Dec 7 2015 update Kinder Morgan (midstream) is having issues $$$...hope Crestwood doesn’t cut corners…left council/Stuart Young an email warning.
From: kim feil <firstname.lastname@example.org>
To: Stuart Young <email@example.com>
Cc: Michael Glaspie <firstname.lastname@example.org>; Robert Shepard <email@example.com>; Robert Rivera <firstname.lastname@example.org>; Lana Wolff <email@example.com>; Charlie Parker <firstname.lastname@example.org>; Jimmy Bennett <email@example.com>; Sheri Capehart <firstname.lastname@example.org>; Kathryn Wilemon <email@example.com>; Jim Parajon <firstname.lastname@example.org>; Trey Yelverton <email@example.com>; Jeff Williams <firstname.lastname@example.org>
Sent: Monday, December 7, 2015 2:45 PM
Subject: Kinder Morgan(piplines/compressor stations) and the Lake Arlington Compressor Station/Crestwood
Oct 2015 update I found this May 2012 report that shows Lake Arlington’s formaldehyde numbers entitled….
Below is a dizzying display of (ongoing) ownership, name changes, and acquistions recorded for you….THE REASON I learned about the history of our Lake Arlington Compressor Station is because I still want to know if the high formaldehyde found was an anomaly or part of an intentional act that backfired (caused blowdown emissions?) Face it, if you know your facility is about to be air tested and your job is on the line, some may be tempted to lets say…… purposely shut down equipment to “pass” the air test? This is…jus’ ma guess…I’ve an actual hope that routine Formaldehyde levels aren’t chronic near so many people and our drinking water source (we don’t test for aldehydes ya’ll in our drinkan’ water). The mystery of why this happened and what they are doing differently to protect our air quallity has not been made available to the public. We breathe the air and we have a right to know!
All I will say at this point is that there will be an official press release from a reputable company at some point in the future, but I have not been made privy to the details. But here is the meat of my open records request for the air permit information so we know what equipment was on the site at the time of the air testing to get an idea of “expected equipment emissions” pending the equipment was properly maintained and there were no malfunctions of equipment during testing.
First watch this 2011 CBS11 video and note on the map the Ft Worth schools (one named Handley) with high levels of carbon disulfide identified. Two are very near the Lake Arlington Compressor Stations and the Echelon Power Plant.
So you may have heard that in June of 2010, the (industry funded) Titan air test uncovered high levels of Formaldehyde. Below you can read Titan’s ASSumptions of why it flunked and then my rebuttal. Then you get condensed info on the TCEQ Air Permits from a 600 page open record report on both compressor stations that sit very close to Arlington’s drinking water source…Lake Arlington.
On a side note, I wish that if compressor stations have to be by people that they at least use Evras Evaporator Units (WITH SCRUBBERS) to cut down on emissions..but those are really expen$ive, and only the Arc Park Ft Worth site uses these (without scrubbers) and so…spoiler alert…Lake Arlington Compressor Station isn’t using Evras Units…..happy breathing ya’ll.
Regarding Lake Arlington Compressor Station RN 105227763 has had some changes in ownership or names. Who cares about all the name changes? Well I believe it is to limit liability and boy does this Lake Arlington Compressor Station have a history!
The TCEQ 2007 Permit By Rule #81995 showed QuickSilver Resources Inc customer number to be #601075708. The application paper work and $450 check was written by ESE Enviro Solutions Engineering.
Then ownership changed to Cowtown Pipeline L.P CN 603242710 on 9/20/2007.
The LP (limited Partnership makes it easier to attract investors since the only liability for limited partners is the capital they invest in the business).
There is an email between Karen Young & Jennifer Beatty (Air Permits Review) dated 9/24/2007 where Beatty confirmed the updates were completed for the request that Quicksilver no longer be afiliated as an owner/operator with Lake Arlington Compressor Station effective 9/20/2007.
The name then changed to Cowtown Pipeline Partners L.P on 10/1/2008.
In a letter dated 12/31/2008, Zephyr Environmental Corp (now handling paper work) on behalf of “Cowtown Pineline LP” sumbitted a PBR registration ($450) revision to add a “new” compressor (number 7) and revise dehydrator and reboiler emissions.
But in June 2009, this SEC document clearly establishes Quicksilver’s “affliation” with Cowtown…
Then in July of 2009, there was an application for Standard Permit #90487 (since air testing showed higher emissions than reported) and a check for $900 (ck#106579) dated 7/10/2009 was made to TCEQ from…wait for it…Quicksilver.
I asked TCEQ about why the check was from Quicksilver when they were not spposed to be affiliated and here was their response…
From: Johnny Bowers <email@example.com>
To: kim feil
Sent: Monday, August 26, 2013 12:31 PM
Subject: RE: is this email correct on the NSR 81995?
On June 11, 2010 the Titan air test uncovered high formaldehyde at five of the nine monitors and less than two months later Quicksilver sold to Crestwood the sale was completed on 10/1/2010.
The sec document reads… “The transaction, announced on July 22, 2010, includes Crestwood’s purchase of a 100% interest in Quicksilver GP, 5,696,752 common units and 11,513,625 subordinated units in Quicksilver Gas Services and a note payable by Quicksilver Gas Services which had a balance of approximately $58 million at closing.”
This link has a map that you can bullet down and see that it shows the name “Crestwood Lake Arlington Plant”.
Then on Oct. 7, 2013 there was a merger between Crestwood and Inergy Midstream….
“HOUSTON and KANSAS CITY, Mo., Oct. 7, 2013 /PRNewswire via COMTEX/ — Crestwood Midstream Partners LP CMLP +0.65% (“Crestwood Midstream”) and Crestwood Holdings LLC (“Crestwood Holdings” and, together with Crestwood Midstream, “Crestwood”) and Inergy, L.P. (“Inergy L.P.”) and Inergy Midstream, L.P. (“Inergy Midstream” and, together with Inergy L.P., “Inergy”) today announced that the merger of Crestwood and Inergy has been completed. The combination is a fully integrated midstream partnership platform with a total enterprise value of approximately $8 billion.”
Several days later, a wholly owned subsidiary of Crestwood Midstream Partners LP called Crestwood Arrow Acquisition bought Arrow Midstream Holdings LLC that is valued at $750 million.
Below is an email cut and paste where Crestwood Claims that Quicksilver owned Lake Arlington Compressor Station for the Public Information Request for any reportable emission events during the Titan testing (June 11,2010).
From: Molly Wentworth
Sent: Thursday, January 03, 2013 1:41 PM
To: Tammy Glasscock
Cc: Matt Norton
Subject: RE: Request for Records
Good Afternoon Tammy,
Crestwood Midstream Partners did not own this site at the time the RIF has designated. It was owned by Quicksilver Resources. However, we are looking to see if we have , if any, information. If we could please have until Friday, 1/11/2013, it would make our search easier.
Thank you for your understanding,
Molly Wentworth Environmental Advisor
Crestwood Midstream Partners LP D: 817-339-5441 C: 682-429-0830 F: 817-339-5401 firstname.lastname@example.org
Molly from Crestwood checked to see if any records (explaining the high Formalydehyde during the Titan air test) were forwarded to them by Cowtown/QuickSilver. In a follow up email Molly wrote …“We could find no records that indicate either a reportable or recordable emission event.“
In the months following the failed Titan air test, I found notes in an email dated Nov of 2010 that they have added 3 electric compressor units. I recall getting this information by phone from Bradley Hodges from the City of Ft Worth Gas Drilling Department. I understand that this brings the number of compressors to 7 but that not all 7 will be used at the same time, but as back up during blowdowns.
So I have sent a gazillion emails trying to find out what equipment was there during testing, what equipment was online and running…and since then what has been done to improve air quality (besides the 3 electric compressors that were added), and hopefully explain if the failed air quality test for formaldehyde and carbon disulfide was an anonomaly or something they learned from and improved out there.
So whatever became of Quicksilver after they sold stinky ol Lake Arlington Compressor Station? Well in March of this year (2013) Quicksilver UN-Americanly agreed to sell 25% of their other Barnett Shale assets to the Japanese for $485 million. These poor Japanese “suckers” now have to fund 25% of the Barnett Shale development going forward. How “helpful” Quicksilver was to assist Japan from getting off of nuclear dependency.
Now read on about what Titan had to say was the cause of the high Formaldehyde at the area being tested which was the compressor station….
5.4 Quicksilver (Gas Services) Lake Arlington (COFW 5)
“As shown in Tables 11 and 12, all detected VOC concentrations were below their respective AMCVs, as the maximum concentrations for all VOCs, across all sample locations and composite times, were less than 84% of their respective AMCVs. As shown in Figures 7 and 8, most of the depicted compounds appeared in the upwind samples at concentrations similar to those measured in the downwind samples. However, there were a few compounds detected in downwind samples at concentrations higher than those found upwind.
Barnett Shale Energy Education Council Natural Gas Sites – Cities of Fort Worth and Arlington, Texas Ambient Air Quality Study 19 July 12, 2010As shown in Table 14, with the exception of the carbonyl sulfide concentration at QLA5DC, all 1-hour sulfur compound concentrations were less than their respective AMCVs. The QLA5DC carbonyl sulfide concentration of 130 ppbv is higher than the odor-based AMCV of 55 ppbv, but far below (7%) of the 1,800 ppbv health-based AMCV. Upon review of Figure 7, TITAN determined that the NG Site operation is contributing to the ambient air concentration of carbonyl sulfide; however, it should be noted that the QLA5DC point was located well within the property interior (estimated at 50-75 feet within the interior), and off-site concentrations would be lower. This sampling point was re-located due to the existence of a plant road and a sound wall immediately north of the compressor engines. In TITAN’s opinion, the carbonyl sulfide exceedance does not indicate a significant off-site exposure problem because it’s related to odor, not health effects, and the site is located in a heavy industrial area. As previously stated, the 130 ppbv concentration is only 7% of the health-based AMCV.
As shown in Table 13, five of the nine formaldehyde concentrations were higher than the 41 ppbv health- based AMCV. Upon review of Figure 7, TITAN made the following observations:
• As the wind rose shows, the wind direction was consistently from the south during the formaldehyde sampling event. Wind speeds were steady, between 5 and 10 miles per hour. Therefore, emissions were continually transported from south to north throughout the event period, with minimal wind variability.
• The formaldehyde concentrations at four sampling stations (QLA5DC, QLA5DE, QLA5CU, and QLA5UE), all of which are south of Highway 303, are low in magnitude and remarkably consistent, ranging from 4.16 ppbv to 5.57 ppbv. Because of the low concentrations and minimal variability, the samples at these four sites are representative of the background formaldehyde concentrations in the sampling domain during the sampling event period.
• The formaldehyde concentrations at sampling stations QLA5DR and QLA5CD, both of which are north of Highway 303, primarily reflect impacts from vehicular emissions from Highway 303, especially considering the constant south wind and the minimal background concentrations at stations QLA5DC and QLA5CU. Of note, the formaldehyde concentration at station QLA5DR, which could potentially have had some impacts from the NG Site, is more than 45 ppbv lower than the concentration at station QLA5CD. Therefore, the NG Site formaldehyde impacts at station QLA5DR during the sampling period were likely relatively small (or the QLA5DR concentrations would have had a magnitude similar to or higher than the QLA5CD impacts, instead of being lower than the QLA5CD impacts).
• The formaldehyde concentrations at the three westernmost sampling stations, QLA5DW, QLA5UW, and QLA5UC, were very likely caused by emissions from an unidentified low- elevation source located to the near south/southwest of the NG Site. The depicted concentration pattern suggests that emissions from this unidentified source were transported northward in a well-defined plume, with the highest monitored concentration at QLA5UW (126.91 ppbv), a slightly lower concentration at QLA5UC (100.31 ppbv) to the east of the plume centerline, and a slightly lower concentration monitored at QLA5DW (81.29 ppbv) due to the continued dispersion of the northward advecting plume. Formaldehyde concentrations at sampling points located on or near the eastern portion of the NG Site (QLA5UE, QLA5DC, and QLA5DE) are indicative of background levels because those sampling sites apparently were not within the plume that affected the sampling points in the western portion of the sampling domain.
Based on the above, it is TITAN’s opinion that the elevated formaldehyde concentrations are not being caused by NG Site operations, but instead are being caused by both vehicular traffic and an unidentified source located to the near south/southwest of the NG Site. During the sampling event, TITAN field personnel did not identify any type of emission source that could have caused or contributed to the formaldehyde concentrations at QLA5DW, QLA5UW, or QLA5UC.
Overall, TITAN found that the NG Site operations are not significantly impacting the ambient air concentrations in the vicinity, and that the site’s ambient air quality is in-line with that of a heavy industrial urban area.”
My rebuttal to Titan’s conclusion of “offsite sources” is here… If you look at this link, it has really good clarity of the drill site (just go the Lake Arlington area), and then look at the Titan pic here…
Titan tried to say that Formaldehyde QLA5 DR 68.8 ppb (northcentral quadrant) and CD 114.4 ppb (northeast quadrant) were high because of hwy 303 road emissions, but I think …
DR monitor captured winds hitting the sound wall that flew up and “fell out” (formaldehyde) hugs ground right? I also think that…
CD monitor captured winds hitting the sound wall, and ricocheted to the east and fell out there.
I think that the DW 81 ppb (northwest quadrant) was a no brainer in that the Glycol Unit’s on the southwest quad of the site blew and fell out there. This would explain the low background/normal levels on the DC 4.86 ppb (north central) & DE 5.57 monitors (north east).
UW 127 ppb and UC 100 ppb, (those south of the site and closest to the Glycol Units) may be that Formaldehyde was so concentrated that it hugged the ground right where it originated which is why UE, further (on the southeast quadrant) away is low at background levels.
I looked at the 2-4pm timeframe they claim the Formaldehyde tests were taken have a 8 mph wind speed, 180.5 ave wind direction in degrees and an average wind gust of 16.5 mph.
The aerial map shows just how far away the Excelon padsite is, but it has 14 separators and I understand separators do not have any reportable emissions in tons per year.
Also on the Titan Production Data Summary Report, I noted that they posted the throughput of the sampling day for a 24 hour period and compared it to the 30 days prior amouts. In looking at how much gas was compressed per MCF/day and how much was dehydrated per MCF/day, the only two compressor stations with this info populated was Lake Arlington and the Arc Park Compressor/Evaporator Station. It was interesting to note that Arc Park’s throughput was 25% more gas compressed, yet dehydrates 66% LESS than what lake Arlington processes which shows that if we had those Evras evaporator units, our Lake Arlington Gylcol Reboilers and Regenerator emissions would be less. I recall when Ft Worth was considering allowing injection wells, I asked if the pilot plan was so successful for the Evras Evaporating Units, then why not employ more of them and was told they were too expen$ive.
So through an open records request …I learned that Lake Arlington Compressor Station PRIOR to the Titan air test turned out to have been under-reporting their emissions so much so that a year before the Titan air test, they had to change from a minor source air permit to a major source air permit……
A couple of the distinctions between a Permit By Rule ($450 fee) and a Standard Permit ($900 fee) is the fee is double and a Standard Permit has more reporting requirements.
OK if U R still with me…here is the very boring list of equipment since the inception of the Lake Arlington and the adjacent Handley Compressor Stations where I sorted out what I felt was the relevant info from that 600 page open records request….fast forward to the bottom and learn (of yet another reason) why you should use a very good filter if you drink Arlington Gasland Texas water by all the industrial inputs near the lake’s edges…..
From: Darryl Westbrook <Darryl.Westbrook@arlingtontx.gov>
To: ‘kim feil’ <email@example.com>; Cynthia Simmons <Cynthia.Simmons@arlingtontx.gov>
Sent: Monday, September 9, 2013 1:32 PM
Subject: RE: Q on if we test for Carbon Disulfide because it was found near 3 Ft Worth schools video
The State monitors for Carbon Disulfide at the treatment plants on an annual basis. We do not test for aldehydes.
Darryl Westbrook | Assistant Director/Business Services |Arlington Water Utilities | (817) 459-6601
From: kim feil [mailto:firstname.lastname@example.org]
Sent: Wednesday, September 04, 2013 12:26 PM
To: Darryl Westbrook; Cynthia Simmons
Subject: Q on if we test for Carbon Disulfide because it was found near 3 Ft Worth schools video
Darryl, please watch this cbs news report and let me know if we test for any aldehydes in our drinking water?
—– Forwarded Message —–
From: kim feil <email@example.com>
To: “firstname.lastname@example.org” <email@example.com>
Sent: Wednesday, September 4, 2013 11:48 AM
Subject: High Carbon Disulfide near 3 Ft Worth schools video
So we don’t test for aldehydes….who can change that? People contact your local,state and federal reps to change this. Here is another post about the other compressor station in Arlington that exceeded Benzene on one of 8 TCEQ air tests.