IMAGES -Operator utilized an unlined and unpermitted production pit. Operator allowed E&P waste to leak from the production pit resulting in SAR concentrations in soil exceeding table 910-1 standards

LARIMER COUNTY, COLORADO DocNum:	200307619	Date Rec'd:	4/15/2011
Operator:	SKEAR PROPERTIES LTD PARTNERSHIP	Oper. No.	79290
Address:	6054 S CR 13 LOVELAND , CO 80537
Company Rep.
Well Name/No.
Location	T R
Fac.ID:		Fac.Type:
API number:	05-069 -06213	County
COGCC Rep:	STEVE LINDBLOM	Phone:	(303 ) 894-2100

Alleged Violation:
Date of Alleged Violation: 3/11/2011			Approx. time of violation:
OPERATOR UTILIZED AN UNLINED AND UNPERMITTED PRODCTION PIT. OPERATOR ALLOWED E&P WASTE TO LEAK FROM THE PRODUCTION PIT RESULTING IN SAR CONCENTRATIONS IN SOIL EXCEEDING TABLE 910-1 STANDARDS.
Act, Order, Regulation, Permit Conditions Cited:
RULE 324.A.a, RULE 904.a.(2), RULE 906.b, RULE 907.a.(1).
Abatement or Corrective Action Required to be Performed by Operator
SUBMIT SPILL REPORT, FORM 19 AND SITE INVESTIGATION AND REMEDIATION WORKPLAN, FORM 27. CEASE USE OF THE PRODUCTION PIT BY 4/22/2011. DISCONTINUE FUTURE USE OF PRODUCTION PIT UNTIL PRODUCTION PIT PERMITTED IN ACCORDANCE WITH RULES 903 AND LINED IN ACCORDANCE WITH RULE 904 TO PREVENT FURTHER LEAKAGE OF PRODUCED WATER.
Abatement or Corrective Action Required to be Completed by: 5/15/2011
This section to be completed by Operator when alleged violation is corrected
Company Rep:		Title:
Signature?		Date:	4/15/2011 2:16:13 PM
Company Comments:
COGCC Signature? Date: N/A
Resolution approved by:		Title:

Final Resolution
Date		Case Closed?		Letter Sent?		COGCC person
No Final data found. click images to enlarge 910. ALLOWABLE CONCENTRATIONS AND SAMPLING FOR SOIL AND GROUND WATER a. Soil and ground water allowable concentrations. The allowable concentrations for soil and ground water are in Table 910-1. Ground water standards and analytical methods are derived from the ground water standards and classifications established by WQCC. b. Sampling and analysis. (1) Existing workplans. Sampling and analysis for sites subject to an approved workplan shall be conducted in accordance with the workplan and the sampling and analysis requirements described in this rule. (2) Methods for sampling and analysis. Sampling and analysis for site investigation or confirmation of successful remediation shall be conducted to determine the nature and extent of impact and confirm compliance with appropriate allowable concentrations. A. Field analysis. Field measurements and field tests shall be conducted using appropriate equipment, calibrated and operated according to manufacturer specifications, by personnel trained and familiar with the equipment. B. Sample collection. Samples shall be collected, preserved, documented, and shipped using standard environmental sampling procedures in a manner to ensure accurate representation of site conditions. C. Laboratory analytical methods. Laboratories shall analyze samples using standard methods (such as EPA SW-846 or API RP-45) appropriate for detecting the target analyte. The method selected shall have detection limits less than or equal to the allowable concentrations in Table 910-1. D. Background sampling. Samples of comparable, nearby, non-impacted, native soil, ground water or other medium may be required by the Director for establishing background conditions. (3) Soil sampling and analysis. A. Applicability. If soil contamination is suspected or known to exist as a result of spills/releases or E&P waste management, representative samples of soil shall be collected and analyzed in accordance with this rule. B. Sample collection. Samples shall be collected from areas most likely to have been impacted, and the horizontal and vertical extent of contamination shall be determined. The number and location of samples shall be appropriate to the impact. C. Sample analysis. Soil samples shall be analyzed for contaminants listed in Table 910-1 as appropriate to assess the impact or confirm remediation. D. Reporting. Soil Analysis Report, Form 24 shall be used when the Director requires results of soil analyses. E. Soil impacted by produced water. For impacts to soil due to produced water, samples from comparable, nearby non-impacted, native soil shall be collected and analyzed for purposes of establishing background soil conditions including pH and electrical conductivity (EC). Where EC of the impacted soil exceeds the allowable level in Table 910-1, the sodium adsorption ratio (SAR) shall also be determined. F. Soil impacted by hydrocarbons. For impacts to soil due to hydrocarbons, samples shall be analyzed for TPH. (4) Ground water sampling and analysis. A. Applicability. Operators shall collect and analyze representative samples of ground water in accordance with these rules under the following circumstances: i. Where ground water contamination is suspected or known to exceed the allowable concentrations in Table 910-1; ii. Where impacted soils are in contact with ground water; or iii. Where impacts to soils extend down to the high water table. B. Sample collection. Samples shall be collected from areas most likely to have been impacted, downgradient or in the middle of excavated areas. The number and location of samples shall be appropriate to determine the horizontal and vertical extent of the impact. If the concentrations in Table 910-1 are exceeded, the direction of flow and a ground water gradient shall be established, unless the extent of the contamination and migration can otherwise be adequately determined. C. Sample analysis. Ground water samples shall be analyzed for benzene, toluene, ethylbenzene, xylene, and API RP-45 constituents, or other parameters appropriate for evaluating the impact. D. Reporting. Water Analysis Report, Form 25 shall be used when the Director requires results of water analyses. E. Impacted ground water. Where ground water contaminants exceed the allowable concentrations listed in Table 910-1, operators shall notify the Director, and submit to the Director for prior approval a Site Investigation and Remediation Workplan, Form 27, for the investigation, remediation, or monitoring of ground water to meet the required allowable concentrations. 912. VENTING OR FLARING NATURAL GAS a. The unnecessary or excessive venting or flaring of natural gas produced from a well is prohibited. b. Except for gas flared or vented during an upset condition, well maintenance, well stimulation flowback, purging operations, or a productivity test, gas from a well shall be flared or vented only after notice has been given and approval obtained from the Director on a Sundry Notice, Form 4, stating the estimated volume and content of the gas. The notice shall indicate whether the gas contains more than one (1) ppm of hydrogen sulfide. If necessary to protect the public health, safety or welfare, the Director may require the flaring of gas. C Gas flared, vented or used on the lease shall be estimated based on a gas-oil ratio test or other equivalent test approved by the Director, and reported on Operator's Monthly Production Report, Form 7. d. Prior to flaring of any gas, operators shall construct a special purpose pit in compliance with Rule 903. e. Operators shall notify the local emergency dispatch or the local governmental designee of any natural gas flaring. Notice shall be given prior to flaring when flaring can be reasonably anticipated, or as soon as possible but in no event more than two (2) hours after the flaring occurs. 900-13 as of November 30, 2006 Table 910-1 ALLOWABLE CONCENTRATIONS AND LEVELS Contaminant of Concern Allowable Concentrations Organics in Soil: EPA Method 8015 (modified) TPH-Non-Sensitive Area 10,000 mg/kg TPH-Sensitive Area 1,000 mg/kg Organics in Ground Water: EPA Method 8020 1 Benzene 5 μg/l 1 Toluene 1,000 μg/l 1 Ethylbenzene 700 μg/l 1 Xylenes (Total) 1,400 to 10,000 μg/l 5 Inorganics in Soils4 Electrical Conductivity (EC) <4 mmhos/cm or 2x background Sodiun Adsorption Ratio (SAR) <12 pH 6-9 Inorganics in Ground Water Total Dissolved Solids (TDS) <1.25 x background 1 Chlorides <1.25 x background 1 Sulfates <1.25 x background 1 Total Metals in Soils: EPA Method 3050 4 Arsenic 41 mg/kg 2 Barium (LDNR True Total Barium) 180,000 mg/kg 2 Boron (Hot Water Soluble) 2 mg/l 2 Cadmium 26 mg/kg 2 Chromium 1,500 mg/kg 2 Copper 750 mg/kg 2 Lead 300 mg/kg 2 Mercury 17 mg/kg 2 Molybdenum 3 Nickel 210 mg/kg 2 Selenium 3 Silver 100 mg/kg 2 Zinc 1,400 mg/kg 2 1Concentrations taken from CDPHE-WQCC 2Concentrations taken from API Metals Guidance: Maximum Soil Concentrations 3Concentrations are dependent on site-specific conditions 4Consideration shall be given to background levels in native soils 5For this range of standards, the first number in the range is a strictly health-based value, based on the WQCC’s established methodology for human health-based standards. The second number in the range is a maximum contaminant level (MCL), established under the Federal Safe Drinking Water Act which has been determined to be an acceptable level of this chemical in public water supplies, taking treatability and laboratory detection limits into account. The WQCC intends that control requirements for this chemical be implemented to attain a level of ambient water quality that is at least equal to the first number in the range except as follows: 1) where ground water quality exceeds the first number in the range due to a release of contaminants that occurred prior to September 14, 2004 (regardless of the date of discovery or subsequent migration of such contaminants) clean-up levels for the entire contaminant plume shall be no more restrictive than the second number in the range or the ground water quality resulting from such release, whichever is more protective, and 2) whenever the WQCC has adopted alternative, site-specific standards for the chemical, the site-specific standards shall apply instead of these statewide standards. What were the imposed fines for such an atrocity? An unlined pit? Absolutely ridiculous! Is this notice of  'alleged violation' still alleged? Email WTFRACK.ORG@GMAIL.COM  to request the full pdf analytical report. please comment

Fracking Letter from Retired Public School Teacher to CO Gov. Hickenlooper

23011 County Road 150

Agate, CO 80101

August 3, 2011

Governor John Hickenlooper

136 State Capitol

Denver, CO 80203

We appreciate the effort you are doing requiring oil and gas companies to disclose the chemicals used in hydraulic fracturing. We would like you to consider implementing additional rules to protect the citizenry from other potential hazards. My wife and I live in central Elbert County and are anticipating the oil development in the near future and are very concerned about the effects on our health, the environment and our property values.

One doesn’t have to look too hard to find numerous incidences of the consequences of living in an industrial site. We have worked and lived in Elbert County for 30 years and have looked forward to retiring on our ranch where we grow organic vegetables, raise dairy goats, chickens and a few steers. (By the way, we met you at the Elbert County Democratic party last year and voted for you.) We consider ourselves lucky to watch the constellations move through the night sky. We can hear the coyotes call, the songbirds sing and the wind blow through the Ponderosa Pines. Our well water is ample and good. We know that when the ten story, 150’, oil rigs move in with generators running 24/7, lights lighting up the sky at night, non stop truck traffic and the smell of spent diesel fuel and open hydraulic fracking fluid pits, that will all change. With the mortgage debacle, our property is now worth less than what we owe on it; to make matters even more dismal, property values around oil fields typically depreciate 25% to 75%. And, because of President Lincoln’s 1862, grant of mineral rights to the railroad (and subsequent purchase by them by Anadarko) we’ll get nothing in royalties.

It is obvious that the Colorado Oil and Gas Conservation Commission, after attending numerous meetings hosted by them, don’t care about the results of hydraulic fracturing on the public. It is fruitless to talk to them. We have petitioned the county commissioners to install regulations to protect the county but apparently the State regulations preempt the counties’. The Colorado Supreme Court has given the oil companies the right to drill on anyone’s land to get to their minerals. Surface owners have no rights.

Clearly this is not a government by the people or for the people because the laws do not protect the people. Clearly the government is for large corporations by large corporations, who, by the way, have grossed billions of dollars in the first two quarters of this year and have been subsidized by the taxpayers.

I am not a petroleum engineer or a geologist or an attorney (I’m a retired public school teacher who can’t afford an attorney) so don’t have a good grasp of what to ask specifically but have watched numerous on line videos, read as much as I can, and, like I’ve stated, gone to as many meetings and discussions as I physically could. I have watched the documentaries ‘Gasland’ and ‘Split Estate’. I’ve read ‘Collateral Damage’ by Tara Meixsell. I’ve talked to geologists and people who work for Encana, Chesapeake, and Anadarko. I’ve driven through Garfield and Weld counties. I feel that my list below is reasonable to protect public safety and health.

1) The set back for distance to residences or existing water wells should be changed to at least 1320’, a quarter mile. Three hundred fifty feet is totally inadequate.

2) The EPA is currently evaluating stricter air pollution regulations. I don’t think it is unreasonable to ask for a moratorium on drilling until the EPA completes its evaluation in early 2012.

3) I don’t believe that it is unreasonable to ask the oil companies to purchase infrared cameras for the county so that property owners can capture air quality emissions on film as evidence.

4) Counties should have the oil companies pay an impact fee to have an independent company test all wells for aquifer depth and water quality before, during and for a minimum of five years after the well has been fracked.

5) Oil companies should have to maintain the road and bridge infrastructure.

6) Counties need deputies to monitor the truck traffic and to help monitor the behavior of transient workers.

7) Our local fire departments need equipment and personnel to fight potential fires quickly. Special foam is needed to fight toxic chemical fires. Our local stations are ill equipped.

8) Counties need their own inspectors to monitor the drilling. There are only 17 inspectors from the COGCC for the 40,000+ wells in the State.

9) Bonds need to be collected to compensate for lost property values especially for those of us who have our mineral rights severed.

10) All fluids used in hydraulic fracturing should be contained in closed loop systems. There should be no open pits allowed.

11) Toxic chemicals should be banned from fracking fluids.

12) Regulations need to be in place to control the disposal of used liquids.

13) Night lights need to be modified.

For the sake of Laura Amos, Chris Mobaldi and the countless others who have become sick, died or have had their lives needlessly disrupted, thank you for considering the above. I look forward to hearing/reading your response,

Rick Blotter

rickblotter@hotmail.com

303-621-2468

WTFrack.org FRACK-EXHIBIT III

FRACK EXHIBIT III

COLORADO

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 State of Greed

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The map illustrations below are of well locations in three counties North Eastern Colorado. The three counties alone comprise over 20,000 active O&G wells!  That's roughly 40% of the entire State of Colorado's active O&G count.  Just imagine, Colorado is talking about hosting over 100,000 active Oil & Gas wells!  That's sick! That's a 'State of Greed."

I surmise that the State of Colorado will be a Superfund State like no other.  Imagine just 10% of all active wells have or eventually will contaminate the natural resources. That's 10,000 contaminated areas in Colorado.  Colorado prides itself on having beautiful, pristine areas where other states may envy.  We'd like to ask the State of Colorado: "What the hell are you doing?" You must be in someones pocket or you have lost what it means to be a Coloradoan!  Our natural resources are worth more money than the state is gaining from the Oil & Gas industry.

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WTFrack.org Frack Exhibit II

FRACK EXHIBIT II

COLORADO

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WTFrack.org FRACK-EXHIBIT I

FRACK EXHIBIT I

COLORADO

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WTFrack.org has compiled a compendium of  images to illustrate the real devastation that the Oil & Gas Industry imposes on our natural lands.  The exhibit below is one of many that clearly show the massive scarring that occurs to clear a large space to 'frack' for oil and gas. The images below show visible fracking pad 'scars.' The scars are more than 2-5 times the size of a football field. 

We will also show you the 'open pits' that are a very hot topic of fracking discussion.  The open pits are either polymer lined pits or non-lined pits where up to >15 million gallons of 'produced water' is stored.  Produced water is a water & chemical cocktail mix that is used to frac a well.  We all know that there are more than 649 toxic chemicals found in frac fluid. This produced water is stored in an open pit (as shown) where it evaporates.  What are the chemical concentrations of this toxic cocktail that are evaporated in to the air? 

Some of the images contain visible wildlife 'social trails' where animals naturally walk towards a water or food source.  Are these open pits safe for wildlife such as birds, deer, elk, rabbits, small mammals, etc...?

Many of the images appear to show the natural resource visibly sterile.  Void of any vegetation whatsoever, even in areas where there are no active wells.  Would this indicate that remediation has not taken place or been successful by the COGCC? We urge the State of Colorado to investigate these areas and remediate them immediately.

The Oil & Gas Industry appears to have one vision.  Their vision is long-term natural resource destruction for short term monetary gains only to themselves. What will they destroy next?  Don't believe the rhetoric that is spewed in the media regarding the urgency to change to natural gas. If America invested it's brains and money in renewable energy innovation and production it could sustain itself for an unimaginably long time and still posses our oil reserves if we ever needed them.

What is the cost/benefit in this devastatingly ugly toxic venture? We dare say a picture is worth a thousand words, or a thousand lives.

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