The Seven Safeguards –
This is a brief summary of a
work in progress by Citizens for Huerfano County, as presented on November
23, 2011 in writing and orally, before the Huerfano County Board of County Commissioners:
1. A substantial bond or
escrow account, to be set aside by any oil and gas developer in Huerfano
County before any site development or drilling, specifically for surface level remediation,
reclamation and to cover expected costs to municipal, domestic and agricultural
water sources and wells, costs to the County Shops, County Fire Protection
Districts, County Sheriff and Municipal Police Departments, County Health Department, and costs to cure expected
damages to citizen health. Our conservative estimate of the amount of this
bond/escrow, just for health damages is $6,117,000.00 (6117 people in
the county, with 10 percent affected, at $10,000 in health care costs per person.)
2. Three surveys, each
of 10 square miles proposed well sites before any site development or drilling:
A) Surface geochemical (“sniffer”) survey to identify and document existing hydrogen
sulfide, methane gas seeps B) Surface radioactivity
survey to identify known radioactives in the vicinity of proposed well
sites and C) Surface 3D seismic
reflection survey (azimuthal) to evaluate the presence and orientation of
natural vertical fractures that could flow fluids (hydrogen sulfide and other gases,
drilling fluids, fracking fluids, radioactives), so that drilling and
production operations can avoid natural hazards.
3. Only non-toxic chemicals
are to be used for drilling and fracking and all such chemicals will be
disclosed, by CAS number, to the County and to the public at least 60 days before
each drill or frack using such chemicals. Samples taken of drilling and fracking fluids
before, during, and after drilling/fracking
operations, to verify what is actually going into the ground.
4. Water quality: Baseline samples to be taken at least 60 days
prior to activity at any well site, for 5 miles in all directions, of all domestic and livestock water wells, of
the intake to all municipal waterworks, and of all other creeks and surface
run-off areas. Baseline population of benthic invertebrates (bugs in the
stream) immediately above and below, as well as approximately 2,000 feet
upstream and 5,000 feet downstream of the proposed well site. Monitoring samples
of water and benthic invertebrates from the same sources to be taken, analyzed
and reported to the County Health Department (accessible to the public) once a
week during well site preparation, drilling, fracking, production and
reclamation. If any drilling, fracking, or gas production chemicals are
detected at any of these locations, well operator will cease and desist all operations until the
situation is fixed. No produced water is
to be placed on any county paved or dirt roads, or otherwise discharged on the
surface.
5. Air quality: Baseline
samples to be taken at least 60 days prior to any well site activity on a still
day at the well site location, and at three appropriate, additional points TBD.
Monitoring samples from the same sources to be taken once every two weeks
during drilling, fracking, production and
reclamation. Whenever readings at any of the locations exceed allowable limits, as
evidenced by an audible alarm in County
Police Dispatch and at the site, then operator will immediately shut down of all operations at
the site, including deliveries and haulage, until the situation is fixed. All sources of gaseous effluent at the site
must be either (1) fitted with adequate
filtering or vapor recovery units, or (2) enclosed. In either case, all gaseous
effluent from all sources and enclosures must be filtered and cleaned of toxic
chemicals and particulate before being discharged into the air. Noise abatement
equipment on all portable equipment and vehicles and noise abatement insulation
of all enclosures.
6. A pitless, closed loop
drilling system will be required with all injection materials mixed in
containers and with all flowback and other produced materials stored in enclosed containers and trucked off
to licensed disposal site(s).
7. No Flaring and adequate,
onsite emergency response: There will be no flaring and well operator will
have onsite both fire and hazmat personnel to deal with any fires or other
accidents.
