Closed-Loop Mud System = Open-Air Toxic “Drilling Mud” farming by schools?

Update Jan 12 2018

—- Forwarded Message —–
From: kim feil <>
To: Zacariah Hildenbrand <>
Cc: “” <>; Jeff Williams <>; Robert Shepard <>; Lana Wolff <>; Kathryn Wilemon <>; Sheri Capehart <>; Michael Glaspie <>; Trey Yelverton <>; Victoria Myers <>; Jim Parajon <>; Cynthia Simmons <>; Buzz Pishkur <>; Chris Turner <>
Sent: Friday, January 12, 2018 12:40 PM
Subject: Hero time to NORM test land farmed Mayfield Farms at 7301 Silo Rd
Our exiting-out-of-office councilman, Charlie Parker, voted no to a proposed housing development citing safety reasons of proximity to the gas well pad site on 1/9/18. Per our ordinance we have a 600 ft set back but we regularly violated that setback down to 300 ft with owner or council permission. The Mayfield Development was approved to be as close as 180 ft at 7301 Silo Rd in southeast Arlington despite Charlie’s lone voice of reason. My goal of this update is twofold….
1. to ask UTA Clear to test the soil or get the City to contact the Texas AgriLife Extension Service Soil, Water and Forage Testing Laboratory (979-845-4816), or our local county Extension office.
2. and to educate the rest of our City Council thinking that Arlington residents can live on potentially mud farmed properties surrounding padsites….
2015 silo mud farm

2015 Google imagery on Silo Rd near Seguin High School from another blog with emails to Arlington officials about mud farming risks in Arlington 

Mayfield Farm frack site

2018 Google imagery ….Notice how the perimeter of the drill sites have that signature BROWN look to it AND NOTHING EVER GROWS? Make them test it for radionuclides!!!!

What is mud farming?….

Here are more Arlington suspect pictures and my blog on the subject…

And here is what our government has to say about it….

Listen to this audio of a criminal case


Here is one lawyer’s notes about landfarming (radioactive?) drilling mud…(drilling mud that dries up and flies around as particulates in the summer to be huffed into innocent lungs by families and students in Arlington)….

With Rule 8 stipulating low salinity (honor system) tests…if under compliance, then low salinity usually means low radionuclides…. but alas there is no safe LOW exposure to radiation either…to be risking unearthing this stuff and spreading it on the ground to go airborne is unconscionable.

Agrilife Extension has information on what they really should be testing for in consideration of landfarming even with low salinity being harmful to plants….

agrilife land farming testing

Texas AgriLife Extension
Service link
on landfarming oil & gas waste

Here are a few issues with what is in drilling mud….

Drilling mud having Bentonite going airborne in the summers in itself is a particulate concern as the MSDS sheets say not to inhale the stuff.

And then I have blogged about how the advent of drilling in Arlington may have yielded Bromate contamination that started showing up in our DRINKING WATER …..

Bromide (found in drilling mud) turns to (problematic/carcinogenic) Bromate when we try to clean it for drinking water … Read the EWG report here when we failed Arlington’s public health with exceedances in our drinking water…..

So buyers beware in Arlington when choosing a home ….or school because the bottom line is our local, state, and federal laws have loopholes and our City ordinance eludes to the state and is vague that as long as state rules are followed…go for it.

We need to use Local Home Rule law to forbid mud farming here in Arlington….HB40 would beg to disagree saying we’d be making it cost prohibitive by mandating they take the more expensive route in making them haul it off for proper disposal.

If landfarming in such a way to prevent run off is so important, yet no one is making sure it ain’t happening….why risk this activity near our homes, schools, and in our water shed?

END update.

Here is a 2015 video I had with a RRC employee on the subject of mud farming/land farming instead of costly disposal.

June 2014 UPDATE…heres the letter I sent cause I cannot attend tonight’s City Council meeting where they approve a Unified Development Code that at first glance doesn’t seem to be regulation friendly to renewable distributed energy production….also there is a conflict with their definitions of “Closed Loop” when it comes to geothermal verses drilling mud.

From Me
To jim.parajon@arlingtontx.govrobert.cluck@arlingtontx.govRobert Rivera and 12 More…
Today at 2:39 PM
Also your solar & wind energy regulations are too strict…why not be as permissible with those regs like U R with the frackers?
*What is a Closed-Loop Mud System?
“This is a process where all cuttings that are created by the drilling of the new hole will be transported by truck off location to an approved disposal system. The cuttings are normally distributed on top of the ground & turned in by a tandem or disk like equipment. All of the disposal sites have been approved & monitored by the Railroad Commission. Cuttings are particles of formation obtained from a well during drilling operations. They are brought to the surface by circulating mud-laden fluid.”

a. Closed System
A geoexchange system shall be “closed-loop”, meaning it shall be designed so that it does not remove or introduce any fluid into the ground, groundwater, or any body of water.


May 2014 FYI nothing is closed-looped about the radioactive drilling mud they drag up from the bowels of the earth that I suspect is being dumped near Arlington and Mansfield schools.

Yet another report on drilling waste being radioactive and booming is here by bloomberg.

—- Forwarded Message —–
From: kim feil <>
To: cindy powell <>; “” <>; “” <>
Cc: Buzz Pishkur <>; “” <>; “” <>; “” <>; “” <>; Robert Rivera <>; “” <>; “” <>; “” <>; “” <>; “” <>; “” <>
Sent: Tuesday, May 6, 2014 9:24 PM
Subject: toxic mud farming suspected near AISD schools

Below is the results of a recent Open Records Request with the City of Arlington’s Gas Well Department.

 “Please send info on any NORM readings of the frack sand mitigation socks that catch flying frack sand. No opacity violation was issued on the Bruder event and there should have been one. Here is the video …….but more important is that we need to know where these sacks are being disposed of as there have been violations in other states where these sacks have been improperly disposed of and they are radioactive. 

How can the city show the residents that they will enforce mitigation devices as the ordinance states and that the driller is properly disposing of these and that they are not ending up in our landfills? Here is more info on that

Below is the city’s response. They were not able to answer my question…what they “did” send me however opened another can of worms related to the term … “Closed-Loop Mud System” which turns out that the name is so misleading because the mud is not sequestered in closed tanks. It is allowed to be spread out in the open (urban?) fields to which I’m suspecting is adjacent to the AISD and MISD schools.
Please read my research on recent studies on TENORM. I have pictures of AISD schools near what TCEQ has verified to be some type of land application….

I have to do open records with the RRC to get these Arlington locations, but I have a feeling that not all mud farming is identified via permits (that I believe have annual testing for chlorides? before more “drilling mud” farming can occur). The reason I believe the RRC doesn’t know where all the mud farm sites are is because I have a Aug 2012 audio of a RRC rep saying that no testing is needed of water (soil) “where the owner gives permission to land farm on the same lease the well is on”. So then there may be no records where a permit was not needed.

The hot Texas sun will bake that radioactive drilling mud and send it airborne and it only takes one NORM particle to be inhaled to start disease.

Then there is the concern for wildlife, pets, produce, run off… what have we done allowing this risk near AISD schools?

*What is a Closed-Loop Mud System?
“This is a process where all cuttings that are created by the drilling of the new hole will be transported by truck off location to an approved disposal system. The cuttings are normally distributed on top of the ground & turned in by a tandem or disk like equipment. All of the disposal sites have been approved & monitored by the Railroad Commission. Cuttings are particles of formation obtained from a well during drilling operations. They are brought to the surface by circulating mud-laden fluid.”

Cindy, Hibbs and Cavazos, please comment on how you plan to assist me in having some soil tested in these suspect areas?

My goal is to have the public be informed so that they can decide if they want their children and families living in urban drilling settings where our air, soil, and water sheds are subjected to the risks of heavy metals, chemicals, BTEX, hydrocarbons, arsenic and NORM.

Law suits may not be allowed at the school, city, or state level but once people become informed, sanctions could be placed on drilling towns if people decide not to live in shale areas if that means a higher cancer risk .

I can’t fully inform everyone with perfect science by myself…but lately the momentum is there as more people are on board with the topic of drilling not being safe as first touted. Like the decades of denial that cigarettes cause cancer.

I’m getting record hits on my blog and just yesterday attorneys Harris, Finley & Bogle in Ft Worth (who specialize in protecting the oil and gas companies) are reading/searching out my work.

Please lead the efforts I have started here...if you are last to show concern, shame on you and let the people make their “move”.

Kim Feil

TEX LG. CODE ANN. A§ 253.005 : Texas Statutes – Section 253.005: LEASE OF OIL, GAS, OR MINERAL LAND
“(c) A well may not be drilled in the thickly settled part of the municipality..”

Texas Administrative Code, Title 30, Part 1, Chapter 101, Subchapter A,
Rule 101.4, Environmental Quality, Nuisance

No person shall discharge from any source whatsoever one or more
air contaminants or combinations thereof, in such concentration and
of such duration as are or may tend to be injurious to or to adversely
affect human health or welfare, animal life, vegetation, or property, or
as to interfere with the normal use and enjoyment of animal life, vegetation,
or property.
—– Forwarded Message —–
From: City of Arlington – Open Records <>
Sent: Monday, May 5, 2014 2:03 PM
Subject: Open Records Request :: W015342-050214

— Please respond above this line —

Feil Kim
Old Town Neighborhood Association
Arlington, TX 76011
RE: Public Records Request for Community Development and Planning records

Dear Feil Kim,

Your public information request to the City of Arlington, received 5/2/2014, has been referred to me for response. The below information are the only records/information found that are responsive to your request:

City of Arlington – Gas Well Ordinance:

31. Waste Disposal. Unless otherwise directed by the RRC (Railroad Commission), all tanks used for storage shall conform to the following:

a. Operator must use portable closed steel storage tanks for storing liquid hydrocarbons. Tanks must meet API standards. All tanks must have a vent line, flame arrester and pressure relief valve. No tank battery shall be within one hundred (100) feet of any dwelling or other combustible structure.

b. Drilling mud, cuttings, liquid hydrocarbons and all other field waste derived or resulting from or connected with the drilling, re-working or deepening of any well shall be discharged into above-ground tanks (closed loop mud system). All disposals must be in accordance with the rules of the RRC and any other appropriate local, state or federal agency.

c. Unless otherwise directed by the RRC, waste materials shall be removed from the site and transported to an off-site disposal facility not less often than every thirty (30) days. Water stored in on-site tanks shall be removed as necessary.

All waste shall be disposed of in such a manner as to comply with the air and water pollution control regulations of the State, this Ordinance and any other applicable ordinance of the City.

For further Texas state regulation information, please contact:

Texas Railroad Commission Contact Information:

Fort Worth
(817) 882-8966
City Hall, 13th Street Annex,
401 W. 13th Street, 76102

Oil & Gas
Main line: (512) 463-6838
Please contact me if you have any questions regarding this matter.
Jyl Miller*
Community Development and Planning

—————–lovely we need to add to our ordinance that the operator secure a third party tester and test for radionuclides…..did we not learn our lesson like when the LABC spill in Arlington happened……here is my blog on the LABC  SPILL environmental test results.

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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