Summary: This post compares two databases for fracking chemicals by looking at a single well pad operated by Kerr McGee Oil and Gas (reported as Anadarko in FracFocus). The primary conclusion is that FracFocus disclosures are incomplete. For this one site, Colorado’s new ECMC system revealed 17 additional chemicals, including known hazardous materials like acrylamide and formaldehyde that were not listed in FracFocus. We also found that this pattern of significant gaps in FracFocus reporting was consistent for similar disclosures across 20 other well pads from the same operator.
In our post, “Colorado’s New Rules vs. FracFocus: What a Difference Data Makes“, we outlined the major differences between the legacy FracFocus disclosure system and Colorado’s new, more comprehensive ECMC database. We hypothesized that comparing these two data sources for the same fracking job would reveal significant gaps in the public’s access to chemical information if limited solely to FracFocus.
Here, we examine the disclosures for one well pad, the “Labrisa 11-35HZ” operated by Kerr McGee Oil and Gas (“Anadarko” in FracFocus; parent company: Occidental). This post is one in a series of deep dives into individual well pads.
Wellpad details and disclosure links
| Parameter | Value |
|---|---|
| Operator name (in FracFocus): | Anadarko Petroleum Corporation |
| Operator name (in ECMC): | KERR MCGEE OIL & GAS ONSHORE LP |
| Wellpad name (in ECMC): | Labrisa 11-35HZ |
| Wellpad ID : | 485208 |
| County: | Weld |
| Map to wellpad: | Google Map |
| Number of FracFocus wells: | 10 |
| Number of ECMC wells: | 10 |
ECMC disclosure link
FracFocus disclosures
| API Number (and link) | Fracking Start Date |
|---|---|
| 05123522360000 | 2024-05-05 |
| 05123522370000 | 2024-05-05 |
| 05123522380000 | 2024-05-05 |
| 05123522390000 | 2024-05-05 |
| 05123522400000 | 2024-05-05 |
| 05123522410000 | 2024-05-24 |
| 05123522420000 | 2024-05-24 |
| 05123522430000 | 2024-05-24 |
| 05123522440000 | 2024-05-24 |
| 05123522450000 | 2024-05-24 |
Is the Comparison Valid?
Before we analyze the chemicals, we need to confirm 1) that we are looking at the same fracking events in both datasets and 2) that the brand-named products are the same in both datasets.
Details of date comparisons
The figure below show the dates of record for each well in these disclosures. The “spud” date is the first date of drilling. Also shown are the “JobStartDate” for FracFocus disclosures and “Downhole commencement date” for the ECMC disclosures. We use these data to verify that the FracFocus and ECMC disclosures are reporting on the same fracking event.
The ECMC and FracFocus date align exactly.
Details of product comparisons
We compare the lists of product names to ensure that the fracking chemicals in the disclosures are indeed from the same fracking events.
Several product names perfectly match. Mismatches: 1) Water and sand are on the FracFocus list but not the ECMC list (which is typical in many ECMC disclosures). 2) The ECMC name “Al1-7” and “Y007” are very close matches to FracFocus names and likely are due to shortcuts or typos. 3) H2PRO is a product that uses Chlorine dioxide (CLO2 from the FracFocus list). 4) HCL-15 and 7.5% HCL are similar products.
We conclude that these product names are referring to the same fracking events.
Validation summary:
Because the reported start dates and the product names for the operation align, we can confidently proceed with a direct comparison of the chemical lists disclosed in each system. The FracFocus chemical lists have been aggregated to match the pad-level reporting of the ECMC.
The Four Categories of Chemical Data
Our analysis sorts the reported chemical ingredients into four distinct categories. This framework helps us isolate exactly what new information the ECMC system provides and highlights holes in the ECMC disclosures.
Trade Secrets
Trade secrets are only allowed in FracFocus. Because the ECMC data must report all chemicals, we expect any trade secrets in FracFocus to have a corresponding entry in either the “ECMC-only” or the “shared” lists.
Trade secret reports
This table lists all trade secrets, by unique ingredient name, in the FracFocus data for this well pad.
| IngredientName | mass (pounds) | TradeName | number of wells |
|---|---|---|---|
| heterocyclic aromatic quaternary surfactant | 3,709 | Y007-FB | 10 |
| aromatic ketone compound | 2,472 | Y007-FB | 10 |
| alcohol ethoxylate propoxylate | 9 | AI1-7 | 10 |
Shared Chemicals
The baseline list of ingredients that are present in both the FracFocus and ECMC disclosures.
Details of shared chemicals
ECMC-Only Chemicals
These are ingredients that appear only in the new ECMC disclosure. These represent the new information, likely including previously unmasked trade secrets and other chemicals not required on a product’s Safety Data Sheet (SDS).
Details of ECMC-Only chemicals
FracFocus-Only Chemicals
These are ingredients that, counter to our hypothesis, might appear only in the FracFocus disclosure. Finding chemicals in this category would be a significant anomaly worth investigating.
Details of FracFocus-Only chemicals
Summary
| Category | Number of materials | Implications |
|---|---|---|
| Trade secrets | 3 | Three unique trade secrets chemicals were reported at this well pad totaling about 6,000 pounds. We expect that they are disclosed, unmasked, in the ECMC-only data or in the shared data. |
| Shared | 13 | |
| ECMC-only | 17 | This list includes several known hazardous materials (acrylamide, methanol, ethylene oxide, formaldehyde) as well as many materials for which little is known about their hazard profiles. This large number of chemicals implies that FracFocus disclosures are woefully incomplete. |
| FracFocus only | 3 | One of these three, 69011-36-5, is unexpected and is used at over one ton. The Colorado law clearly stipulates that all materials must be included in the ECMC records. On the other hand, 14808-60-7 – sand, was expected to be in the ECMC disclosure but was missing. The third “chemical” on this list refers to a FracFocus record that marks unreported, “inert” chemicals (see figure below). We expect that these “inerts” make up part of the “ECMC-only” list. |
Related disclosures:
As of this date, disclosures for 20 other Kerr-McGee well pads are similar to the disclosures summarized above in that, they have:
- A handful of trade secrets in FracFocus that are likely disclosed in the ECMC reports.
- A long list of chemicals that appear only on the ECMC disclosures, implying a significant deficit in the FracFocus disclosures.
- A short list of chemicals that should be in ECMC but are not.
Search:
| Location ID | Well pad name |
|---|---|
| 329899 | Camenisch 10-33HZ |
| 336383 | Moser Fed 3-21HZ |
| 432444 | Wishbone PAD A |
| 434750 | Wardell Fed 13-7HZ |
| 481941 | Charlene Nelson 12-34HZ |
| 482983 | Swartz 2-4HZ |
| 483324 | Rainbow 24-9HZ |
| 483325 | Blue Chip 6-22HZ |
| 483362 | Hethcock Fed 6-5HZ |
| 484136 | Land Fed 10-29HZ |
| 485056 | Schmerge 9-4HZ |
| 485057 | Vista 13-16HZ |
| 485209 | Lizzy 8-36HZ |
| 485278 | Salazar 5-20HZ |
| 486288 | Rademacher 14-30HZ |
| 486289 | Clover 2-29HZ |
| 486291 | Alfalfa 8-20HZ |
| 486605 | Acacia 13-17 |
| 487050 | Hickory 10-34HZ |
| 488186 | Larkspur Fed 4-32HZ |
Cover art by Becky Mansfield (modified by author)
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