Dust Odors Electric Motors …How Arlington Gas Drilling Ordinance “CAN” protect YOU

Please send our council a request to enforce 7.01 #6 to use catalytic convertors on the drill sites with lift compressors, thanks.
—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: Jim Parajon <jim.parajon@arlingtontx.gov>; Trey Yelverton <trey.yelverton@arlingtontx.gov>
Cc: Robert Rivera <robert.rivera@arlingtontx.gov>; Lana Wolff <lana.wolff@arlingtontx.gov>; Charlie Parker <charlie.parker@arlingtontx.gov>; Robert Shepard <robert.shepard@arlingtontx.gov>; Jimmy Bennett <jimmy.bennett@arlingtontx.gov>; Michael Glaspie <michael.glaspie@arlingtontx.gov>; Sheri Capehart <sheri.capehart@arlingtontx.gov>; Kathryn Wilemon <kathryn.wilemon@arlingtontx.gov>; Cynthia Simmons <cynthia.simmons@arlingtontx.gov>; Collin Gregory <collin.gregory@arlingtontx.gov>; Jeff Williams <jeff.williams@arlingtontx.gov>; “jessica.minley@arlingtontx.gov” <jessica.minley@arlingtontx.gov>; Cindy Powell <cpowell@aisd.net>
Sent: Monday, November 23, 2015 1:53 PM
Subject: All that is missing is local inspector enforcement of 7.01 #6 Urban production techniques/Arlington CAN lead
In the response below from Mr Short, At this time, we do not maintain a list specific to if a site that has registered a permit by rule utilizes catalytic convertors”TCEQ doesn’t know which (if any) PBR accts (drilling operators) use catalytic convertors on their lift compressors.
Since our vehicles are state mandated to have catalytic convertors, what is stopping us from mandating that our drillers use catalytic convertors via our Protective to Public Health – Gas Drilling Ordinance?  We have language in 7.01 #6 that states “All drilling and production operations to be conducted in such a manner as to minimize, so far as practicable, dust, vibration, or noxious odors, and shall be in accordance with the best accepted practices incident to drilling for the production of gas and other hydrocarbon substances in urban areas”.
And during blowdowns…we must make them use (or make sure that they are using) the process that bleeds down whats in the pipes to a sales line first… and NOT letting 100% of whats in the pipes go into the atmosphere ….these are no brainer items for what is expected in Urban Drilling Best Practices where people live, work, go to school, be entertained/vacation, & pray.
We M U S T enforce BACT Best Available Control Technologies through this language already adopted in our ordinance. All that is missing is ENFORCEMENT.
Currently under the PBR (permit By Rule) the drillers “can” voluntarily use BACT. But the state doesn’t MANDATE it if they are under these limits (25 tpy vocs)….
List emissions in tpy for each facility (add additional pages or table if needed):
·       Are the SO2, PM10, VOC, or other air contaminant emissions claimed for each facility in this PBR submittal less than 25 tpy?
 YES  NO
·       Are the NOx and CO emissions claimed for each facility in this PBR submittal less than 250 tpy?
 YES  NO
The only recourse is for us at the city level to be more stringent under Home Rule Law via our gaswell ordinance. These are above ground systems HB40 says we have control over.
We need to have a meeting….when can we meet Jim?
1) which pad sites are NOT using catalytic convertors on their lift compressor engines? A visual inspection can determine who can improve their emissions reductions.
2) who is blowing down these lift compressors without FIRST emptying into the sales line/separator system?
This should be part of our inspection process. Sadly the 7.01 #16 specifically for Lift Compressors only concerns noise.
Arlington  M U S T  lead in this endeavor…nothing less is expected if Arlington is to be
L I V E A B L E / breathable.
Thanks
Kim

 

—– Forwarded Message —–
From: Samuel Short <samuel.short@tceq.texas.gov>
To: kim feil <kimfeil@sbcglobal.net>
Cc: Steve Dayton <steve.dayton@tceq.texas.gov>
Sent: Monday, November 23, 2015 9:44 AM
Subject: RE: TERP not eligible for stationary engines at drill sites
Good morning Ms. Feil,
Depending on the area in which the facility is located, most oil and gas sites utilize 30 Texas Administrative Code Chapters 106.352(a)-(k) or 106.512. These permit by rules have certain NOx requirements associated with them. In addition, federal standards New Source Performance Standards (NSPS) JJJJ and Maximum Achievable Control Technology (MACT) ZZZZ, both located in the Code of Federal Regulations, may also apply at these locations. At this time, we do not maintain a list specific to if a site that has registered a permit by rule utilizes catalytic convertors. Thank you
Samuel Short, Manager
Rule Registrations Section
Air Permits Division, TCEQ
(512) 239-5363
From: Steve Dayton
Sent: Friday, November 20, 2015 9:12 AM
To: kim feil
Cc: Samuel Short
Subject: RE: TERP not eligible for stationary engines at drill sites
Ms. Feil,
I have forwarded your request to Mr. Sam Short, Manager of our Rule Registrations Section.  That is the group that deals with the PBRs.  Their number is (512) 239-1264.  He will have someone work on your request regarding PBRs.
Also, to follow up on your discussion, you are correct that certain pipeline compressor projects could be funded under TERP.  The difficulties with what you are discussing include: (1) the grants can’t be used for meet any permit standards for emissions; (2) to be eligible, a retrofit system must be verified by EPA to reduce NOx emissions on that particular type of engine by a defined percentage (at least 25%) – and the emissions reductions for these types of systems on stationary compressors have not necessarily been verified through an official verification program; (3) in addition to the PBR requirements, the engines in general may have to meet certain regulatory standards for emissions and standards they must meet if they upgrade the engine, and any grant would be based only on the additional reductions that may be achieved beyond those standards, making the level of emissions reductions not be enough to qualify for enough grant money to make the project work.
So in some cases, stationary compressor projects may be eligible under the grant program, primarily electrification.  Retrofitting an existing engine with emission control systems could be eligible, but there are a lot of criteria that would have to be met.
Stephen Dayton
Technical Specialist
Implementation Grants Section
Air Quality Division
Texas Commission on Environmental Quality
(512) 239-6824
How is our customer service? Fill out our online customer satisfaction survey at www.tceq.texas.gov/customersurvey.
cid:image001.png@01CE990A.069A20D0
From: kim feil [mailto:kimfeil@sbcglobal.net]
Sent: Thursday, November 19, 2015 11:26 PM
To: Steve Dayton
Subject: Re: TERP not eligible for stationary engines at drill sites
“..to a limited extent, emissions from stationary engines where the engines are not covered under permit requirements”.  OK technically every Arlington padsite under a PBR is not required to use emission control devices (aka not covered under a permit) on the compressor/engines if they claim to be under 25 tpy VOC’s which they all do.
I don’t understand why those lift compressors that do not have catalytic convertors aren’t fair game for emission controls when the emission devices can capture the majority of the NOX.
Help me get a list of PBR’s who do not use catalytic convertors.
Please respond.
Kim
—– Forwarded Message —–
From: Steve Dayton <steve.dayton@tceq.texas.gov>
To:kimfeil@sbcglobal.net” <kimfeil@sbcglobal.net>; “robert.rivera@arlingtontx.gov” <robert.rivera@arlingtontx.gov>
Cc: Amanda Guthrie <Amanda.Guthrie@tceq.texas.gov>
Sent: Thursday, November 19, 2015 9:47 AM
Subject: RE: Question-Urban Drilling Sites
Ms. Feil,
Thank you for your interest in our grant programs.  Our Emissions Reduction Incentive Grants (ERIG) Program is statutorily directed towards mobile emissions and, to a limited extent, emissions from stationary engines where the engines are not covered under permit requirements.  In addition, our programs are aimed at reductions in nitrogen oxides (NOx).  This type of project is not eligible under our ERIG Program.
We encourage you to contact our air permitting staff at (512) 239-1250 with any questions regarding permit requirements and questions about compliance.
Sincerely,
Stephen Dayton
Technical Specialist
Implementation Grants Section
Air Quality Division
Texas Commission on Environmental Quality
(512) 239-6824
How is our customer service? Fill out our online customer satisfaction survey at www.tceq.texas.gov/customersurvey.
cid:image001.png@01CE990A.069A20D0
From: kim feil [mailto:kimfeil@sbcglobal.net]
Sent: Tuesday, November 17, 2015 5:15 PM
To: Amanda Guthrie
Subject: we just spoke on the phone
—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To:amanda.guthrie@tceq.tx.gov” <amanda.guthrie@tceq.tx.gov>
Cc: Robert Rivera <robert.rivera@arlingtontx.gov>
Sent: Tuesday, November 17, 2015 1:25 PM
Subject: we just spoke on the phone
Most of the Urban Drilling padsites operate under an honor system (called Permit By Rule) saying that their operations are under 25 tons per year VOC’s in our neighborhoods. Therefore there is no mandate or incentive for them to employ Best Available Control Emissions Technologies (like catalytic convertors on lift compressors)…until NOW through the ERIG program? Our 20 million in tax dollars? could be used to get the cleanest air possible at these Urban Drill sites since the drillers won’t pony-up on their own.
Thanks for checking into the appropriateness of my idea to have the drilling operators apply for this money.
Kim
—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: Maria Carbajal <maria.carbajal@arlingtontx.gov>; “jessica.minley@arlingtontx.gov” <jessica.minley@arlingtontx.gov>; Collin Gregory <collin.gregory@arlingtontx.gov>; Chris Klaus <cklaus@nctcog.org>
Cc: Jim Parajon <jim.parajon@arlingtontx.gov>; Trey Yelverton <trey.yelverton@arlingtontx.gov>; Jeff Williams <jeff.williams@arlingtontx.gov>
Sent: Tuesday, November 17, 2015 12:54 PM
Subject: Arl 2.3 million cu ft annual CH4 waste… How to force drilling operators to apply for ERIG assistance for lift compressors?
This page provides information on the ERIG Program that provides grants for eligible activities to offset the incremental costs of projects that reduce emissions of nitrogen oxides (NOx) from high-emitting internal combustion engines in eligible areas.
Preview by Yahoo
Here is my quick and dirty on these lift compressors (not including compressor stations)…info 4 free-thank me later…
Image removed by sender. image
TCEQ has on file through the NOVELL system where you can type in the PBR registration number. That is where I saw that the Truman site (and the GM site) have lift c…
Preview by Yahoo
I posed the Q earlier with one of the Arlington gaswell inspectors if there was a city mandate for catalytic convertors for these lift compressors, but was referred to TCEQ.
If the state won’t make them use Best Available Control Technologies (cause they are under their 25 tpy on their PBR estimates), and the city doesn’t force them via weak gas well language, then how can these funds be accessed by the city to turn around with some incentive plan to ask the operators to add BACT to these lift compressors?
—– Forwarded Message —–
From: Texas Commission on Environmental Quality <tceq@service.govdelivery.com>
To: kimfeil@sbcglobal.net
Sent: Tuesday, November 17, 2015 9:05 AM
Subject: Texas Emissions Reduction Plan (TERP) Program Update
Emissions Reduction Incentive Grants (ERIG) Program Application Workshops
ERIG application workshops have been scheduled to provide an overview of program requirements and the application process. Workshops are free of charge and registration is not required.
  • ARLINGTON: December 7, 2015
    9:30 a.m. Dealer Workshop
    1:30 p.m. Applicant Workshop
    North Central Texas Council of Governments
    616 Six Flags Drive
    Arlington, TX 76011

 

end update————-

Back in 2012 I asked for enforcement 7.01 #6….regarding closed flowback tanks…keep asking…i won’t quit…will you?

 

Words on a page, they fail to be enforced and even when they seem to mean one thing, it’s another.

Screen shot 2015-11-13 at 12.02.35 PM

So why bother?

We see visible plumes of exhaust and silica dust as well as toxic steam …..I’ve seen the film of dust on my car during fracking, I’ve smelled familiar odors of diesel exhaust, and I’ve smelled odors that were unidentifiable….the words on a page that fail to be enforced must be accountable to the citizens that trust those words will have teeth to protect them…

Screen shot 2015-11-13 at 12.09.44 PM

http://www.arlington-tx.gov/cityattorney/wp-content/uploads/sites/15/2014/05/GasDrilling-Chapter.pdf

Screen shot 2015-11-13 at 12.09.23 PM Screen shot 2015-11-13 at 12.08.05 PMScreen shot 2015-11-13 at 12.07.44 PMScreen shot 2015-11-13 at 12.06.56 PMScreen shot 2015-11-13 at 12.06.44 PMScreen shot 2015-11-13 at 12.06.26 PM

We live and very well may die early in ArlingtonGasFAIL Texas

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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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