Will Arlington enforce VII 7.01 A6 emission mitigation in our Gas Drilling Ordinance ?

Truman/Cowboy Stadium

Update as of 1/16/2013) ….Chesapeake has drilled the last of the 4 permitted wells near the Cowboy Stadium. The last well to be fracked should be done using natural gas because that Best Available Control Technology (BACT) * exists.

Chesapeake’s failed response on 1/15/2013 reads…“Unfortunately, all the necessary infrastructure isn’t there just yet, and will not likely be in place by the time the next well at the stadium site is hydraulically fractured.”  

T H I S    I S     N   O   T    the answer Arlington breathers deserve !!!!!!!

Will the city invoke their gas drilling ordinance VII 7.01 A6?  “… minimize,so far as practicable, dust, vibration or noxious odors, and shall be in accordance with the best accepted practices incident to drill for the production of gas and other hydrocarbon substances in urban areas. All equipment used shall be so constructed and operated so that vibrations, dust,odor or other harmful or annoying substances or effect will be minimized by the operations carried on at any drilling or production site or from anything incident thereto, to the injury or annoyance of persons living in the vicinity;….Proven technological improvements in  industry standards of drilling and production in this area shall be adopted as they become available if capable of reducing factors of dust,vibration and odor……”

*technology to frack using natural gas info is here ….

http://www.ogj.com/articles/2013/01/apache-would-replace-diesel-with-gas-on-frac-jobs.html?cmpid=EnlDailyJanuary112013

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Another example of Chesapeake NOT drilling responsibly in urban areas is their “Feil-Fail-RESPONSE”** below as to why they will not use Urban Flowback tanks.

Back in August of 2012,  I had zero response for Senator Davis’ staff to file for an Attorney General’s opinion in getting the city to enforce their ordinance to enforce emission mitigation controls during flowback to use pressurized, ventless flowback tanks that is  appropriate for flowback operations in urban areas so as not to use the traditional, OPEN HATCH “industry standard” ones as the red tank is pictured below .

Photo by askchesapeake.com

** How not to answer a question by Chesapeake

—– Forwarded Message —-
From: Julie Wilson <julie.wilson@chk.com>
To: kim feil
Sent: Wed, January 23, 2013 2:03:17 PM
Subject: RE: Last night’s Arlington meeting/follow up request on why Chk doesn’t flowback in pressurized, ventless flowback tanks

Kim -

We choose not to respond to inquiries that are clearly rhetorical, inflammatory, previously addressed, or accusatory in nature.  We have every confidence in the degreed, experienced professionals in our industry, both inside our company and in the cities and regulatory agencies who monitor our activities. When our attempts to share information with you are ridiculed and vilified, we don’t see the point in continuing those efforts. We understand that you disapprove of our industry and our operations, and since no amount of credible science will change your position, there is no point in engaging in argument about it.  

—I NEED HELP!—it seems the FBI does not investigate industrial environmental terrorists that I believe Chesapeake is guilty of in not using BACT in densly populated areas.  Love letters continue for you to read and as my database of how long I have been asking for this….
—– Forwarded Message —-
From: kim feil <kimfeil@sbcglobal.net>
To: Gregory.Lucas@texasattorneygeneral.gov
Sent: Thu, August 9, 2012 1:58:21 PM
Subject: Who can help me enforce a public protections measure to make the city enforce their ordinance?

I am in a panic because they are about to frac 3 wells within a 1/2 mile of my home at the Truman site (310 N Collins St)  near the Cowboy Stadium in Arlington TX starting on August 24th. This is a high density, low income area of workers and renters – some within 600 feet.

While a Green Completion is planned (the gathering line goes in early fall), I am concerned with emission exposures prior to the Green Completion equipment/pipeline where “top flow” fluids will be volatilizing during initial flowback that comes off the open hatch flowback tanks.  Our ordinance states the well may not flow or vent directly into the atmosphere without first directing through a separator OR into a portable tank.  The flaw/loophole with this wording allows the well to flow directly into an open hatch flowback tanks which violates the spirit of the ordinance in keeping VOC’s out of the public airshed.

A company called Vapor Point sells scrubbers for these open hatch flowback tanks and I need help from the Attorney General’s Office to contact our City Manager,  trey.yelverton@arlingtontx.gov and our Mayor,robert.cluck@arlingtontx.gov, to ask them mandate these scrubbers by invoking the gas drilling ordinance VII 7.01 A6 to “… minimize,so far as practicable, dust, vibration or noxious odors, and shall be in accordance with the best accepted practices incident to drill for the production of gas and other hydrocarbon substances in urban areas. All equipment used shall be so constructed and operated so that vibrations, dust,odor or other harmful or annoying substances or effect will be minimized by the operations carried on at any drilling or production site or from anything incident thereto, to the injury or annoyance of persons living in the vicinity;….Proven technological improvements in  industry standards of drilling and production in this area shall be adopted as they become available if capable of reducing factors of dust,vibration and odor……”

Our city inspector could also purchase these scrubbers in advance and keep them in stock for the upcoming flowback and then invoke Article VII 7.01 A6 15 “…If the Fire Inspector believes that it is necessary to take emergency action due to a potential or actual situation that danger to persons and property exists …the Inspector may then employ any…..material which the Inspector deems necessary….Operator shall reimburse the City…”.

 

Our leaders tell us that our dry gas has little VOC’s, but down the road in Colleyville TX, the city funded Titan air study by Modern Geosciences found benzene during flowback from Jan 30 thru Feb 16 2012, to be up to 85ppb which violates the 2 week threshold ATSDR MRL by over 9 times.  A citizen funded air study also found benzene at 54ppb for that same drillsite during flowback.

 

The Arlington flowback videos showing a white cloud wafting off these tanks don’t lie….this stuff is under pressure and volatilizing in our airshed in our neighborhoods. 

 

It is time for Arlington to step it up and set a precedence for mandating best operating flowback procedures in making the operators use scrubbers on these open hatch flowback tanks during well cleanup which is the phase PRIOR to Green Completions.

Sincerely,

Kim Feil

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Lets not forget the recent death of a 21 yr old Colorado flowback worker that died from hydrocarbon poisoning…..

 

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