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.