Marathon’s well near Grayling: a ‘test’ or a ‘nightmare’?

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by Ellis Boal

Chance discovery

One day in August I drove to Crawford County to take a look at Marathon Oil’s recent activities along King Road in Beaver Creek Township, which is near Grayling.

State Beaver Creek 1-23 HD1, a horizontal frack well in the state forest, has been producing on a pad there, tapping the nearly-two-mile-deep Utica-Collingwood shale for some time.

State Beaver Creek 1-23 HD1, on August 15. Photo: Ellis Boal

In late July Marathon applied for a second horizontal frack well on the same pad, named State Beaver Creek 1-14 HD1, which would explore into the Detroit River formation, about a mile shallower than the Utica-Collingwood.

This is the first high-volume frack well to explore in this formation in Michigan.

Not much was happening that day on the pad. But previously I had noticed an unusual feature on the plat accompanying the application for the new well, a half-mile away. It was labeled “State Beaver Creek D4-11″. The nomenclature is not typical for Michigan wells and no operator name was given. I thought it might be a processing facility of some kind.

D4-11

D4-11, still a forest on August 15. Photo: Ellis Boal. Click for close-up.

I didn’t see a direct two-track through the forest between the wellpad and D4-11, so I drove around and found an old one leading to the spot where it was supposed to be. There was nothing but trees, and a few scattered stakes and flags. No permit was posted. Nothing indicated that something big was about to happen.

A week later, in a quick turnaround time DEQ issued the permit for State Beaver Creek 1-14 HD1.

In September I inquired of DEQ what was going on with D4-11. On September 18 DEQ tech Kelley Nelson wrote that it is a well, not a processing facility. It was regulated under part 625 of the Michigan environmental law. Therefore, she said, it was a totally confidential operation. I asked if that meant the permit number, and even the fact whether the well was permitted, were unavailable. She answered:

You are correct. Nothing is available for any part 625 test well. It is confidential for 10 years.

Well, “nothing” was not really the whole truth. Part 625 regulations required Marathon to send the first page of its application to Beaver Creek Township, “post the permit in a conspicuous place” at the surface location until drilling is completed, and post a “conspicuous” sign near the wellhead showing the permit number.

D4-11, a/k/a the “science well,” under construction on August 26. Photo: Gary Cooley.

Obtained publicly from the township, the first page of the application tells us: Marathon posted a conformance bond of $33,000, the well is vertical, sour gas is expected, the intended total depth is 4700 feet, and the target formation is the Amherstburg. This is a fossil-bearing non-shale formation in the Detroit River group, the same formation being explored by State Beaver Creek 1-14 HD1. Vertically, D4-11 is just 300 feet deeper.

Marathon refers to D4-11 informally as a “science well.”

I visited again on September 20. This time there was a nearly-200-foot drill rig there, operating with a loud hum. The rig name, Ensign 161, was prominent on the side.

I was wearing my letsbanfracking t-shirt. Three workers came out. I identified myself and we chatted. They were from out of state. I asked who was the supervisor. They didn’t know, they said.

Later toward midnight I drove by again, this time staying on King Road. Through 100+ yards of trees I could hear the hum. Over the tree line I could see lights on the rig.

D4-11, operating on September 22. Photo: Gary Cooley

Two days later Gary Cooley, who has a home a little over a mile from D4-11, visited and took pictures of the rig in operation.

FOIA request

On September 22, I sent DEQ a formal FOIA request asking for all its documents on the facility. DEQ denied it on October 1, citing section 8 and section 9 of part 625.

But section 9 only says that the application and permit are “confidential in the same manner as provided for logs and reports on these wells.” Section 8 says “Logs on brine and test wells shall be held confidential for 10 years after completion.” It adds that “logs” — but not “reports” — can be held confidential even longer, forever.

Marathon’s application, permit, and pre-drilling correspondence with DEQ are not “logs.” So according to these sections, they were not confidential until the well was “completed.” And according to part 625 rules, completion was not until the well reached its “permitted depth or the [DEQ] has determined drilling has ceased.” Obviously, D4-11 was not complete on September 20 or 22. Ensign 161 was still there, and working.

So DEQ should have produced the application, permit, and all records other than logs.

Exploring for gas and oil

On October 2 I visited again. A different worker came out to say hello. He said his name was “Trace” and he was the Marathon safety man. Asked how long the rig would be there, he didn’t know and said they were hoping to find gas or oil. He gave the card of his boss in Houston, in case there were further questions.

A brief internet search showed that earlier this year Ensign 161 was active at Marathon wells in three different counties of western North Dakota. Fracking for oil there is big business.

Trace’s information, Ensign 161’s design and history in frack country, and D4-11’s exploration in the Detroit River group all mean there is a second reason the well information is not confidential. By its title, part 625 only regulates “mineral” wells. Mineral wells include so-called “test wells.” A test well determines the presence of a “mineral, mineral resource, ore, or rock unit,” or obtains data related to “mineral exploration or extraction.” Exploratory test wells look for “an orebody or mineable mineral resource.”

Oil and gas are not “minerals”

Part 625 does not define “mineral.” But in ordinary English minerals are understood to be hard, crystalline, and inorganic. They are extracted by mining.

Gas and oil are extracted by drilling. They are not in DEQ’s list of Michigan minerals. There are no minerals of any kind in Crawford County, according to the list. Anyway, the idea of looking for a mineral in a 4700-foot hole is ridiculous.

Cooley’s nightmare. Photo: LuAnne Kozma. Click for close-up.

Rules under part 625 say if a mineral well encounters oil or gas of any value, the operator has to stop and apply for a separate permit under part 615. This is the part of the law that covers exploration for gas and oil. Part 615 part makes no mention of targeting minerals. It specifically does not apply to “mine and quarry drill and blast holes.”

Part 615, not part 625, was the part under which DEQ granted the “exploratory” permit given for State Beaver Creek 1-14 HD1. As an exploration well for gas and oil, D4-11 should have been permitted if at all under part 615, not part 625.

Whats’ the difference? A big one is that confidentiality under part 615 is quite limited. Logs and other data are confidential only for 90 days after completion and then only if the operator requests confidentiality. All other documents, including applications, permits, and pre-drilling correspondence, are routinely made public to me or anyone else at any time. The same is true of logging and production data after the 90 days has passed, or even before 90 days if the operator did not request confidentiality.

Another difference is that part 625 has no rules prohibiting nuisance noise. Part 615 does.

What will D4-11 do to the countryside?

Part 625 rules allow for horizontal mineral wells, though fortunately this well is vertical. The rules also allow for acidizing, perforating, and fracturing.

As mentioned, so far only the first page of Marathon’s application for D4-11 has been made public. Applications typically run to 50 or 100 pages. The full application had to include an environmental impact assessment.

DEQ’s form for that required Marathon to identify distances to nearby water wells and other human-made features, and wetlands, surface waters, and endangered species. Marathon should have stated if high-volume fracking will be done in which case it should have specified the water volumes and a water assessment, and identified at least some of the chemicals. It should have explained how muds, cuttings, pit fluids, and brines would be disposed. It should have given details about any flowline or other facilities on the pad, and explained how it would deal with soil erosion and sedimentation.

Cooley and Ban Michigan Fracking are appealing DEQ’s refusal of D4-11 information except for the logs. Ninety days after completion the logs will be requested too. A monster operation like this is a matter of public concern. People birding, hunting, or snowmobiling in the forest are entitled to know what DEQ knows, including the environmental effects and everything else.

Separately, On October 8 I wrote the Marathon boss asking him to confirm Trace’s statement that D4-11 was looking for gas and oil, and provide a copy of the “application [and] permit.” A week later a PR flack wrote back confirming a permit was issued but refusing to send any documents.

D4-11, October 16. Photo: LuAnne Kozma.

Lighting the heavens

LuAnne Kozma (the director of Ban Michigan Fracking and the Committee to Ban Fracking in Michigan) and I visited the site again on October 6, at twilight. Ensign 161 was lit up. She recorded the sounds and pictures in the video above.

On October 16 we visited the last time. Drilling was complete. The pad was quiet and empty, a gash in the forest with a blowout preventer at the center. No sign displayed the permit number, “conspicuously” or at all.

Ensign 161 had moved a half-mile to the pad of 1-14. It was drilling there in the same Detroit River formation.

The rig is expected back at D4-11 soon, after Marathon runs the numbers. It cost millions to cut the trees, excavate the pad, and bring in the rig. The company won’t want to walk away empty-handed. And next time the bore would not just be vertical. It could be aimed right at Cooley, his nightmare.


Marathon Oil makes its move with new Michigan frack well

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By Ellis Boal

Marathon Oil applied for a horizontal frack well in Michigan this past July, its first since buying out Canadian frack company Encana’s Michigan frack wells and permits last year and becoming the biggest potential fracker in the state.

Marathon acquired 430,000 acres of state leases from Encana. At the October auction of the Department of Natural Resources (DNR) it added 148,000 acres, and 53,000 more this May. That works out to nearly 1000 square miles of leases under state land. The number does not count private leases it may also own.

The Department of Environmental Quality (DEQ) granted permit # 61130 unusually quickly, on August 21.

Stake and flag for Marathon’s applied-for State Beaver Creek 1-14 HD1 in Crawford County. In the background is the blowout preventer for the existing State Beaver Creek 1-23 HD1. Click and then click again to enlarge. Photos by Ellis Boal, 8/15/15.

Till now Marathon has kept its plans under wraps.

The 80-page application is viewable and downloadable here.

Named “State Beaver Creek 1-14 HD1,” the well, located in Crawford County, would descend to a true vertical depth of 4400 feet into what is called the “Detroit River” formation. This is a Devonian-age rock composed of a mixed series of carbonates, evaporites, and sandstones. It is shallower than the record-breaking Utica-Collingwood frack wells drilled in the area by Encana in 2012. Horizontally in the Detroit River formation, the bore would then head south 5255 feet.

It would be an exploratory well. The surface hole is said to be 55 feet south of an earlier Beaver Creek wellhead on the same pad, named “State Beaver Creek 1-23 HD1,” which is now producing.

Encana’s application for the earlier well cited 350,000 barrels of water, or 14.7 million gallons, as the amount it would use for fracking.

Marathon’s surveyor was Dean Farrier. He claims to moonlight as a “biologist.” In January 2013 he prepared an environmental impact assessment for the gathering line for the earlier Beaver Creek well. Asked by the Public Service Commission to demonstrate the efforts and resources he used to write the assessment, he said he “conducted a thorough onsite survey of [the] pipeline route for the presence of protected species” including what he called “Kirkland’s” warblers.

The claim is ridiculous. He didn’t pay attention in the biology classes. They are “Kirtland’s” warblers. At the time of his survey they were actually 1000+ miles south, wintering in the Bahamas.

Kirtlands are beautiful, popular, and endangered birds, for which a local community college is named.

Marathon’s application says the new well may pass through sour gas (H2S) zones. H2S is lethal. The application includes a 30-page “contingency plan” for dealing with H2S. If there is an uncontrolled release, the extreme recommended solution is to ignite the well via an upwind approach, wearing self-contained breathing apparatus, using a meteor-type flare gun and a safety rope attached to a backup responder, with a quick retreat path available. After ignition, H2S converts to sulfur dioxide which is also highly toxic, according to the contingency plan.

The new well will have a permanent water well. The environmental impact assessment of the application says volume of frack water will be “1.815 gallons.” On a later page the application says “1,815,000 gallons.”

Waters Landfill

The Waters landfill in Crawford County. Photo by LuAnne Kozma.

Cuttings and muds will be disposed at Waste Management’s nearby Waters landfill.

The chemical constituents of the frack fluid are said to be: water, hydrochloric acid, crystalline silica quartz, tributyl tetradecyl phosphonium chloride, hemicellulase enzyme, propargyl alcohol, methanol, hydrotreated light petroleum distillate, alcohol C12-16 ethoxylated, ammonium chloride, naphthalene, ethanol, heavy aromatic petroleum naphtha, and guar gum.

The public health study of the University of Michigan’s Graham Sustainability Institute identified three of these as particularly concerning:

  • methanol (cardiovascular, dermal, hepatic, neurological, irritant/corrosive)
  • hydrotreated light petroleum distillate (carcinogen, irritant/corrosive)
  • silica (dermal, ocular, respiratory).

Marathon also filed an application for a pooled 800-acre spacing unit. It notes there are numerous critical unknowns with the Detroit River formation in this area. These include reservoir pressure, permeability, porosity, hydrocarbon saturation, and in-situ rock stresses. This well would be the first in the drilling unit.

Marathon paid a $300 application fee.

Marathon welcomes the public

   

Photos by Gary Cooley, 9/5/15.

Photos by Gary Cooley, 9/5/15.

As it was assembling equipment to start drilling the new well in early September, the company put this sign up on the site. It says:

Photographing or otherwise recording this facility or its operations is prohibited without written consent from the company.

The sign adds “Access to this facility is limited to authorized personnel only.” It refers to the area as “company property.” It claims the right to search the “person, personal property, and vehicle” of any visitor to the premises. It adds that anyone “suspected” of violating a “company policy” may be “referred to law enforcement officials.”

But the state owns the property. Marathon has a permit to drill, but it does not have a permit to exclude visitors. People have the right to walk in the state forest, carry a camera, and use it. The DNR manages it and its policy is:

Michigan’s forests are of incredible value to the people, animals, plants, and other organisms that live in and travel through the State.

On September 22 Ban Michigan Fracking demanded of Hal Fitch, DEQ’s supervisor of wells, that DEQ order the company to paint over the offending language. Fitch refused. He wrote back saying there was “no evidence of any violations of either Part 615 or Part 625“, the laws he administers.

Under current Michigan law, DEQ’s job is to “foster” the industry “favorably.”

The Graham Institute completed its intensive two-year report this month on high volume hydraulic fracturing (HVHF) in Michigan. One thing in the executive summary that it got right was a criticism of the DEQ’s current policy involving the public and well permitting. It said the policy “hinders transparency about HVHF operations in the state.” Fitch’s response proves the point.

The next day BMF made the same demand of DNR. DNR promptly sent staff to the pad and told the foreman to take down the sign.

The threatening bullying sign had been up, unchallenged, for three weeks.