Here are my comments, please send yours to email Public-Comment@twdb.texas.gov
—– Forwarded Message —–
From: kim feil <email@example.com>
To: “Public-Comment@twdb.texas.gov” <Public-Comment@twdb.texas.gov>
Sent: Tuesday, March 8, 2016 7:49 PM
Subject: Comment on 2017 TWDB plan
My name is Kim Feil from Arlington TX. Here are my comments for the 2017 TWDB water plan. I have been looking at the loopholes in public protections related to our water supplies and have many points to share. This 1994 USGS link , which is over 20 years old, shows research that uncovered pesticide detects along the Texas Trinity River (which supplies over 50% of Texans their drinking water). Note this is a SURFACE runoff problem and can be related to the risk we have in the huge build out of all the oil & gas activities along our water ways.
In the 2011 Lake Arlington Master Plan
on 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“ and accounting for the increased loads is important.
1) While I see rain harvesting, is there any provisions for water banking in times of floods? Here is a California pilot program I have info on…but careful what we wish for if the water being banked is impaired by all the drilling build out.
Since then UT Arlington’s CLEAR has more information of indirect aggregate risks to GROUND water quality in their latest study…
“Indirect evidence of pollutant migration via microannular fissures in well casing”
If you want the full UTA Clear pdf. please email firstname.lastname@example.org and ask for the details on their study, “Elucidating hydraulic fracturing impacts on groundwater quality using a regional geospatial statistical modeling approach”
UPDATE for TWDB response on item #1 water banking……
—– Forwarded Message —–
From: Merry Klonower <Merry.Klonower@twdb.texas.gov>
To: kim feil <email@example.com>
Cc: Matt Nelson <Matt.Nelson@twdb.texas.gov>
Sent: Wednesday, March 9, 2016 5:07 PM
Subject: RE: 2017 State Water Plan 2 questions
We’ve answered your questions below as we understand them but if you need additional information, please let us know.
1) By “banking” we understand you to mean retaining or storing flood water for later use. Yes, the state water plan includes both existing and additional future water supply from reservoirs that capture and store large volumes of water during high flow events, including when flooding occurs, and using that water at other times including during times of drought.
The water plan includes water demand projections for all water use sectors including for power generation, manufacturing, and mining. While the state water plan considers the impacts on water quality of the recommended strategies in the plan, the plan primarily focuses on meeting water needs (potential shortages) through a variety of strategies including conservation and water supply projects.
Director of Communications
Texas Water Development Board
‘Mining needs increased by approximately two-thirds from the 2012 plan’s estimates.
This is partly due to the increased water demand projections associated with hydraulic fracturing activities’. This current TWDB draft may NOT encompass this breaking story of Chevron’s frack attack on west Texas’ water inventories. I feel that communication to Chevron as to where they will procure water for hydraulic fracturing is in order.
3) No one is keeping track of what produced water quantities leave the padsites and if they make it to the injection well sites. A remedy is to categorize the produced waters as TENORM which requires TxDot manifests with more control and accountability. This event as documented was on I-30 just West of University Dr. on 4/5/2014….https://www.youtube.com/watch?v=_ep3iGTbIh0.
4) In the future, O&G activities could include less disposal wells and more “treat & release” of produced waters where allowable west of the 98th meridian
but the RRC does not require any treatment or testing for NORM.
Here is the …
Currently the $750. If the discharged water will not reach surface waters of the State or the discharge point is west of the 98th meridian and the water is for agriculture or wildlife use, the fee is not required”.
The EPA has it’s own application too…see this link here
self-testing/reporting does NOT include looking for NORM.
When Arlington TX had a spill near the LABC church and a densely populated neighborhood I blogged
the results complaining that no one tested for NORM then.
Here is the RRC self test/self reporting criteria before releasing produced waters in Texas (west of the 98th meridian).
on produced water constituents page 12
5) And besides not asking for NORM or TENORM, the RRC also doesn’t require testing for constituents found on the Frac Focus Chemical Disclosure Registry either…remember some of those are top-secret…
page 13 note: some more better news is that gas wells have 5 times less contaminated water than oil wells, but 5 times less than what?
6) AS SEISMICITY (frackquakes) may begin to LIMIT the use of some injection wells in Texas, we need to require rigorous testing before releasing or selling refurbished O&G waste waters such as for brine road salting, dust control, & fire fighting.
They also say they use the distilled liquid to re-frack with. Part of what I am concerned with recycling brine/flowback is the creation of what I call increasing toxicity (“frack-on-crack”) risk if they use any type of chlorine application (they say they use activated charcoal to make the distilled water but the very nature of chlorine is that it is a salt and wiki says Calcium chloride (chemical formula CaCl2) is the ionic compound of calcium and chlorine.)…they may be making a bromate/halogen nightmare in storm run off effluents?
Regarding Calcium chloride, a company called Tetra chemicals says “This product is widely used in oilfield applications as completion and workover fluids to increase density, and as a drilling mud additive to increase density and prevent clay hydration”. In Oklahoma, they are already starting to limit some injection wells so we must ensure the new product isn’t worse than the original waste product.
7) Since the urban drilling started in Arlington where I live, in 2007 our TTHM’s have started going up to almost triple the pre drilling numbers. Likewise in Ft Worth, their TTHM’s have started going down in 2012 that correlate with the drilling BUST in the Barnett Shale, and so the TWDB needs to understand the TTHM impacts if the urban drilling boom returns to north Texas.
Water PROTECTION against toxic padsite runoff and casing failures is essential to be built into the water plan, yet not much in the draft on this elephant in the room.
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