RESPONSIBLE drilling defined / what about INVERSION, Colloids, & Halides?

https://www.facebook.com/AnInconvenientTruth/photos/a.122793927863612.23038.117074698435535/480946085381726/?type=1&theater

Update Dec 2014 here is a list *** from Colorado….it is EXTENSIVE….glad to know that others feel long lists make sense.

Until responsible drilling methods are adopted, the *antiquated law where

“subsurface mineral rights trump surface rights”

needs to be abolished

to the extent that slavery needed to be abolished.

—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: “David.Porter@rrc.state.tx.us” <David.Porter@rrc.state.tx.us>; “Barry.Smitherman@rrc.state.tx.us” <Barry.Smitherman@rrc.state.tx.us>; “Christi.Craddick@rrc.state.tx.us” <Christi.Craddick@rrc.state.tx.us>; “Christi.Craddick@rrc.state.tx.us” <Christi.Craddick@rrc.state.tx.us>
Cc: “ramona.nye@rrc.state.tx.us” <ramona.nye@rrc.state.tx.us>
Sent: Saturday, November 8, 2014 9:29 PM
Subject: Examples of Responsible Drilling/Denton ban

The rules for drilling were written for rural areas, likely before the unconventional method.

 

If we HAVE to frack by people, animals, & produce, please address each idea. 

Note these tips did not just pop into my head, I’ve had five years to learn where problems have occurred in the past.

 Examples of Responsible Drilling…. 

 

1) use electric rigs, & engines -not dirty diesel or dirty field gas

2) use rot proof cement and rust proof steel for the casing (must be seismic proof too) ..video tape ALL cement casing pours when it comes back up to the top through the annulus so that there is proof of an even pour and ensure all wells have electric bond log tests

3) use radioactive free isotope tracers to see if they reached their frack zone & in fracking fluid

4) use uranium free/non toxic explosives in perf guns to bomb holes in the casing

5) use silica dust catchers (no trespass allowed during fracking)

6) use non toxic fracking chemicals and non **toxic recycled water (not single use water!)

7) use pressurized, ventless, “closed” flowback tanks

8) use vapor recovery units on storage tanks

9) have a 12-18 month timeframe to permanently shut in the well after it peters out-no lift compression

10) use LNG or CNG vehicles..NO DIESEL in the air or in the drilling mud.

11) brine road spraying or drilling mud farming get base line & follow up testing of soil & water

12) ensure condensers are used on glycol units

13) guarantee auto shut-ins will work when well heads freeze up and the produced water trucks cannot get to the sites.

14) frack and then flowback right away – don’t let it sit in the ground for months festering bacterial sulfide growth to sour and damage the well and sicken people

15) have zero tolerance for under inspected, or faked Waste Disposal Injection Well casing pressure tests

16) state entities overseeing oil and gas should regulate how close old wells are to new wells

17)  spills risk arsenic & COLLOIDs to affect ground water and or later drain into storm water systems-so flooded padsites need to be held & tested before releasing

18) shut down fracking operations during weather inversions if using nonelectric engines

19) City inspectors/first responders  should have infrared camera and on hand suma canister air testers

20) Fracking fluid tracers must be used

21) refrain from using plunger lifts to remove fluids from the well

22) stop the methane leaks at every stage from cradle to grave-thats responsible drilling until then stop saying NG is better than burning coal

…please feel free to comment on why these aren’t responsible drilling ideas..

*antiquated law….

Cowan v. Hardeman, 26 Tex. 217, 222 (1862) = surface rights with a split estate.
Texas constitution allowed Spanish laws to continue.

The Spanish Mining Act of 1783 gave the Crown all mineral rights.

The State constitution of 1867 gave mineral rights to private property owners.

---

**toxic, recycled water part 1 of 2…

http://pubs.rsc.org/en/content/articlelanding/2014/em/c4em00376d#!divAbstract

The study appeared in the Royal Society of Chemistry journal Environmental Science: Processes and Impacts….

“However, the presence of various fatty acid phthalate esters in the Barnett and Marcellus produced waters can be related to their use in drilling fluids and breaker additives rather than their presence in connate fluids. Halogen containing compounds are found in each of the water samples, and although the fluorocarbon compounds identified are used as tracers, the presence of chlorocarbons and organobromidesformed as a consequence of using chlorine containing oxidants (to remove bacteria from source water), suggests that industry should concentrate on non-chemical treatments of frac and produced waters.”  

**toxic, recycled water part 2 of 2….

http://www.wateronline.com/doc/how-does-fracking-impact-drinking-water-0001

“there is concern that halide-contaminated surface water subsequently treated for drinking purposes with conventional methods, such as chlorination or ozonation, could lead to the formation of toxic byproducts…..Installation of halide-specific removal techniques in centralized brine treatment facilities may be a better strategy to mitigate impacts on downstream drinking water treatment plants than altering disinfection strategies. The potential formation of multiple [disinfection byproducts] in drinking water utilities in areas of shale gas development requires comprehensive monitoring plans beyond the common regulated [disinfection byproducts],” the study said.

---

—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: mike dean <mwd0518@sbcglobal.net>; Jackie Barnd <jcb4455@sbcglobal.net>; melissa McDougall <mcadomk@yahoo.com>; Mary Kelleher <marykatekell1963@yahoo.com>; “bob.horton@rshorton.com” <bob.horton@rshorton.com>; Gary Hogan <hogangaryfwtx@aol.com>
Cc: “David.Porter@rrc.state.tx.us” <David.Porter@rrc.state.tx.us>; “Barry.Smitherman@rrc.state.tx.us” <Barry.Smitherman@rrc.state.tx.us>; “Christi.Craddick@rrc.state.tx.us” <Christi.Craddick@rrc.state.tx.us>; “Cc: “ramona.nye@rrc.state.tx.us” <ramona.nye@rrc.state.tx.us>
Sent: Sunday, November 9, 2014 1:30 PM
Subject: Re: {NCTCA} additional Examples of Responsible Drilling issues/ban

 

Mike, I’ll add the “shut down fracking operations during inversions” to my list.

If they use electric drilling rigs, the inversions won’t be a problem…sadly though when electric rigs are used, we shift the energy load to increase emissions at the power plants that run on either coal or natural gas….now if the power plants used wind and solar….hint hint.

Inversions during fracking is a problem cause if they frack with Caterpillar hybrid engines, they use gas and diesel at the same time.

http://www.caterpillar.com/en/company/innovation/natural-gas/natural-gas-101.html

Regarding inversions during flowback, I believe they have no control over shutting down during flowback operations, but if they used the pressurized, gas buster, ventless flowback tanks as suggested, then inversions won’t be a problem during flowback.

Kim

---

From:  <mwd0518@sbcglobal.net>
To: “kimfeil@sbcglobal.net” <kimfeil@sbcglobal.net>; Jackie Barnd <jcb4455@sbcglobal.net>; melissa McDougall <mcadomk@yahoo.com>; Mary Kelleher <marykatekell1963@yahoo.com>; “bob.horton@rshorton.com” <bob.horton@rshorton.com>; Gary Hogan <hogangaryfwtx@aol.com>; Mike Dean <mwd0518@sbcglobal.net>
Cc: “David.Porter@rrc.state.tx.us” <David.Porter@rrc.state.tx.us>; “Barry.Smitherman@rrc.state.tx.us” <Barry.Smitherman@rrc.state.tx.us>; “Christi.Craddick@rrc.state.tx.us” <Christi.Craddick@rrc.state.tx.us>; “Christi.Craddick@rrc.state.tx.us” <Christi.Craddick@rrc.state.tx.us>; “Cc: “ramona.nye@rrc.state.tx.us” <ramona.nye@rrc.state.tx.us>
Sent: Sunday, November 9, 2014 11:27 AM
Subject: Re: {NCTCA} additional Examples of Responsible Drilling issues/ban

Kim,

Good ones listed. I still have concern over fracking when an air inversion is happening and such needs to be monitored and operations suspended during its occurrence.   This event happens here locally more than 50% of our days. It may be for only a few hours or it may a large portion of the day. But when emissions are admitted into the air, they can be held down to the ground and can increase the concentrations vastly.  Anyone who is not familiar with needs contact their local weather man or college meteorological department for the facts of this occurance.
What you have mentioned below does not include carbon monoxide and carbon dioxide emitted from all the equipment used/running during fracking and intensified/concentrated during an inversion.    

I also think the industry needs to recycle water used and there needs to be more control over waste water disposal. (even if they use

friendly chemicals, they are still using up our precious water and can be lubricating faults and causing earth shifting problems as in known in  areas of Tarrant and nearby counties as well. One example of  this is Azle and Springtown.

—– Forwarded Message —–
From: mwd0518@sbcglobal.net>
To: “kimfeil@sbcglobal.net” <kimfeil@sbcglobal.net>
Sent: Saturday, January 17, 2015 8:16 AM
Subject: Re: {NCTCA} Last night’s TCEQ Public Hearing on Ozone Attainment SIP coverage

Kim, I heard from a nurse at Cooks Children Hosp how much their patient load of children with lung issues had increased since 2008,

three times greater than the population increase. I tried to get figures from the hospital and no one would help!! Found that the industry

donates to the hospital considerably and they receive considerable income from such patients. I also have not done any more on getting

the air/temperature inversions facts in this area from a creditable source. I do have the documentation as to the daily occurrence of and

know that we have such more than 50 % of our days. I am certain that if we had someone with the credentials to explain the occurrence,

that information it would make a difference in the campaign against.

---

Colorado  “LIST” added on Dec update to this blog…

“The Supplement Binder for the Dec. 10 meeting of the governor’s task force offers “potential solutions” as to adjacent landowner rights (see Page 8-11 in Dec. 10 Meeting Notes). One section of the task force’s preliminary solutions is reported here:

#2 PROBLEM: Neighbors to oil and gas development have little or no power to protect their property

POTENTIAL SOLUTIONS

1) Give homeowners standing to request a hearing

1. Examine Colorado’s APA “aggrieved party” status
2. Homeowners within 1,000 feet could be given standing to require COGCC hearing

2) Extend notification provisions and standing to tenants of surface owners

1. COGCC Rule 305.c and 305.d

3) Citizen suit provision

Response D:

1) Increase Local Government Authority in Regard to Oil and Gas Operations

1. Provide local governments with full zoning and planning authority over oil and gas operations, similar to powers that local governments currently have over other industrial and commercial operations; and/or,
2. Establish Enforceable Comprehensive Development (Drilling) Plans that require local government participation and approval.

2) Address Noise and Vibration Issues

1. Require electric or natural gas powered drilling rigs;
2. Modify regulations to make increase stringency of noise regulations;
3. Employ noise suppression practices that keep the noise below accepted health standards for engines (e.g. enclosures, sound blankets and hospital grade mufflers);
4. Prohibit vehicle backup alarms from 7 pm to 7 am; and
5. Require electric compressor engines and install compressors in a specially designed building to mitigate noise and vibration issues.

3) Address Odor and Air Quality Concerns

1. Require new rules to address the issues omitted during the 2014 AQCC fugitive emission rulemaking as identified in the Statement of Basis and Purpose of the Rule;
2. Require Tier 4 engines for equipment on well site to reduce emissions;
3. Eliminate open tanks for any fluids other than fresh water and during drilling and well completion operations;
4. Require green completion practices and ensure production facilities and pipelines are in place to ensure green completions practices are used;
5. Require natural gas sales line installation prior to completion activities to minimize flaring;
6. Require dust suppression practices using a vacuum system or comparable process to control dust from completion activities; and,
7. Require automated systems to determine tank levels and methods to minimize emissions from tank unloading activities.

4) Address the Lack of Critical Information and Data Regarding Oil and Gas Operation’s Impact On Public Health

1. Require the COGCC and Oil and Gas operators to provide local primary care and emergency care providers, along with county health officials, of oil and gas operations in a given geographic area via the COGCC’s online mapping tool or other means;10
2. Require that healthcare providers and county health officials receive information on symptoms associated with exposure to common chemicals and pollutants associated with Oil and Gas operations;
3. Establish a system whereby health professionals report symptoms that are consistent with exposure to common chemicals/pollutants used in Oil and Gas Operations to CDPHE; and
4. Create a CDPHE maintained, searchable database regarding exposure incidences and reported symptoms that is available to researchers, health professionals, policy-makers and the public via the Internet.

5) Increase Information and Data Regarding Oil and Gas Operation’s Impact on Air Quality

Require cradle to grave air quality monitoring whereby:

1. Air Quality is continuously monitored at all drilling/well sites and at proximate residential areas, from baseline before the first activity at the site until the end of all operations at the site; and,
2. Air Quality Data is transmitted to CDPHE, which creates and maintains a searchable air-quality database that is available to researchers, health professionals, policy-makers and the public via the Internet.

6) Address Residents Safety Concerns

1. Require pipelines or water recycling to minimize truck trips;
2. Require telemetry system to notify the operator of upset conditions with remote well shut-in capability;
3. Require fire suppression systems for well sites; and
4. Require outreach and training with local emergency response agencies.

7) Leak Detection and Repair

1. Require better systems to increase leak detection and response via telemetry and/or other means;
2. Substantially increase inspections, particularly where telemetric leak detection is not possible; and
3. Require immediate repair of leaks and remote well shut-in capability.

8) Address Citizen Concerns Regarding Chemicals Used in the Hydraulic Fracturing Process

1. Require full disclosure of all chemicals used in the fracking process, including concentrations and quantities of chemicals used at each well; and,
2. Establish a fully searchable, sortable database that is available to researchers, health professionals, policy-makers and the public via the Internet.11

9) Improve Complaint Procedures and Establish a More User Friendly Complaint Process

1. Require signage with operator and COGCC contact information at well sites for residents as well as local emergency contact information, the COGCC complaint hotline, and EPA emergency response spill hotline;
2. Allow that complaints may be filed with the COGCC in writing, via electronic communication, via telephone or in person;
3. Ensure that all complainants, no matter by which method their complaint is filed, are afforded complainant status in COGCC proceedings; and,
4. Allow ample time for residents to file complaints.12

Response E:

1) The need for greater protective setbacks for multi-well, nonconventional drill sites. This also includes removing the exemptions for existing multi-well pad sites and surface use agreements which allows even the 500 ft. setback to be ignored. We have yet to have a substantive conversation about this option and we need to–our work will not be seen as credible if we don’t engage in conversation about one of the main reasons the task force was formed.

2) Local control–while setbacks can raise the protective floor that all citizens deserve–local government should have more of a say in helping determine locations and additional mitigations. Longmont’s regulations are not a ban and are a common sense, balanced approach that other communities should be allowed to explore.”  

end 12/14 update