Sunday, June 3, 2012

Public Input on Jenny C1 Well


Here is the Public Input that was given by CHC to the COGCC on the Jenny C1 well.

1. The Pit and Water/Soil ProtectionThe water table listed is only 14 feet and the hydraulic conductivity of the soils at the site at least "moderately high".  How will the COGCC ensure compliance of surrounding water and soils with the concentration levels in table 910-1? Pit liners are known to leak. Will there be baseline sampling and monitoring? Are additional requirements from 901.c appropriate?  They are probably not sufficient in this case.  Closed loop drilling should be used.  Otherwise, this pit creates a danger and a risk. Also, where is the pit application (Form 15)? What is going to be in the pit? What waste will there be and how will it be disposed of?

2. Baseline Water TestingThere appear to be about 3-4 water wells within approx. 1/2 mile of this site.  Given the other questions, it is important that they be tested.  Additionally, the Huerfano River is approx. 1/2 mile away and could be impacted.  Downstream testing would help monitor surface water pollution levels and ensure compliance.

3. Nearby Oil and Gas Wells in Same FormationForm 2 #19 has the distance to the nearest well permitted/completed in the same formation as 30 miles, and the proposed total measured depth is 2250. Impact Energy well Huerfano State 1-36 is about 500 feet away and it had 2,150 TVD. There are 4 wells (Huerfano State 1-36, HRI-BAR 35-1, Huerfano State 2-36, and Sporleder 1-26) within approx. 1 mile that have TVD of 1800-2330.  Please evaluate the accuracy of the application on this point, and examine the records of these nearby O&G wells to ensure they have integrity and pose NO risk in this case. 

4. Improvements/Canal Close to SiteForm 2A #15 says "There are no improvements within 400 ft of the site." Rule 303.d(3)C requires this information. Yet, there seems to be a canal to the south-southwest less than 400 feet away (see Google maps). Please evaluate the accuracy of the application on this point, and the implication of the canal so close.

5. Sensitive Area Non-Determination Form 2A #14 has "Is this a sensitive area?" = NO and "Was a Rule 901.e Sensitive Area Determination performed?" =  NO.  How can the operator claim this is not a sensitive area if the No Sensitive Area Determination has been made?  Is this a flaw in the application?

6. Sensitive Wildlife HabitatIn Form 2A #1 "This location is in a sensitive wildlife habitat area" is NOT checked, but a quick check of the COGIS maps indicates that it IS (for the Pronghorn).  Please evaluate the accuracy of the application on this point, and the implication of the SWH.

7. CDOW and CDPHEWhat did CDOW do and what information did they look at to assess the location before passing their Form 2A task?  What did CDPHE do and what information did they look at to assess the location before passing their Form 2A task?

8. Source of Certain Information on the Form 2AForm 2A (#6) has that salt sections and H2S are NOT expected to be encountered.  Form 2A And #10 and #11 Current/Future Land Use = "Dry land". How were these determined?

9. Aquifer ProtectionThe surface casing is planned to go 250' deep.  What is the location/depth of deepest aquifer, and where did the information come from?  Bedrock aquifers do exist in Huerfano county (see e.g. McLaughlin - USGS paper 1805).

10. Dikes/Faults/FracturesWhat are the locations of the deep dikes/fractures/faults in the vicinity?  These features create secondary hydraulic conductivity from depth to surface. They can be transmissive. Dikes are mapped on the surface (, but not all are visible on the surface.  They extruded from the magma and not all reached the surface. These features should be avoided.  What has been done to determine separation and barriers from these natural features (both during drilling and fracking) at the location?

11. Type of Well and Drilling Plan?Will this be a vertical well? There is no drilling plan diagram.  Also, is this well for oil, gas or CBM? "Gas" is checked in Form 2 #2, but the planned depth is comparable to prior CBM wells drilled in the county, and the Niobrara is being explored by SWEPI for oil. Given the problems with Petroglyph and CBM drilling, please be careful not to allow the same situation/problem to occur.

12. Will There Be Hydraulic Fracturing? Examination of the other oil and gas wells nearby (Impact Energy), shows there was no production. Will this well be hydraulically fractured?  There are no production pits listed. Would that mean 'no'? If it IS to be fracked, what is the depth and direction?  This would have to be known to evaluate in advance the presence of adequate frack barriers and lack of connectivity to natural fractures which can move fluids out of the target formation.

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