Loopholes Found In Urban Drilling Public Protection

Many steps to safer urban drilling

I live at ground zero for urban drilling.
We have about 60 pad sites in our 99 sq mile town here in Arlington TX.
Our state and local government will not enforce these two laws….
1) 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..”
2. 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.
We had a drill spill in Lake Arlington, our drinking source, back in 2010. We also have about 100 drilling laterals under our lake that are at migration risk for seismic events and or cement failures.
We have had over a dozen gas release emission events that the general public knows about. On September 10th 2018, Arlington Fire Department’s Sergeant Crowsen said at a Frown Hall meeting (due to a fracking accident) that they respond to about 10-15 gas well complaints a year. Per our 2019 budget on page 120, it will cost us almost $500,000 in 2019 for gas well emergency response readiness.
The following are the items lacking in our URBAN oil and gas drilling ordinance………………..


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.
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
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.
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.
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.
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
So please find with this email our official request to add to our GW ordinance to minimize low-frequency noise.
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
See example of my protest hearings at  one June 5 evening meeting in 2012, https://www.arlingtontx.gov/cms/One.aspx?portalId=14481146&pageId=15052707
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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