----- Forwarded by Greg Nizich/RTP/USEPA/US on 08/19/2011 02:48 PM -----

 

From: "Kim & Ken Feil" kimfeil@sbcglobal.net

Sent: 09/16/2010 04:54PM

To: "Anne Inman" <ainman@tceq.state.tx.us>, "Annette Maxwell" <AMaxwell@tceq.state.tx.us>, 

CCG-ONG@EPA, David Bary/R6/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA, Jeannine 

Hale/R6/USEPA/US@EPA, Edward Hanlon/DC/USEPA/US@EPA, <hq-publicaffairs@usace.army.mil>, 

<info@northtexasair.org>, "Michael Honeycutt" <MHoneycu@tceq.state.tx.us>, 

<michael.o'quinn@rrc.state.tx.us>, Nick Parsons/RTP/USEPA/US@EPA, "Sid Slocum" 

<SSLOCUM@tceq.state.tx.us>, "Walker, Tony" <TWALKER@tceq.state.tx.us>, 

<bshaw@tceq.state.tx.us>, "Shannon Ethridge" <SEthridg@tceq.state.tx.us>, "Alyssa Taylor" 

<ATAYLOR@tceq.state.tx.us>, <MABAKER@tceq.state.tx.us>, "Danielle Nesvacil" 

<dnesvaci@tceq.state.tx.us>, <kcauble@tceq.state.tx.us>, eyesondrilling@EPA, Timothy 

Herfel/R6/USEPA/US@EPA, <jwessel@tceq.state.tx.us>, "Winona Henry" 

<WHENRY@tceq.state.tx.us>

Subject:Gas Drilling Ordinance citizen comment/ 

Dear RRC, TCEQ and EPA please consider this a best demonstrated citizen input towards the making of a 

strong city gas drilling ordinance.

The title of my citizen comment white paper is ...

 "Testing and Verifying at Every Stage"

In being under bonded, currently our ordinance is at $50,000 per active well and then it drops to 

$10,000. I used the example of the Assumption Parish well blow out in LA and how in the worst case 

scenario-having to dig a relief well would cost $3.7 million and how that was in a rural area.

Our road fees need to account for long term road damages whether it is a city street or a state highway. 

Currently, we are accessing $200 per well. In figuring how many trucks per day are needed to haul off 

produced water during the first month or so of drilling, I used the frequently asked questions off of the 

City of Dallas Gas Drilling website that said for the first month or so to expect 5,000 barrels per day per 

well and that each truck can carry 120 barrels. That works out to about 42 trucks per day during peak 

water flow. The website quotes from an XTO source in the following paragraph so I am assuming that 

XTO supplied the city with this information. In contrast, Chesapeake has given me a 2,500 barrels per 

day estimate. Mr. Tony Rutigliano told me that there would be 16-21 trucks per day per well as their 

estimate for truck traffic during the peak brine production time.

The total truck weight for the first month on our roads is about 50 tons per well. After the water 

production drops off, there would be an additional 200 tons (Chesapeake) to 400 tons (XTO) of truck 

traffic weight for the life of each well. That just in our downtown Arlington area we can multiply that by 

the 100 wells already approved and we are talking about 28 million tons (Chesapeake) and 45 million 

tons (XTO) of truck traffic road (and air quality) stress for the next twenty years in our downtown area.

There is not a general agreement between XTO and Chesapeake as to how much produced water our 

Barnett shale initially generates. What else are we to believe when the drillers promise/give stats/ or 

are trusted to report spills/emission violations?
On the two unresolved issues in the field (the UTA spill, and the “above health threshold” formaldehyde 

readings at Lake Arlington/Quicksilver compression station), I suggest that our ordinance needs to make 

the drillers test & report. Likewise, our city needs to do its own independent testing to verify 

compliance.

So far the city has not collected any penalties for non-compliance---how will they know when they need 

to collect $$$? Hopefully it is not when it's OBVIOUS because that is dangerous. In the future, maybe 3 

to 10 years later if people near gas gathering sites have cancer, that will be hard to prove and no money 

can bring back life or good health. There is already an American Lung Association report out about 

higher asthma rates in Tarrant County which also happens to be a major gas gathering area/Barnett 

Shale.

In offering my suggestion to further speak on phase 3 for health and safety I like to say that the only way 

I'd feel safe from unseen gases is if all the cites in the Barnett Shale were equipped with a monitoring 

system for the life of the well that has infrared camera detectors. This would involve city employees 

who do nothing but watch these cameras in shifts. My prayer is that these expensive cameras can be 

pointed at an offsite security monitor and can remotely detect unseen emissions. Then we can monitor 

many sites for methane leaks and for units needing vapor recovery systems or repairs. This would 

eliminate the expense of driving or flying over different pad sites AND create a system to $ fine the 

drilling companies.

Our gas ordinance needs to address how to know the content of these emissions. This will assist in 

lawsuits later if allowed to continue.

That is where suma canisters, First Detect Spectrometers, or mobile vehicles equipped with air testing 

devices could be used. Once we have the evidence, the city could start issuing citations or fines. These 

fines need to be so high that they severely curtail future non compliance. Currently, our ordinance has a 

60 day window to become compliant or they can get a citation.

Our ordinance should also prevent drillers with a history of noncompliance and accidents from getting 

SUP’s.

In testing mandates, both the city and the drillers need baseline testing of each site for air, water and 

soil. I am asking for the ordinance to also mandate baseline blood testing of willing hi-impact residents 

and employees to see their present VOC/BTEX blood content.

Compliance mandates should then include ongoing testing (air, water, soil, & blood) and report to the 

city at each phase of drilling. The city should not trust but verify by also conducting their own testing.

The water testing would involve both surface water and ground water.

That would mean the drillers would have to drill a nearby water monitoring well to test the ground 

water. The driller and the city employee would draw water and soil samples at every stage and use 

separate labs for analysis. During fracing, this would be the time to take more frequent daily/hourly? 

samples.

These safeguards enacted through a strong gas drilling ordinance will in my opinion cover the health 

(not safety from explosion) section of our gas drilling ordinance. If the city piloted one site that is to 

begin soon, this can be a city's Best Demonstrated Practice. I checked with an EPA Natural Gas Star 

Dept. to see which city has reported to have a strong gas drilling ordinance and so far they do not track 
that nor has any city come forward to brag about one. The city of Arlington can save face for not doing 

air testing by at least piloting such a method of "testing and verifying at every stage" to be the leader for 

other cites.

It is their duty to protect the citizens from a potentially hazardous industry 

http://www.gaswells.org/Speech.html that has encroached on this town in our neighborhoods.

Sincerely,

Kim Feil, President Old Town neighborhood Association

409 N Elm Street

Arlington TX 76011