Arlington Revising GW Ordinance as More Stringent is a Lip Mover

Posted on November 15, 2018 by Kim Triolo Feil
UPDATE May 2019
On May 22, 2019 the second reading being placed on the consent agenda was passed without incident to the second part changes to our Gas Well Ordinance. I have an earlier blog from 2016 asking for ordinance changes relating to air quality, and during the public comment I asked about them making changes related to protecting our air quality.   In response, they asked TCEQ & RRC to give a presentation at the day session (glad I found out in time to attend, but I could not ask any questions being a closed work session in the day). I handed a note to the police that keep the public away from council but the jerk would not pass it on and Wilemon knew I had a note, but would not get up and grab it…good riddance to her (she got booted out after 16 years due to term limits)!!
During Citizen Participation I read the email I sent them just after the day session…..
But I also added a memory they’d like to forget when the Compressor Station at Lake Arlington FAILED on Formaldehyde readings….https://barnettshalehell.wordpress.com/2012/10/30/formaldehyde-just-wont-go-away-in-barnett-shale-hell/.
—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: Sheri Capehart <sheri.capehart@arlingtontx.gov>; Robert Shepard <robert.shepard@arlingtontx.gov>; Jeff Williams <jeff.williams@arlingtontx.gov>; Lana Wolff <lana.wolff@arlingtontx.gov>; Kathryn Wilemon <kathryn.wilemon@arlingtontx.gov>; Michael Glaspie <michael.glaspie@arlingtontx.gov>; Gincy Thoppil <gincy.thoppil@arlingtontx.gov>; Alisha Stallard <alisha.stallard@tceq.texas.gov>; Jessica Youngblood <jessica.youngblood@arlingtontx.gov>; Jaret Wessel <jaret.wessel@tceq.texas.gov>; Don Crowson <don.crowson@arlingtontx.gov>; Trey Yelverton <trey.yelverton@arlingtontx.gov>; Helen Moise <helen.moise@arlingtontx.gov>; Marvin Sutton <mabranic@sbcglobal.net>; Roxanne Thalman <roxanne.thalman@arlingtontx.gov>; matt.baker@tceq.texas.gov <matt.baker@tceq.texas.gov>; Bud Weinstein <bweinstein@mail.cox.smu.edu>; Chris Kite <chris.kite@tceq.texas.gov>; richard.chism@tceq.texas.gov <richard.chism@tceq.texas.gov>; eolaguer@harc.edu <eolaguer@harc.edu>; eolaguer@harcresearch.org <eolaguer@harcresearch.org>; pgallagher@harcresearch.org <pgallagher@harcresearch.org>; mmorris@nctcog.org <mmorris@nctcog.org>; Jenny Narvaez <jnarvaez@nctcog.org>; Chris Klaus <cklaus@nctcog.org>
Cc: TXsharon <sharson@gmail.com>
Sent: Wednesday, May 22, 2019, 12:54:50 PM CDT
Subject: Formaldehyde testing Arlington 30K lbs/yr estimated
Last night during Citizen Participation at the Arlington City Council meeting, I spoke of HARC environmental tester saying Formaldehyde is a problem with natural gas production and I brought back up when the Lake Arlington Compressor Station had their air test fails (see attached picture)
Back in 2011 I emailed Richard Chism asking for the Mobile Air Monitoring Van to be deployed here from Austin and never got a response. https://barnettshalehell.wordpress.com/2011/09/24/formaldehyde-needs-further-testing-says-experts-how-you-can-help/
I imagine by now the technology has changed and the van is obsolete, I hope the TEXAS taxpayers got their money’s worth thou I doubt it.
WHO CAN get the state to use their latest and greatest technology to test for Formaldehyde in Arlington? Or maybe   W E the gas rich City can, or maybe cash from NCTCOG can employ HARC environmental testers out of Houston?
I only see my blog entries becoming more valuable over time…as I grow my social media…more people are learning about what our council has done to risk its citizens by allowing urban drilling without any real health or environmental impact review.
Kim
—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: Sheri Capehart <sheri.capehart@arlingtontx.gov>; Robert Shepard <robert.shepard@arlingtontx.gov>; Jeff Williams <jeff.williams@arlingtontx.gov>; Lana Wolff <lana.wolff@arlingtontx.gov>; Kathryn Wilemon <kathryn.wilemon@arlingtontx.gov>; Michael Glaspie <michael.glaspie@arlingtontx.gov>; Gincy Thoppil <gincy.thoppil@arlingtontx.gov>; Alisha Stallard <alisha.stallard@tceq.texas.gov>; Jessica Youngblood <jessica.youngblood@arlingtontx.gov>; Jaret Wessel <jaret.wessel@tceq.texas.gov>; Don Crowson <don.crowson@arlingtontx.gov>; Trey Yelverton <trey.yelverton@arlingtontx.gov>; Helen Moise <helen.moise@arlingtontx.gov>; Marvin Sutton <mabranic@sbcglobal.net>; Roxanne Thalman <roxanne.thalman@arlingtontx.gov>; matt.baker@tceq.texas.gov <matt.baker@tceq.texas.gov>
Sent: Tuesday, May 21, 2019, 6:25:34 PM CDT
Subject: A few takeaways on TCEQ & RRC presentations OVERALL F A I L here why….
Your dog & pony show at today’s City Council work session was apparent that you did not want to ask the really hard questions of your guest speakers from the RRC & TCEQ ….like how the oil & gas industry is federally exempt from the new OSHA silica standards to a later date and how they aim to protect us in the interim.
You did not solicit citizen questions in advance or allow me to have that police officer to hand one of you a question that you could have asked them. I wanted Wilemon to ask what device monitors FORMALDEHYDE. I know it is not the suma canister because I was told it is too corrosive to the canister. I was told a long time ago that knowing the Formaldehyde levels lies in having the air mobile monitoring van from Austin be dispatched. I was able to ask Jaret Wessel after the day session in the elevator if he would on our behalf request monitoring here in Arlington because years ago when I asked I was denied (I think it was I think Matt Baker-by phone-who was my contact when I first met him showcasing the van at a NCTCOG open house). I also had an email action back in 2011 for this as well. I mentioned to Wessel about my nosebleeds coinciding with the installation of the Truman padsite lift compressors and how I had to have a medical procedure to stop the nosebleeds. Gincy was in such a hurry to their next meeting and relieve him of a commitment to address my request, that I informed her of my expectations for her to follow up on my request.
Here is another Arlington citizen at a frownhall meeting complaining about nosebleeds, Eight Grade Arlington TX gal testifys on Frackquakes & her nosebleeds.
I am glad you took the steps to have them make their useless to us presentations….hard questions could have been how many nuisance violations have they gotten in urban drilling so far?
It was good your “who tests the groundwater before and after” question revealed how they don’t …they only find the water table depth to know how far to run the stainless steel casing (which last time I read was only 200 ft past the water table).
When you asked how long before they respond to a complaint or emission event and what if the event has passed by the time they arrive to test, well to remedy that big loophole, you should mandate 24 hour air monitoring by the operators.
Had you asked me I would have had you ask them if there was any truth to the rumor…A reporter for the Shorthorn told me in secrecy that he was working a story not too long ago about tariffs on stainless steel and how that some drillers might not be able to procure that certain grade of expensive steel for those blow out preventers that only come from (Japan?) one part of the world. To my knowledge the story was not released.
I am glad Capehart got her answer that a FLIR is a brand of an optical gas imaging camera and if it is good enough for the state to use, then it should be good enough for our inspectors and gas well response team, so lets budget for it next year finally?
We should also ask them about class I verses class II injection wells and how the handling of the waste throughout Arlington has exemptions from the more stringent truck manifest protections such as knowing how much left our individual padsites and if any spilled or was dumped along the way….these are things I have email you about over the years, yet no questions on the truck manifest loophole.
You guys brought this industry into our town and then you hide behind HB40 and allow these exemptions that risk public health etc…..you need to invoke HOMERULE LAWS to protect us and fight it out in court.
Kim
UPDATE 3/26/2019 ! So during the day session today Councilwoman Capehart summarized the effectiveness of her meeting last night…now if you saw the videos I posted on my blog as mentioned in the below comment, I kind of disagree. Then when the mayor was talking about Dr Epstein and her position on safety of gas wells in urban Drilling, the broadcast went silent.…https://youtu.be/Dctzu5kaQHk
UPDATE 3/26/2019
—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: Victoria Myers <victoria.farrar-myers@arlingtontx.gov>; Jeff Williams <jeff.williams@arlingtontx.gov>; Kathryn Wilemon <kathryn.wilemon@arlingtontx.gov>; Michael Glaspie <michael.glaspie@arlingtontx.gov>; Lana Wolff <lana.wolff@arlingtontx.gov>; Robert Shepard <robert.shepard@arlingtontx.gov>; Roxanne Thalman <roxanne.thalman@arlingtontx.gov>; Sheri Capehart <sheri.capehart@arlingtontx.gov>; Helen Moise <helen.moise@arlingtontx.gov>; Trey Yelverton <trey.yelverton@arlingtontx.gov>; Jim Parajon <jim.parajon@arlingtontx.gov>
Cc: Cynthia Simmons <cynthia.simmons@arlingtontx.gov>
Sent: Tuesday, March 26, 2019, 11:54:18 AM CDT
Subject: Last nights 5.th gas well FrownHall, resident 200 ft UTA padsite said he smelled Benzene during drilling
In case you missed last nights 5th official Frown Hall meeting on super-majority needed vote to allow gas wells closer than 600 feet, Arlington TX Show of Hand Fracking Setback Vote.
Below is some other footage on other gas well related concerns as well as my official citizen request for Industrial Hygiene efforts & equipment needed to test our airshed for longterm, chronic, exposures to hydrocarbons.
Additionally, Capehart was made aware (as the two other council people also present at the meeting last night) of the OSHA 2016 silica standard and how the oil & gas industry is exempt until June of 2021. I have and am asking for local silica rules to be added to our ordinance to protect us and the workers in the interim.
Here is a video on how the City hides behind regulators and regulations (like HB40, a ban on fracking bans), Arlington Texas frown Hall example of Railroad Commission failure.
Here is a video on how the City is NOT trying to repeal HB40, Citizen Asks what Arlington is pushing 4 gas well related local control this legislative session.
Following this citizen”s comments in not protecting us in allowing urban drilling without the City doing localized air testing, Not Accepting None-Answer on Why We Don”t Air Test in Arlington TX Urban Drilling,
Capehart interrupted another citizen challenging Capehart’s statement about why infrared cameras give false readings. Instead Capehart asked Chief Crowson to come speak to the matter, but Crowson only addressed ER response readiness and agreed Industrial Hygiene (IH) is NOT under his authority. So now that we know we have a gap in our aesthetic-only inspections, lets have our inspectors do quarterly air monitoring. Hire an (IH) consultant and lets get started using the ATF funds for equipment for public long-term exposure airshed testing protections thank-you!  ….Arlington Gasland TX Fire Chief Crowson Industrial Hygiene not their job to test the airshed
Below are the air related environmental bills filed this session. We need ARLINGTON  leadership to add language for the 10 ton/25 tpy rule to include “aggregate” emissions (in total all the drilling related to oil & gas) since many different operators are in close proximity to each other.  The current rule is allowed by EACH ownership and NOT by aggregate emissions in a proximity which amounts to for example a 20 ton/50 tpy rule per proximity….we need the URBAN DRILLING industry to be responsible for AGGREGATE emissions in the rule, “10 tons per year of a single air toxic, or less than 25 tons per year of a combination of air toxics”.
Click for options HB 4599 Author: Blanco
Last Action: 03/08/2019 H Filed
Caption Version: Introduced
Caption: Relating to the establishment and implementation by the Texas Commission on Environmental Quality of a program to reduce the emissions of greenhouse gases in this state; authorizing a fee.
Click for options HB 4600 Author: Wilson
Last Action: 03/08/2019 H Filed
Caption Version: Introduced
Caption: Relating to requirements for certain air quality permit applications for aggregate productions located in the jurisdiction of a municipality.
Click for options SB 185 Author: Miles
Last Action: 02/01/2019 S Referred to Natural Resources & Economic Development
Caption Version: Introduced
Caption: Relating to the response to certain oil or gas well accidents by state agencies and responsible parties.
Click for options HB 4409 Author: Wilson
Last Action: 03/08/2019 H Filed
Caption Version: Introduced
Caption: Relating to monitoring emissions of air contaminants from certain mining-related facilities; imposing of a fee.
HB 522 Author: Allen | et al.
Last Action: 02/20/2019 H Referred to Environmental Regulation: Feb 20 2019 12:02PM
Caption Version: Introduced
Caption: Relating to the consideration of the cumulative effects of air contaminant emissions in the emissions permitting process.
 HB 3034 Author: Zwiener
Last Action: 03/13/2019 H Referred to Environmental Regulation: Mar 13 2019 12:36PM
Caption Version: Introduced
Caption: Relating to the requirements for aggregate production operation air permits.
 HB 4409 Author: Wilson
Last Action: 03/08/2019 H Filed
Caption Version: Introduced
Caption: Relating to monitoring emissions of air contaminants from certain mining-related facilities; imposing of a fee.
Click for options SB 1380 Author: Rodríguez
Last Action: 03/14/2019 S Referred to Natural Resources & Economic Development
Caption Version: Introduced
Caption: Relating to the analysis of inspection and maintenance requirements for air quality permits issued by the Texas Commission on Environmental Quality for certain oil and gas facilities.
SB 2233 Author: Buckingham
Last Action: 03/21/2019 S Referred to Natural Resources & Economic Development
Caption Version: Introduced
Caption: Relating to monitoring emissions of air contaminants from certain mining-related facilities; imposing of a fee.

Area Sources of Urban Air Toxics

Area sources are smaller stationary sources of air pollution that emit less than 10 tons per year of a single air toxic, or less than 25 tons per year of a combination of air toxics. Through the Integrated Urban Air Toxics Strategy, and multiple separate listings, the EPA identified 68 area source categories that represent 90 percent of the combined emissions of the 30 urban air toxics.

List of 68 Area Sources of Urban Air Toxics
Acrylic Fibers/Modacrylic Fibers Production Iron and Steel Forging
Agricultural Chemicals and Pesticides Manufacturing Iron Foundries
Aluminum Foundries Lead Acid Battery Manufacturing
Asphalt Processing and Asphalt Roofing Manufacturing Medical Waste Incinerators
Autobody Refinishing Paint Shops Mercury Cell Chlor-Alkali Plants
Carbon Black Production Miscellaneous Organic NESHAP
Chemical Manufacturing: Chromium Compounds Municipal Landfills
Chemical Preparations Municipal Waste Combustors (MWC)
Chromic Acid Anodizing Nonferrous Foundries
Clay Products Manufacturing (Clay Ceramics Manufacturing) Oil and Natural Gas Production
Commercial Sterilization Facilities Paint Strippers
Copper Foundries Paints and Allied Products Manufacturing
Cyclic Crude and Intermediate Production Pharmaceutical Production
Decorative Chromium Electroplating Plastic Materials and Resins Manufacturing
Dry Cleaning Facilities Plastic Parts and Products (Surface Coating)
Electrical and Electronic Equipment – Finish Operations Plating and Polishing
Fabricated Metal Products Polyvinyl Chloride and Copolymers Production
Fabricated Plate Work Portland Cement
Fabricated Structural Metal Manufacturing Prepared Feeds Materials
Ferroalloys Production: Ferromanganese & Silicomanganese Pressed and Blown Glass and Glassware Manufacturing
Flexible Polyurethane Foam Fabrication Operations Primary Copper (not subject to MACT)
Flexible Polyurethane Foam Production Primary Metal Products Manufacturing
Gas Distribution Stage 1 Primary Nonferrous Metals (Zn, Cd and Be)
Halogenated Solvent Cleaners Public Owned Treatment Works
Hard Chromium Electroplating Secondary Copper Smelting
Hazardous Waste Incineration Secondary Lead Smelting
Heating Equipment, Except Electric Secondary Nonferrous Metals
Hospital Sterilizers Sewage Sludge Incineration
Industrial Boilers Fired by Coal, Wood and Oil Stainless and Nonstainless Steel Manufacturing Electric Arc Furnace
Industrial Inorganic Chemical Manufacturing Stationary Internal Combustion Engines
Industrial Machinery and Equipment – Finish Operations Steel Foundries
Industrial Organic Chemical Manufacturing Synthetic Rubber Manufacturing
Inorganic Pigments Manufacturing Valves and Pipe Fittings
Institutional/Commercial Boilers Fired by Coal, Wood and Oil Wood Preserving
Kim Feil https://barnettshalehell.wordpress.com/ TEX LG. CODE ANN. A§ 253.005 : Texas Statutes – Section 253.005: LEASE OF OIL, GAS, OR MINERAL LAND “(c) A well may not be drilled in the thickly settled part of the municipality..” Texas Administrative Code, Title 30, Part 1, Chapter 101, Subchapter A, Rule 101.4, Environmental Quality, Nuisance No person shall discharge from any source whatsoever one or more air contaminants or combinations thereof, in such concentration and of such duration as are or may tend to be injurious to or to adversely affect human health or welfare, animal life, vegetation, or property, or as to interfere with the normal use and enjoyment of animal life, vegetation, or property. To op-out from blind copied emails, hit the reply button and request on the subject line or in the subject text. Feedback is encouraged.
UPDATE 2/120/19 On the gas well ordinance changes, the most impactful item (requiring a super majority and doing away with paid signatures within the 600 ft buffer) that would have made it harder to expand certain drill sites already imposing on the 600 ft setback is postponed as the industry is pushing back. In fact they had a rep with an oil and gas association say they changed their mind about existing changes that were voted in last night. The one thing they didn’t like was how our Planning Development Director could make the call if an electric rig is mandatory. There are issues the driller has of either access to electric power or electric rig availability.
And all the other language passed with one Shepard abstain (if I recall correctly) regarding being more stringent about noise, and road dust, more inclusive notifications to the neighbors (from 600 feet to 1,320 feet) about active padsite times, moving from 6 month no-drill-re-apply-for-permit to giving them two years to drill before having to re-apply for permit, but after that first year, they need to provide that more inclusive notifications.
The one thing they should have loved is how after the zone and the first well is approved (drill zone and first well must occur concurrently) the rest of the wells that could fit on that drill zone will be administratively approved so no more input from us little citizen noise makers.
Within one year if they get two citations, they is some council oversight on future wells on that zone instead of admin approval.
I read to them my 10 item for safer drilling and told them as a Home Rule city, we can be more protective than the state and federal government and that the rules for drilling were concocted when it was not in urban areas and how we should be the leader setting best practices for public health protections instead of letting the operators tell us what is standard operating equipment and pollution mitigation.
—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: Jeff Williams <jeff.williams@arlingtontx.gov>; Victoria Myers <victoria.farrar-myers@arlingtontx.gov>; Robert Shepard <robert.shepard@arlingtontx.gov>; Kathryn Wilemon <kathryn.wilemon@arlingtontx.gov>; Michael Glaspie <michael.glaspie@arlingtontx.gov>; Lana Wolff <lana.wolff@arlingtontx.gov>; Sheri Capehart <sheri.capehart@arlingtontx.gov>; Roxanne Thalman <roxanne.thalman@arlingtontx.gov>; Helen Moise <helen.moise@arlingtontx.gov>; Trey Yelverton <trey.yelverton@arlingtontx.gov>; Jim Parajon <jim.parajon@arlingtontx.gov>; Jessica Youngblood <jessica.youngblood@arlingtontx.gov>; Jason M. Allen <jmallen@cbs.com>
Sent: Tuesday, February 19, 2019, 10:33:13 AM CST
Subject: GW Ordinance Existing Section 7.01 #6 & #15 are in place for Home Rule protections but…….
Currently our GW ordinance, Section 7.01, has these two provisions:
6. “All drilling and production operations shall 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.” .…”Proven technological improvements in industry standards of drilling and production in this area shall be adopted as they become available if capable of reducing factors of dust, vibration and odor”. 

Since we are the Urban Drilling guinea pigs, we are to set the Home Rule protective measures so other towns and other operators know what the accepted practices should be.

15. “No person shall allow, cause or permit gases to be vented into the atmosphere or to be burned by open flame except as … permitted by law, then such vent or open flame shall not be located closer than three hundred (300) feet…” 
Home Rule added protections are needed to protect those outside of 300 feet as the wind and weather conditions dictate where and how much of the fallout is endured by unsuspecting, innocent Arlington citizens.
—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: Jeff Williams <jeff.williams@arlingtontx.gov>; Victoria Myers <victoria.farrar-myers@arlingtontx.gov>; Robert Shepard <robert.shepard@arlingtontx.gov>; Kathryn Wilemon <kathryn.wilemon@arlingtontx.gov>; Michael Glaspie <michael.glaspie@arlingtontx.gov>; Lana Wolff <lana.wolff@arlingtontx.gov>; Sheri Capehart <sheri.capehart@arlingtontx.gov>; Roxanne Thalman <roxanne.thalman@arlingtontx.gov>; Helen Moise <helen.moise@arlingtontx.gov>; Trey Yelverton <trey.yelverton@arlingtontx.gov>; Jim Parajon <jim.parajon@arlingtontx.gov>; Jessica Youngblood <jessica.youngblood@arlingtontx.gov>; Jason M. Allen <jmallen@cbs.com>
Sent: Tuesday, February 19, 2019, 8:28:23 AM CST
Subject: my Top Ten Safer Drilling list was published in Tarrant Chronicle please add to your gas well ordinance changes
FYI see below I updated for the air quality item #1 (f)
Tonight I will bore you reading this list, so here is a heads up, thank you for considering adding these items since Home Rule allows you to be more protective of public health than the state and federal government…remember the rules for drilling were in place when they were NOT in the city limits, so it is up to you to protect us, thank you.
—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: Birdscopies Info <info@birdscopies.com>
Sent: Tuesday, February 19, 2019, 8:01:16 AM CST
Subject: One copy email text
(this text was updated to include the whole list on my sidebar)

1.

1. ELECTRIC mandate:
a. Mandate electric drilling rigs.

b. Mandate electric frac pumps Evolution Well Services – Innovation Not Imitation.

c. Do not use diesel or NG fired lift compressors that use dirty field gas, rather use electric submersible pumps,Wellbore Compressor, Natural Gas Recovery, Artificial Lift, Well Head, Electric Submersible Pumps, ESPs, Plunger Lift, Sucker Rod Pumps, Gas Lift Systems, Hydraulic Pumping Systems, Progressive Cavity Pumps, Oil Recovery, Convert Natural Gas, Liquefi

d. Mandate electric compressor stations, but have back up power in the event of electric outages. https://barnettshalehell.wordpress.com/2015/02/28/april-11-2011-two-padsites-spewed-on-arlington-residents/

e. Replace gas-assisted glycol pumps with electric pumps.https://www.epa.gov/sites/production/files/2016-06/documents/ll_glycol_pumps3.pdf
2. Video tape ALL cement casing pours when the cement comes back up to the top through the annulus so that there is proof of an even pour and ensure all wells have electric bond log tests.  Wireline Electric Logs tell an important geological story…to file or not to file that is the Q!
3. All drilling mud farming and brine “road spraying” should have application sites’ soil & groundwater tested for toxins and NORM. Transition Lancaster Visits PA Gasland

4. During fracking where the radioactive silica dust is flying around, we need the industry to contain the dust to OSHA 2016 standards at 50 micrograms per cubic meter of air averaged during an 8-hour shift. Currently, the oil & gas industry is getting preferential treatment to not have to be in compliance until June 23 2021. There is no entity looking out for the residential silica exposures, only worker exposures. Here is a video of what the silica exposures during fracking look like at our Bruder drill site,  https://www.youtube.com/watch?v=DWw8U40Q4Sk

4. Ban the use of Hydrofluoric and Hydrochloric Acid for less caustic treatments such as chelates. https://chelates.nouryon.com/siteassets/Brochure-dissolvine-stimwell.pdf

5. Mandate flowback tanks that have vent lines that can be connected to vapor recovery/capture systems or combustion devices (gas-busters) Frac Tanks & More from DHI Energy Servicetanks. Here is a video of what happens in our backyards in Arlington….. Flow Back in North Texas.

6. Blowdowns of compressors whose excess goes to the storage tanks should have Vapor Recovery Systems rather than venting. Here is a Lake Arlington tank battery emitting VOC’s 24/7….Lake Arlington Natural Gas Waste Storage Tanks Infrared camera reveals toxins constantly spewing

7. The pipeline should be in place FIRST before fracking, and the operator should have no DELAY for flowback should occur immediately after fracking so that injected water/chemicals don’t sit in the ground for months festering bacterial sulfide growth to sour/damage the well and sicken people…..https://barnettshalehell.wordpress.com/2012/03/05/slammed-with-sudden-nausea-from-flowback-odors-business-womans-blood-pressure-soars-after-vomiting
8. The setback away from people should be substantial. Rural method drilling is not acceptable in urban areas. An environmental tester who has a Phd said that the health effects are being seen downwind from about 1,800 – 2,500 feet. 
https://barnettshalehell.wordpress.com/2012/09/05/envir-tester-ph-d-master-public-health-on-fracking-emissions-fallout-distance-1800-2500-feet-of-the-downwind-effect /
NOTE THIS>>>https://barnettshalehell.wordpress.com/2015/11/09/voc-study-averaged-17-ppb-benzene-in-dry-gas-wells-300-ft-away-in-utah/
9. Equip local GW inspectors who need to test for methane leaks with FLIR cameras. https://barnettshalehell.wordpress.com/?s=flir
10. Use phage therapies instead of dangerous gluteraldehydes to control festering bacteria and offensive odors.  https://barnettshalehell.wordpress.com/2016/02/16/dont-bank-on-phage-fixn-well-souring/
11) Use closed mud containers. 
12) Have aerial water spray mist for flying frack sand. But don’t let the toxic water go into environment.
13) No diesel truck idling
14) Need 24 hour hotline to TCEQ and City Gas Well Inspectors. Our city website’s online status report is too vague. (ex. currently it can say “workover” and no real information of what that entails. Breathers do not need to be downwind to pre-production and maintenance activities. They need to know that they are risking their health. It’s time for the truth.
15) Equip First Responders with sensitive BTEX detection equipment. (I know of four auto shut in failures so far they were exposed to rouge wells) https://barnettshalehell.wordpress.com/2011/08/02/tceqs-first-glance-equipment-is-not-sensitive-enough-to-detect-long-term-benzene-effect-screening-levels-at-1-4ppb/
16) Simulate neighborhood evacuation plan and robo calling run through. Train an appointed person to push red button in an emergency when the AFD cannot do it if they are in a mass ER event. https://barnettshalehell.wordpress.com/2014/10/07/arlington-neighborhood-citizen-designated-red-button-pushers-needed-in-emergencies/
17) Flood waters on pad sites should be lab tested for Drilling Mud, Frack Chemicals, Produced Water and Maintenance Chemicals before being released. https://barnettshalehell.wordpress.com/?s=flooded
19) Baseline Air, Soil, and Surface Water testing should be required with post production re-testing to make comparison analysis. The LABC spill did not test for NORM and we had no baseline. https://barnettshalehell.files.wordpress.com/2016/03/labc-water-tests.pdf
20) Nitro Lifts or any other well maintenance should NOT be allowed to vent via an open well or it’s chemical treatments to the atmosphere…which includes sending to storage tanks with thief hatches that vent. See 1,140 ppm TVA reading near my son’s junior high school, https://barnettshalehell.wordpress.com/2013/11/18/viagra-for-the-eagleford-shale-already/
21) Use blow out preventer between the drill and the frack stage in case flooding occurs.
22) Use tighter truck manifests that make them account for the TENORM waste water amounts leaving Arlington and have those amounts match up to their injection well destination. https://barnettshalehell.wordpress.com/?s=tenorm
24). Replace high pneumatics with low to no bleed pneumatics.https://www.epa.gov/sites/production/files/2017-09/documents/2-devices_colorado2004.pdf
————————End 2/19/2019 UPDATE—————————-
Here are two January 28 2019, work session videos on air quality show a miserable FAIL while our council goes through the motions of trying to make changes to our Gas Well Ordinance as more stringent….https://www.youtube.com/watch?v=fE19iFvg2JE 
These changes were prompted by a Youtube video gone viral back in 2018, in Councilwoman Capehart’s district called Fracking Accident.
Following that accident was some very upset citizens at a subsequent FROWN-HALL meeting.
—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: Trey Yelverton <trey.yelverton@arlingtontx.gov>; Jim Parajon <jim.parajon@arlingtontx.gov>; Jessica Youngblood <jessica.youngblood@arlingtontx.gov>; Victoria Myers <victoria.farrar-myers@arlingtontx.gov>; Jeff Williams <jeff.williams@arlingtontx.gov>; Robert Shepard <robert.shepard@arlingtontx.gov>; Roxanne Thalman <roxanne.thalman@arlingtontx.gov>; Kathryn Wilemon <kathryn.wilemon@arlingtontx.gov>; Lana Wolff <lana.wolff@arlingtontx.gov>; Michael Glaspie <michael.glaspie@arlingtontx.gov>; Sheri Capehart <sheri.capehart@arlingtontx.gov>; Helen Moise <helen.moise@arlingtontx.gov>; Don Crowson <don.crowson@arlingtontx.gov>; Gincy Thoppil <gincy.thoppil@arlingtontx.gov>
Cc: Cynthia Simmons <cynthia.simmons@arlingtontx.gov>
Sent: Wednesday, November 28, 2018, 9:20:06 AM CST
Subject: 3 reasons to do away w/ 70% waiver support/Changes to our Gas Well ordinance
I am in support of doing away with the extortion-like influence of how the drilling operators can pay for a person’s signature inside of the 600 ft buffer for three reasons that should help you move forward with eliminating waver exception counts to get to 70%.
1) Most live out of town and do not get to breathe the emissions
2) For the Truman site, one owner had three small parcels inside the 600 ft buffer and got three votes AND lived out of town
3) If you are serious about not allowing remaining build out, you will deny ALL new drill-zone permits effectively defacto banning (but still be in HB40 compliance). Otherwise, you can take more time and pursue my suggested air quality related HOME RULE regulations (listed below) that you can impose to be more protective than the state/TCEQ and federal government.
I am also in favor of the work-over notification and hope this video exchange between Jim Parajon will serve as a reminder that i never had the choice to check the winds and check my family into a hotel away from harm……https://www.youtube.com/watch?v=E6cSg0Fi0jk
There is a home 300ft away at the Truman drillsite in our Entertainment District….I shudder to think Total will care about our City as a tourist destination and any evacuation nightmares should we get another Fannin Farm (business as usual) event during any stadium events.
Thank you in advance for your attempt at protective measures (except for the deferring air quality issues to the TCEQ which is a cop out)….the blood money I admit has been put to a noble use for Texas LIVE…I just hope we won’t need it to plug and abandon any City wells in the future as third and fourth tier operators become the norm.
I recall City officials admitting this money coming in would not be long term….the time is now to get off the Texas teet of Urban Drilling…cancer sux and this is not a family friendly industry I am tired of promoting you recklessly bought into…
Kim Feil https://barnettshalehell.wordpress.com/ TEX LG. CODE ANN. A§ 253.005 : Texas Statutes – Section 253.005: LEASE OF OIL, GAS, OR MINERAL LAND “(c) A well may not be drilled in the thickly settled part of the municipality..” Texas Administrative Code, Title 30, Part 1, Chapter 101, Subchapter A, Rule 101.4, Environmental Quality, Nuisance No person shall discharge from any source whatsoever one or more air contaminants or combinations thereof, in such concentration and of such duration as are or may tend to be injurious to or to adversely affect human health or welfare, animal life, vegetation, or property, or as to interfere with the normal use and enjoyment of animal life, vegetation, or property.
On Tuesday, November 27, 2018, 9:07:18 AM CST, kim feil <kimfeil@sbcglobal.net> wrote:

We do not mandate that the operators flow back into pressurized, closed containers that they haul off to the injection wells later after it’s finished venting into the neighborhoods. Currently we flow back into open hatch containers that the TCEQ admits cannot be closed (without being pressurized) because it could become an explosive environment with the fluids being under pressure which means they have vocs in them.

We do not mandate continuous air testing during the various pre-production or post production stages.
We should require the Operators to do continuous air monitoring using a non-biased contracted third party company during the different phases of getting the wells into production to include radiation detection devices during fracking to see what’s coming up mixing with the flying around silica dust.
Then we should also mandate that they air test after the wells are in production and during the gas lift compressor blowdown maintenance where they release the contents of the piping into the atmosphere that which they cannot blow down past the 200 PSI when they direct the contents of the piping to the storage tanks where the thief hatches continually vent VOCs into the atmosphere 24/7.
We do not have closed loop systems in Urban Drilling, we allow venting in our neighborhoods, near our schools, churches, and businesses.
Now is the time to put real teeth and our gas drilling ordinance as far as air quality concerns are.
I would like to be able to see the results of the air monitoring online in real time.
We should also mandate a stricter truck manifest so that when they truck off the contents of the storage tanks daily to the injection Wells that the amount match up so that there are no spills along the way that we will never know about.
Additionally we should mandate no mud farming in the city limits. We do not want the waste fluid spread on adjacent land with the permission of the property owner which currently the Railroad Commission allows because when that wastewater drys in the hot Texas Sun our windy conditions risk NORM that can blow around in the dirt and dust and get in our air shed.
Thank you
Sincerely,
The City of Arlington’s worksession on Tues, 11/13/18 had talk of becoming more stringent in their gas well drilling ordinance.
In the end they probably still won’t get their inspectors or AFD a FLIR camera to see what’s leaking. They still want to leave the air quality complaints to TCEQ purvue.
The email below doesn’t even address other issues I’ve uncovered over the years such as the risk of radioactive mud farming, flowing back in open top containers, not flowing back immediately and letting the flowback sour, to name a few.
Leaving TCEQ n charge of air quality is the biggest copout and I am so glad term limits are headed their way even though they are already trying to undo the Nov 6 vote!
—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: Trey Yelverton <trey.yelverton@arlingtontx.gov>; Jim Parajon <jim.parajon@arlingtontx.gov>; Jessica Youngblood <jessica.youngblood@arlingtontx.gov>; Victoria Myers <victoria.farrar-myers@arlingtontx.gov>; Jeff Williams <jeff.williams@arlingtontx.gov>; Robert Shepard <robert.shepard@arlingtontx.gov>; Roxanne Thalman <roxanne.thalman@arlingtontx.gov>; Kathryn Wilemon <kathryn.wilemon@arlingtontx.gov>; Lana Wolff <lana.wolff@arlingtontx.gov>; Michael Glaspie <michael.glaspie@arlingtontx.gov>; Sheri Capehart <sheri.capehart@arlingtontx.gov>; Helen Moise <helen.moise@arlingtontx.gov>; Don Crowson <don.crowson@arlingtontx.gov>
Cc: Cynthia Simmons <cynthia.simmons@arlingtontx.gov>
Sent: Thursday, November 15, 2018 10:26 AM
Subject: Points to make and requsts to let Dr. Cynthia Simmons spearhead the changes to our Gas Well ordinance
During the day session you took each component of what (surface wise) our town as a Home Rule City can regulate on the gas well ordinance to become more stringent. This in the wake of HB40 cracking down on setback defacto bans and citizen lead petitions oj fracking bans.
Setbacks:
I disagree when Mayor Williams called the citizen notification from 600 ft to quarter mile “significant” (now that the STR’s will be too)…how disingenious to compare the two ordinances when the STR issues relate to mere nuisance and the GW ordinance is of both nuisance AND PUBLIC HEALTH CONCERNS in living near industrial processes.
Willams does not understand or pretends that this “public notifiacation” will make a difference when our current GW ordinance allows an exception to the 600 ft setback via a 70% (paid off) landowner(s) approval (to be closer than 600 ft down to at the most 300 ft setback). I have seen Councilman Shepard quiz speakers to see if they reside within the City AND the 600 foot setback.
Tuesday after the day worksession, I thanked Councilwoman Capehart for suggesting we do away with the 70% and have ALL setback exception requests undergo a supermajority council vote. I reminded her that within a 70% landowner search (as I found with the Truman site) that one landowner can own many parcels which count as separate votes too which adds to the voting disparity. There is nothing in our ordinance that give renters a vote that live in that buffer. Generally these land owners can also be out of town owners getting to decide to be closer than 600 feet when they won’t share that added risk.
All of this political posturing I witnessed Tuesday has the appearance of public health and nuisance concerns at heart. Now lets see some action.

It’s time for Texas to regulate oil and gas drilling at a safe distance…

Earlier this year, we attended a town council meeting in Arlington where we provided a scientific perspective on…
Air Quality
I have spoken over the years on almost all drilling agenda items because I myself am downwind to additional pollutants stemming from our industrialization of our good town. Here are the rebuttals from the day session I want to post to you and on my blog and the driving force in having you ask Dr Simmons to take on this public health responsibility in the GW ordinance changes.
It is a cop out to continue to allow TCEQ to respond to air quality complaints as they have 24 hours to come out and take an air sample and then we wait 6 weeks for the results…..which by that time the emission event is usually gone, and their suma canister sampling BTEX related of 50 constituent misses some pollutants such as formaldehyde, The air testing needs to be continuous as TexWells just called for in a recent Dallas News editorial calling for what I am asking YOU to add to your ordinance (I boldfaced for emphasis) ….”One prospective policy reform is to adopt the 1,000 feet distance while requiring operators to conduct continual air quality monitoring, with the data available to all concerned parties”.
 
There is recognition that the TCEQ suma snapshot is a pic in time that is dependant on the meterological conditions and the timing of grabbing the sample DURING the offensive odors as they are occurring. I have asked Sargent Crowsen to at least keep a suma on hand…maybe Jessica’s team can arrange this with TCEQ?
Our state nuisance laws encompass duration as a consideration. Some the active phases of drilling/fracking/drilling out the plugs..etc. are intermittent which makes nuisance offenses hard to pin down (the Truman Downtown Entertainment Odor Event of January 2013 that I sued Chesapeake in small claims court wher in pretrial the only evidence allowed was an email proving they lied to the City and the state about the location and source of the odor. Of note I could not get the 2013 Truman Emission Event TCEQ inspector’s field notes that died with him on a Houston hwy accident.
The (appointed, retired) judge threw out my case because I had no engineer report and had no doctors report confirming odors entering my home and cause eye burn and my mother-in-law to have malaise of which others also had health issues too when I Interviewed them. So we need a better criteria to find nuisance offenses in our GW ordinance.
 
Noise
As I wrote in the Facebook Arlington Texas Talk UNcensored… “they (you) only bothered to say what decibles above the ambient noise they could decrease by… (currently they (you) try to regulate any exceedances 5 db above ambient in the day and 3 db above ambient at night)……they (you) did not address the harmful low frequency harm that, Jane Lynn reminded me of…please check out this 2014 Ft Worth Weekly fracking related article out…. .Compressing Agony“

Compressing Agony

By Fort Worth Weekly
Charles Morgan chose his home in Buffalo, a little town 70 miles southeast of Fort Worth, for its serene surroun…
So please find with this email our official request to add to our GW ordinance to minimize low-frequency noise.
 
Dust
OSHA has revamped their particulate laws that went into effect back in October of 2017 but have allowed an additional 3-4 years (June 2021) for the oil & gas industry to figure out how to contain their silica dust flying during fracking…I myself have had my car dusted and I live 1,200 feet away from the Truman drillsite. I have asked the fire department to be present to water down any flying radioactive fracking dust, maybe that can be added to the ordinance too? 
The most effective way you can become more stringent (without violating HB40) at this point of an almost build out drilling town is to deny ALL 37 remaining drillingzones in Arlington so they cannot finish the buildout.
For starters please take Capeharts suggestion to enact a supermajority to all setback exceptions and have Dr Simmons be more involved, thank you.
Thank you
Kim Feil
Musician and Fracivist
————————————-
As I published this today, WordPress notified me it was my 1,000th post.
I don’t feel so proud in having neglected my family and my music all these fracking years…but I WILL NEVER GIVE UP THIS FIGHT AND NEITHER SHOULD YOU!
 
 

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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