Category Archives: Water & Fracking


by Rick Casey, with assistance from other members of the Larimer Alliance

Wednesday, October 20, 2021, the COGGC Commissioners heard public testimony during an important hearing: whether to renew the operating license for Wellington Operating Company’s three permits for its RIBs (Rapid Infill Basins), or pits, for another five years. In the end they approved the permits but not before they heard five powerful testimonies from the local community and read numerous comments from the public.

The Larimer Alliance has been aware of Wellington Operating’s (WO) dumping of produced water into RIBS or pits into the Boxelder Creek alluvial for some time and knew the permits for the pits were coming up for renewal this Fall 2021.

The produced water from WO oil field is created when the oil wells pump water from deep aquifers containing the oil. After the oil is removed with Enhanced Oil Recyclers (EORs), the remaining water is either injected back 5,000 feet into the aquifer where it came from, or it is lightly treated and dumped into the RIBs or pits located in northern Larimer County, south of E CR 70 and N CR 11. Wellington Operating estimated two thirds of the total wastewater is injected and one third is dumped into the pits. The pits allow wastewater to enter the groundwater flowing under them to be carried down the Boxelder Creek watershed to the Cache la Poudre River.

This might remind readers of the old saying, “Dilution is the Solution to Pollution” and now, even when we know this pollution never goes away, this concept is still being used as a means of disposing contaminants. To justify this, the industry and governments call this dumping to groundwater a “beneficial use” or “recycling” and “waste minimization” — all euphemisms crafted by industry to conceal their highly negative environmental effects. We believe Larimer County and the COGCC should be describing these pollutants more accurately.

This water is toxic due to the naturally occurring radioactive particles, salty brine, heavy metals, and oil and gas contaminants that are commonly found in it. There are also additional chemicals added to this wastewater to prevent bio-fouling in the pipes which adds to the toxicity of the water. The permit provided details on the process of treatment of this wastewater and included numerous tests for contaminants including for PFAS, the so-called forever chemicals, and one was found in a very small quantity. This triggered the Commissioners to require PFAS testing of this water at least once per year and more often, if any are found.

It is likely more contaminants are in this water but exactly what they are won’t be known unless oil and gas operators are required to have water quality lab tests for others and then required to report them to the COGCC. The industry is self-regulated so operators not regulators take the samples and submit them to labs. Should this be allowed?

The COGCC Commissioners also required WO to notify Larimer County in any future actions after Matt Sura, an oil and gas attorney for Larimer County government, entered the discussion during the hearing and asked that the Commissioners pause the hearing until Larimer County is able to review the permit. The Commissioners declined to consider this request but from now on the County will be informed of any permit action by Wellington Operating. According to the COGCC Director, notification to Larimer County about this permit reissue was not legally required.

The quest continues: where is the data on water & fracking?

My next question was to the Division of Water Resources, at

Dear DWR:

I am trying to find out where the state records are which show where fracking operators get their water, and where that ‘produced water’ ends up. I am most interested in Front Range operators, from Adams County northward.

Finding answers to those two simple questions is proving surprisingly difficult. Neither the COGCC or CDPHE have been able to help me.

I realize the data records may not be structured to answer such a question from the public, since they were perhaps not designed that way to begin with; however, as the political pressures on our water resources intensify, the data will need to be marshalled, somehow, to answer such questions, as times change. If you have any comments on that issue, I’d be interested in hearing that as well.

Best regards,
Rick Casey

The quest begins: where is the data on water and fracking?

This is request I made to the Colorado Department of Water Resources today:

Hello DWR:

I have a report from CO DNR (Dept of Natural Resources?) that writes about water and fracking, circa January 2017. Please see attached.

It refers to a “Colorado Water Diversions table”, and shows a line in the report where there is a breakdown of water use, with one line for “hydraulic fracturing.”

I have tried finding this report on your website to no avail. I cannot remember how I found this report, and it is unfortunate that it does not contain any other identifying information, such as who or what office authored the report.

I am basically a concerned citizen that volunteers for a non-profit, and we are trying to find the answer to two simple questions: 1) how much water goes into fracking? (preferably on a county basis), and 2) where does the produced water go?

I am hoping someone in your office might be able to help me.

Rick Casey


Comment to BOCC 3/16/2021

Dear Commissioners,

Something has come to my attention and I want you to know about it, if you don’t already. I was looking at the wells in Northern Larimer County while on the COGCC website and I found something very concerning. I have added the screen shots below for you. You can see the dotted black line at the border of Larimer County and Weld County and the yellow areas where Fort Collins and Wellington are located on this map. It shows many lakes and ponds located in northeast Larimer County. Many of these lakes, I believe, are used for irrigation. They’re also used by livestock and wildlife and the groundwater supports the huge cottonwoods in this area.

The next screen shot is the same location but this time I selected the “Specified Area CDPHE Regulation 42” option and this is what I saw.

The CDPHE Regulation 42 Specified Area was defined in 1999 by the Colorado Water Quality Control Commission (WQCC) and the Colorado Oil and Gas Commission (COGCC). They ruled that the ground water in this area was, in their words, “a waste” and not expected to be used in the future for domestic or agricultural purposes.  This ruling allows the exclusion of the groundwater throughout this entire area from even basic protection from pollutants associated with the exploration, development, or production of crude oil and natural gas.

According to this ruling, Tables 1- 4 of the Basic Standards for Ground Water, 41.0 do not apply for this area. Additionally, the groundwater organic chemical standards included in Table A of Section 41.5.C.3 of the Basic Standards for Ground Water (5 CCR 1002-41) for benzene, toluene, ethylbenzene, xylenes, and benzo(a)pyrene do not apply to oil and gas producing formations within this specified area. Then, last year during the pandemic the Water Quality Control Commission published the following ruling:


This new ruling is the same old ruling from 1999 but in this one, the Water Quality Control Commission attempts to justify this new ruling by saying this only applies to certain geological formations in the ground and not surface water.

What this ruling did was open this entire area to be used as a dumping ground for toxic produced water that comes out of fracked wells. There is no guarantee that the produced water these companies are injecting into wells in this area are not connected to surface water somewhere. Concrete used in these wells fail often so there is a high potential for aquifirs in the area to be contaminated.

Commissioners, I implore you to question these rulings and demand that this polluting of our natural resources is stopped. How can we allow these beautiful lakes, wetlands, and grassland areas to become permanently polluted with toxic hydrocarbons, radioactive materials and other harmful compounds?

Thank you so much for your time and attention.

Lori Brunswig

Fort Collins, CO

(Please see the current ruling on page 175 at the following link.)