Bob Arrington forewarns COGCC about hazards of Ursa’s A Pad

Bob Arrington, at a drilling rig near his home in Battlement Mesa, on August 25, 2016. [Source: Earthjustice: Methane: A Dangerous Problem, An Easy Solution]

Bob Arrington, PE, is a Battlement Mesa citizen representative on Garfield County’s Energy Advisory Board (EAB). He also represents the Grand Valley Citizens Alliance and the Battlement Concerned Citizens. This week he submitted his comment to the COGCC regarding Ursa’s proposed A Pad and injection well.

Included with Bob’s letter is his presentation, A Very Bad Place to Try an Experiment? Ursa Pad “A” Injection Well, where he outlines the inherent hazards surrounding the placement of an injection well at the A Pad site.

For more information about Ursa’s Battlement Mesa Phase II application pending with the COGCC see:  Submit comments now for Ursa’s Battlement Mesa Phase II application

The full text of his letter is published below. Click on the title of his presentation to view.

**********

COGGC Staff
Colorado Oil and Gas Conservation Commission
120 Lincoln St #801
Denver, CO 80203

I am submitting the following detailed presentation against the proposed Pad A application submitted by:

Ursa Resources Group II, Inc.
Headquarters
1600 Broadway, Suite 2600
Denver, CO 80202
Or corresponding Field Office

Pad A is located in Battlement Mesa next to the public waste treatment facility and the Colorado River. The site is nestled into the hillside and is planned with a retaining wall. It is approximately 600 feet from the river, less than 500 feet from homes, and “sound walls” will be useless for homes.

Pad fire catching brush on fire between homes and pad will be able to race upslope and, with incendiary type of brush, will be able to equal the devastation recently witnessed in Elko, Nevada. However, there will be no time for evacuations as it can reach the homes in minutes raining burning embers. If one of the waste storage tanks for injection blows-up, as in the Greely injection well fire, it could land up on the hill and maybe the homes.

The pad is within a 1000 feet of the storage reservoir for Battlement water supply and it will be easy for fugitive benzene to contaminate.

The CDPHE should still be concerned with this location, water supply, and LUMA location.

My concern goes much deeper to the geology they are proposing for this location as an injection well site. Besides the problems discovered with the Pad B site, the close injection from Pad A to a Basement fault and the location in an identified upper strata site of faults and joints. Moving a mile to a mile and a half to the Southeast would be far more prudent to attempt an injection well. I have recommended in my enclosure at looking to the WPX seismic work that was done recently to see if it would clear up the fault geology that they were encountering.

I would say that the public might not tolerate another Firestone disaster and there is no need for these risks.

Moreover, unless the Colorado Supreme Court rules to the contrary, the COGCC has been charged by the Colorado Appeals Court to regard Health, Safety and Well Being, not as a “balance”, but as a protection to be preserved.

This is a dangerous site and the potentials have been sounded. Please examine very carefully before “approving” this site. The injection well is NOT a necessary part of this application and can be located elsewhere or trucked out from a nearby pad “Speakman” on Stone Quarry Road with the installation of a “terminal” for waste water truck loading. The Speakman Pad already has injection operations and no more quantity should be allowed.

Respectfully,
Robert L. Arrington, P.E.

Click here to read: A Very Bad Place to Try an Experiment? Ursa Pad “A” Injection Well

Conclusion

But – Why the “must be here”?

  • For the lines of wells, the picked Class II sites spacing and location would allow formation flooding under the active wells.
  • Using that flooding pressure to create new liquid bottom pressure could be an attempt to “energize” the producing gas wells.
  • The overlaying formations are not “impervious”.
  • This is against the rules to use Class II waste (toxic) disposals in this manner. Every well site becomes a potential leak point.
  • The zone is bad, almost on top of one of two major basement faults, but operator could alleviate by moving more central between the faults which they seemingly refuse to consider.
  • Regardless of where it is located, pipelines can replace truck traffic. A pipeline terminal can be used to keep traffic out of Battlement.
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