While I found it needed a hell of a lot more work in Air Quality Protections, the industry came out in full friggn’ force last night to oppose the changes in our woefully inadequate ordinance. Although only given two minutes to speak, I did get a quote in the Star Telegram, http://www.star-telegram.com/2011/11/01/3492400/arlington-council-delays-vote.html
A few months ago at the Tierre Verde breakfast meeting, Councilwoman Capehart expressed the need for a neighborhood meeting even for those that do not own minerals. This needs to occur before the SUP. At this meeting, city staff should inform the public of the exemptions that the oil and gas industry has.
Per the American Progress.org, hydrofrac’n is exempt from the Safe Drinking Water Act.
Flooding has been a problem for at least one Arlington drill site and folks need to know that drillsite storm water run off is exempt from the Clean Water Act.
The Clean Air Act of regulating aggregate, small sources of air pollutants do not apply to the industry either, so when you see a drill site at each city block, know that we are NOT protected from cumulative, multiple emissions at the state or federal level.
City staff needs to inform the public and school officials that the industry is exempt from reporting toxic emissions in the Toxic Release Inventory, and that the waste deposal is exempt from control of the Resource Conservation & Recovery Act.
And they should know that the industry enjoys broad, categorical exclusions from comprehensive, environmental statements by the National Environmental Policy Act.
But most importantly, they need to know that oil and gas is exempt from being defined as hazardous substances by the Comprehensive Environmental Response, COMPENSATIONAL & LIABILITY Act.
Current regulations allow public risk as high as 4 people per thousand. The EPA aims to get that risk down to 4 in one hundred thousand. But their safeguards will only apply to major source sites which exempts the majority of our urban sites via the self policing Permit By Rule. This is why we must have a strong local ordinance to safeguard the public.
TexasStatutes – Section 253.005 forbids drilling in heavily settled municipalities. The mechanism of how urban drilling is legal needs to be stated in the heading of the new ordinance.
Our air quality is quickly deteriorating and we need to push for NG vehicles to quickly replace the diesel truck fracking traffic to reduce our overall benzene exposure.
TCEQ says our Barnett Shale has less than half of a percent (.005) of benzene, and Chesapeake says it is .001. By now council has seen the TCEQ UTA infrared camera (invisible hydrocarbons) videos. Since IR camera’s turn on at 10 million parts per billion VOC’s, multiply that by .001 and that puts our point source dry gas benzene exposure starting at 10,000 ppb before it wafts to the fence line breathers. For those beyond in the fall out zone, they…we… are at the mercy of humidity, wind speed and wind direction as to who gets repeated doses.
Article 7 sect 7.01
A, 15. enacts a lein against the working interests. We need to include the mineral holders at their percentage stake too in reimbursing the city.
A,16. Gas lift Compressors need to be electric. I am working with TCEQ to find the root cause of the newer odors and UTA has recently gotten lift compressors for their aging wells.
A, 23. Rigs Demand electric drilling rigs. Use back up diesel generation on generators in case of a power outage.
A, 30.Vapor Recovery Units are needed during the frac’n stages where huge methane losses escape. The “EXCAPE” device written about on globalmethane dot org prevents 83% of emissions, returns additional net profit, and reduces worker and resident exposures by 84%.
A, 32. a) 1. In covering a well bore after frac’n and before the x’mas tree, require a Blow out Preventor.
B, WellSetBacks SouthLake has 1,000 ft, and the FWLeague of Neighborhoods suggested a 3,000 ft setback to FWISD.
G, Closed Loop Mud Systems is a misleading term because a slide show from a 2008, District 2 Town Hall Meeting showed an uncovered mud container-let’s correct this.
If Green Completions are the industry standard, then they shouldn’t mind us mandating it so we have protection from the 2.nd tier drillers.
Article 7, Section 7.01
H Compressor Stations ….we should prohibit large, line gas fired compressors because they require high bleed pneumatics (Dr Melanie Sattler PE). Low to no bleed pneumatics should be mandated.
As the ERG, Ft Worth air study recommended, catalysts and/or catalytic convertors should also be standard.
Our current compressor station should require back up generators to kick in if we lose power so that we don’t have another multiple drill site emission event like back on April 12.
ANY engine, compressor or generator (except back up generators) on ANY type padsite should not be fueled with cheap, on-site, unprocessed gas because raw, unpurified gas contains more SMOG forming, nonmethane VOC’s such as formaldehyde, & benzene.
To reduce benzene, mandate glycol dehydrators to run at 200 psi and not 900 psi. We hear so often that our dry gas has less VOC’s than wet gas. Please UNderstand that we have by design UNknown, UNconventional shale, pre-production toxic emissions. Arlington should ask Pantego & DWG to help pay for air testing to specifically get at this information before approving this new ordinance.