Arlington Gas Lift Compressors up to 2.3 million cu ft annual CH4 Losses to atmosphere

The TCEQ Truman (drillsite by ATT Stadium) Chesapeake PBR 2013 estimated emissions as found on the TCEQ Novell system. Note their eleven storage tanks. Per PIR emails two lift compressors were added, one on 12/3/14 and the other on on 5/22/15 which adds 263 pounds per year per engine…times TWO engines is 526 pounds per year in my noseshed!
Screen shot 2015-11-17 at 11.11.36 AM
Guesstimate that 526 ppy Formaldehyde (CH2O) per padsite times 55 padsites? in Arlington could yield what…say….almost 30,000 pounds annually of Formaldehyde sourced nosebleeds CITY WIDE?
——————————
Note in the below email in boldfaced is my questions to the TCEQ on the Truman PBR.
—– Forwarded Message —–
From: Samuel Short <samuel.short@tceq.texas.gov>
To: “kimfeil@sbcglobal.net” <kimfeil@sbcglobal.net>
Cc: Elizabeth Smith <elizabeth.smith@tceq.texas.gov>; Jaret Wessel <jaret.wessel@tceq.texas.gov>; Aimi Tanada <Aimi.Tanada@tceq.texas.gov>; David Reyna <david.reyna@tceq.texas.gov>
Sent: Tuesday, April 5, 2016 8:23 AM
Subject: FW: on the attached PBR for the loading page typo?

Good morning,

The regional office forwarded me your questions with regards to the attached PBR oil and gas emissions spreadsheet. I had one of the Section’s technical specialist look it over and hopefully we have fully addressed all your questions. Please let me know if you have any additional questions. Thank you

Samuel Short, Manager

Rule Registrations Section

Air Permits Division, TCEQ

(512) 239-5363

Samuel.Short@tceq.texas.gov

Hello, please reference PBR 106536 on the loadings page… is the

105.24 VOC uncontrolled correct or should it be 1.05?

Both the numbers are correct depending on where you are looking on the spreadsheet. 105.24 TPY represents the total VOC from crude oil and 1.05 TPY represents the VOC from produced water which is 1% of the total VOC of crude oil.

Since the oil or condensate liquid floats on top of the water phase, it is the VOCs that are contributing to the partial pressure of the tank. Therefore, when estimating working and breathing losses, the tank should be assumed to have 100% VOC content. The agency does recognize that applicants may attain their own speciated sample from the tank which may reduce the VOC content entrained in the water. Therefore, at this time applicants represent a VOC content of 1% or greater for produced water. These results should account for the known types of emissions associated with produced water from storage tanks.

For further information please see the Guidance “Emissions Representation for Produced Water

And for the wt% benzene on the produced water tanks…were they suppose to provide support notes? When you hover above the red triangles it says that. How do I convert wt% to pounds per year?

The company is supposed to provide the gas lab analysis used to fill out the spread sheet attached to the permit application. This covers the support notes you mention.

To convert to wt% to pounds per year you would need to take total gas emissions for the gas lab analysis entered and multiple by they percent of the gas or product emitted (in this case Benzene).

For example, let’s say you have total gas emissions of 8.33 lb/hr and Benzene at wt% of 0.05%. To find the lb/hr of Benzene you would (8.33*0.05/100) = 0.0042 lb/hr.

For the example you submitted in the spread sheet the emissions are so small for Benzene that you only see 0.00.

And for the engines/formaldehyde, they were made to use emissions info prior to controls and so what is the final formaldehyde emissions?

 

The formaldehyde emissions are based on the manufactures test data from the engine as represented in the spread sheet example.  The final formaldehyde emissions from the engine are 0.03 lb/hr and 0.12 tpy for the engine.

From: Elizabeth Smith
Sent: Friday, April 01, 2016 9:13 AM
To: Samuel Short
Cc: Jaret Wessel; Aimi Tanada
Subject: FW: on the attached PBR for the loading page typo?

Sam,

It appears that the questions below may be better handled by someone in APD.  Would someone from your group be able to respond to Ms. Feil?

Thanks,

Elizabeth M. Smith

Air Section Manager

TCEQ DFW Region

817-588-5838

From: Aimi Tanada
Sent: Monday, March 28, 2016 7:34 AM
To: Jaret Wessel <jaret.wessel@tceq.texas.gov>; Elizabeth Smith <elizabeth.smith@tceq.texas.gov>
Subject: FW: on the attached PBR for the loading page typo?

From: kim feil [mailto:kimfeil@sbcglobal.net]
Sent: Sunday, March 27, 2016 2:01 AM
To: Aimi Tanada <Aimi.Tanada@tceq.texas.gov>
Subject: on the attached PBR for the loading page typo?

Hello, please reference PBR 106536 on the loadings page… is the

105.24 VOC uncontrolled correct or should it be 1.05?

And for the wt% benzene on the produced water tanks…were they suppose to provide support notes? When you hover above the red triangles it says that. How do I convert wt% to pounds per year?

And for the engines/formaldehyde, they were made to use emissions info prior to controls and so what is the final formaldehyde emissions?

Thanks

Originally this post was to inform of the potential methane losses to the environment with all the blowdown maintenance of lift compressors at all the drill sites in Arlington (and elsewhere)…instead I realized that our CITY INSPECTIONS ARE INADEQUATE AND A WASTE OF TAX DOLLARS !…

You will need to go through the info here to get to the good part where I prove the statement…

“This makes me see that giving a pass, fail, or N/A answer to these questions on our CITY GASWELL INSPECTIONS is like “giving a visual inspection to a vagina to see if passes the sniff test for AIDS” based on Collin’s first response in not knowing about emission control devices on lift compressors that they inspect!”

Once to get to that part, I eventually go back to blowdown information and

 

Screen shot 2015-11-17 at 4.15.54 PM

“Regarding your lift compressors that are on the Urban Drilling Barnett Shale drill sites and compressor stations such as the G3406NA, 3306NA, and your G3608 tale, can you tell me if these units include a catalytic converter to control emissions or if there is an option to purchase these as add ons? If so please provide the model numbers and if these controls would reduce NOX by 25% which is the requirement the state has to consider in awarding any of the twenty million dollars available in TERP funding”. update=NO RESPONSE FROM THIS VENDOR

update on trying to get TERP funding=FAIL!

Please send our Arlington City Council a request to enforce 7.01 #6 of our Gas Well Drilling Ordinance to use catalytic converters 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 in an ozone non-attainment area like we are:
25 tpy of VOC, SO2, PM10, other
AND
250 tpy of NOx & CO
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? (update NO RESPONSE from Jim Parajon)
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 converters. Thank you
Samuel Short, Manager
Rule Registrations Section
Air Permits Division, TCEQ
(512) 239-5363
 END UPDATE___________________________________________

Based on a Chesapeake emissions estimate on the GM padsite’s blowdown figures, I calculated that city wide for Arlington’s BLOWDOWN (maintenance) events from lift compressors, that our Urban Drilling experiment can release up to 2.3 million cubic feet of dirty, raw (mostly methane) gases into our atmosphere annually (if every padsite ends up with two lift compressors). This contributes to GHG emissions that the feds are finally regulating under the Clean Air Act due to climate change.

On TCEQ’s Permit By Rule database on file through the NOVELL system anybody can type in their local gaswell padsite in their airshed’s PBR registration number and see emissions information. That is where I saw that the Truman site (and the GM site) has non-electric engines that release direct ozone formation constituents, NOX and VOC’s in our airshed.

Screen shot 2015-11-17 at 11.11.36 AMPictured above is the TCEQ Truman Chesapeake PBR 2013 estimated emissions as found on the TCEQ Novell system. Note their eleven storage tanks. Per PIR emails two lift compressors were added, one on 12/3/14 and the other on on 5/22/15 which adds 263 pounds per year per engine…times TWO engines is 526 pounds per year in my noseshed!

TCEQ has twenty million dollars available for grants to reduce emissions and so the idea is to see if we can help these poor drilling operators afford to use emission controls at these drill sites in our backyards of Urban Drilling since our ordinance has weak language to specifically mandate BACT (Best Available emission Control Technologies). See in the boldface below for the Arlington Gas Well Ordinance WEAK language….

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“.

WHO DECIDED on our city gas well ordinance WHAT WAS “best accepted practices” ??????

I do not  “accept” best accepted practice…I EXPECT Best Available Control Technologies (BACT).

….we all should especially since no one did a health & environmental impact study for URBAN DRILLING.

Two types of emissions come from the Viagra art of water/gas lifting:

  1. engine exhaust from combustion engines which can be mostly controlled with catalytic converters (why don’t we mandate catalytic convertors. Or just flat out mandate these engines be electric? One draw back from the electric engines is they are dangerous when we have electrical black outs…I blogged about this before) and
  2. blowdown GHG’s (green house gases… along with BTEX).

Under the TCEQ’s Permit By Rule (the honor system), drillers are not obligated to purchase emission control devices if the site itself emits under 25 tpy VOCs, SO2, PM10, other AND under 250 tpy NOx & CO. That would be where the city should come in and mandate AND VERIFY the use of catalytic converters on compressor engines via  O U R  Gas Well Ordinance.

So if there are solutions to the engine exhaust, what then can be done about the blowdown gases from the lift compressors that our Dream City has allowed which is speeding us over the climate change cliff?

First of all did we ever realize these wells would need compressors? Here is a comical video on that subject matter that I videotaped at the Pantego TX city meeting with a Carrizo representative.

A Carrizo rep said at the Pantego P&Z Dec 2012 meeting that these more expensive ELECTRIC lift compressors are routinely taken down for “PLANNED” maintenance and that their process to mitigate emissions during shut down (blowdown) is as follows… “that gas is sent into the sales line until its actually bled down to the low lying pressure that’s in that system-down to about 200 lbs and then ..it…(the excess pressure/gas)goes to the tanks” (which indirectly vents to the atmosphere please watch/listen to that video.

So if Carrizo (now Enervest) takes the care to not release everything in the piping to the atmosphere…OTHER operators should at least be doing it too?…how to know?…. and unless we spell that out in our ordinance and then (verify) they are doing this…we may be missing the opportunity to stop methane from unnecessarily going into our atmosphere every time they take down the compressors to maintain the valves.

A month earlier (Nov 2012) this video was taken at that Pantego Carrizo site that shows what is probably a lift compressor blowdown because here is the google earth shot showing what is low and next to the tanks…a shed looking thang….Screen shot 2015-11-19 at 8.59.12 AM

In addition to compressor blowdowns, the storage tanks vent  to the atmosphere. Here is a video /audio of the Pantego storage tanks venting event.

Here is a NCTCOG presentation from Chesapeake and Devon that to me reads like a laundry list of excuses to NOT employ BACT’s.

Getting back to the Chesapeake Truman PBR info (this padsite is near the ATT Stadium), note just the Carbon Monoxide in itself is worrisome (short-term memory loss anyone?) as an INdirect contributor to ozone formation. Per engine (times two for the Truman site), figure at least 6 tpy of Carbon Monoxide (CO)  based on the Truman’s Caterpillar model G3406 NA.

Why am I fretting over 12 tpy of CO when the state doesn’t worry about it until its 250 tpy?

BECAUSE ITS IN OUR NEIGHBORHOODS AND URBAN DRILLING SHOULD MANDATE BEST AVAILABLE CONTROL TECHNOLOGIES  ….P E R I O D.

So the million dollar question is if they voluntarily use emission control devices on these lift compressor engines?  Catalysts take nasty pollutants like Carbon Monoxide and convert it to CO2 using a platinum metal and we should take advantage of that technology….we are mandated to have these on our vehicles.

So hold yer breath and read the  total F AI I L response from one of our Arlington city officials who work in the gas well inspection department….. 

DSCN5367

Not helpful here…..I pay local property taxes…this irks me

When I probed further I got this city response…

—– Forwarded Message —–
From: Collin Gregory <Collin.Gregory@arlingtontx.gov>
To: ‘kim feil’ <kimfeil@sbcglobal.net>
Sent: Monday, November 23, 2015 3:56 PM
Subject: RE: 7.01 #21 exhaust muffler same as catalytic convertor?

Kim,

1.       An internal combustion engine is an engine that generates motive power by the burning of gasoline, oil, or other fuel with air inside the engine, the hot gases produced being used to drive a piston or do other work as they expand. 

2.    A muffler is a device for decreasing the amount of noise emitted by the exhaust of an internal combustion engine. 

3.    A catalytic converter is used to convert harmful pollutants into less harmful emissions before they ever leave the engines exhaust system. 

7.01 #21 states:

Exhaust from any internal combustion engine (this could include such engines as a vehicle engine, a compressor, a generator, etc…) , stationary or mounted on wheels, used in connection with the drilling of any well or for use on any production equipment (which means that any engine on the site that is used in drilling or production activity falls into section 7.01 #21.  That would include rigs, compressors, generators, tools or equipment) shall not be discharged into the open air unless it is equipped with an exhaust muffler, or mufflers or an exhaust muffler box constructed of noncombustible materials sufficient to suppress noise and prevent the escape of obnoxious gases, fumes or ignited carbon or soot.

Inspections of engines on-site are done through both visual inspection and noise monitoring.  Any engine that is suspect of being out of compliance with 7.01 #21 will be required to be shut down and removed from site.  Please refer to inspection results on the gas well web page for compliance status of sites. 

http://www.arlingtontx.gov/email/COA%20logo.png

Collin Gregory
Gas Well Coordinator

Community Development and Planning, City of Arlington

817.459.6593 | Fax 817.459.6665

Mail Stop  01-0241 | 101 W. Abram St. | Arlington, TX 76010
www.arlingtontx.gov | www.myarlingtontx.com

http://www.arlingtontx.gov/email/Facebook-icon-email.png  http://www.arlingtontx.gov/email/Twitter-icon-email.png  http://www.arlingtontx.gov/email/YouTube-icon-email.png

 

update 2/19/2016…..

Screen shot 2016-02-19 at 10.41.46 AM

2/19/2016 update…FINALLY! PROOF TRUMAN SITE “IS” USING A CATALYTIC CONVERTOR/CATALYST SEE THE “YES” ANSWER TO THE NSCR Catalyst question? This shouldn’t have been this hard to me to find on my own to get this info!!

This makes me see that giving a pass, fail, or N/A answer to these questions on our CITY GASWELL INSPECTIONS is like…

 “giving a visual inspection to a vagina to see if passes the sniff test for AIDS”

based on Collin’s first response in not knowing about

emission control devices on lift compressors that they inspect!

 

Screen shot 2016-02-19 at 12.24.33 PM

end of that rant……

Below are a few more snap shots of the Truman PBR…think I found a typo…its bad enough I found out that the Chesapeake GM padsite had underestimated benzene emissions by 75%!

 

Screen shot 2016-02-19 at 10.42.59 AM

Screen shot 2016-02-19 at 11.05.03 AM

ooops a typo on the 105.24 tpy?

While talking about vaginas and  AIDs, I minus well get back to BLOWdowns…(no wonder alot of people refer to the whole fracking process as “fracking”- the noun IS the verb and it is happening to us in our own backyards)….

I looked at the General Motors padsites PBR# 101916, in their Process Description, their Caterpillar 3306 NA engines have an estimated 20 blowdowns a year per engine from their two 145 horsepower lift compressors “Approximately 1,000 cubic feet of gas could be vented to the atmosphere during a blowdown. One blowdown could occur in a one hour period”.  I figure 20,000 cubic feet of methane per year per lift compressor. If each of Arlington’s 57 padsites (including UT Arlington) has two lift compressors, then 114 lift compressors times an annual 20,000 cubic ft of natural gas equals about 2.3 million cubic feet of GHG’s annually released in  O U R Arlington TX air shed (not including our two gas compressor facilities).

In looking at Q3  2015 Arlington gas well inspection reports only about half of the pad sites currently have lift compressors…and it is routine practice to have the compressor units picked up and removed from the site, so unless I do a PIR for the site plans of each padsite, I can only guess how many lift compressors we have so this is the high end estimate of 2.3 million cubic feet per year…just in Arlington (gasland) Texas. Note after the Aliso Canyon leak was plugged, this article came out http://www.texasobserver.org/fracking-barnett-shale-disaster/

California Capped a Massive Methane Leak, but Another is Brewing — Right Here in Texas

DSCN3584

General Motor’s 2012 PBR on compressor BLOWdowns

Yesterday a TCEQ guy pointed an infrared camera at one of the lift compressors at my Truman site by my house when investigating a sewerey odor complaint me and my husband experienced on 11/10/15 and while he did not experience any “odors”, his camera did see “exhaust” coming off of the one compressors that he was able to point the camera at (meaning he was offsite trying to get a look). And so it must be running on natural gas and therefore has combustion. With combustion comes formaldehyde (nose bleeds anyone?). On the Truman site, their PBR shows the formaldehyde emissions to be 500 lbs per year (before controls) and 80 lbs per year of Benzene….in my neighborhood.

OH BTW the lift compressor methane losses info of my estimated 2.3 million cubic feet annually of GHG’s does NOT include the two Arlington Compressor Stations (Lake Arlington & Eden/Harris locations) that do nothing but compression (see email below)…….
Arlington TX is a global warming leader!  Gotta lead somehow…really embarrassed.
As usual, here are my love letters for future generations to reference that I tried…what will YOUR children ask of YOU that YOU could’ve done in this endeavor to slow down climate change?
—– Forwarded Message —–
From: Anne Inman <anne.inman@tceq.texas.gov>
To: kim feil <kimfeil@sbcglobal.net>
Sent: Wednesday, August 28, 2013 12:55 PM
Subject: RE: R these math conversion errors on VOC lbs/hr to tpy?

Dear Ms. Feil:

I have reviewed the two subject registrations (PBR 79984 and standard permit (SP) 90487) concerning your questions on lbs/hr to tpy math conversion for two sites.   The math is correct for the conversions in all three cases below.  However, in the second case, the company rounded up the blowdown emissions significantly that without the permit file, a person reviewing the registration letter and the associated public technical review would not have the specifics of the conversion.

PBR 79984 had condensate loading emissions listed for the throughput volume of condensate of one 400 bbl tank per year.  The company represented this would unlikely but would estimate conservatively emissions in the event of producing condensate.    Tank calculation using EPA Tanks 4.0.9d listed the condensate as gasoline with an RVP of 8.   The calculations showed vapor pressures of 4.1873 psia minimum, 4.6885 psia average and 5.32370 psia maximum and a 68 vapor molecular weight.  So the following loading calculations using a vapor pressure of 7 psia and a temperature of 521.4 degree R should be conservative.   Condensate loading emissions are based upon AP-42 Section 5.2.2.1, 1995 Edition, equation LL= 12.46 SPM/T where S=0.6, P =7 psia, M= 62 MW, T = 521.4 degree R, and no control or efficiency.   LL = 6.22 lbs VOC/1000 gal loaded.   Company listed 16,074 gal/yr of condensate throughput or 383 bbls/yr on the Truck Rack Loading calculations sheet.  They also listed only loading 1000 gal/hr as the maximum amount of condensate loading.    Therefore 6.22 lbs/hr and (16,000 gal/yr*6.22 lbs VOC/1000 gal loaded) 0.05 tpy were listed as the loading emissions.

PBR 79984 had compressor blowdowns purge total volume calculated by assuming a volume release of gas released based upon the equation Q(Mcfh)= D(in0^2*P1(psi) from page 278 of the Pipeline Rules of Thumb, Fourth Edition and using parameters (diameters, lengths and pressures) from 15 different vessels/components.  The parameters are listed on page 1 of the Compressor Blowdown Calculations VOC Emissions Quantification- Inputs and Volume Calculation Page in the file.  3291.7 scf/blowdown was calculated.   The site gas analysis was applied to the blowdown emissions and 0.69 lbs VOC/blowdown was calculated.    The company assumed 60 blowdown /yr per compressor.  The company also assumed that it takes 0.25 hrs/blowdown but assumed 4 blowdowns total per hour and rounded the result to 3.0 lbs/hr total for the short term value.  They also calculated the annual blown emissions for both compressors as 60 blowdowns/compressor* 2 compressors/2000 lbs/ton equals 0.04 tpy and rounded up to 0.10 tpy.

SP 90487 had a maximum working emission rate of 31.02 lbs/hr from filling each tank at a maximum pumping rate of 16,800 gal/hr using Equation 1-23 (Lw = 0.0010 MvPvaQKnKp) in AP-42 , Chapter 7, 9/97 Edition.   Only 10,000 bbls/yr of methanol are put through each  tank so that only 25 hours of pumping occurs at the maximum rate for the yearly working loss.   The differences in calculating the average annual and maximum working losses are based upon the differences in true vapor pressure at daily average liquid surface temperature of 2.20 psia and the true vapor pressure at daily maximum liquid surface  temperature of 2.42 psia.   Lw(avg) = 705.10 lbs/yr and Lw(Max) = 775.61 lbs/yr.   Ignoring the standing losses for the maximum methanol tank working emission rate of 31.02 lbs/hr  and adding the yearly tank standing loss of 0 0.08722 tpy to the average annual working loss of 705.1lbs/yr/2000lbs/ton = 0.35255 tpy, a total of 31.02 lbs/hr and 0.43977 tpy  = 0.44 tpy are calculated for the methanol tank losses.

I hope this helps explain the emission quantification questions you have.

Sincerely,

Anne M. Inman, P.E.

Manager, Rules Registration Section

Air Permits Division, Office of Air, TCEQ

512-239-1276

Anne.Inman@tceq.texas.gov

http://home.tceq.state.tx.us/internal/exec/communication/gif/tceqseal_color_initials.gif

From: kim feil [mailto:kimfeil@sbcglobal.net]
Sent: Tuesday, August 27, 2013 10:03 PM
To: Anne Inman
Subject: R these math conversion errors on VOC lbs/hr to tpy?

Regarding the Handley Compressor Station RN 105072979, CN 602673071  2007 PBR#79984 may have a math error for Fugitives /truck loading with VOC lbs/hr at 6.22 converting incorrectly to .05 tpy and a math error for

Blowdowns with VOC lbs/hr at 3.0 incorrectly converting to .10 tpy.

Regarding Lake Arlington Compressor Station RN 105227763, Standard Permit #90487 may have a math error for

Methanol tanks 5 & 6 with Voc lb/hr at 31.04 incorrectly converting to .44 tpy and a math error for

tanks 7,8,11, & 12 having related errors where the lbs/hr is > tpy.

Please let me know why these are like this, thanks.

Kim Feil

 ————————

Love letter to the city….

—– 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?
Here is my quick and dirty on these lift compressors (not including compressor stations)…info 4 free-thank me later…
I posed the Q earlier with one of the Arlington gaswell inspectors if there was a city mandate for catalytic converters 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.
  • EL PASO: December 3, 2015
    1:30-4:30 p.m. Applicant Workshop
    El Paso Public Library-Main Branch
    501 North Oregon Street
    El Paso, TX 79901
  • 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
  • LONGVIEW: December 8, 2015
    1:30 p.m.
    Longview Public Library
    222 West Cotton Street
    Longview, TX 75601
  • HOUSTON: December 8, 2015
    6-8 p.m. Applicant Workshop (en Español)
    Tracy Gee Community Center
    3599 Westcenter Drive
    Houston, TX 77042
  • HOUSTON: December 9, 2015
    9:30 a.m. Dealer Workshop
    1:30 p.m. Applicant Workshop
    Tracy Gee Community Center
    3599 Westcenter Drive
    Houston, TX 77042
  • CORPUS CHRISTI: December 9, 2015
    1:30 p.m.
    TCEQ Region 14 Office
    NRC Bldg., Ste. 1200
    6300 Ocean Dr., Unit 5839
    Corpus Christi, Texas 78412
  • BEAUMONT: December 10, 2015
    1:30 p.m.
    Southeast Texas Regional Planning Commission
    2210 Eastex Freeway
    Beaumont, Texas 77703
  • AUSTIN: December 10, 2015
    9:30 a.m. Dealer Workshop
    1:30 p.m. Applicant Workshop
    TCEQ’s Austin Office
    Building E, Room 254S
    12100 Park 35 Circle
    Austin, TX 78753
  • SAN ANTONIO: December 14, 2015
    9:30 a.m. Dealer Workshop
    1:30 p.m. Applicant Workshop
    Alamo Area Council of Governments
    8700 Tesoro Drive, Suite 700
    San Antonio, TX 78217
  Please contact us toll-free at 800-919-TERP (8377) or by email at terp@tceq.state.tx.us with any questions. 
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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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