IF U did not make the meeting=PLEASE EMAIL your comments to the EPA ASAP!!!
Kim Feil’s comments Arlington TX
The ERG Ft Worth one million dollar air fracking study a few years ago found methane levels 2-10 times above world background levels.
EPA says of the NSPS (New Source Performance Standards)…”During the initial flowback stage, there is no requirement for controlling emissions from the vessel, and any gas in the flowback during this stage may be vented”. And you admit yourself that your inadvertent NSPS coverage of tanks where they exceed 6 tpy could discourage recycling of flowback and produced water due to the huge throughput of these tanks. I am asking you to consider the flowback tanks to be mandated to be pressurized with gas busters so they are ventless from the initial flowback stage to the separator-ready stage because no one is regulating the unknown effluents emanating from the stale waters coming up from the bowels of the earth that “VOC focused air testing instrumentation” doesn’t pick up.
A a couple of years ago stale water odors came into my home and burnt my eyes near the ATT Stadium. Initial flowback needs to go into ventless tanks because no one regulates the stale water odors and collecting ALL methane releases is important. If the NSPS sets out to be protective of public health, then this is relevant to the revisions because additionally, the problem with the EPA encouraging recycling waste water is that unintended byproducts of water treatment disinfectants are NOT recommended because they can make frack on crack! Think of it how the term NORM becomes TENORM when mans adds his touch..so too does flowback waste being recycled undergo dangerous FRACKENSTEIN chemical reactions.
Avner Vengosh, a geochemist studying water quality at Duke University, said “This disinfection process generates by-products if the water contains two components: One is organic matter, which is common in many of the streams and rivers; the other component is halogen, which means bromide and iodide. We did some experiments with colleagues from Stanford University and showed that a tiny amount of hydraulic fracturing fluid mixed with surface water could trigger the formation of disinfection byproducts. Some components, such as iodinated trihalomethanes, which are extremely toxic, are not being regulated by the Environmental Protection Agency (EPA) and could be generated from the introduction of the wastewater into drinking water utilities. Even a tiny spill with a small amount of the bromide and iodide could trigger the formation of those highly toxic disinfection by-products in drinking water”. If onsite recycling cannot remove the Frackenstein constituents , then even transporting this waste to injection wells presents a risk that outweighs the rewards.
Posted today on Skytruth….Scientists in Siberia are closely monitoring a mysterious rising mound as a spate of fresh craters prompt warnings of spontaneous explosions in the permafrost landscape…. They’ve discovered a mound of soil-covered ice, which they believe is set to explode ‘at any moment’. It’s potentially bigger, they say, than the 80m wide crater which sparked the whole investigation last year and up to 20 more have since been identified. Scientists have established the craters are linked to underground methane ponds which appear to be warming – and releasing gas – due to rising temperatures. Now there are warning the escaping methane now poses a threat nearby natural gas pipelines and infrastructure for a chain reaction event.
So the unnatural melting causing natural methane release is out of our control so all steps to curb manmade methane leaks is more dire now than ever.