Summary: This post compares fracking chemical disclosures from the legacy FracFocus system with Colorado’s new, more comprehensive ECMC database for a single well pad: the “Timbro 0101” operated by Verdad Resources. The analysis validates that both systems are reporting on the same fracking events, then sorts the disclosed chemicals into four categories to identify discrepancies. The findings reveal that while FracFocus disclosures are incomplete (missing 15 ingredients), the new ECMC system is also unexpectedly missing five chemicals, totaling over 400,000 pounds. The comparison suggests that even with the new rules, some trade secrets may remain masked and reporting is still not fully comprehensive.
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 “Timbro 0101” operated by Verdad Resources, LLC. 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): | Verdad Resources LLC |
| Operator name (in ECMC): | VERDAD RESOURCES LLC |
| Wellpad name (in ECMC): | Timbro 0101 |
| Wellpad ID : | 468727 |
| County: | Weld |
| Map to wellpad: | Google Map |
| Number of FracFocus wells: | 15 |
| Number of ECMC wells: | 15 |
ECMC disclosure link
FracFocus disclosures
| API Number (and link) | Fracking Start Date |
|---|---|
| 05123510810000 | 2023-12-04 |
| 05123510820000 | 2023-12-04 |
| 05123510830000 | 2023-12-16 |
| 05123510840000 | 2023-12-16 |
| 05123510850000 | 2023-12-04 |
| 05123510860000 | 2023-11-24 |
| 05123510870000 | 2023-12-16 |
| 05123510880000 | 2023-11-24 |
| 05123521660000 | 2023-11-24 |
| 05123521670000 | 2023-11-16 |
| 05123521680000 | 2023-11-16 |
| 05123521690000 | 2023-11-16 |
| 05123521700000 | 2023-11-03 |
| 05123521710000 | 2023-11-03 |
| 05123521720000 | 2023-11-03 |
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 match perfectly or are nearly identical. The only mismatches are water and sand on the FracFocus list but not the ECMC list (which is typical in many ECMC disclosures).
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.
| Ingredient Name | mass (pounds) | Trade Name | number of wells |
|---|---|---|---|
| acrylamide copolymer | 387,037 | Ingredient Container* | 9 |
| acrylamide acrylate polymer | 250,016 | Ingredient Container | 12 |
| hydrotreated distillate | 233,149 | Ingredient Container | 9 |
| inorganic salt | 216,990 | Ingredient Container | 12 |
| alkylbenzene sulfonate #1 | 116,462 | Ingredient Container | 15 |
| alkylbenzene sulfonate #2 | 38,824 | Ingredient Container | 15 |
| ethoxylated alcohols | 31,263 | Ingredient Container | 15 |
| acrylamide polymer | 29,017 | Ingredient Container | 6 |
| ethoxylated alchols | 8,866 | Ingredient Container | 3 |
| modified thiourea polymer | 8,502 | Ingredient Container | 15 |
| inorganic salt #2 | 6,605 | Ingredient Container | 3 |
| ethoxylated fatty acid | 6,605 | Ingredient Container | 3 |
| surfactant | 6,605 | Ingredient Container | 3 |
| fatty amine salt | 6,436 | Ingredient Container | 9 |
| acetate compound | 4,835 | Ingredient Container | 6 |
| oxyalkylated nonyl phenolic resin | 4,487 | Ingredient Container | 15 |
| oxyalkylated phenolic resin | 1,490 | Ingredient Container | 15 |
| polymer | 685 | Ingredient Container | 15 |
| organic salt | 631 | Ingredient Container | 8 |
| ammonium salt | 65 | Ingredient Container | 9 |
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 | 20 | Many unique trade secrets chemicals were reported at this well pad totaling well over a million pounds. Usually we would expect that disclosed “extra” chemicals in the ECMC-only category would correspond to the FracFocus trade secrets. However, in this case, there are more trade secrets than extra ECMC only materials. It seems likely that some trade secrets have not been unmasked in the ECMC disclosures. |
| Shared | 29 | |
| ECMC-only | 15 | This list includes 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 | 5 | One of these chemicals, 14808-60-7 – sand, was expected to be in the ECMC disclosure but was missing. The other 4 are unexpected and total their usage totals over 400,000 pounds. The Colorado law clearly stipulates that all materials must be included in the ECMC records. |
Related disclosures
As of this date, disclosures for 6 other Verdad Resources well pads are similar to the disclosures summarized above in that, they have:
- Several trade secrets in FracFocus that may or may not be 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.
| Location ID | Well pad name |
|---|---|
| 454529 | Arnold 02N-64W-24 |
| 470925 | Onion-Berg-Gourd PAD |
| 483467 | Kiwi 2920 |
| 473534 | Georgene 2828-2833 |
| 481827 | Peanut Fed 3403 |
| 482909 | Fawn 2734-2833 |
Cover art by Becky Mansfield (modified by author)
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