TCEQ goes after NOx instead of fracking & earthquakes which creates OZONE

Troop 68 in Decatur TX—that’s ma’ boy!

Why am I not surprised that TCEQ isn’t interested in finding OZONE issues with emissions from big oil and gas? They want to focus on NOX because it has the most reactivity (verses VOCs).

I begged to differ…. they need to look at how methane burning’s combustion (and other fossil fuels) = NOX.

And they need to look at (for starters) how much NOX is created in just the drilling phase for natural gas and oil from those nasty diesel driven rigs.

In looking at my old notes from the one million dollar Ft Worth Barnett Shale air study, I noted that…

1).They were not tasked to report on the topic of the huge methane losses while my handwritten notes show that Ft Worth has 5-10 ppm methane when the world wide background average is 2 ppm).

2).They also were not asked to make any health recommendations about drilling trucks and onsite engines creating NOX which fuels our ozone noncompliance air quality problems.

3). A question was raised if they had data regarding emissions during a drilling fire or mishap, but they did not have any information on that.

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I used to attend the NCTCA Air Qualtiy regional meeetings where there was discussion of how to make Ozone federal attainment standards…but at the last meeting I went to, they were running out of time to agree on what to turn in for a “plan”, and on top of that there wasn’t enough leaders that even showed up to vote on anything. So when the meeting was adjourned, I stood up and clapped and sarcastically said “bravo-job well done… NOT…this is MY family’s airshed!”

So now, I am glad to personally present the info to our uninformed TCEQ about a new study that shows that the act of cracking rocks makes Ozone.…I hope the TCEQ will change their mind about NOT going after the frackers.

In a previous blog, I quoted….Live science who reported…

“In research published in the International Journal of Environmental Research and Public Health in 2011, Grant and a research team found that tectonic stresses in the Earth’s crust send “massive amounts of primarily positive air ions into the lower atmosphere.” When these ions react with water, oxidization takes place and animals may be irritated or posioned by this ozone. This may explain why they flee or die and become beached.

This report goes on to say …”A group of physicists at the University of Virginia — investigating reports of animal behavior before earthquakes — discovered that rocks, when crushed under high pressure that mimicked the force of an earthquake, emitted high levels of ozone gas.

“Even the smallest rock fracture produced ozone,” researcher Catherine Dukes told LiveScience in an earlier interview.”

SO I hope if the TCEQ understands they need to regulate the injection wells >that cause earthquakes >that also cause Ozone.…yep its the frackers fracking up our Ozone. 

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—– Forwarded Message —–
From: Nina Castillo <nina.castillo@tceq.texas.gov>
To: kim feil <kimfeil@sbcglobal.net>; Chris Kite <chris.kite@tceq.texas.gov>
Cc: Stephen Davis <stephen.davis@tceq.texas.gov>; Zarena Post <zarena.post@tceq.texas.gov>; Keith Sheedy <keith.sheedy@tceq.texas.gov>; Walker Williamson <walker.williamson@tceq.texas.gov>
Sent: Friday, December 6, 2013 2:21 PM
Subject: RE: EPA SIP RE: Methane as greenhouse gas factor/modeling and exclusion

Good afternoon Kim,

Thank you for providing additional information regarding methane in the Fort Worth area. I am forwarding your email to Chris Kite who provided the methane and ozone information in the previous email.

Thanks,

Nina Castillo

State Implementation Plan (SIP) Team

Air Quality Division

512-239-4415

From: kim feil [mailto:kimfeil@sbcglobal.net]
Sent: Thursday, December 05, 2013 9:32 PM
To: Nina Castillo
Subject: EPA SIP RE: Methane as grenhouse gas factor/modeling and exclusion

Nina, I need to share with you some things I recently learned….please click the links to read…

Cracking rocks makes ozone...

Methane leaking near water treatment plants is a huge concern of synergistic toxins.

Methane forming formaldehyde is worrying because TCEQ’s sumas test for neither Methane nor Formaldehyde.

I’ve also heard from a prominent scientist that methane in sunlight breaks down to create formaldehyde and other ozone precursors.

The ERG Ft Worth air study representatives reported during the citizen briefing that Ft Worth has from 2 ½ to 5 times more methane in our ambient air than the average worldwide background.  With heat or sunlight, Methane reacts with halogens like chlorine. These chlorinated hydrocarbons are dangerous to our liver, kidneys and central nervous system.  The ERG study admitted that they could not address the numerous combinations of reactive mixtures.

Ft Worth averaged almost 21,000 tons of methane losses per year which was only 20 times less than the total methane losses from the BP Gulf coast disaster. This tells me that we can improve on NOT allowing methane to escape to the atmosphere (which is a potent green house gas). Through self policing, the industry has demonstrated a callous disregard for our minerals by their inaction to employ Best Available Emission Control Technologies which can help improve ozone exposures to our lungs, buildings, and food supply.

*******************************************************************

Response

Mr. Hogan,

 Thank you for your question.  Our current scientific understanding of ozone formation does not lead us to your conclusion that methane is many times more damaging and ozone creating than NOx.  Methane does react to form ozone, but it does so very slowly.  So it is only important when considering background ozone levels on a global scale over periods of months and years, rather than on a local/regional scale over periods of hours and days.

 Methane and the other main components of natural gas (e.g., ethane, propane, and butane) have very low reactivity with respect to ozone formation.  The U.S. Environmental Protection Agency (EPA) definition of volatile organic compounds (VOC) can be found at http://www.epa.gov/ttn/naaqs/ozone/ozonetech/def_voc.htm, and is also included in the Code of Federal Regulations (CFR).  Here is an excerpt in italics:

40 CFR 51.100(s) – Definition – Volatile organic compounds (VOC)

(s) “Volatile organic compounds (VOC)” means any compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate, which participates in atmospheric photochemical reactions.

(1) This includes any such organic compound other than the following, which have been determined to have negligible photochemical reactivity:  methane, ethane…”

For the full list of compounds excluded from this definition of VOC, please refer to the web link provided above.  For additional information, here is a link to a presentation about our current ozone modeling efforts given in the Dallas-Fort Worth (DFW) area on November 5:  http://www.tceq.texas.gov/assets/public/implementation/air/am/committees/pmt_dfw/20131105/20131105-DFW-Ozone-75ppb-Kite.pdf

Slides 38-41 summarize how most ozone formation throughout DFW and eastern Texas is generally “NOx limited”, which means that ozone will be reduced when NOx is reduced.  Due to the very large contribution of naturally occurring reactive VOC from trees and other vegetation (e.g., isoprene and monterpenes), reducing relatively low reactive VOC from human activity is usually not very effective for reducing ozone.  There are exceptions to this, particularly where highly reactive VOC (HRVOC) are concentrated both spatially and temporally in areas like the Houston Ship Channel that have a high density of petrochemical facilities.

Natural gas is predominantly composed of methane—up to 95% for what is categorized as “dry” gas.  The remainder is composed of ethane, propane, and butane in differing amounts, and then trace amounts of other compounds.  Slide 38 demonstrates the wide range of ozone formation reactivity among different VOC groups, with xylenes being the most reactive:

  th The  ozone reactivity of methane is so low that it is not even on the list;

–       ethane is the least reactive of all those on the list—meaning that it is 143 time less reactive than xylene;

–         propane also has low reactivity—it is 38 times less reactive than xylene; and

–          butane falls into the paraffin category that is 40 times less reactive than xylene.

 Even though ethane is technically not a VOC by EPA’s definition provided above, it is nonetheless included in our modeling efforts.  I hope this summary helps.  If you have any scientific or technical information available (e.g., reports, studies, etc.) that demonstrate higher ozone formation reactivity from methane, ethane, propane, and butane than what is presented here, please provide them for our review and we will be happy to discuss them with you.

 I can be reached either by e-mail or phone at (512)239-1959.  Thanks.

 Chris