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Oil, gas input welcomed

Posted: Wednesday, Jun 19th, 2013

DEL NORTE — The Bureau of Land Management San Luis Valley Field Office is seeking public input on the preliminary environmental assessment for the proposed San Francisco Creek #1 Well.

The environmental assessment (EA) is being conducted in response to an application for permit to drill from the Dan A. Hughes Company.

The proposed exploratory oil and gas well would be drilled on a 35-acre lot owned by the Dan A. Hughes Company near County Road 13, approximately five miles south of Del Norte. San Francisco Creek is about a mile away from the proposed drilling pad and access road.

The project area is within a small rural subdivision made up of approximately 33 lots that are 35-40 acres in size.

The federal mineral rights below the private land were leased for 10 years from the Bureau of Land Management in 2006.

Last fall the BLM conducted public scoping measures for the San Francisco Creek Application for Permit to Drill and over the course of a 30-day period received 42 written comments addressing a wide range of resource concerns. The public comments identified many issues addressed within the environmental analysis, such as water and air quality, wildlife, visual resources and geology.

However, there were also scoping comments that did not trigger BLM’s guidance on what is considered an issue requiring analysis under NEPA (National Environmental Policy Act.) Some examples of those concerns include statements about whether or not oil and gas development is necessary (generally expressed as a “favor” or “oppose” position statement); concerns regarding potential for a larger oil field development if producible quantities of minerals are discovered (outside the scope of this analysis); and the effect of local land-use ordinances on BLM authority (previously decided by law).

The BLM also received many comments encouraging consideration of the Rio Grande County Hydrology study. While not generally part of a routine environmental analysis for an Application for Permit to Drill, the BLM was able to work cooperatively with the Rio Grande County team to consider their findings within its analysis.

Public involvement and input a vital part of the NEPA process. The BLM will collect public comments on this draft environmental analysis for 30-day period before finalizing the document and making a decision on the Application for Permit to Drill.

Comments would be most effective if received by July 18 and should be mailed to the San Luis Valley Public Lands Center, Attention: Paul Tigan, 1803 W. Highway 160, Monte Vista 81144. Comments may also be submitted electronically to BLM_CO_SLVPLC_Comments@blm.gov

Before including an address, phone number, email address, or other personal identifying information with comments, the public should be aware their entire comment—including personal identifying information—may be made publicly available at any time. Asking to withhold personal identifying information from public review cannot be guaranteed.

To view the EA and other information concerning the proposed well, log on to www.blm.gov/co/st/en/fo/slvfo/Current_Planning_Efforts/San_Francisco_APD1.html or call Paul Tigan at 852-6274.

An EA provides evidence for determining whether to prepare an Environmental Impact Statement (EIS) or a statement of “Finding of No Significant Impact” (FONSI). If the decision maker determines that this project could have “significant” impacts following the analysis in the EA, then an EIS would be prepared for the project. If the project would not have “significant” impacts, a Decision Record may be signed for the EA approving the selected alternative, whether the proposed action or another alternative.

BLM decisions issued as a result of this EA would apply only to BLM administered public lands (mineral estate).

The BLM’s policy is to make mineral resources available for disposal and to encourage development of mineral resources to meet national, regional, and local needs in accordance with BLM’s multiple-use mandate under the Federal Land Policy and Management Act of 1976.

The BLM oil and gas leasing program promotes the development of domestic oil and gas resources and the reduction of U.S. dependence on foreign energy sources. Oil and gas exploration and development is recognized as an appropriate use of public lands in the Resource Management Plan (RMP) that provides management direction for the leased area. BLM will consider the proposed exploratory drilling and access in a manner that avoids or reduces impact on other resources and activities as identified in the RMP.

The BLM will decide whether to approve the proposed [San Francisco Creek #1 Well] action based on the analysis in the Environmental Assessment. This EA will analyze the proposed action to construct a well pad and access road, in order to drill and develop federal minerals from a private surface location. Access to the proposed well pad would be on existing county and rural roads. The finding associated with this EA may not constitute the final approval for the proposed action.

The BLM may choose to: a) implement the project as proposed, b) implement the project with modifications/mitigation, c) implement an alternative to the proposed action, or d) not implement the project at this time. The BLM will approve, deny or approve with modifications.

The BLM will take into consideration approved standards for public health including standards pertaining to soils, riparian systems, plant and animal life, threatened and endangered species and water quality.

In the draft EA the BLM stated, “Implementation of the proposed action would include drilling through the Conejos Formation aquifer to potentially tap into oil and gas traps from the San Juan Sag oil and gas play. The proposed action could produce hydrocarbons and contribute to the national energy supply as well as well as lead to beneficial subsurface information about the Conejos Formation, the San Juan Sag, and the geologic interpretation of the area. If improperly cased and cemented, the proposed action could lead to cross-contamination of water and hydrocarbon bearing aquifers.”

BLM Onshore Order #2 requires that the proposed casing and cementing programs shall be conducted as approved to protect and/or isolate all usable water zones.

The surface casing will also be deepened from 1100’ to 1400’ to reduce the probability of contamination as a result of the 1400’ deep water wells that are located in the vicinity, the draft EA stated.

“Before drilling an intermediate hole, the surface casing will be cemented in place to surface between the casing and the formation, and also be pressure-tested to verify the success of the cementing job. In addition, BLM will require increased volumes of drilling mud and fresh water be readily available on location as a preventative measure to counter any downhole pressures that could be seen. Additional storage tanks will also be available onsite to handle excess volumes of water that could be seen from the Conejos.

“A cement bond log will be required on the production casing (and the intermediate casing, if this is run), to ensure the quality of the cement bond between the casing and the formation. As required by BLM regulations, 50 feet of cement will be required above and below any producing interval, or any zone of interest. Given the high potential for encountering vertical and horizontal natural fractures in the San Francisco Creek #1 well that could contribute to crossflow and contamination, all casing that is run in the well will be cemented from bottom to top so that no casing will be exposed directly to the Conejos waters that are present, or to the targeted oil and gas formations that may be found at depth. Remedial cementing procedures will be required if it’s determined that cementing doesn’t meet BLM requirements.”

?The draft EA added that because surface water is scarce and groundwater heavily utilized for agricultural and domestic uses, “protection of this vital and vast groundwater resource is essential. During the drilling process, the proposed well would pass through usable groundwater aquifers. Potential impacts to groundwater resources could occur if appropriate cementing and casing programs are not strictly followed.

“The impacts could include loss of well integrity, surface spills, or loss of fluids in the drilling and completion process.”

The EA also addressed the concern of possible chemical additives used in drilling activities to be introduced into the water producing formations without proper casing and cementing of the well bore.

“Changes in porosity or other properties of the rock being drilled through can also result in the loss of drilling fluids. In such conditions, drilling fluids, as well as naturally-occurring metals and radioactive material, can be introduced into freshwater holding aquifers unless proper cementing and casing are applied.”

The EA talked about the possibility of hydraulic fracturing, if used, introducing chemical additives into the hydrocarbon producing formations and affecting the mobility of naturally occurring substances in the subsurface, particularly in the hydrocarbon-containing formation.

“The ability of these substances to reach to groundwater or surface water as a result of hydraulic fracturing activities is a potential concern … Potential impact to groundwater could occur if fractures extend beyond the target formation and reach aquifers, or if the casing or cement around a wellbore fails under the pressures exerted during hydraulic fracturing.

“In addition, hydraulic fracturing requires extensive quantities of water, equipment, and vehicles, which could increase risks of accidental spills or leaks. Surface spills or releases may flow into nearby surface water and infiltrate into the groundwater.”

Again, the BLM referred to Onshore Order #2, which requires casing and cementing to protect usable water zones.

“Well casing along with cement would be extended beyond the deepest fresh-water zones to insure that drilling and hydraulic fracturing fluids remain within the well bore and protect groundwater and surface water.

“Vertical and horizontal fractures in the formations may be encountered during drilling and could contribute to potential migration between formations. As a result, all casings that run-through the well should be cemented from bottom to top so that no casing will be exposed directly to the fresh or usable water zone, or to the targeted oil and gas formations.

“Shallow aquifers would be protected by extending and properly cementing the conductor casing to adequate depths.”

Regarding animal life, 15 species of Threatened, Endangered, or sensitive (TES) wildlife were reviewed for potential presence within or near the project area, including the Gunnison prairie dog, Northern leopard frog, milk snake, bald eagle, ferruginous hawk, peregrine falcon, mountain plover, burrowing owl, Brewer’s sparrow, fringed myotis, Townsend’s big-eared bat, big free-tail bat, Rio Grande cutthroat trout, Rio Grande sucker, and Rio Grande chub.

The draft EA pointed out that during drilling these species could be exposed to higher volumes of vehicular and human traffic, and their habitat could be disturbed by such activities as the drill site construction and road to the site. Mitigating measures could include surveys and appropriate timing to minimize habitat disturbance.

The mitigation measures should ensure that while some wildlife would be displaced or its habitat affected, no species’ viability would be impacted, the EA draft stated.

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