Hi and thank you so much for your commentary! Your participation is highly appreciated and you bring up some very interesting details! The information you provide for this specific Chevron site is informative, and we appreciate the fact that some land application sites are more thoroughly monitored than other complementary disposal operations, such as pits for the wastewater. If you take a moment to explore the map above, you will see that we do in fact differentiate Wastewater Pits from Centralized E&P Waste Management Facilities, and while Land Application sites are still a concern, they are not actually included in the map. There are 144 other land application sites, besides this Chevron facility near Rangely, and this represents a legitimate threat to groundwater and surface water resources. When we consider the risk posed by all these land applications of exploration and production (E&P) wastes as defined by the 900 series rules (COGCC. 2008. https://cogcc.state.co.us/reg.html#/rules), we address them together with other inadequate waste disposal operations such as pits. This is because they pose very similar threats and contaminants are transported along the same pathways. We understand completely that these processes are different, and are happy to hear that this Chevron facility calculates the amount of carcinogens and other volatiles mixed into the topsoil. Unfortunately both approaches, burying drilling wastes or allowing produced waters to percolate and evaporate from the surface do not adhere to the same standards met by operators in many other states. The focus of this specific piece of research is the threat to groundwater. Impacts to groundwater, surface water, soil, air quality and wildlife has all been documented from land application sites as well as pits. Many states have eliminated these antiquated techniques of burying oil and gas wastes, regardless of the E&P process that generates the waste or wastewater. It is true that some sights pose a larger risks than others, but in all cases these wastes contain known carcinogens and other toxics including TENORM and heavy metals.

Example – under the section “Centralized Exploration and Production Waste Management Facilities”, second paragraph, “As can be seen in the Figure 2 to the right, land application sites are little more than farms that don’t grow anything, where wastewater is mixed with soil. Groundwater monitoring wells around these sites measure the levels of some contaminants. Inspection reports show that sampling of the wastewater is not usually – if ever – conducted. The only regulatory requirement is that oil is not visibly noticeable as a sheen on the wastewater fluids in impoundments, such as the one in Figure 3 below, operated by Linn Operating Inc., which is covered in an oily sheen.”

In fact, the Chevron facility shown (near Rangely) is a land treatment facility for hydrocarbon waste ONLY. WasteWATER is not allowed, as salt inhibits biodegradation process. The author clearly doesn’t understand the difference between a treatment option for oily sludges and an evaporation pit for wastewater (as he lumps together the land treatment example with the disposal pit example). Further,, in the case of the Chevron facility, the applied oily waste is routinely sampled and used to calculate air emissions to comply with the permit conditions. Farm equipment is used to till under the waste within a couple of hours of application to minimize emissions and the groundwater monitoring wells are inspected quarterly. Sampling is conducted if any groundwater is found, but this facility sits atop 2000 feet of Mancos shale. The only groundwater is perched (isolated) atop the shale layer and there has been no groundwater detected in the monitoring wells since they were installed.

Do your homework. I understand you have legitimate concerns and the industry does need to be accountable. But articles such as this significantly oversimplify complicated issues and damage your credibility, making is easy to reject, out of hand, any evidence or argument (regardless of merit) presented by your organization.