
34.0%
|
GREAT
WESTERN * 2 reported
|
0.0%
|
0.0%
|
50.0%
|
GRYNBERG
* 3 reported
|
0.0%
|
0.0%
|
34.0%
|
HIGH
PLAINS DISPOSAL * 1 reported
|
0.0%
|
0.0%
|
0.0%
|
HYNDREX
* 1 reported
|
0.0%
|
0.0%
|
100.0%
|
KP
KAUFMAN * 23 reported
|
13.0%
|
30.0%
|
91.0%
|
KERR
MCGEE * 391 reported
|
59.0%
|
2.0%
|
47.0%
|
LONE
STAR * 1 reported
|
0.0%
|
0.0%
|
100.0%
|
MACHII
* 6 reported
|
17.0%
|
17.0%
|
100.0%
|
MATRIX
* 2 reported
|
50.0%
|
0.0%
|
0.0%
|
MERIT
*15 reported
|
20.0%
|
0.0%
|
47.0%
|
MINERAL
* 1 reported
|
0.0%
|
0.0%
|
0.0%
|
MONAHAN
*3 reported
|
0.0%
|
0.0%
|
67.0%
|
NOBLE
* 236 reported
|
31.0%
|
2.0%
|
69.0%
|
PATINA
* 20 reported
|
30.0%
|
0.0%
|
30.0%
|
PETRO
CANADA *29 reported
|
45.0%
|
0.0%
|
62.0%
|
PETROLEUM
DEVELOPMENT * 158 reported
|
47.0%
|
3.0%
|
67.0%
|
PRIMA
* 1 reported
|
0.0%
|
0.0%
|
0.0%
|
RED
WILLOW * 3 reported
|
0.0%
|
0.0%
|
33.0%
|
STARLIGHT
* 3 reported
|
0.0%
|
0.0%
|
0.0%
|
SYNERGY
* 2 reported
|
0.0%
|
0.0%
|
0.0%
|
TEXAS
AMERICAN RESOURCES *2 reported
|
0.0%
|
0.0%
|
100.0%
|
TOP
OPERATORS * 1 reported
|
0.0%
|
0.0%
|
100.0%
|
US
EXPLORATION * 1 reported
|
0.0%
|
0.0%
|
0.0%
|
WALSH
PRODUCTIONS * 1 reported
|
0.0%
|
0.0%
|
0.0%
|
WINDSOR
* 1 reported
|
0.0%
|
0.0%
|
0.0%
|
Weld
County “Spill Release Reports" (08/28/2003 - 01/05/2012)
|
|||
60
Randomly Picked
|
If 60
statistically represent 1,000, estimated
|
Estimated
Unrecovered Fluid (1,000 reports)
|
|
Spill
Area (square feet)
|
146,717,366
|
2,445,289,440
|
|
Oil
Spilled (gal)
|
65,646
|
1,094,100
|
|
Oil
Unrecovered (gal)
|
49,476
|
824,600
|
824,600
|
Produced
Water Spilled (gal)
|
31,164
|
519,400
|
|
Produced
Water Unrecovered (gal)
|
23,016
|
383,600
|
383,600
|
Other
Spilled (gal)
|
34,104
|
568,400
|
|
Other
Unrecovered (gal)
|
32,844
|
547,400
|
547,400
|
Total
Estimated Unrecovered Fluid (gal)
|
1,755,600
|
||
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3.
Colorado Oil and Gas Association Statement Not Correct, Again
Contamination of Laramie-Fox Hills Aquifer and Residential Water Well Occurred in 2009
Fort Collins, CO -- In the February 28, 2012 online version of the Denver Post, the President of the Colorado Oil and Gas Association is quoted as making this statement:
3.
For Immediate Release
February 29, 2012
Sierra Club Poudre Canyon Group and Clean Water Action
Contacts: Shane Davis, 509-570-4422; Gary Wockner, 970-218-8310
February 29, 2012
Sierra Club Poudre Canyon Group and Clean Water Action
Contacts: Shane Davis, 509-570-4422; Gary Wockner, 970-218-8310
Colorado Oil and Gas Association Statement Not Correct, Again
Contamination of Laramie-Fox Hills Aquifer and Residential Water Well Occurred in 2009
Fort Collins, CO -- In the February 28, 2012 online version of the Denver Post, the President of the Colorado Oil and Gas Association is quoted as making this statement:
Colorado's
rules include provisions addressing "cementing and casing of wells,"
Schuller said. And since 2009 "there has not been a drilling or
hydraulic-fracturing incident that has affected groundwater, and there have
been no incidents which have affected a family's or community's drinking
water," she said. http://www.denverpost.com/news/ci_20058409
This statement is not
correct.
One such "incident" occurred on August 11, 2009 in which toulene and dissolved methane were found in a residential water well in Weld County that included contamination of the Fox-Hills Aquifer. The homeowner filed a complaint ("gas bubbles were present in his water"). The COGCC tested the water and found the contaminants. The COGCC required a nearby gas well to be tested and concluded there was a hole in the casing. The gas well was then shut down. The operator (Eddy Oil) was fined $46,200 and required to remediate the property owner's impacts. The extent of the contamination to the Laramie-Fox Hills aquifer is unclear at this time as is any effort to decontaminate the aquifer.
Here is the "NOAV" Report for the incident: http://cogcc.state.co.us/cogis/NOAVReport.asp?doc_num=200222149
Here is the Spill/Release Report ("Form 19, 6/99"): http://water.clean.home.comcast.net/~water.clean/Form-19-Final-at-02-19-10-EDDY-OIL-CO.pdf
Here is the "Administrative Order By Consent 1V-349" in which it states (http://water.clean.home.comcast.net/~water.clean/Administrative-Order-By-Consent-1V-349.doc):
One such "incident" occurred on August 11, 2009 in which toulene and dissolved methane were found in a residential water well in Weld County that included contamination of the Fox-Hills Aquifer. The homeowner filed a complaint ("gas bubbles were present in his water"). The COGCC tested the water and found the contaminants. The COGCC required a nearby gas well to be tested and concluded there was a hole in the casing. The gas well was then shut down. The operator (Eddy Oil) was fined $46,200 and required to remediate the property owner's impacts. The extent of the contamination to the Laramie-Fox Hills aquifer is unclear at this time as is any effort to decontaminate the aquifer.
Here is the "NOAV" Report for the incident: http://cogcc.state.co.us/cogis/NOAVReport.asp?doc_num=200222149
Here is the Spill/Release Report ("Form 19, 6/99"): http://water.clean.home.comcast.net/~water.clean/Form-19-Final-at-02-19-10-EDDY-OIL-CO.pdf
Here is the "Administrative Order By Consent 1V-349" in which it states (http://water.clean.home.comcast.net/~water.clean/Administrative-Order-By-Consent-1V-349.doc):
16. Based on the above facts,
COGCC Staff contend that a hole in the production casing in the Well resulted
in a significant waste of oil and gas resources and a significant adverse
impact on public health, safety or welfare or the environment as it pertains to
Rule 324A.a. COGCC Staff further contend that Eddy Oil’s failure to maintain a
casing program to prevent the migration of produced gas from Codell Formation
in the Well to the Laramie-Fox Hills Aquifer resulted in the degradation and
contamination of ground water. (page 3)
"COGA's statement
in the Denver Post is not correct," said Shane Davis of the Sierra
Club, Poudre Canyon Group. "Groundwater and aquifer contamination have
occurred in a residential water well since 2009."
Further, the Sierra Club and Clean Water Action point out that "since 2009," Spill/Release Reports sent to the COGCC by drilling operators in Weld County show that 46.3% of the 452 spills/releases contaminated groundwater and 2.2% of 452 spills/releases contaminated surface water. (Table here: http://water.clean.home.comcast.net/~water.clean/SC-CWA-to-COGA-Since-2009-2-29-2012.pdf)
"Groundwater and surface water are being contaminated by oil and gas production activities," said Gary Wockner of Clean Water Action.
The Sierra Club, Poudre Canyon Group and Clean Water Action continue to analyze the data from Weld County, Colorado.
--end--
Further, the Sierra Club and Clean Water Action point out that "since 2009," Spill/Release Reports sent to the COGCC by drilling operators in Weld County show that 46.3% of the 452 spills/releases contaminated groundwater and 2.2% of 452 spills/releases contaminated surface water. (Table here: http://water.clean.home.comcast.net/~water.clean/SC-CWA-to-COGA-Since-2009-2-29-2012.pdf)
"Groundwater and surface water are being contaminated by oil and gas production activities," said Gary Wockner of Clean Water Action.
The Sierra Club, Poudre Canyon Group and Clean Water Action continue to analyze the data from Weld County, Colorado.
--end--
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4.
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