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COLORADO RESEARCH

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RESPONSE BY STATE:


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February 27, 2012

Ms. Tisha Schuller
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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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


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):

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.

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