The Whitewater Unit is approximately 15 miles south and east of Grand Junction, and contains 90,400 acres. Property in the Unit is owned by various entities, including the federal government, the City of Grand Junction, and private individuals. The proposal is to drill up to 108 new wells from 12 new or existing well pads.
There is a history of exploration in this area; 54 wells have been drilled since 1974. Of those 54 wells, most have been plugged and abandoned. However, in 2009 and 2010, Fram drilled seven wells, of which two are currently producing. Fram determined that it was not economically viable to produce natural gas at this time. The factors cited, which impact economic viability, are the high content of nitrogen & carbon dioxide in the produced gas, which requires treatment prior to any sale to ultimate consumers; the need for compression to transport the natural gas; and the market rate for natural gas is too low to justify those expenses.
However, in drilling for gas, Fram struck oil, hence the request to scrap the gas drilling plan and concentrate instead on oil. The plan is to initially drill vertical wells, which could later be expanded with horizontal wells. Drilling will be on four new well pads in the first year, and eight new well pads in the second year. This is a project that is expected to take four years to complete, with about 25 wells being drilled each year.
The exploratory activity will primarily take place in the Dakota formation, which generally is 4,500 to 5,000 feet beneath the surface. Each well will take approximately 10 days to drill and 5 days to complete. On the first and last days of drilling, there will be 13 – 15 heavily loaded trucks traveling to the well site. Each of the other days will require 3 – 5 light truck loads and 3 – 5 heavy truck loads. The plan is to keep dust down by watering the roadway and limiting the speed of the trucks to 30 miles per hour.
There are some jobs involved in this project. During the drilling phase, there will be 18 workers per day. During the completion phase, there will be five workers per day. The work on the wells will go on 24 hours a day, seven days a week. Wells will be fracked. Fram says that instead of using water in their fracking activities, they will use foam that is 85% CO2 and 15% methanol. Other chemicals that may be in the fracking fluids have not been detailed in the proposal.
In completing the wells, Fram indicates that the surface casing will extend to a minimum depth of 100 feet below any freshwater aquifers within one mile of the well site. It is important to note that these wells are in the proximity of the watershed from which the City of Grand Junction obtains its drinking water.
In addition to wells, Fram will construct pipelines to connect this project with the Trans-Colorado pipeline at two gathering stations within the unit. The Trans-Colorado pipeline connects with the Rocky Mountain Express Pipeline, which takes gas to the east coast. My assumption is that this work will allow the gas that will be produced from oil exploration to be sent to market instead of being flared off. It will take 4 – 7 days to construct one mile of pipeline. The proposal anticipates a little less than 30 miles of pipeline will be constructed, mostly along side existing roads.
The compression of the pipeline needs to be tested. Fresh water is used in the testing. That fresh water will be purchased from the City of Grand Junction, then transported by truck to the testing location. The proposal indicates the water will ultimately be disposed of “in a commercial disposal facility.”
There are many questions arising from this proposal, which should be the subject of comments to the BLM:
· Given the proximity to the Grand Junction water supply, will there be prior and post fracking testing of water in order to establish a baseline water quality.
· Will there be markers put in the fracking fluids, so that there is a direct line of accountability in the event that water quality is compromised.
· Will all chemicals in fracking fluids be disclosed.
· Will there be any flaring of gas.
· Wouldn’t top to bottom cementing be a better practice than the proposal to cement to 100 feet below the surface water.
· What “commercial disposal facility” will accept the waste water.
· What enforcement is available to ensure that truck traffic will not exceed 30 mph, and is that a safe speed given the road conditions and terrain.
The BLM is seeking written comments on this proposal by December 1, 2011. They may be sent in writing to:
Grand Junction Field Office
2815 H Road
Grand Junction, CO 81506
Or Emailed to: BLM_CO_GJ_Web_Mail@blm.gov
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