Letter asking 4 non-chemical brine treatments & reclassify loads as TENORM

Sometimes a good old fashioned letter (or twenty) can educate and motivate so that we can have new protective rule making…
Screen shot 2016-01-11 at 11.12.57 AM
—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: “co’hara@spartnerships.com” <co’hara@spartnerships.com>
Sent: Sunday, January 10, 2016 11:18 PM
Subject: Chelsea, request for YOUR HELP in pleading with our legislators for new laws to prohibit the use of chemicals to treat/recycle/repurpose oil & gas waste waters.
Ms. O’Hara, my name is Kim Feil and I live in Arlington very near General Motors & ATT Stadium. I also live with about 55 drill sites in our inner city limits of almost 100 square miles in our air & water shed. I am reaching out to you because my 5+ year volunteer research on loop holes to public protections of Urban Drilling has recently uncovered that some proactive measures are needed to protect our drinking water resources in the Barnett & Eagle Ford Shales that our municipalities have the job of disinfecting.
Currently we inject the majority of oil & gas waste at injection well disposal sites, but the increased seismicity we are seeing in Oklahoma could one day cause a change in the use of injection wells in Texas if we start to see more seismicity here. Being proactive or reactive to how we dispose oil & gas waste waters (also known as formation/produced/brines) could involve the use of either more above ground waste storage pits (that risk ground & surface water resources with floods and leaks) or apply for a permit to “treat & release” where allowed.
In treating & releasing (allowed west of the 98th meridian), this is where I NEED YOUR HELP in pleading with our legislators for new laws to prohibit the use of chemicals to treat/recycle/repurpose oil & gas waste waters. The work of geochemists like Avner Vengosh, Dr Plata, and others say that adding chemicals like chlorine complicates the already toxic, briny fluids (I call this complication “frack on crack”). Just last week in Midland a 23 year old died from an explosion in mixing chemicals for a waste water recycling company.
Also in our Texas permitting process for treating and releasing, the RRC and the EPA does not mandate we test for radionuclides or any of the chemicals found on the Frac Focus Disclosure Registry before releasing. Treating produced waste waters without the use of chemicals is a prudent measure in reducing unwanted, cytotoxic disinfectant by products.
An example of the harm that may have already occurred right here in Arlington is that since we started Urban Drilling in 2007, we saw elevated TTHM (total trihalomethane) levels of DBP’s (disinfectant by products). We have almost tripled TTHMs from our 2003-2006 levels. I even see the decrease correlation in Ft Worth’s TTHMs starting in 2012 when drilling dropped off when natural gas prices went down.
In our Lake Arlington 2011 Water Protection Plan, we looked at a drill site’s “load” using Denton TX’s water study info to understand how much that would add to the risk. Ref pg 511 “Under this scenario, an average a gas well site point source is estimated to contribute 7,100 lbs of TSS annually to the receiving waters in the watershed“.
I also need your help in reclassifying how our oil & gas waste waters are not reflecting it’s proper constituency during truck hauling on our roadways. These fluids are not natural formation waters since we added man-made chemicals in hydrofracturing the shale, along with additives in the drilling mud, and have disturbed and created halogens in mining for these energy resources. Specifically these waste waters and drilling mud/mud farming should be classified as Technologically Enhanced or TE-NORM. To reach the sweet spot we look for the most energy dense, radioactive formations and with this reclassification, TXdot requires more accountability/record keeping with such loads than what is currently required.
Thank you for forwarding this email, or doing your own research and asking our/your representatives to help us protect our drinking water resources with the advent of such a great build out of padsites all over Texas, thank you.
Kim Feil
———————–end personalized letter example——–
Below is a tweeked version of the above personalized letter cut and paste ready for our representatives…
—- Forwarded Message —–
From: XXX
To: XXX
Sent: Sunday, January 10, 2016 11:25 PM
Subject: request for YOUR HELP in pleading with our legislators for new laws to prohibit the use of chemicals to treat/recycle/repurpose oil & gas waste waters.
Dear Legislator, I am writing because proactive measures are needed to protect our drinking water resources in the Barnett & Eagle Ford Shales that our municipalities have the job of disinfecting.
Currently we inject the majority of oil & gas waste at injection well disposal sites, but the increased seismicity we are seeing in Oklahoma could one day cause a change in the use of injection wells in Texas if we start to see more seismicity here. Being proactive or reactive to how we dispose oil & gas waste waters (also known as formation/produced/brines) could involve the use of either more above ground waste storage pits (that risk ground & surface water resources with floods and leaks) or apply for a permit to “treat & release” where allowed.
In treating & releasing (allowed west of the 98th meridian), this is where I NEED YOUR HELP in writing a new law to prohibit the use of chemicals to treat/recycle/repurpose oil & gas waste waters. The work of geochemists like Avner Vengosh, Dr Plata, and others say that adding chemicals like chlorine complicates the already toxic, briny fluids (I call this complication “frack on crack”). Just last week in Midland a 23 year old died from an explosion in mixing chemicals for a waste water recycling company.
Also in our Texas permitting process for treating and releasing, the RRC and the EPA does not mandate we test for radionuclides or any of the chemicals found on the Frac Focus Disclosure Registry before releasing. Treating produced waste waters without the use of chemicals is a prudent measure in reducing unwanted, cytotoxic disinfectant by products.
An example of the harm that may have already occurred right here in Arlington is that since we started Urban Drilling in 2007, we saw elevated TTHM (total trihalomethane) levels of DBP’s (disinfectant by products). We have almost tripled TTHMs from our 2003-2006 levels. I even see the decrease correlation in Ft Worth’s TTHMs starting in 2012 when drilling dropped off when natural gas prices went down.
In our Lake Arlington 2011 Water Protection Plan, we looked at a drill site’s “load” using Denton TX’s water study info to understand how much that would add to the risk. Ref pg 511 “Under this scenario, an average a gas well site point source is estimated to contribute 7,100 lbs of TSS annually to the receiving waters in the watershed“.
I also need your help in reclassifying oil & gas waste waters during truck hauling on our roadways. These fluids are not natural formation waters since we added man-made chemicals in hydrofracturing the shale, along with additives in the drilling mud, and have disturbed and created halogens in mining for these energy resources. Specifically these waste waters and drilling mud/mud farming should be classified as Technologically Enhanced or TE-NORM. To reach the sweet spot we look for the most energy dense, radioactive formations and with this reclassification, TXdot requires more accountability/record keeping with such loads than what is currently required.
Thank you for helping to protect Texan’s drinking water resources.
————-
UPDATE here is one response and Senator Cornyn failed to mention the frack chemicals in his first sentence in the second paragraph.

—– Forwarded Message —–
From: Senator Cornyn <SenateWebmail@cornyn.senate.gov>
To: kimfeil@sbcglobal.net
Sent: Tuesday, January 12, 2016 3:01 PM
Subject: Thank You For Contacting My Office

Dear Mrs. Feil:

Thank you for contacting me to express your concerns regarding the process of hydraulic fracturing and protecting our environment. I recognize the time and effort that you are dedicating to actively participate in the democratic process, and I appreciate that you and other concerned citizens have provided me the benefit of your comments on this matter.

As you may know, hydraulic fracturing uses a mixture of water and sand to extract oil and natural gas from dense shale far beneath the groundwater level. The hydraulic fracturing practice has been studied by the Environmental Protection Agency, the Ground Water Protection Council, and the Interstate Oil and Gas Compact Commission. At every step in the drilling process, energy producers are subject to state regulations as well as federal requirements through laws such as the Occupational Safety and Health Act; the Environmental Response, Compensation and Liability Act; and the Toxic Substances Control Act.

Federal environmental law has evolved over the past forty years to include the regulation of air quality, water quality, chemicals in commerce, development of regulatory criteria for the management and disposal of solid and hazardous wastes, and the cleanup of environmental contamination. I support efforts to improve our nation’s environmental quality and I believe regulations should be based on the best available science and risk-based standards. You may be certain that I will keep your concerns in mind as these matters are discussed.

I appreciate having the opportunity to represent Texas in the United States Senate. Thank you for taking the time to contact me.

Sincerely,

JOHN CORNYN

United States Senator

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