City of Arlington FAIL on inspecting emission control devices

“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!”

—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: Collin Gregory <Collin.Gregory@arlingtontx.gov>
Cc: Jim Parajon <jim.parajon@arlingtontx.gov>
Sent: Friday, February 19, 2016 3:01 PM
Subject: City Inspections missing catalyst emission control devices on the lift compressors they inspect

Update Collin, I just updated a blog about how I found my answer in the TCEQ/Novell permit data base in search of my long awaited answer you could not help me with….

https://barnettshalehell.wordpress.com/2015/11/17/arlington-tx-est-gas-well-lift-compressors-2-3-million-cu-ft-annual-ch4-losses-to-atmosphere/

and so the YES answer is that they “are” using an NSCR (non selective catalytic reduction device) meaning they are controlling emissions with their G3406 NA lift compressor engines. But unless you know what they look like, each time they come back from being maintained, we chance that they may not be equipped with the NSCR and we need a specific check list for that. Do our inspectors have access to the lift compressor’s maintenance records?

The current check sheet the city uses is too vague…. is the muffler you inspect for sound AND exhaust?

Please have the city inspection form be specific such as…

Gas Lift Compressor:

_______Sound Mitigation/Muffler

_______Gases, Fumes, Carbon, or Soot

           a) NSCR catalyst_____

           b) SCR catalyst______

           c) JLCC catalyst_____

           d) Other_____________

_______ Maintenance up to date

You said in the email below that the noise comes from the sound of the exhaust, but a muffler box muffles sounds and does not act as a catalyst to transform effluents (for example CO is converted to CO2 by the platinum metal in the catalytic converter), and so the wording of the ordinance is disingenuous and misleading at best.

I asked for a meeting with Jim Parajon months ago on this and he never responded.

Please respond to these concerns of transparency and competency of our inspection process that my tax dollars support, thank you.

Kim

—– 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. 

 

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

 

 

 

 

From: kim feil [mailto:kimfeil@sbcglobal.net] 
Sent: Monday, November 23, 2015 12:04 PM
To: Collin Gregory
Subject: Re: 7.01 #21 exhaust muffler same as catalytic convertor?

7.01 #21 speaks of an exhaust muffler is that just for diesel engines?

Is your definition of an exhaust muffler the same as a catalyst (catalytic convertor)?

—————-end email————–

typical quarterly inspection in Arlington

Our inspectors should be able to do a visual to make sure the lift compressors coming and going for maintenance keep coming back with NSCR’s and SCR’s attached.

 

---

From: Collin Gregory <Collin.Gregory@arlingtontx.gov>
To: ‘kim feil’ <kimfeil@sbcglobal.net>
Sent: Thursday, November 5, 2015 1:12 PM
Subject: RE: Q if Truman site utilizes catalyst for engines

 

Good afternoon Kim,

I couldn’t pull up either of the links below but I did look up the G3406 electric power generator you referenced.  Since gas well sites are permitted by rule by the TCEQ each item on that site must have the ability to be audited by the TCEQ, show their emissions levels and prove they are below the allowable State standards.  I am unaware of the types of catalysts (if any) that would be used on this generator to mitigate emissions, I would suggest contacting the TCEQ to see if an audit was performed on that site and what catalysts would have been used for that type of equipment.  Have a wonderful afternoon and try to stay dry.   

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

From: kim feil [mailto:kimfeil@sbcglobal.net]
Sent: Wednesday, November 04, 2015 1:42 PM
To: Collin Gregory
Subject: Q if Truman site utilizes catalyst for engines

In looking at TCEQ’s PBR registration I saw them refer to two engines.

I noted they use the Caterpillar G3406 NA and my question is if they use a catalyst to mitigate the emissions.

The next question is what do they use those engines for?

Thanks

file:///Users/kimfeil/Downloads/SUPINFO%20106536%20Chespeake%20Operating%20Inc%20(352)106536.196928.SUPINFO.pdf

OR

https://webmail.tceq.state.tx.us/gw/webpub (see

 —-end email string——

BEGIN related TCEQ communication….

—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: “aimi.tanada@tceq.texas.gov” <aimi.tanada@tceq.texas.gov>
Sent: Friday, February 19, 2016 10:00 AM
Subject: support docs for Q R they using catalytic convertors?

In looking in the Novell system https://webmail.tceq.state.tx.us/gw/webpub

at Truman’s PBR 106536

at the link…SUPINFO 106536 Chespeake Operating Inc (352)106536.196928.SUPINFO.pdf

 

I see a reference to the Caterpillar G3406 and am confused because you said they use a G3406NA that has three sets of emission numbers……

 

 

Below is also a Caterpillar document that says the G3406 “is” the G3406 NA and it says that a catalyst is standard.

Question 1) Is a catalyst the same thing as a Catalytic Converter?…..

 

 

 

The confusion start when I see the EMIT technologies document with two sets of emission figures on the left side of the page. On the right side of the page has two catalog numbers with info on the Catalytic Converter and the Air Fuel Ratio Controller….

 

To add to the confusion is the next page is a price quote ….

 

 

 

 

This quote has individual pricing for a $1,500 catalytic converter product number EAH-1450T-0606F-20CEE and another quote for a $2,390 Air Fuel Ratio Controller, part # ENG-S-125R-TA. On quote# QUO-01660-97VB dated 8/11/2010 prepared for Rock Brisco of Midcon makes me question #3) if this quote is for the Truman site, please clarify on my three questions thanks.  

Kim

 

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From: kim feil <kimfeil@sbcglobal.net>
To: Aimi Tanada <Aimi.Tanada@tceq.texas.gov>
Sent: Thursday, February 18, 2016 4:21 PM
Subject: Re: ONE more Q on Truman/GM audit, R they using catalytic convertors?

 

Thank you for clarifying that…are those catalytic convertors noted from a visual inspection? The reason I ask is that I saw on the Truman PBR that they checked off the box that they were not controlling emissions (truck loading section and storage tanks)… and in the TCEQ NOVELL database, EMIT technologies posted two sets of emission numbers….

I am trying to see if the catalytic converters are standard with the G3406NA, I recall the catalysts have their own part number, but I cannot find my notes on that.

Please let me know how to verify online via the Novell system how to see if catalytic converters are being used especially since they are not mandated.

Thanks

Kim Feil

 

---

From: Aimi Tanada <Aimi.Tanada@tceq.texas.gov>
To: kim feil <kimfeil@sbcglobal.net>
Sent: Thursday, February 18, 2016 2:28 PM
Subject: RE: ONE more Q on Truman/GM audit, R they using catalytic convertors?

 

Ms. Feil,

Yes, both sites are using catalytic converters on their engines.

Aimi Tanada

Environmental Investigator

DFW Region Air Section – Barnett Shale Team

Texas Commission on Environmental Quality

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

From: kim feil [mailto:kimfeil@sbcglobal.net]
Sent: Thursday, February 18, 2016 9:53 AM
To: Aimi Tanada <Aimi.Tanada@tceq.texas.gov>
Subject: ONE more Q on Truman/GM audit, R they using catalytic convertors?

R they using catalytic convertors?  thanks

---

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

From: kim feil [mailto:kimfeil@sbcglobal.net]
Sent: Friday, February 12, 2016 12:27 PM
To: Jaret Wessel <jaret.wessel@tceq.texas.gov>
Cc: Clark xx>; Anne Inman <anne.inman@tceq.texas.gov>; Aimi Tanada <Aimi.Tanada@tceq.texas.gov>
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