5,000 lb Reportable Emission Amounts not reasonable in Urban Drilling

Jan 2014 UPDATE Of course no follow up as usual from our Arlington officials, but over a year later (and after working with state rep Diane Patrick)  the city now posts (so far only one)  A Gas Well Incident Report Form where they contacted either and/or the TCEQ/RRC …… but alas so many AFD dispatches occur that do not get reported (unless the citizens do) to TCEQ/RRC/EPA .   Anytime you see, hear or smell something call the EPA Eyes on Drilling National Response Center for 24/7 service at 1 800 424 8802 and they disseminate this down to the TCEQ or RRC level who then contacts the operator for a report.
Reportable Quantities were written in an era of only rural drilling taking place.  Its time to revise the Reportable Quantity rules.…..

“Step 1.B: Determine the reporting threshold for each chemical emitted. The threshold for a chemical is the lowest one that appears in the three following lists. If the chemical does not appear on any of these lists, the threshold quantity is 100 lb.”

Chemical RQ (lbs)
acetaldehyde 1,000(1)
butanes (any isomer) 5,000
butenes (any isomer,
except 1,3-butadiene) 5,000(1)
carbon monoxide 5,000
decanes (any isomer) 5,000
ethanol 5,000
ethylene 5,000(1)
hexanes (any isomer) 5,000
Isopropyl alcohol 5,000
mineral spirits 5,000
nitrogen dioxide 100(3)
nitrogen oxide 100(2)
octanes (any isomer) 5,000
pentanes (any isomer) 5,000
propane 5,000
propylene 5,000(1)
toluene 1,000(1)
Here is the link for land & water RQ spills.
Funny how this list doesn’t include Benzene and so that would then be lowered to 100 lbs as the reportable quantity (I believe 10 pounds is the law for Benzene)…gee 99.9 lbs of Benzene is unthinkable to be released and not reportable in an urban area…1 tsp of Benzene can contaminate around 261,000 gl of water.
I looked at the TCEQ website specifically searching for a Benzene Reportable Quantity and on this link it refers me to the RRC. In searching the RRC website, all I found was the H8 spills report, but no guidlines as to what or how much is a reportable amount.  So 99.9 lbs of Benzene doesn’t have to be reported….in an urbanly, highly densely, populatedly, area for our air, water, & soilshed…..shit!  It was bad enough that this goes on in rural areas that eventually get into our foodchain.
FYI I called Michelle Marak at 512-463-6829 on this RRC report to verify what the reportable amounts were and she said the RRC requires any spill over 5 barrels (which is .555 tonnes or 1,223 lbs of condensate) to be reported which is a different set of rules that the drillers have to follow.
She told me that we (Tarrant County) only had 20 spills since they started keeping the records and that none were REPORTED after 2009…..really?
Here is a home video of the UTA SPILL in 2010….I guess it was under five barrels?

—– Forwarded Message —-

From: kim feil
To: jim.parajon@arlingtontx.gov
Cc: trey.yelverton@arlingtontx.gov; Stuart.Young@arlingtontx.gov; roger.venables@arlingtontx.gov; robert.cluck@arlingtontx.gov; robert.shepard@arlingtontx.gov; Robert Rivera <robert.rivera@arlingtontx.gov>; jimmy.bennett@arlingtontx.gov; michael.glaspie@arlingtontx.gov; lana.wolff@arlingtontx.gov; vote4cparker@gmail.com; sheri.capehart@arlingtontx.gov; kathryn.rowe@gmail.com; Susan Schrock <sschrock@star-telegram.com>; tips@wfaa.com; DJ Zitko – ArlingtonVoice.com <dj@arlingtonvoice.com>; collin.gregory@arlingtontx.gov
Sent: Wed, July 4, 2012 12:11:33 PM
Subject: How can I get access to a report of the incidents at drill sites that your dept or the AFD responds to?

Jim, I should have been requesting open records requests at least by the month or week for Arlington Fire Department responses to our drill sites (50 last year?). I plan on starting to do more open records as a hunting expedition, but to do it daily could be a drain on city resources?  Jim, does your dept. get a report from AFD….what is your communication method between your dept. and the AFD on drilling spills and emission “events”?
I’d like to see that report from last year and I’d to see this info be on line to be made public even if no violation of our ordinance is found.
To say that you will only post those offenses that are found to be in violation of the ordinance is not appropriate because anytime the public hears, sees, or smells something and the city spends money responding to these “events”, we should have access to this info even if it is just nusiance related (which I’ve already emailed our council on how urban drilling violates our nusiance laws).
As an urban drilling watchdog, I cannot do my job effectively without access to this information. I work for free and do provide a service to our community…folks regularly thank me for my work….please help me do my best.
In the recent two emission events (one in May and one in April), I investigated that Carrizo did not report these two emission events to the TCEQ and found out that it was because it was under 5,000 lbs (for most regulated effluents) and was under the reportable quantities amount. Here is a link on what doesn’t get reported that can be likened (on a smaller BTEX scale) with refinery emission events in Port Arthur LA.
The two emission events across from Arlington’s Huntchinson Jr High didn’t qualify as reportable emission amounts (per Carrizo) with the TCEQ, and did not violate the city ordinance, yet had two of our AFD fire trucks responding on one of the events. In the incident report, another truck was called out to follow the white cloud that was almost 3 blocks big wafting around in the neighborhoods. It also stated that one of our gas well coordinators was called to the scene to respond too.
In the spirit of transparency….Jim, please let me know who else can decide what needs to be reported on the city’s drill site web page, and at least share with me the best way to start requesting this info from the open records department.
Kim Feil
The fireworks and parade both were truly spectacular!
Here is a little vid I made of the parade…..

About Kim Triolo Feil

Since TX Statute 253.005 forbids drilling in heavily settled municipalities, I unsuccessfully ran for City Council Seat to try to enforce this. Since Urban Drilling, our drinking water has almost tripled for TTHM's. Before moving to Arlington in 1990, I lived in Norco’s “cancer alley”, a refinery town. It was only after Urban Drilling in Arlington did I start having health effects. After our drill site was established closest to my home, the chronic nosebleeds started. I know there are more canaries here in Arlington having reactions to our industrialized airshed (we have 55-60 padsites of gas wells). Come forward and report to me those having health issues especially if you live to the north/northwest of a drill site so I can map your health effects on this blog. My youtube account is KimFeilGood. FAIR USE NOTICE: THIS SITE MAY CONTAIN COPYRIGHTED MATERIAL THE USE OF WHICH HAS NOT ALWAYS BEEN SPECIFICALLY AUTHORIZED BY THE COPYRIGHT OWNER. MATERIAL FROM DIVERSE AND SOMETIMES TEMPORARY SOURCES IS BEING MADE AVAILABLE IN A PERMANENT UNIFIED MANNER, AS PART OF AN EFFORT TO ADVANCE UNDERSTANDING OF THE SOCIAL JUSTICE ISSUES ASSOCIATED WITH EMINENT DOMAIN AND THE PRIVATIZATION OF PUBLIC INFRASTRUCTURE (AMONG OTHER THINGS). IT IS BELIEVED THAT THIS IS A 'FAIR USE' OF THE INFORMATION AS ALLOWED UNDER SECTION 107 OF THE US COPYRIGHT LAW. IN ACCORDANCE WITH TITLE 17 USC SECTION 107, THE SITE IS MAINTAINED WITHOUT PROFIT FOR THOSE WHO ACCESS IT FOR RESEARCH AND EDUCATIONAL PURPOSES. FOR MORE INFORMATION, SEE: HTTP://WWW.LAW.CORNELL.EDU/ TO USE MATERIAL REPRODUCED ON THIS SITE FOR PURPOSES THAT GO BEYOND 'FAIR USE', PERMISSION IS REQUIRED FROM THE COPYRIGHT OWNER INDICATED WITH A NAME AND INTERNET LINK AT THE END OF EACH ITEM. (NOTE: THE TEXT OF THIS NOTICE WAS ALSO LIFTED FROM CORRIDORNEWS.BLOGSPOT.COM)
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