Colorado Oil and Gas Conservation Commission

Raton Basin Groundwater Quality Complaint Investigation Case Studies

Peter Gintautas

The statements made during the workshop do not represent the views of opinions of the Colorado Oil & Gas Conservation Commission (COGCC). The claims made by participants have not been verified or endorsed by the COGCC

PROMOTE THE RESPONSIBLE AND BALANCED DEVELOPMENT OF COLORADO’S

OIL & GAS RESOURCES

• Ensure: Exploration and production of oil and gas resources are conducted efficiently.

• Mineral owners’ rights are protected. • Oil and gas production is conducted in a manner

consistent with protection of public health, safety, and welfare, including the environment & wildlife resources.

COGCC MISSION

• Implement CDPHE-WQCC GW Standards & Classifications.

• Permit & oversee the management of E&P Wastes.

• Approve & oversee Site Investigation and Remediation

• Respond to complaints alleging impacts to public health safety and welfare and the environment (water, vegetation & soil).

• Conduct studies to establish baseline and current conditions prior to or during O&G development and monitor to detect changes

• Environmental review of O&G locations – Form 2A.

COGCC ENVIRONMENTAL GROUP

Complaints 2001 - 2012

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WATER WELL, BASELINE &

GROUNDWATER

NOISE ODOR & AIR QUALITY

DUST PITS LIGHTING

Combined, these six complaint types represent 1,277 complaints of 2,729 complaints, or 46%, recorded by COGCC from 2001 - 2012.

• Analytical results from >6,000 water wells & >6,500 oil and gas wells.

• Collected by the COGCC, Operators, other agencies

• Studies by COGCC to establish Baseline and Current Conditions

• Collected in response to complaints and requests

• Required by Orders of the Commission (Cause 112)

• Required by Rules (317B, 318A.e.4., 608, 609 and 908.b.9.)

• Required as part of Site Investigation and Remediation activities.

GROUND WATER PROTECTION INVESTIGATIONS & MONITORING

North Park Basin

North Park Basin

North Park Basin

North Park Basin

North Park Basin

South Park Basin

South Park Basin

South Park Basin

South Park Basin

South Park Basin

Canon City EmbaymentCanon City EmbaymentCanon City EmbaymentCanon City EmbaymentCanon City Embayment

San Luis Basin

San Luis Basin

San Luis Basin

San Luis Basin

San Luis Basin

Piceance BasinPiceance BasinPiceance BasinPiceance BasinPiceance Basin

HugotonHugotonHugotonHugotonHugoton

Raton BasinRaton BasinRaton BasinRaton BasinRaton BasinSan Juan Basin

San Juan Basin

San Juan Basin

San Juan Basin

San Juan Basin

Paradox Basin

Paradox Basin

Paradox Basin

Paradox Basin

Paradox Basin

Uintah Basin

Uintah BasinUintah Basin

Uintah Basin

Uintah Basin

Sand Wash BasinSand Wash BasinSand Wash BasinSand Wash BasinSand Wash Basin

Denver Julesburg BasinDenver Julesburg BasinDenver Julesburg BasinDenver Julesburg BasinDenver Julesburg Basin

• Blue – water samples • Green – oil/gas well samples

Drilled 11/2006 Completed and first produced 03/2007 Spill from pit reported 01/2011

Lobo 13-4 CBM well and nearby water well location

Looking south in pit Improper preparation of pit bed prior to installation of liner

Looking north at fill slope with lined pit not visible Darker soil areas are where spill emerged

House with water well 707184

Spill path

Spill path

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mg/

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Date Samples Collected

707184 Water Well Changes in TDS, SO4, Ca and HCO3 Alk. Concentration

TDS Sulfate Calcium Bicarb. Alk.

Cem

ent S

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No baseline sampling and analysis available

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707184 Water Well Changes in Sr Concentration

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No baseline sampling and analysis available

Lobo 13-4 chronology Well spud 18 November 2006 Well completed 23 February 2007 seven zones perfed and fraced First produced March 2007 and Last produced April 2011 Produced 6710 Mcf gas, 529,000 barrels water Operator tried cement squeeze at perfs in zone considered to be main water production zone in November 2010 Landowner noted Ca residue in dishwasher late December 2010 Landowner found active spill late January 2011

Lobo 13-4 COGCC rule 205 request for information on products used downhole at Lobo since April 1, 2009 Cement squeeze in late November 2010 only downhole activity since well completed in March 2007 Chemical products used in cement squeeze Cement Gypsum (mainly a calcium sulfate product) Source of elevated calcium, sulfate and strontium observed in groundwater at 707184 was gypsum used as cement additive

Molokai 13-36 (Tr) Spud 18 July 2006 – air percussion one of two compressors failed attempted to continue drilling bit stuck drilling hole for surface casing both compressors operational attempt to remove drilling string hole pressured up Complaints 19 July 2006 water well owner observed water geysering First sampled 20 July 2006 by COGCC staff

Molokai location

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Date Samples Collected

704681 Water Well Changes in TDS, Na, Ca SO4, and HCO3 Alk. Concentration

TDS Na

Ca Bicarb. Alk.

Mol

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One baseline sample prior to drilling incident

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F (m

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704681 Water Well Changes in F and Mn Concentration

Mn F Mol

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One baseline sample prior to drilling incident

Site Investigation – 2 domestic wells sampled by operator multiple times subsequent to impacts. One baseline sample at both water wells prior to drilling in the area. Notices of Alleged Violation Issued to Operator. Administrative Orders by Consent with fine paid by operator. Network of groundwater monitoring wells (6 total) installed by operator including continuous monitoring by pressure transducers. Quarterly sampling and analysis with semi-annual reports. One of the domestic wells impacted during the Molokai incident and also the second impacted well (which is now a monitoring well) and both have been sampled as part of the national frac study (Raton Basin retrospective)

NFR, Alibi and Kosar Complaints North Fork Ranch 14-1R, spud 22 September 2009 completed 8 December 2009 landowner complaint (21 December 2009) alleging impacts to groundwater from damage to casing of deeper CBM well (NFR 14-1V) on location during frac of the shallower CBM well on the same pad Mechanical Integrity Test (MIT) of 14-1V (29 December) passed and witnessed by COGCC staff No impacts

NFR, Alibi and Kosar Complaints Alibi 23-2, spud 24 April 2010 completed 28-30 June 2010 landowner complaint (30 June 2010) alleging impacts to groundwater from the frac job at the Alibi 23-2 CBM well Water samples collected from domestic well and Alibi flowback on 1 July 2010 as part of complaint response. COGCC letter to landowner (1 December 2010) closing complaint with no impacts to groundwater from CBM well stimulation observed. Landowner filed for Order Finding Violation with Commission with full hearing before Commissioners in February 2011. Commission did not find violations of COGCC rules.

NFR, Alibi and Kosar Complaints Kosar 22-11, spud 24 September 2011 completed 29 November 2011 landowner complaint (30 September 2011) alleging impacts to groundwater from drilling of Kosar 22-11 and manifested as increased sediment in well water Domestic well sampled (4 October 2011) in response to complaint. Well sampled at same time as part of the Raton Basin retrospective portion of the EPA national study of hydraulic fracturing.

Water well sampled multiple times prior to alleged impacts

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Cond

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Date Samples Collected

705323 water well Total Dissolved Solids and Conductivity

Conductivity median prior to July 2010

TDS median prior to July2010

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Date Samples Collected

705323 water well Na Concentration

Sodium median prior to July 2010

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median -10%

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705323 water well Cl concentration and pH

pH Cl Alibi 23-2 frac

North Fork Ranch 14-1 R drilling and completion Kosar 21-11

drilling

Water well treatment

Water well treatment used a product containing concentrated hydrochloric acid which accounts for observed changes in early February 2011 shown in this and previous two slides.

January 2011 705323 Water Well Treatment Activities

5 gallons of Cotey Chemical Coro. “Liquid Acid Descaler” product poured into well (late January 2011) by licensed pump installer hired by the landowner. Product is a mix of HCl, glycolic acid and nonionic surfactants designed to remove iron scale. Well purged and swabbed after product in well 3 days. Landowner reported groundwater was green and verbally complained that the color and turbid appearance indicated his well now had frac flowback from the Alibi 23-2 frac of late June 2010. Samples of groundwater collected on 3 February 2011 as part of investigation of complaint alleging impacts to groundwater from Alibi 23-2 frac.

Alibi Frac Overall Composition • Nitrogen Foam Frac • 14 Stages (85-257 barrels water pumped in individual stages) • Primary Ingredients and Composition of the Frac (by weight)

– Water, Sand, Nitrogen and Guar – 59.5%, 22.6%, 17.5% and 0.14%

• Other Products and Composition of the Frac (by weight)

– HCl 0.18% – Foamer 0.10% (2-butoxy-ethanol, methanol, ethylene glycol)

– Breakers 0.006% (sucrose, NaCl, ethylene glycol)

– Biocide 0.001% (2,2-dibromo-3-nitrilopropionamide)

– Envirohib 0.0004% (ethylene glycol)

N2 as Unintentional Frac Tracer Nitrogen foam fracs have been used in the Raton Basin since the late 1990s. 15-20% (by weight) of the frac fluid is nitrogen from liquid N2. Nitrogen/Argon ratios in groundwater have been used as a means to trace biogeochemical processes in the water. In the relatively shallow groundwater system typical of coals and other aquifers in the Raton Basin, the ratio of N2/Ar is typically a function of the ratio of the two gases in the atmosphere, the solubility of the two relatively inert gases in water as well a temperature of the recharge area. The foam frac introduces relatively pure nitrogen into the subsurface and this can be used to trace frac fluids. In the Alibi frac more than 210,000 pounds of nitrogen were injected as part of the stimulation fluids.

1022

704

50 59 50 57 50 55

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Alibi 23-2 gas

Alibi 23-2 liquids

705323 water well

705323 water well

705323 water well

705323 water well

705323 water well

705323 water well

N2/Ar

Nitrogen/Argon Ratios

Flow

back

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se 0

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/201

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back

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4/12

03/0

7/13

Mean N2/Ar of 147 domestic well groundwater samples in Las Animas county is 65 with a range of 5-129.

Acknowledgements

COGCC staff and management past and present Debbie Baldwin and Dave Neslin Jim Milne and Matt Lepore