Hydrogen sulfide high at 53 wells, Noble says

By Dennis Webb
Wednesday, December 7, 2011

Noble Energy is reporting dangerous levels of hydrogen sulfide gas have been measured at least once at dozens of its wells not just in Garfield County, but Weld County as well.

The company says 21 of its wells in the Piceance Basin have had levels at or above 100 parts per million on at least one occasion, as have 32 wells in the Grover oil and gas field in Weld County.

Short-term exposures at such levels can cause several health problems, and exposures lasting hours can cause death. But Noble Energy says safety protocols are in place to protect workers.

Noble Energy reported its findings as part of a response to allegations by state regulators that it failed to comply with requirements to report hydrogen sulfide gas encountered at oil and gas sites in the two counties.

Noble Energy also reported lower levels of hydrogen sulfide at eight of its wells in Mesa County, several miles south of Parachute. Noble Energy spokesman Stephen Flaherty said gas chromatograph tests at those sites all found levels less than two parts per million. The highest reading for any of those wells was 50 ppm, using a less accurate test designed simply to confirm the presence of the gas for the sake of workers, he said.

Bureau of Land Management spokesman David Boyd said that when Noble Energy has experienced hydrogen sulfide at federal well pads in the Piceance, it hasn’t been in the natural gas itself, but in liquids at the sites, and it has been associated with some wells on a pad but not others. That suggests it was introduced, he said.

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H₂S Safety Factsheet

Hydrogen sulfide (H2S, CAS# 7783-06-4) is an extremely hazardous, toxic compound. It is a colorless, flammable gas that can be identified in relatively low concentrations, by a characteristic rotten egg odor. The gas occurs naturally in coal pits, sulfur springs, gas wells, and as a product of decaying sulfur-containing organic matter, particularly under low oxygen conditions.

 It is therefore commonly encountered in places such as sewers, sewage treatment plants (H2S is often called sewer gas), manure stockpiles, mines, hot springs, and the holds of fishing ships. Industrial sources of hydrogen sulfide include petroleum and natural gas extraction and refining, pulp and paper manufacturing, rayon textile production, leather tanning, chemical manufacturing and waste disposal.

Hydrogen sulfide has a very low odor threshold, with its smell being easily perceptible at concentrations well below 1 part per million (ppm) in air. The odor increases as the gas becomes more concentrated, with the strong rotten egg smell recognizable up to 30 ppm. Above this level, the gas is reported to have a sickeningly sweet odor up to around 100 ppm.

However, at concentrations above 100 ppm, a person's ability to detect the gas is affected by rapid temporary paralysis of the olfactory nerves in the nose, leading to a loss of the sense of smell. This means that the gas can be present at dangerously high concentrations, with no perceivable odor.

Prolonged exposure to lower concentrations can also result in similar effects of olfactory fatigue. This unusual property of hydrogen sulfide makes it extremely dangerous to rely totally on the sense of smell to warn of the presence of the gas.

Health Effects of Hydrogen Sulfide

H2S is classed as a chemical asphyxiant, similar to carbon monoxide and cyanide gases. It inhibits cellular respiration and uptake of oxygen, causing biochemical suffocation. Typical exposure symptoms include:

L O W	0 - 10 ppm	Irritation of the eyes, nose and throat
M O D	10 - 50 ppm	Headache Dizziness Nausea and vomiting Coughing and breathing difficulty
H I G H	50 - 200 ppm	Severe respratory tract irritation Eye irritation / acute conjunctivitis Shock Convulsions Coma Death in severe cases

Prolonged exposures at lower levels can lead to bronchitis, pneumonia, migraine headaches, pulmonary edema, and loss of motor coordination.

Working with Hydrogen Sulfide

Most countries have legal limits in force that govern the maximum allowable levels of exposure to hydrogen sulfide in the working environment. A typical permissible exposure limit in many countries is 10 ppm. While the distinctive odor of H2S is easily detected, its olfactory fatigue effects mean that one cannot rely on the nose as a warning device. The only reliable way to determine exposure levels is to measure the amount in the air. Regular monitoring will help to identify areas and operations likely to exceed permissible exposure limits, and any areas that routinely pose overexposure hazards should be equipped with continuous monitoring systems.

With a vapor density of 1.19, hydrogen sulfide is approximately 20 percent heavier than air, so this invisible gas will collect in depressions in the ground and in confined spaces. The use of direct reading gas detection instrumentation should be required before entering confined spaces such as manholes, tanks, pits, and reaction vessels that could contain an accumulation of H2S gas.

Wherever possible, exposure should be minimized by employing adequate engineering controls and safe working practices. Such methods include ensuring good ventilation and changing work procedures and practices. Where engineering controls cannot adequately control levels of exposure, it may be necessary to supplement them with the use of suitable personal protective equipment (PPE) such as supplied-air respirators. A qualified industrial hygienist or safety professional should be consulted for guidance on the suitability and correct use of respirators.

Should a co-worker ever be overcome by H2S gas, do not attempt a rescue until you are properly protected yourself. The rescuer can very easily get caught out by venturing into a confined space without adequate protection. Remember that at levels above 200 ppm, collapse, coma and death due to respiratory failure can occur within seconds after only a few inhalations so you can be overcome yourself very quickly. Such incidents are sadly all too common and only serve to make the rescue effort twice as difficult.

source:SafetyDirectory.com

Petro-Canada Resources (USA) Inc. fined $20,000 - Complaint regarding trucks dumping drilling wastes near the Cache La Poudre River

BEFORE THE OIL AND GAS CONSERVATION COMMISSION

OF THE STATE OF COLORADO

IN THE MATTER OF ALLEGED VIOLATIONS OF THE RULES AND REGULATIONS OF THE COLORADO OIL AND GAS CONSERVATION COMMISSION BY PETRO-CANADA RESOURCES (USA) INC., WELD COUNTY, COLORADO

) ) ) )

CAUSE NO. 1V ORDER NO. 1V-356

ADMINISTRATIVE ORDER BY CONSENT

(Pursuant to Rule 522.b.(3) of the Rules and Regulations of the

Colorado Oil and Gas Conservation Commission, 2 CCR 404-1)

FINDINGS

1. On June 6, 2006, the Colorado Oil and Gas Conservation Commission (“COGCC” or “Commission”) approved an Application for Permit-to-Drill (“APD”) submitted by Petro-Canada Resources (USA) Inc. (“Petro-Canada”) for the Deshazo #24-41 Well (API No. 05-123-23922) (the “Well”), located in the NE¼ SE¼ of Section 24, Township 6 North, Range 67 West, 6^th P.M.

2. On April 11, 2007, Weld County Environmental Health Services received a complaint regarding trucks dumping drilling wastes at a location in the SW¼ NE¼ of Section 33, Township 6 North, Range 66 West, 6^th P.M., which at the time was owned by Mr. Buxman. The location is adjacent to the Cache la Poudre River.

3. On April 12, 2007, Weld County Staff conducted a site inspection and observed an area of approximately 300,000 ft² adjacent to the river where water-based bentonitic drilling mud had been disposed. Weld County Staff referred the matter to COGCC Staff (“Staff”) for investigation (COGCC Complaint No. 1175595).

4. On April 13, 2007, Staff inspected the mud disposal site. Staff identified Petro-Canada as one of two parties responsible for the drilling mud disposal. Staff directed Petro-Canada and Noble Energy Production, Inc. (“Noble”), the other responsible operator, to cease drilling mud disposal at the site and take immediate steps to prevent drilling mud from migrating into the Cache la Poudre River. At Staff’s direction, Noble and Petro-Canada constructed earthen berms along portions of the river to prevent additional drilling mud from entering the river.

5. During the April 13, 2007 inspection, Staff collected a representative sample of the drilling mud for organic analysis. The sample had a total petroleum hydrocarbon (“TPH”) concentration of 115 mg/kg, which is below the concentration level found in Table 910-1 in effect at the time of 1,000 mg/kg for soil in sensitive areas, and a benzene concentration of 88 µg/kg, which is below the benzene concentration level of 0.17 mg/kg² found in Table 910-1.

6. The landowners at the disposal site told Staff they had agreed to the disposal but did not have a written disposal agreement with any party. The landowners also told Staff they did not intend to till the mud into their land, in that trees and brush piles made much of the disposal area unsuitable for tilling.

7. On April 20, 2007, Staff conducted a second site inspection. During this inspection, the Staff observed an area where it appeared that drilling mud may have previously entered the river. Staff estimated that less than five gallons of waste mud had migrated to the river. Corrective actions taken by Noble and Petro-Canada prevented more mud from reaching the river. A surface water sample taken at the point where the mud entered the river contained concentrations of benzene, toluene, ethylbenzene, and xylenes (“BTEX”) below the laboratory detection limit. Concentrations of BTEX compounds were trace or non-detect in a drilling fluid sample taken near the point of entry had trace amounts. Acting upon the assessment that site remediation had not yet begun, Staff instructed Noble and Petro-Canada to immediately remove all free liquids from the disposal site for off-site disposal.

8. On April 23, 2007, Petro-Canada notified the National Response Center of a release of drilling fluids.

9. On April 26, 2007, Staff issued a Notice of Alleged Violation (“NOAV”) #1175599 to Petro-Canada, which include alleged violations of the following COGCC rules:

a. Rule 324A.a., which requires operators to take precautions to prevent significant adverse environmental impacts to air, water, soil, or biological resources to the extent necessary to protect public health, safety and welfare and to prevent the unauthorized discharge of gas;

b. Rule 907.a.(1), which provided at the time of the discharge that operators ensure that exploration and production (“E&P”) waste is properly stored, handled, transported, treated, recycled, or disposed to prevent threatened or actual significant adverse environmental impacts to air, water, soil or biological resources or to the extent necessary to ensure compliance with allowable concentration levels in Table 910-1, with consideration to WQCC ground water standards and classifications;

c. Rule 907.d.(3).b., which requires operators to dispose of water-based bentonitic drilling fluids by acceptable methods of land application, such as production facility construction and maintenance, and lease road maintenance. Additionally, operators are required to obtain written authorization from the surface owner prior to land application of water-based bentonitic drilling fluids and to retain records about the disposal.

The NOAV required certain abatement or corrective actions to be taken by the operator by May 10, 2007. The actions required Petro-Canada to submit a Spill/Release Report Form 19 and a Site Investigation and Remediation Workplan, Form 27 to: describe the corrective actions previously taken by Noble, the other responsible operator; remove the remaining drilling mud; determine the approximate thickness of the mud; determine if shallow ground water at the disposal site was impacted; and provide COGCC copies of the written landowner disposal authorizations.

10. On April 30, 2007, Noble submitted a Form 19 to the COGCC. Noble determined that approximately 4,900 barrels of waste mud from the Well were disposed of by third-party contractors at the site. The disposed mud covered an area approximately 300,000 ft² in a layer 3-to-5 inches deep. Petro-Canada and Noble removed approximately 1,540 barrels of free liquid from the disposal area after April 20, 2007 and before April 27, 2007.

11. On April 30, 3007, Noble submitted a Form 27 to the COGCC. Staff approved the Form 27 work plan with additional conditions on May 17, 2007. Pursuant to the approved Form 27 work plan, Petro-Canada and Noble removed the remaining drilling mud for disposal at their respective land farms. Noble also sampled soil and groundwater in the disposal area. Concentrations of BTEX, total volatile hydrocarbons including gasoline range organics, total extractable hydrocarbons and diesel range organics were all below regulatory standards in the soil. BTEX compounds were not detected in the sampled groundwater.

12. On May 8, 2007, Noble provided Staff with copies of Authorization Forms for Land Treatment of Water Based Betonitic Drilling Fluids between Rocky Mountain Energy Solutions and the landowners dated April 9, 2007.

13. Rule 523. specifies a base fine of One Thousand dollars ($1,000) for each day of violation of Rules 324A.a., 907.a.(1), and 907.d.(3)B. Rule 523.a.(3) specifies that “the maximum penalty for any single violation shall not exceed Ten Thousand dollars ($10,000) regardless of the number of days of such violation,” unless the violation results in significant waste of oil and gas resources, damage to correlative rights, or a significant adverse impact on public health, safety or welfare or the environment.

14. For purposes of this Administrative Order by Consent (“AOC”) only, Staff consider each violation to have occurred for a minimum of ten days, April 11, 2007 through April 20, 2007, inclusive. Further, Staff reserve the right to present evidence that any and all violations resulted in significant waste of oil and gas resources, damage to correlative rights, or a significant adverse impact on public health, safety or welfare or the environment, and, that as result of that impact, the maximum penalty of Ten Thousand dollars ($10,000), under Rule 523.a.(3), should not apply.

15. Petro-Canada violated Rule 324A.a. because it failed to take precautions to prevent significant adverse environmental impacts to air, water, soil, or biological resources to the extent necessary to protect public health, safety and welfare by allowing water based bentonitic drilling mud to be improperly disposed of. A base fine of Ten Thousand dollars ($10,000) has been calculated for the violation of Rule 324A.a.

16. Petro-Canada violated Rule 907.a.(1) because it failed to ensure that E&P waste, including water based bentonitic drilling mud, was properly stored, handled, transported, treated, recycled, or disposed to prevent threatened or actual significant adverse environmental impacts to air, water, soil or biological resources or to the extent necessary to ensure compliance with allowable concentration levels in Table 910-1, with consideration to WQCC ground water standards and classifications. A base fine of Ten Thousand dollars ($10,000) has been calculated for the violation of Rule 907.a.(1).

17. Petro-Canada violated Rule 907.d.(3)B. because it failed to dispose of water-based bentonitic drilling fluids by acceptable methods of land application, such as production facility construction and maintenance or lease road maintenance. Additionally, it failed to obtain written authorization from the surface owner prior to land application of water-based bentonitic drilling fluids and failed to retain records about the disposal. A base fine of Ten Thousand dollars ($10,000) has been calculated for the violation of Rule 907.d.(3)B.

18. Staff have calculated a base fine of Thirty Thousand ($30,000) dollars for those violations brought under this AOC.

19. Staff may reduce the fine amount if it finds mitigating circumstances as is provided for by Rule 523.d. Based on Petro-Canada’s cooperation with COGCC, its prompt response and thorough remediation efforts, evidence that the landowners had consented to the disposal operation, and Petro-Canada’s post-NOAV compliance history regarding waste drilling mud handling and disposal practices, Staff have reduced the fine amount from Fifty Thousand ($30,000) dollars to an adjusted fine of Twenty Thousand dollars ($20,000) for purposes of this AOC only. If the NOAV is not resolved by consent, Staff reserve the right seek the full amount of the base fine for each day for each violation without reduction for the factors described above or any other facts or circumstances.

20. Payment of the fine pursuant to this AOC does not relieve Petro-Canada from its obligations to complete abatement or corrective actions set forth in the NOAV, as may be amended or modified by Staff, or the approved Form 27.

21. Petro-Canada should execute this AOC no later than fourteen (14) days after the date it is executed by Staff for recommendation to the Commission for expedited approval. Fines may increase if this matter is not recommended for expedited approval.

22. Petro-Canada, or its successors or assigns, should be required to remain responsible for complying with this AOC, in the event of any subsequent sale of property.

23. Pursuant to Article IX, of the “Memorandum of Agreement” between the Water Quality Control Division (“WQCD”) and the COGCC, adopted February 15, 2000, Staff has conferred with WQCD enforcement staff in determining the monetary penalty against Petro-Canada for violations of WQCC standards for surface waters.

24. Petro-Canada agrees to the findings of this AOC only for the purpose of expeditiously resolving the matter without a contested hearing. Notwithstanding the above, Petro-Canada does not admit to any of the factual or legal determinations made by the Commission herein, and fully reserves its right to contest same in any future action or proceeding other than a proceeding to enforce this AOC.

25. On December 31, 2009, Noble Energy, Inc. (“NEI”) entered into a Purchase and Sale Agreement with Petro-Canada and Suncor Energy (Natural Gas) America Inc. (“SENGAI”) to purchase certain assets, and assigned certain of its rights under the Purchase and Sale Agreement (“PSA”) to Noble Energy WyCo, LLC, which agreed to be jointly and severally liable to Petro-Canada and SENGAI for the obligations and liabilities of NEI under the PSA and other transaction documents.

ORDER

NOW, THEREFORE, IT IS ORDERED, that Petro-Canada Resources (USA) Inc. violated Rules 324A.a., 907.a.(1), and 907.d.(3)B., resulting from its oil and gas operations at the Deshazo #24-41 Well, located in the NE¼ SE¼ of Section 24, Township 6 North, Range 67 West, 6^th P.M., for those acts alleged in this AOC.

IT IS FURTHER ORDERED, that Petro-Canada Resources (USA) Inc. is hereby assessed an adjusted fine of Twenty Thousand dollars ($20,000) for the Rule violations set forth above.

IT IS FURTHER ORDERED, that this Administrative Order by Consent does not relieve the operator from undertaking and completing abatement or corrective actions that may be required by the Notice of Alleged Violation described in Finding No. 9, above, or any amendments or modifications thereto specified by the Staff, or the approved Form 27.

IT IS FURTHER ORDERED, that Petro-Canada Resources (USA) Inc. shall execute this Administrative Order by Consent no later than fourteen (14) days after the date it is executed by the Staff for recommendation of expedited approval by the Commission.

IT IS FURTHER ORDERED, that under the State Administrative Procedure Act the Commission considers this order to be final agency action for purposes of judicial review within thirty (30) days after the date this order is mailed by the Commission.

IT IS FURTHER ORDERED, that an application for reconsideration by the Commission of this order is not required prior to the filing for judicial review.

IT IS FURTHER ORDERED, that the provisions contained in the above order shall become effective forthwith.

IT IS FURTHER ORDERED, that the Commission expressly reserves its right after notice and hearing, to alter, amend, or repeal any and/or all of the above orders.

RECOMMENDED this day of____________, 2010.

OIL AND GAS CONSERVATION COMMISSION

OF THE STATE OF COLORADO

By ____

Rob Willis, Enforcement Officer

Dated at Suite 801

1120 Lincoln St.

Denver, Colorado 80203

AGREED TO AND ACCEPTED this _________day of_______________, 2010.

PETRO-CANADA RESOURCES (USA) INC.

By __________________________________________

Signature of Authorized Company Representative

Noble Energy, Inc., sole member of Noble

Energy WyCo, LLC

____________________________________________ Print Signatory Name

____________________________________________

Title

Junk Propaganda Reporting at its Best? - Greeley Tribune: Oil and Gas "We don't Have a lot of Problems"

Oil and gas is a fixture in life, government of Weld County

By aromano@greeleytribune.com">Analisa Romanoaromano@greeleytribune.com

Greeley Tribune

Tuesday, September 20, 2011

These days, oil and gas isn’t just an industry in Weld County — it’s a way of life.

“People are used to it,” said Weld planning director Trevor Jiricek.
So is the Weld County Planning Commission. Because it has been inundated with applications to extract, store and process oil and natural gas, the commission hosted a special meeting Tuesday to focus on five requests submitted by the mammoth natural gas collector, DCP Midstream.
Jiricek said about 50 percent of the requests submitted to the planning department have to do with oil and gas.

“It makes you wonder what percent beyond that 50 is not directly related to oil and gas, but some kind of support,” Jiricek said. He said up to 75 percent of the activity surrounding land use cases could have their roots in the oil and gas industry.
Last year, the commission issued 841 building permits for oil and gas, which is three times that of 2005. And this year is on track to surpass 2010, according to a work output report from Weld’s Department of Planning Services, with 115 oil and gas building permits issued in August alone.
To compare, 50 residential building permits were issued in 2010, about one-fifth of what was issued in 2005.

As governments in Weld County well know, those permits have translated to an abounding flow of severance and property tax revenue from oil and gas companies.
In fiscal 2011, Weld received $1.72 million in severance tax revenue, in addition to $846,000 in mineral leases, according to the Colorado Department of Local Affairs.

Weld County assessor Chris Woodruff said the overall oil and gas class in the county is valued at $2.4 billion, translating to a taxable value of $5.2 billion.

In other words, Woodruff said, for every dollar of property taxes paid, about 47 cents comes from the oil and gas industry.Every case the commission heard Tuesday would build up the infrastructure needed for a pipeline in the Niobrara Formation that would transfer natural gas.DCP, which specializes in the transportation of gas, hopes to see the 57 miles of pipeline completed by mid-2013, said Greg Kardos, the company’s asset manager for Weld County.
“The D-J Basin is reinventing itself in anticipation of Niobrara,” Kardos told the commission.

The four gas compressors and electric gas processing facility DCP is requesting would add to the 150 jobs the company already has based in Weld County, he said. Jason Maxey, a member of the planning commission, said his only concern was whether the additions would take away irrigated farm land.

However, no concerns were voiced in the hearing portion of the meeting.

Jiricek said opposition to oil and gas activities is not usually the norm because the adverse effects are often successfully mitigated and because residents of Weld County see the industry as a part of everyday life.
“It’s been a gradual building of the industry,” he said. “We don’t have a lot of problems.”

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Ever consider that an industry has flown in by night and has not provided the public with appropriate health information regarding the potential hazards of fracking?  Do the people of Weld County even know what fracking is?  Do they know the EPA's death ratio standards for cancer acceptance levels for VOC emissions?  We are starting to think that the County doesn't either.




According to the COGCC's website, to date, Weld County has had:

• More than 1,000 Field Inspections
• More than 1,000 Notice of Alleged Violations
• More than 1,000 Public Complaints
• More than 1,000 Spill/Incident reports where 433 Spills CONTAMINATED GROUNDWATER and 30 spills CONTAMINATED SURFACE WATER
• More than 1,000 Remediation Forms filed 
• only 229 Mechanical Integrity Tests

Do the people of Weld County know about all of these problems ththe State Oil and Gas Conservation Commission has filed? Our guess is that they do not.  We will replay what we wrote just the other day about the death/benefit the EPA supports.



BELOW

EPA’s risk review estimates that the cancer risk from air toxic emissions from natural gas transmission and storage is approximately 90 in 1 million.

While EPA considers a risk level of 90 in 1 million to be acceptable, the agency is proposing changes to this standard that would lower the risk level to 20 in 1 million. What a nice way to dilute the issue...

Dividing 90 deaths into one million equals one death per 11,111 people in a population.

Therefore, the risk FOR CANCER ONLY, is guaranteed to be 1 in 11,111. The EPA says that is acceptable. Now are they also considering the well density of an area parallel with its population?


Consider an area like Weld County, Colorado which has an estimated 18 - 20,000 active oil and gas wells and a population of 268,000 citizens, which equates to 15 active oil and gas wells per citizen! That's a staggering proposition. In order to estimate the death ratio per a set population, we'd have to understand the estimated amount of toxic chemicals emitted per well on average and use the EPA's formula.

What if the death ratio was 1 in 5,000? That would equate to roughly 54 people dead from cancer caused from toxic emissions in the air. Would this be an annual event? Does anyone think an industry should be unregulated under the Clean Air Act?

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