Summary: This post provides a direct comparison of hydraulic fracturing chemical disclosures for the “Fox Creek 25 SE” well pad (466299) of Bison VI, analyzing data from the legacy FracFocus registry against Colorado’s new, more comprehensive ECMC database. The analysis reveals significant gaps in the FracFocus data, identifying 15 chemicals—including hazardous materials like methanol and acrylamide—that were reported in the ECMC system but absent from FracFocus. This case study highlights the striking incompleteness of FracFocus disclosures and the critical new information provided by the ECMC system.
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, “Fox Creek 25 SE,” operated by BISON IV OPERATING 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): | Bison IV Operating LLC |
| Operator name (in ECMC): | BISON IV OPERATING LLC |
| Wellpad name (in ECMC): | Fox Creek 25 SE |
| Wellpad ID : | 466299 |
| County: | Weld |
| Map to wellpad: | Google Map |
| Number of FracFocus wells: | 5 |
| Number of ECMC wells: | 5 |
ECMC disclosure link
FracFocus disclosures
| API Number (and link) | Fracking Start Date |
|---|---|
| 05123503680000 | 2024-11-14 |
| 05123503690000 | 2024-11-22 |
| 05123503710000 | 2024-11-15 |
| 05123503730000 | 2024-11-22 |
| 05123503740000 | 2024-11-22 |
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.
One well drilled in 2020 (05-123-50372) has apparently not been fracked. For the other 5 wells, the ECMC and FracFocus dates 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. Mismatches include: 1) water is on the FracFocus list but not the ECMC list (which is typical in many ECMC disclosures), and 2) the product “MBC 516” is present only on the FracFocus disclosures. This product, by Nashville Chemical, is a biocide and was reported on all 5 FracFocus disclosures.
We conclude that these product names are referring to the same fracking events.
Validation summary:
With the exception of the one additional product name on FracFocus disclosures, the reported start dates and the product names for the operation align. Therefore, we can proceed with a direct comparison of the chemical lists disclosed in each system, keeping that one discrepancy in mind. 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 |
|---|---|---|---|
| no hazardous ingredients** | 498,966 | Other Chemical(s)* | 5 |
| alcohol ethoxylate propoxylate | 34 | Other Chemical(s) | 5 |
** This record of “no hazardous ingredients” is still called out as “proprietary” in all the FracFocus disclosures.
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 | 2 | Two trade secrets “types” were recorded in the FracFocus disclosures. One type accounted for almost half a million pounds. |
| Shared | 24 | |
| ECMC-only | 15 | This list includes known hazardous materials (acrylamide, methanol) and others for which little is known about their hazards. We expect that the trade secrets that account for half a million pounds are unmasked in this list, but cannot confirm that. This large number of chemicals implies that FracFocus disclosures are strikingly incomplete. |
| FracFocus only | 2 | Although they were of relatively small mass, these two materials were unexpected. The Colorado law clearly stipulates that all materials must be included in the ECMC records. It is possible that one or both of these may be components of MBC 516. |
Related disclosures
As of this date, disclosures for at least 12 other Bison VI well pads are similar to the disclosures summarized above in that, they have:
- A handful of 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 |
|---|---|
| 485676 | Ce PAD |
| 485812 | Dittmer PAD |
| 485658 | Boomhog 8-59 3 |
| 484554 | Wade 8-59 17 PAD |
| 455576 | Harlequin North PAD |
| 477204 | Ancona PAD |
| 455365 | Shoveler PAD |
| 481938 | Eider North PAD |
| 454592 | Cinnamon Teal PAD |
| 444377 | Fox Creek 28 SWSE |
| 487296 | Fiscus 23 |
| 453399 | Mottled PAD |
Cover art by Becky Mansfield (modified by author)