MSS = Maintenance StartUp & ShutDown-HOW STANKY IS IT?

STRAIGHT FROM THE HORSES MOUTH LINK GPO CODE OF FEDERAL REGISTER IS HERE…..
—– Forwarded Message —–
From: Danielle Nesvacil <danielle.nesvacil@tceq.texas.gov>
To: kim feil <kimfeil@sbcglobal.net>
Sent: Wednesday, September 2, 2015 10:17 AM
Subject: Re: pir#23345 to narrow down to just Arlington TX info

Dear Ms. Feil:

I apologize for the delayed response.  Drilling sites are typically not point sources that report to the point source emissions inventory.  Instead, the TCEQ generally inventories drilling activity as an area source, which means the TCEQ develops emissions estimates on the county level (not the site level) for these activities.

Under the New Source Performance Standards (NSPS) Subpart OOOO, hydraulically fractured gas well sites are now required to submit certain types of reports to the TCEQ;  you can visit this page for more information: https://www.tceq.texas.gov/assistance/air/new-source-performance-standard-subpart-oooo-notification-and-delegation-update

I am not sure whether the NSPS OOOO requires emissions estimates to be submitted as part of these reports.  For example, looking at the Well Completion/Flowback Notification form, the information required does not appear to include emissions estimates.

Hope this helps,
Danielle


From: kim feil <kimfeil@sbcglobal.net>
Sent: Friday, August 28, 2015 12:19 PM
To: Danielle Nesvacil
Subject: Re: pir#23345 to narrow down to just Arlington TX info

I am trying to find out MSS emissions are for a typical urban drill site in Arlington TX

From: Danielle Nesvacil <danielle.nesvacil@tceq.texas.gov>
To: kim feil <kimfeil@sbcglobal.net>
Sent: Friday, August 28, 2015 10:05 AM
Subject: Re: pir#23345 to narrow down to just Arlington TX info

 

Hi Ms. Feil–
I’m not sure what you mean by “exemption.”  The TCEQ has required and continues to require different types of MSS reporting under its rules. Here are some MSS reporting requirements that I am aware of (there may be others):
2.  If a site is required to report to the emissions inventory,  MSS emissions are also required to be reported in the emissions inventory per 30 TAC 101.10 ( http://texreg.sos.state.tx.us/public/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc=&p_tloc=&p_ploc=&pg=1&p_tac=&ti=30&pt=1&ch=101&rl=10 ) and 30 TAC 101.211 (see link above).
3.  For sites located in nonattainment or maintenance areas (as well as other specific counties) that do *NOT* report to the emissions inventory, annual reports detailing emissions events and MSS data were required to be submitted by companies until recently.  Beginning in 2015, these reports are no longer required to be submitted.  See this link for more information: http://www.tceq.state.tx.us/airquality/point-source-ei/ee-smss.html
I can definitely answer questions about #2 and assist you with #3.  For questions about #1, please contact your local regional office.
Thanks,
Danielle

From: kim feil <kimfeil@sbcglobal.net>
Sent: Thursday, August 27, 2015 11:42 AM
To: Danielle Nesvacil
Subject: Re: pir#23345 to narrow down to just Arlington TX info

So that means they are not participating in the annual emissions equipment inventory and have been granted an exception to filing this MSS info?

From: Danielle Nesvacil <danielle.nesvacil@tceq.texas.gov>
To: “kimfeil@sbcglobal.net” <kimfeil@sbcglobal.net>
Sent: Thursday, August 27, 2015 9:03 AM
Subject: Fw: pir#23345 to narrow down to just Arlington TX info

 

Dear Ms. Feil:
Thank you for your recent Public Information Act request.  I had prepared the attached letter before I received the following email requesting a price quote for the Arlington, TX area.
This morning, I reviewed the sites identified in the attached letter.  None of them are reported as being located in Arlington, so there would be no responsive information to provide you if we limited the search to Arlington, TX.
Please note that we are still in the process of reviewing the 2014 emissions inventories so the information in this letter is subject to update or changes.
Please let me know if you have any questions.
Thanks,
Danielle

From: OPENRECS
Sent: Wednesday, August 26, 2015 4:17 PM
To: Danielle Nesvacil
Subject: FW: pir#23345 to narrow down to just Arlington TX info

From: kim feil [mailto:kimfeil@sbcglobal.net]
Sent: Wednesday, August 26, 2015 4:14 PM
To: OPENRECS <OPENRECS@tceq.texas.gov>
Subject: pir#23345 to narrow down to just Arlington TX info
Please requote me a price on this PIR 23345 making the search just to Arlington, thanks
kim

END UPDATE


Here are the stages of emissions
Site prep-truck emissions
Drilling Rig engine, compressor, & vehicle emissions
Fracking engine, compressor & vehicle emissions
Flowback top flow VOC’s and water truck hauling emissions
Drilling out the plugs/production emissions & vehicle emissions
Post Production storage tank flask emisions & vehicle emissions
DAILY produced water truck evacuation emissions
Maintenance, restimulation/refrack, compressor blowdown emissions & vehicle emissions

UNPLANNED/upset emissions


Here is an email I sent to NCTCOG to find out who can request PIR’$ now that these MSS records are being focused on being reported as of Jan 5 2014.


Here is a helpful email on containing flowback (I boldfaced FYI)…I hope this includes topflow before the green completion devices are used.
—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: Rob Lawrence <Lawrence.Rob@epamail.epa.gov>
Sent: Tuesday, September 4, 2012 8:58 PM
Subject: What is being done about flying frack silica dust?

From: Rob Lawrence <Lawrence.Rob@epamail.epa.gov>
To: kim feil <kimfeil@sbcglobal.net>; swilson@earthworksaction.org
Cc: Ruben Casso <Casso.Ruben@epamail.epa.gov>; Bruce Moore <Moore.Bruce@epamail.epa.gov>; Donald-M Smith <Smith.Donald-M@epamail.epa.gov>
Sent: Thu, August 23, 2012 3:36:58 PM
Subject: New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants – Oil and Gas Sector

Sharon and Kim – In general, EPA’s newly published air quality regulations for Oil & Gas Sector will not take effect until October 15, 2012, at the earliest.  However, after they take effect, in most cases, until January 1, 2015, the gases from a completion operation will either have to be recovered or flared – unless a local prohibition exists against flaring.  After January 1, 2015 “green” or reduced emission completions will be required – in most cases – for completion operations.  The published regulation and specific excerpts from the regulatory text are included below for your convenience. We hope this information is helpful.On August 16, 2012, the New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants – Oil and Gas Sector, signed last April, were published in the Federal Register.  Here is the summary of today’s action, taken from the Federal Register:This action finalizes the review of new source performance standards for the listed oil and natural gas source category.  In this action the EPA revised the new source performance standards for volatile organic compounds from leaking components at onshore natural gas processing plants and new source performance standards for sulfur dioxide emissions from natural gas processing plants.  The EPA also established standards for certain oil and gas operations not covered by the existing standards.  In addition to the operations covered by the existing standards, the newly established standards will regulate volatile organic compound emissions from gas wells, centrifugal compressors, reciprocating compressors, pneumatic controllers and storage vessels.  This action also finalizes the residual risk and technology review for the Oil and Natural Gas Production source category and the Natural Gas Transmission and Storage source category.  This action includes revisions to the existing leak detection and repair requirements.  In addition, the EPA has established in this action emission limits reflecting maximum achievable control technology for certain currently uncontrolled emission sources in these source categories.  This action also includes modification and addition of testing and monitoring and related notification, recordkeeping and reporting requirements, as well as other minor technical revisions to the national emission standards for hazardous air pollutants.  This action finalizes revisions to the regulatory provisions related to emissions during periods of startup, shutdown and malfunction.

§ 60.5375 What standards apply to gas well affected facilities?
If you are the owner or operator of a gas well affected facility, you must comply with paragraphs (a) through (f) of this section.
(a) Except as provided in paragraph (f) of this section, for each well completion operation with hydraulic fracturing begun prior to January 1, 2015, you must comply with the requirements of paragraphs (a)(3) and (4) of this section unless a more stringent state or local emission control requirement is applicable; optionally, you may comply with the requirements of paragraphs (a)(1) through (4) of this section.

For each new well completion operation with hydraulic fracturing begun on or after January 1, 2015, you must comply with the requirements in paragraphs (a)(1) through (4) of this section.

(1) For the duration of flowback, route the recovered liquids into one or more storage vessels or re-inject the recovered liquids into the well or another well, and route the recovered gas into a gas flow line or collection system, re-inject the recovered gas into the well or another well, use the recovered gas as an on-site fuel source, or use the recovered gas for another useful purpose that a purchased fuel or raw material would serve, with no direct release to the atmosphere. If this is infeasible, follow the requirements in paragraph (a)(3) of this section.

(2) All salable quality gas must be routed to the gas flow line as soon as practicable. In cases where flowback emissions cannot be directed to the flow line, you must follow the requirements in paragraph (a)(3) of this section.

(3) You must capture and direct flowback emissions to a completion combustion device, except in conditions that may result in a fire hazard or explosion, or where high heat emissions from a completion combustion device may negatively impact tundra, permafrost or waterways. Completion combustion devices must be equipped with a reliable continuous ignition source over the duration of flowback.

(4) You have a general duty to safely maximize resource recovery and minimize releases to the atmosphere during flowback and subsequent recovery.


§ 60.5430 What definitions apply to this subpart?
Reduced emissions completion means a well completion following fracturing or refracturing where gas flowback that is otherwise vented is captured, cleaned, and routed to the flow line or collection system, re-injected into the well or another well, used as an on-site fuel source, or used for other useful purpose that a purchased fuel or raw material would serve, with no direct release to the atmosphere.

This webpage includes the factsheets and summary of the requirements.  http://www.epa.gov/airquality/oilandgas/actions.html

Rob Lawrence
Senior Policy Advisor – Energy Issues

lawrence.rob@epa.gov

214.665.6580 (Desk)
214.665.7263 (FAX)

Advertisements

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)
This entry was posted in Uncategorized and tagged , , , . Bookmark the permalink.

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s