General Motors Chesapeake padsite’s Benzene UNDERESTIMATED 75% (120 lbs/yr)

Screen shot 2016-02-08 at 7.51.42 PM

PIC link to video of councils latest ground breaking apartment complex NEXT to fracking that they have blessed into our good city without a health & environmental impact study…before they approved the padsite ON General Motors campus, I begged them that the area was already overtaxed with GM emissions, but its all about the greed..read below….

UPDATE February 18 2016

—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: Chris Klaus <cklaus@nctcog.org>; Chris Kite <chris.kite@tceq.texas.gov>
CC: xxxx
Sent: Thursday, February 18, 2016 4:17 PM
Subject: {NCTCA} GM’s padsite was by 75% on Benzene-how can NCTCOG/TCEQ write SIP if drilling permits may be underestimated?
I received an email from TCEQ this morning informing me that my audit request resulted in the resubmission of a new (corrected) PBR.
I uncovered where GM’s Chesapeake drill site had an unreported amount on their PBR permit of Benzene by 75% (120 lbs/yr).
Mr. Klaus and Mr. Kite, please forward this email as appropriate and let me know your responses.
It would be appropriate to ask if NCTCOG can work with TCEQ to see if these underestimates affect any data you were using in writing a SIP for ozone attainment.
As for Mr Sean C Woolverton and the underestimation error, I cannot see what was submitted to STEERS, but if it was wrong on there too…(and it must have been because they resubmitted a new PBR in January because of this)…it would be appropriate to audit some other PBR’s he submitted. If this problem is widespread, I expect some entity to bring criminal charges as allowable by law.
Thanks
Kim Feil

—–end update—-

Arlington Gaswells SPEW an average of  14 lbs of Benzene per DAY city-wide !

If someone told you “sign here to be exposed to 5,000 pounds of Benzene per year city-wide (not including the 10-20 years worth of truck traffic emissions nor the two compressor stations emissions, nor the other town’s fracking emissions blowing to us)” would you have signed?

Averaging a quarter pound of Benzene per day per padsite times 55 padsites here in Arlington gasland Texas is 14 lbs day/city-wide. Note like radionuclides, there is no “safe” amount of exposure to Benzene…. and granted we drive stinky Benzene spewing cars and trucks…did we really need to industrialize our neighborhoods with gas mining production sites?

These BenZene emission estimates whiling including compressor engine blowdowns (planned MSS maintenance), they do NOT include new activity (like workovers or new wells being added which fall under the  NSPS quad o rules) and they do not include the Truck Fracking Traffic emissions daily coming and going from these sites to take away that toxic produced (flashing water) liquids to injection wells (that can later frack up our property & drinking water with frackquakes)

How did I obtain this BENZENE info? Well when you sue a large (albeit failing) energy company and are representing yourself, you dig deep, and in verifying Chesapeake’s permit with the state, I compared a small padsite like the Truman/CowboyStadium by my house to the big padsite(s) at GM and thought…that’s weird that the Truman permit has double the benzene than the GM one so I asked for an audit. I rec’d the results on investigation numbers 1306229 Truman & 1306227 GM Chesapeake padsite.

It turns out that Sean C Woolverton INCORRECTLY certified the emission numbers for the Chesapeake GM Padsite A & B.

He underestimated their benzene emissions by .06 tpy or 120 lbs/yr.

He reported .02 tpy and it should have been .08 tpy.

Thats a 75% error on a BENZENE reporting item!

Should he face criminal charges? The error seems to stem from the number of engines on that site.

TCEQ tried to defend Chesapeake in the investigation by saying that “The benzene emissions were represented correctly in the attached detailed emission calculation, but were inputted incorrectly in the registration form” 

DSCN5366

April 25 2012 E registration form

The investigation report said .o2 tpy should have been .05 tpy for Benzene. TCEQ noted during the Dec 2015 audit that 2 of 3 engines were running. But yesterday I received an update letter saying that GM reran the numbers and resubmitted a new PBR on January 11 2016 based on FOUR engines. The benzene went to .08 tpy (the other constituents went up too). Why would they use numbers based on 4 engines when TCEQ said only 3 engines were out there? It could be that the fourth engine was removed offsite for maintenance at the time of the audit.DSCN5357DSCN5358

In total GM’s Chesapeake padsite operations on their campus have 160 POUNDS OF BENZENE PER YEAR (.44 lb/day) not including the BenZene emissions from their General Motors facility for their SUV’s. And that blows to the Entertainment District & the Viridian.DSCN5280

—– Forwarded Message —–
From: Aimi Tanada <Aimi.Tanada@tceq.texas.gov>
To: kim feil <kimfeil@sbcglobal.net>
Cc: Jaret Wessel <jaret.wessel@tceq.texas.gov>
Sent: Thursday, February 18, 2016 9:04 AM
Subject: RE: Q on Truman/GM audit / Feil vs Chesapeake SC18172

Ms. Feil,

This is in response to your questions below regarding the emission calculations for the permit registrations for the GM A GM B Pad and Truman Pad sites.

A new registration for the GM Pad was submitted on 01/11/16. When submitting this change, Chesapeake re-ran all of the emission calculations for the entire site with updated information for four engines. This updated the previous values reported for benzene emissions from the registration submitted in 2012 as well. Based on the most recent information, the GM Pad shows the total permitted emissions from this site as 12.44 TPY VOC, 2.80 TPY NOx, 12.60 TPY CO, and 0.08 TPY Benzene.

The Truman Pad has not made changes to the site that would impact their emissions since the registration submitted in 2013. This site’s emissions are currently represented as 10.96 TPY VOC, 2.08 TPY NOx, 12.46 TPY CO, and 0.04 TPY Benzene. This site is permitted for two internal combustion engines.

In comparing the detailed emission calculations for the 4 engines at the GM Pad and the 2 for the Truman site, at the GM Pad the engine emission calculations represent emissions for 145 HP, 4-stroke, rich-burn, Caterpillar G3306 NA engines with 7775 Btu/hp-hr in fuel consumption, while the two engines for the Truman Pad use calculations for 215 HP, Caterpillar G3406 NA engines with 7915 Btu/hp-hr in fuel consumption. Differences such as these would impact how the emissions are calculated for each engine that is permitted for the sites.

Sincerely,

Aimi Tanada

Environmental Investigator

DFW Region Air Section – Barnett Shale Team

Texas Commission on Environmental Quality

( (817) 588-5879  * Aimi.Tanada@tceq.texas.gov

—– Forwarded Message —–

From: kim feil <kimfeil@sbcglobal.net>
To: Jaret Wessel <jaret.wessel@tceq.texas.gov>
Cc: Clark ; Anne Inman <anne.inman@tceq.texas.gov>; aimi.tanada@tceq.texas.gov
Sent: Friday, February 12, 2016 12:27 PM
Subject: Q on Truman/GM audit / Feil vs Chesapeake SC18172

Mr. Wessel, Ref investigation numbers 1306227 & 1306229
 
Now that the Benzene audit for the smaller Chesapeake Truman padsite (in comparison to the large Chesapeake GM padsite) is over and TCEQ found out that GM under reported Benzene on their E application PBR by 60 lbs/yr)…why does the Truman site still have more NOX (2.08 tpy) and Carbon Monoxide (12.46 tpy) than GM for Nox (1.4 tpy) and Carbon Monoxide (8.4 tpy)? Should those numbers be audited too? 
 
I do not think GM is using catalytic converters (even though not mandated) on their lift compressors. During the December 2015 audit, the Truman site had one compressor running, and the GM had two of three running; so please respond if the differing types of engines they use account for this.
 
As for the VOC’s (coming off the storage tanks) they “are” appropriately higher for GM (9.36 tpy) than Truman (6.56 tpy).
I am extremely grateful for the first audit. The other department was brushing me off and we all know how polished I am in persistence.
 
Thanks
Kim Feil
 

—————–

—– Forwarded Message —–
From: Chris Kite <chris.kite@tceq.texas.gov>
To: kim feil <kimfeil@sbcglobal.net>
Sent: Monday, February 22, 2016 5:48 PM
Subject: RE: GM’s padsite was by 75% on Benzene-how can NCTCOG/TCEQ write SIP if drilling permits may be underestimated?

Dear Ms. Feil,

Thank you for your e-mail.  The net increase of 120 pounds of benzene per year will not affect the 2017 future ozone design values reported in the most recent attainment demonstration State Implementation Plan (SIP) proposal for the Dallas-Fort Worth (DFW) area: https://www.tceq.texas.gov/assets/public/implementation/air/sip/dfw/dfw_ad_sip_2016/DFWAD_15014SIP_pro.pdf.  The primary reasons for this are:

–          the very small increase in daily anthropogenic emissions that occurs from a net increase of 120 pounds per year; and

–          even though benzene affects human health at high enough concentrations, it has relatively low reactivity for forming ozone.

Provided below is some additional background supporting these statements.  The photochemical modeling used to obtain the 2017 ozone design values has hourly emissions input for each 4 kilometer (km) grid cell within the DFW area.  The table below shows how 120 pounds per year of benzene is only 0.0137 pounds per hour, which is not sufficient to alter the ozone formation chemistry in an environment such as DFW that is limited by emissions of nitrogen oxides (NOx) rather than volatile organic compounds (VOC):

Time Scale

Pounds

Tons

Annual

120

0.06

Daily (Annual/365 Days)

0.32877

0.00016

Hourly (Daily/24 Hours)

0.01370

0.00001

Attached is a presentation that I gave at the North Central Texas Council of Governments (NCTCOG) offices in Arlington on January 31, 2014:

1.       Slide 33 graphically summarizes the concept of a NOx-limited environment for ozone formation.  As shown, the large majority of VOC emissions are from naturally occurring biogenic sources, while the large majority of NOx emissions are from anthropogenic sources.  Even if all of the anthropogenic VOC emissions could be reduced to zero, there would still be very large quantities of biogenic VOC emissions available reacting with NOx to form ozone.

2.       The dark green portion of the biogenic VOC bar chart is for isoprene, which is emitted by oak trees in the presence of sunlight and is highly reactive for forming ozone.

3.       Slide 30 summarizes the wide range of ozone forming reactivity and reaction rates for various compounds.  Maximum incremental reactivity (MIR) is the highest amount of ozone formed when there is abundant NOx and sunlight available for a controlled reaction to go to completion.

4.       Since isoprene from oak trees is both very common and abundant in the atmosphere, it is a good compound to use for comparison purposes.  Isoprene has an MIR of 10.61, which means that up to 10.61 grams of ozone can be formed for every gram of isoprene available in the environment.

5.       Benzene has an MIR of 0.72, so if you divide the 10.61 for isoprene by the 0.72 for benzene, you get isoprene having the potential to form 14.74 times more ozone than benzene on a gram-for-gram basis.

6.       Another critical factor in ozone formation is the reaction rate per compound.  As shown in the far right column on slide 30, the reaction rate for benzene is 81.4 times slower than that for isoprene.

7.       Whenever an abundant amount of isoprene is available in an environment such as DFW, the combination of high reactivity and fast reaction rate leads to isoprene dominating the reaction with NOx to form ozone, which effectively “squeezes out” compounds of lower reactivity and slower rates from being involved in the process.

8.       So a small increase or decrease (e.g., 0.33 pounds per day) of a compound with low reactivity for forming ozone (e.g., benzene) is not sufficient to change the 2017 modeled ozone design values in the DFW attainment SIP.

If you would like more detailed information about ozone forming reactivity, reaction rates, etc., here are some useful resources:

–          The web page of Dr. William Carter at the University of California at Riverside:  http://www.cert.ucr.edu/~carter/

–          Chapter 6, Chemistry of the Troposphere, from the Atmospheric Chemistry and Physics textbook (second edition) that is available through the University of Texas at Arlington library:  http://library.uta.edu/.

Please let us know if you have additional questions.  Thank you.

Chris

 

Back in November I was trying to see if we could use some state funding for purchasing of catalysts for lift compressors in our backyards, but without any luck…we need to make sure these drillers are using Best Available emission Control Technologies even though not mandated.

 

So when you drive by a padside in a “dry” gas field like the Barnett Shale, if you are 300 feet away you “could” be breathing  17 ppb (that is above the TCEQ long term effect screening limits of 1.41 ppb).

aaaahhh the (invisible) smell of carcinogens in our neighborhoods….

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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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