Update I have videos at the City of Arlington council room where TCEQ held a workshop for the industry to learn how to comply with new reporting requirements. I have some footage of “pushback” like they never keep any MSS records?..The date in my archives is 10/5/12.
Almost 11 million hrs of idling trucks spewing diesel carcinogens in Barnett Shale in 2012!
“…(NCTCOG) staff estimated that on average, each truck idles for approximately six hours. Although most respondents were water haulers, an assumption was made that loading and unloading activity is consistent regardless of the type of cargo (e.g. water, rock, mud, or equipment), so this estimate of six hours per day was held constant across all phases and for all analysis years.”
And on page 34 for Tarrant county, here is the per day emissions…
And keep in mind this is just the “truck fracking traffic” related emissions…it does not include the other Barnett Shale emission sources (engines, compressors, tank flashes, etc.) during the pre and post production phases of gas drilling & compression …which include MSS emissions (maintenance, start-up & shut-down) activities….and of course can not possible include the unplanned upsets (accidents) emissions……in our Arlington airshed.
From: kim feil <email@example.com>
To: Chris Klaus <firstname.lastname@example.org>
Cc: “email@example.com” <firstname.lastname@example.org>
Sent: Tuesday, August 18, 2015 6:13 PM
Subject: SIP plan NCTCOG submitted to TCEQ for ozone compliance
Texas Sharon says the operators have had to keep track of MSS all along and only have to give up this info in two situations..1) if exceeded the reporting threshold2) if requested via PIR (which she says she has never been able to get that info even when it was requested).For the COG to effectively help on the SIP (State Implementation Plan) for the Barnett Shale emissions, we need the whole Barnett Shale emissions picture.Will the COG please try to get the non-mobile pre & post production Barnett Shale emissions numbers …ie site set up, drilling, fracking, flowback, drillouts/getting wells into production, storage & flash tank emissions, etc.?Will the COG also try to get the maintenance emissions projections (blowdowns, methanol piping treatments, acidizing treatments, nitrogen lifts/re-stimulations etc.?If this falls into another department of the NCTCOG, please forward this email on as appropriate.The drillers can opt out of the TCEQ annual emissions inventory if they are under the emissions thresholds…
Not to be confused with the NSPS quado rules that basically say any new gas wells completed have to capture the gas……
Electronic Code of Federal Regulations View past updates to the e-CFR. Click here to learn more. e-CFR data is current as of August 12, 2015 Preview by Yahoo So my hope is that if (this NEW?) MSS reporting makes some drill sites go above the emissions thresholds, then the operators HAVE to get the PROPER Standard permit from the state (not an honor system PBR).This information will not help in those cases where two different operators are close in proximity yet their emissions are not aggregated, but maybe next legislative session someone can tackle this?With that said I hope that the TCEQ Emissions Inventory includes MSS emissions and not just post production equipment emissions. And if the NCTCOG undertakes finding out the complete emissions profiles, it would be a way to check to make sure all the operators have the proper permits. This would not duplicate the work of the TCEQ who currently uses an honor system in reporting emissions.Prime example is the Lake Arlington Compressor Station used a PBR from 2007-2009 (possibly longer prior to the PIR) before it changed ownership (a couple/few) times and was finally operating under a Standard permit….https://barnettshalehell.wordpress.com/2013/08/21/lacs-handly-compressor-station-permit-info/Thanks Chris for helping us understand the true emissions numbers for these padsites and compressor stations in our neighborhoods. Where was the NCTCOG or the State Dept. of Public Health with offering to assist in any health and environmental impact studies when Urban Drilling was being discussed?Sincerely,Kim FeilFrom: TXsharon <
To: kim feil <email@example.com>
Sent: Friday, August 14, 2015 4:07 PM
Subject: Re: was this a profracking stance or did I imagine that?
Operators are required to report REPORTABLE emission events to the TCEQ within 24 hours.SUBCHAPTER F: EMISSIONS EVENTS AND SCHEDULED MAINTENANCE,STARTUP, AND SHUTDOWN ACTIVITIESDIVISION 1: EMISSIONS EVENTS§101.201Effective January 5, 2006The non-reportable events are kept by the company but the code says they have to submit that information upon request from TCEQ. MSS emission reporting is not new. I don’t think they have enforced it but the industry is supposed to keep a record of all start up, shut down and emergency emission events. Some are reportable and some are not but the record keeping has been a requirement for a long time. I read your comment on the ST article.
On Fri, Aug 14, 2015 at 9:01 AM, kim feil <firstname.lastname@example.org> wrote:RE: maintenance startup shutdown I did find new studies but they were in California
I attended a 2012? TCEQ workshop in Arlington at city hall to help industry guys learn how to do state and federal required record keeping…I videoed some push back to the (MSS reporting?) process cause it was new… I have lots of footage of that event. I posted that on your facebook…here is my comment on that star telegram article about cutting corners …Since Chesapeake, the predominant driller in Arlington, is poised to be piece-mealed out or taken over, I’ll enjoy my biannual $20 royalty check even more if its signed by a foreign owned company…like China..(boom). California learned the hard way to become environmental savy and decades later when they started the unconventional fracking over there…you betcha 13 impressively resumed authors got together and released this document. I only read 1/3 of it and when they got to the how deep do they need to drill so it doesn’t communicate with ground water and bantered back and forth about the pathways and other moving targets like fault lines (natural and now man-made) I had to stop reading cause it only proved that we are truly guinea pigs in this whole quest for cash in our dash for gas. No wonder DicK Cheny created that Halliburton loophole with its fracking exemptions to the Clean Air & Water federal laws…”nope dat dere weren’t no accident” (no pun). But if you drink water and suck air in the Barnett Shale, you might want to read that document….https://ccst.us/publications/2014/2014wst5.pdf