DOGM Objects to Drilling Activities near Clear Creek
The Utah Division of Oil, Gas and Mining filed an objection last week to a petition for an aquifer exemption requested by Marion Energy Inc. in the area near Clear Creek.
The objection comes after the homeowners association in the area as well as county officials and nine other parties filed written objections to the permitting process for Marion.
The matter is scheduled to come before the division of oil, gas and mining board on Aug. 23. At that time, the board is expected to make a determination regarding the approval or denial of the applications filed which relate to gas extraction activities in the area.
The drilling company is in the process of obtaining the necessary permits to convert a gas well in the Clear Creek Area into a class two injection well.
Injection wells are used to pump water into the ground as part of the process of extracting natural gas from drilling sites in the surrounding area.
In a written objection to the division, Clear Creek Homeowners Association director Ted Helsten asserted a number of challenges against drilling operations. The objections ranged from road damage and utility line problems to failure to meet commitments to property owners in the area.
The homeowners association raised questions as to the impact to water and sewer lines by heavy equipment.
Further, property areas in the area have made objections to how the road has been maintained in the area, claiming that Marion has created safety hazards and is using private property and government land to store materials without permission.
Homeowners also objected to the conversion of the gas well into an injection site, a subject which is at the heart of the objection filed by DOGM.
In the written objection, the homeowners association pointed to three of the faults with Marion's proposal to convert the gas well into an injection site.
"It can damage or destroy the underground spring water aquifer for Clear Creek home owners," stated the homeowners in the objection.
The homeowners added that the proposed well conversion can damage water quality for downstream water users, including the fish habitat.
And finally, the homeowners raised the question of noise generated by construction and operation of the converted well.
In the DOGM objection filed on Aug. 15, division staff addressed concerns as to whether the aquifer exemption application could be approved with compliance to ground water regulation in the area.
"Based on the information submitted, the division believes that this formation is unsuitable for consideration as a candidate for aquifer exemption," stated division staff in the brief.
The division's filing stated that the aquifer in question qualifies as an underwater source of drinking water under rules established by the Utah Division of Water Rights and Water Quality.
Under the rule, any aquifer containing less than 10,000 milligrams per liter of dissolved solids is considered as a potential source of drinking water.
The aquifer in question has been measured at 6,568 milligrams per liter, making it an underground drinking water source under state rules.
Marion's application seeks to exempt the aquifer from classification as a drinking water source.
In order to do so, the state requires that the applicant meet certain criteria.
In the application, Marion requested that the aquifer be exempted because it:
Does not currently serve as a source of drinking water.
Is at a depth or location which makes recovery of water for drinking purposes economically or technically impractical;.
Is contaminated to the extent that it would be economically or technologically impractical.
Has a total dissolved solids level between 3,000 and 10,000 milligrams per liter and is not reasonably expected to be used as a source of fresh or potable water.
All of the areas cited by Marion are valid reasons, if the statements can be supported by research and tests.
In filing the application, the drilling company submitted two samples from two wells in the Clear Creek area.
One sample was submitted as a sample of the water which will be taken from the ground in the process of extracting gas.
The other sample was submitted as a sample of the water currently in the ground where the water will be injected.
However, the division of oil, gas and mining identified a series of specific problems with the samples submitted.
First, DOGM was not contacted prior to collection of the water samples.
When contacted, DOGM will advise applicants of the process required for sampling groundwater.
In addition, samples lack descriptions of the procedures or methods used in collection, storing and transporting the samples.
When notified, the division provides instructions for these processes.
Further, neither sample was submitted with a chain of custody title. This documentation is required to demonstrate who had the samples in their possession and when.
Chain of custody titles are frequently used to show that materials have not been tampered with or damaged between collection and submittal to the division, pointed out DOGM.
Additional concerns raised by the division related to questions raised in reviewing the amount of total dissolved solids in one of the samples.
DOGM staff members determined that the measurements do not comply with similar data collected on similar wells in the area, indicated the state agency.
While the measurements are not impossible, the discrepancy raises questions as to the validity of the water samples.
Other problems with the samples include lack of proper description of the location of the collection site; an expired pH for one of the samples; and failure to isolate the proposed injection interval.
DOGM continued to raise objections in its brief, stating that the proposed injection site would pump water into an aquifer that could be accessed by both municipalities and industries in the future.
The proposed injection site lacks cement bonds near the injection site, noted the state agency.
Without the proper bonding, water injected into the sell could be inserted into any layer along the wellbore and that the sample could have come from anywhere in the wellbore, explained the state agency.
DOGM also pointed out that Skyline mine is pumping water from the Star Point Sandstone and Star Point Coals, which are located about 900 feet higher than the proposed injection zone, into Electric Lake.
The water pumped from the mine contains approximately 70 milligrams per liter of total dissolved solids, clearly making it a potential drinking water source, according to state officials.
The intended injection zone is also highly faulted, with one major fault as close as 400 feet from the wellbore.
Because of the geologic faulting in the layers close to the injection site, the division questioned whether the injected water would be contained within the proposed injection zone.
If it is not contained, it can contaminate other sources of drinking water.
Beyond the objections raised in the brief filed last week, DOGM staff have additional concerns.
Much of the data required in the application process was lacking as of last week, according to the division of oil, gas and mining.
As a result, DOGM staff recommended to the state board of oil, gas and mining that Marion's petition be denied.