I am Faith Chatham, one of the co-founders of DEW Regional Concerned Citizens. I reside at 803 N. Mesquite St. in Arlington, Texas. Thank you for being here today. I personally appreciate those who are in the audience, and those who

are making public comments or submitting written statements. We appreciate the EPA staff members who are present, and your many colleagues who “back in the office” working diligently on this issue. Thank you for careful deliberation of New Natural Gas Air Quality Standards

— for your evaluation of sound science” and some “not so sound”, and your careful consideration of the myriad impacts of existing and proposed policy and for listening to thousands of opinions during this long process.

With escalation of natural gas production in our region, for the past 8 years at least 60% of our time, attention and

resources at DFWRCC has been devoted to studying, evaluating and commenting on Natural Gas Production and

Transportation issues in this region. DEW Regional Concerned Citizens is an “independent” “Think Tank” which focuses

on public policy in the 16 county North Central Texas Council of Government Region. All of our study area is in the Barnett Shale. The North Central Texas COG Region comprises 16 or the 18 counties of the Barnett Share.

In disclosure, DFWRCC does not accept financial contributions from industry or government except for the occasional utilization of meeting space. All DFWRCC researchers and analysts underwrite our own expenses. Most of us have been trained at the University of Texas Institute of Urban Affairs and have earned multiple degrees at UTA, however none of us

are currently employed by UTA. Furthermore, in the spirit of full disclosure, I must add that all of us own at least a small

interest in some parcel of property in Texas which is currently leased for natural gas production.

That being said, of this multi-year journey of examining NG production and public policy from multiple directions and examining research studies coming from all kinds of sources, I will share some of our conclusions.

• In this endeavor of how to produce and regulate (or not regulate) Natural Gas, there is much more than merely the billions of dollars of industry investment and energy sector profit on the table.• How we develop Natural Gas as a “bridge fuel” impacts our National Defense. Failing to implement green completion and industry best practices nationwide, or deterring the implementation of appropriate Air Quality Standards will result in lost profit for investors and the industry and will result in higher health

care expenditure and time lost from school, work and community service by citizens.

• We believe that adoption and implementation of these rules is an important step in sensibly developing Natural Gas as a bridge fuel for current consumption.

• Current economic gains must be balanced with long-term economic sustainability.

• These proposed air quality standards impact not only NG industry, royalty owners and investors, but they directly impact the lives of American families, especially of children, old people, and the medically vulnerable, and those

who work and play out-of-doors.

• Decisions to implement or delays in implementation or non-compliance will literally move or deter the

movement of healthy individuals into those who are medically “vulnerable” or disabled. The standards

Comments to EPA on Proposed NG Air Quality Standards by Faith Chatham (DFWRCC) — Arlington, Texas -Sept. 29, 2011 Page 1 of 4
who advocate for self-regulating and voluntary implementation of industry best practices and proven cost effective technology continue to refuse to them to voluntarily!

In the NCTCOG region we saw some improvement in Air Quality a few years ago following the close of some cement plants. Since then thousands of natural gas wells, hundreds of miles of pipeline and numerous new compression stations have gone on-line in our region. There is a direct co-relation between the escalation of natural gas drilling per county and decline in air quality. Development began in Parker and Wise County, western Tarrant County first. Air quality declined first in those counties and Fort Worth. Development then moved to Arlington and far eastern Dallas

County. As the number of wells has increased in Arlington, the air quality has declined. Dallas county continues to have better air quality than Tarrant even though Dallas has more cars on the road and more population. The major difference is that Tarrant has many more natural gas wells than Dallas

— at least thus far.

According to the National Center for Prevention and Disease Control, there has been an unusual increase in

incidents of breast cancer in six counties in Texas. The counties with the most breast cancers in

Texas are Tarrant, Denton, Wise, Parker, Hood and Johnson are all located in the Barnett Shale, “where emissions

from the exploitation of shale gas are highest, according to 2010 records from the

Texas Commission on Environmental Quality (TCEQ).

Even though the O&G industry is contributing to the local economy, many feel that NG industry still does not

pay its fair share for exploiting the resources in the region because too many operators expose our communities to unnecessary ambient air pollution by refusing to use green completion, proper valve maintenance and replacement of faulty valves and couplings with better technology, and investment in vapor

recovery systems. Seeing the gains in air quality improvement erode despite removing older automobiles from the

highways and higher automobile standards, and successes in closing down some of the worst polluting cement plants in the region, many citizens are angry because they believe “bone-headed” practices by some NG operators has contributed to the erosion of gains in Air Quality. Knowing that billions of dollars of profit is on the table for each

well, resistance by producers to implement relatively low-cost improvements which can capture product, cut emissions, and promote neighborhood health and safety is viewed by many citizens as the industry profiteering at community expense and the industry not paying its fair share in protecting the community from unnecessary air pollution.

As gas production moves closer to homes and schools, traditional “environmental protection” issues are

overshadowed by child endangerment issues.

As wells and pipelines are permitted closer and closer to day care centers, playgrounds, and children’s bedrooms and

school rooms, citizens realize that there are insufficient safety nets for citizens who are harmed by adjacent construction or production activity. OSHA protects workers and promotes jobsite safety for employees but implementation/enforcement of similar rules to protect citizens who are harmed by production practices or NG drill site

or pipeline construction projects near homes, schools, daycares and playgrounds is non-existent or ineffectively enforced.

Comments to EPA on Proposed NG Air Quality Standards by Faith Chatham (DFWRCC) — Arlington, Texas -Sept. 29, 2011 Page 2 of 4
Based on scientific evidence and the impact of “health and economic trends” we conclude that failure to adopt these proposed Air Quality Standards for Natural Gas will result in:

more days lost from work which = lower GNP

more absences from school for pupils and teachers = less effective education

higher health care expenditures for families

higher insurance premium costs for businesses unless capped by governmental action larger public health expenditures by county, state and Federal government

— with budgetary / taxation consequences.

Adoption of these air quality standards will help protect children from exposure to VOCs and other ambient air toxins which have been proven to impact lung development and neurological development in children. Adoption of these rules can literally help protect this nation’s children by removing UNNECESSARY EXPOSURE by air borne by products of the Natural Gas industry. This can preserve and promote the ability children to be able to absorb and

process information. Our national security and nation’s economic future is dependent upon the ability of American to assimilate and process information and to be healthy enough to work and study and serve our nation in various ways.

• The economic survival of communities is at stake.

• These standards impact our nation’s vital natural resources and have immediate and long-term consequences on health, safety ,the environment, food-chain, national defense and our nation’s economic sustainability.

• Breathable air and water and soil which sustains vegetation has always been, and will always be, basic requirements for human life and economic development.

• Our research does not support the claims by industry that adoption of these rules will adversely impact the economies of the communities where natural gas is being developed or where new permits are being considered.

• Adoption of the proposed Air Quality Natural Gas standards will not have a significant negative impact on jobs is the conclusion of an Economic Policy Institute 2011 Study. “A series of air pollution rules from the Obama administration provide major public health benefits with dollar values far greater than their compliance costs, according to a new report by a think tank affiliated with organized labor.” - By Ken Ward Jr. - The Charleston Gazette

— September 21, 2011 (Charleston, WVa)

• In examining the Economic Policy Institute’s report and weighing it with other evidence and reports, FWRCC’s

concurs with the Economic Policy Institute analysts in their 2011 report: “Fears that these rules together will deter economic progress are unjustified.” ... “The dollar value of the benefits of the major rules finalized

or proposed by the EPA so far during the Obama administration exceeds the rules’ costs by an exceptionally wide margin. Health benefits in terms of lives saved and illnesses avoided will be

enormous.”

•

... “Further, .. estimated costs of these regulations .. to the size of the economy, as well as the extended period

over which they will take effect, indicate that they would not be a major impediment to economic or job growth in the near-term or in the future.”

• “The regulations finalized and proposed by the Obama administration are likely to be of tremendous value to the nation, producing a wide range of significant health benefits,” the Economic Institute report said.

Comments to EPA on Proposed NG Air Quality Standards by Faith Chatham (DFWRCC) — Arlington, Texas - Sept. 29, 2011 Page 3 of4
g

y or President, Congress was significantly most unpopular.

There was less opposition to the Clean Air Act than to White House or Congress.

75% of all voters surveyed soundly reject the argument that stricter smog standards will hurt the economy and cost American jobs.

When asked if they favor or oppose EPA’s proposing to update air pollution standards by placing stricter limits on the

amount of smog that power plants, oil refineries and other industrial facilities can release, 75% of all voters surveyed strongly favor stronger EPA standards.

Voters surveyed trust the EPA more than Congress to set clean air standards.There is a +1- 3.7 margin of error. Voters were surveyed in Florida, Ohio/Michigan, Minnesota/Wisconsin and North

Carolina and Virginia. Researchers conclude that this study shows that there is strong support among voters for the EPA in all regions of the country.

Thank you.

Comments to EPA on Proposed NG Air Q.uality Standards by Faith Chatham (DFWRCC) — Arlington, Texas -Sept. 29, 2011 Page 4 of 4
g 

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adaches 

asting three weeks.

I am also experiencing

a lot offatigue, another symptom neighbors are testifying to. Other symptoms

are nosebleeds, burning eyes, sore throat, slurred speech, weak extremities, dizziness and blurred

vision. We hear strange noises and smell strange odors. The fear of the unknown with lack of

regulation has had

a real physical as well as emotional impact upon us.

One day, I decided to call our Chesapeake neighborhood representative to share with her these

negative health effects I had been experiencing which I believed was a direct result ofthe toxins being

emitted into our air. She said, “PROVE IT!” At that moment I realized I was up

a creek without

a

paddle.

And speaking of water, I would like to mention that just last month Chesapeake was found in anotherviolation at our well pad site

— this time for illegally trucking water across the city line to frac a well in

a city that had water restrictions in place due to the drought. Although our city knew what they were

doing, they didn’t cite them until the media exposed their actions. Yet the maximum fine of $2,000 willbe considered just

a mere cost of doing business. And this brings up another important issue

— what

will be the long-term ramifications ofthe billions and trillions of gallons of water that are now being

removed from the water cycle forever? Mankind has survived thousands of years without natural gas

but has always required water to sustain life.Now I want to tell you what happened on April 11, 2011 at around 2:30 a.m.

A storm had blown

through the area knocking out power which in turn had thrown

a compressor station offline which then

caused two separate malfunctions to occur at our drill pad site. Anyhow, since the storm blew in

a

cool front, we opened the windows and went back to sleep. Later,

a terrifying sound like loud jetengines woke us up. It would not stop. We called 911, but the operator was unable to provide us with

clear direction on what to do since our City did not have emergency protocols in place for this type of situation. Simultaneously,

a similar incident was occurring on the other side of town which had

probably confused the 911 operator. Our entire home was quickly filling with

a filthy smelling stench

of chemical odors and gases. My husband and I stepped outside to see what was happening and we could feel the weight like a heavy blanket of fumes covering the neighborhood. The whole experience

was surreal. We quickly went back inside and scrambled to shut all the windows of our home. I was

feeling utterly helpless seeing my 11 year old daughter lying in bed getting

a chemical exposure in her sleep. After some time, my husband proceeded to start his truck and drive to the Fulson pad site to

see what was going on or if emergency crew was there

— totally unaware at the time that his vehicle

could have exploded from the gases which had settled over the neighborhood. There was no one at that

site, but the well was still venting gases. It vented for approximately 1 V2 hours. Meanwhile, back at

the house, I reported the incident to TCEQ. TCEQ’s report which came out

4 months later, stated that

no violations were found. Mind you, they did not arrive on the scene until approximately 8 hours later

to investigate but by that time reported ‘no odors detected’. How much longer will this powerful, unregulated industry be permitted to legally poison us? I am weary of living this nightmare.

. On

behalf of the Gas Processors Association (GPA), I appreciate this opportunity to speak to

you regarding the Proposed Rulemaking entitled “Oil and Natural Gas Sector. New

Source Performance Standards and National Emission Standards for Hazardous Air

Pollutants Reviews,” published at 76 FR page 52738 on August 23, 2011.

GPA is a non-profit trade organization made up of approximately 130 corporate

members, all of whom are engaged in the processing of natural gas, or in the

manufacture, transportation, or further processing of natural gas liquids. GPA’s

membership accounts for approximately 92% of all natural gas liquids produced by the

midstream energy sector in the United States. Our members also produce, gather,

transmit, and market natural gas and natural gas liquids.

Safely bringing clean burning natural gas from producers to U.S. consumers has always

been one of the highest priorities of GPA member companies. The vast supply of natural

gas and natural gas liquids is one of our country’s greatest assets. increased production

and use of natural gas will help reduce our country’s dependence on foreign oil and keep

billions of dollars each year at home in the United States. Therefore, we urge EPA to be

thoughtful and use caution in this rulemaking, ensuring the rules are streamlined,

reasonable and do not impede the production, processing and transportation of natural gas

to U.S. consumers.

In that regard we have only a few short comments to make at this time.
2. GPA respectfully requests an extension of the comment period to December 30,

2011 to allow adequate time for a thorough review ofthe multiple changes

contained in the Proposed Rulemaking. GPA feels that an extension oftime is

justified based on the significant expansion of the regulatory requirements in the

Proposed Rulemaking that would cover a variety of emission units that have not

previously been addressed by these standards. In order to provide meaningful

comments, GPA and other stakeholders need a reasonable amount oftime to

review and verify EPA’s data as well as to collect information that could prove

useful in the rulemaking process. Given the scope and complexity of the Proposed

Rulemaking and the anticipated burdens it will place on the oil and gas sector,

particularly small operators, GPA submits that an additional 60 days for this

comment period is reasonable and appropriate.

3. GPA also requests that that EPA seek an extension of the February 28, 2012

Consent Decree deadline for finalization of the rule. It seems unlikely that EPA

can complete a thoughtful review and response to comments before the current

Consent Decree deadline. For example, ifthe 0MB interagency process requires

90 days for review, which would have to start December 1 St assuming a February

28, 2012 deadline, then EPA would have about one month from the current

October 29th comment submittal deadline in which to review, analyze, and give

thoughtful consideration to the anticipated high number of comments. GPA

7
requirements for notifications, monitoring, recordkeeping, and reporting that will

apply to thousands of small and insignificant sources under the new rule. We do

not believe that EPA has adequately considered the substantial effort and

expenditure required to meet the ongoing paperwork requirements of the new rule.

In that regard, GPA asks for EPA’s consideration and help in rectifying specific

concerns that, left unresolved, will place substantial burdens on our industry

without an associated and justifiable environmental benefit.

GPA has established a workgroup under its Environmental Committee that is reviewing

the Proposed Rulemaking and developing specific and detailed written comments that we

will submit to the EPA. Our comments can be more meaningful to the rulemaking

process if EPA provides the comment deadline extension requested. GPA appreciates

your consideration of our concerns and we look forward to working with EPA to address

these in future comments and discussions. Thank you.

3
already unacceptable levels of air pollution in the

Metroplex.For example, peak ozone on September 27in the zip code 76013 was 127 and ozone peak level in

the San Francisco Bay area was 31 for zip code 94116.

Over time the California ozone levels held fairly steady

at about 25% of the Texas region. We are out of

compliance period and that has economic and health

consequences.

Texas air pollution laws and agencies have failed to

protect us and our environment. This summer a high

pressure system has sealed in the pollutants and

inflicted both searing heat and a devastating drought.

We have been hit with a triple whammey.We need

help.

Your name says it all:

ENVIRONMENTAL PROTECTION AGENCY.

State and local governments do NOT protect us. The

The complaint process takes months.TCEQ uses

outdated summa canisters that let them ignore

emissions peaks.When a complaint finally is sent to a
alone.We need your knowledge,persistence, and

good will to help us in our battle for breathable air,

and drinkable abundant water. We are glad you have

come to Texas.

Specifically , we want vapor recovery systems on all

wells and compressor stations.Drillers should execute

“green completions”.

On September 3,2011 my friends and I outlined our

struggle with Dalworthington Gardens Gathering

Station Number One in a Star-Telegram article.lt was

titled “WOMEN ARE SURE SOMETHING SMELLS AT

COMPRESSOR STATION”

TCEQ has had 8 citizen complaints on this site since

June 2011. Open valves were found in June. A

sickening sweet smell was noted by citizens and

station employees.On August 18,2011 a TCEQ

employee experienced health effects while inspecting

the station. VOC levels were high but citizens still

waiting on results.August 22,2011 more odor and

citizen health complaints led to another

inspection.Police said leak was not harmful because
Our pet cats and chickens have suddenly died during

these episodes. We have experienced shortness of

breath,rapid heart rates and itchy eyes and throats. It

is sometimes difficult to remain outside.

lrby,FeiI and Clark are still waiting on the August 18

and 20thTCEQ reports.We know the VOCs have been

too high there, but once again TCEQ has kept the

public in the dark.

We have asked that Midstream install vapor recovery

systems at that site.They have refused to do this and I

am submitting their September 26,2011 e-mail

containing that refusal.

In this e-mail there are several statements I do not

either comprehend nor accept.

First: they self report 1.76 tons of VOC emissions a

year.ls this by estimate or actual air test?? How can

these figures be verified?

Second: regular TCEQ inspections have got to be very

rare.Each inspector covers thousands of wells and

other industrial sites.
Fourth:Midstream doesn’t test for emissions duringblow down events by their own admission. How can

they report these emissions if they don’t know whatthey are?
Copyrighted page(s) removed. Copyrighted 

material is not available in Regulations.gov since 

it may not be reproduced without consent of the 

copyright holder. 

Removed pages can be viewed at the USEPA 

Docket Center, Public Reading Room. 

Address: 1301 Constitution Ave, NW 

Room 3334 

Washington, DC 20004 

Telephone: 202-566-1744 

Email: docket-customerservice@epa.gov
Below we have listed answers to the inquiries you made via our website at www.summitmidstream.com and info@summitmidstream.com.

1. When will the vapor recovery system be installed? Where will they be installed? What pieces of equipment are?

Summit Midstream did not install a VRU at the DWG station because there is not enough vapor emissions for the unit to operate properly. In order to run a vapor recovery unit (VRU) properly, there needs to be a constant vapor emission from the station. At this time, the DWG station currently emits approximately 115 th of the level of Volatile Organic Compounds (“VOC”s) as an average size gas station. The station is currently 93% below its permitted level of VOC emissions and 98.4% below its permit level for Hazardous Air Pollutants. This is not enough emission to warrant a VRU installation. Below is the DWG station comparison of VOC’s vs. other local industrial sites.

50

45

40

— 35

30

l 25

20

1510

DV•S Sratn

2. When will DFW install charcoal filters at DWG?

Charcoal filtration has been installed at DWG and is currently working. We continuously work towards minimizing any odor from the station and monitor our station 24 hours a day, seven days a week.

City ofArThton 4vg. OS Gac SrarIo Daiaa avaJA.ir GM Facia Lanñ1’l Stato

3. Please let me know a time frame on this “leak” getting fixed.
used by the TCEQ when they perfomi reg1ar checks to the stations.

4. Question...what is that material...what is that chemical being used to burn offthe gas? Do you use diesel fuel?

We do not burn off any gas at the DWG station. We do not use any diesel fuel at the station. d I a cc c c L.L) o(f rectà dsej 5. Please let me know what and when this foul odor and frequent releases will be fixed?

The charcoal filtration should help with any odor from the station. We do not have frequent releases of gas from the station.

6. How often do you do your blowdowns and have you tested the air during that time?

\Ve do not have or perform station blow downs on a regularly scheduled basis. Venting of the station, known as Maintenance, Start Up and Shut Down (MSS) emissions, occur only when compressor units are started/ stopped or for a variety of safety reasons including gas leak detection, fire detection or loss of power. We do not test the air during these events. However. ibeeinissions are included in our

agencies.

u C \SS(S
MC 205Office of Legal Services

Texas Commission on Environmental Quality

P.O. Box 13087

Austin, Texas 78711-3087

Re: Chapter 115 Volatile Organic Compounds Storage Rule Revisions, Rule

Project No. 2010-025-115-EN

Dear Ms. Horn:

The Barnett Shale Energy Education Council (“BSEEC”) appreciates the opportunity to submit comments on TCEQ’s proposed revisions to the Chapter 115 Volatile Organic Compounds (VOC) storage rules. BSEEC is a non-profit educational organization with member companies that account for approximately 85% of Barnett Shale natural gas production in the nine-county non-attainment area. BSEEC members include Chesapeake Energy, Dale Resources, Devon Energy, EOG Resources, Encana Natural Gas, XTO Energy, Newark Energy/Beacon E&P, Pioneer Resources, Quicksilver Resources, Titan Operating, Western Production and Vantage Resources.

Our expanded comments are attached and summarized below.

The proposed rulemaking results from EPA’s January 2011 decision to reclassify the nine- county’ Dallas-Fort Worth (DFW) area as a “serious” nonattainment area under the eight-hour

ozone National Ambient Air Quality Standard (NAAQS). That reclassification triggers the need for TCEQ to submit a state implementation plan (SIP) revision to EPA by January 2012 that incorporates all reasonably available control measures, including all reasonably available control technology (RACT), for sources of relevant pollutants. The current rulemaking addresses RACT for oil and condensate storage tanks and proposes controls that, in TCEQ’s view, would result in VOC reductions that would be used to demonstrate reasonable further progress toward the attainment of the 1997 eight-hour ozone NAAQS in the DFW area. BSEEC members operate condensate storage tanks in the DFW area (although only a limited number in the dry gas production areas — TCEQ should have an exact count from the Barnett Shale Special Inventory) and thus would be directly affected by the proposals here under consideration.

It is apparent that the basis for the current proposal is TCEQ’s belief that substantial amounts

of VOC emissions are emitted from condensate storage tanks in the DFW NAA. TCEQ has

Those counties are Collin. Dallas. Denton, Ellis, Johnson, Kaufiiian, Parker, Rockwall, and Tarrant.
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Q 

w has much more accurate data from the l3amett Shale Special

Inventory which should demonstrate that, in reality, voc emissions from condensate storage tanks in the Barnett Shale production area are much less than previous “top..down” desktop studies have suggested. The recent City of Ft. Worth ERG Study provides additional evidence

that prior studies, such as the present TCEQ inventory and, in particular, the January 26, 2009 Armendariz report “Emissions from Natural Gas Production in the Bamett Shale Area and

Opportunities for Cost Effective improvements”, have overestimated VOC emissions from

condensate storage tanks by multiple factors. Unfortunately, emissions estimates from these

desktop studies have been taken as gospel by some groups, which has led to public calls for additional VOC controls at small oil and gas production facilities where only small amounts of VOC are presently being emitted.

In short, BSEEC urges TCEQ to ensure that there is a sound basis for any new controls

that are imposed, and to ensure that any new controls are truly needed. Please let me know if you have any questions on the attached comments.

Sincerely,

Ed Ireland. Ph.D.

Executive Director

Attachments: (1) BSEEC Comments on Proposed Rulemaking Rule Project No. 2010-025-115-

EN; (2) Environ ‘Review and Analysis of HARC Condensate Production VOC Emissions

Factor” with (3) “Attachment A: HARC H5IC Report Site Data”
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n counties within the DFW NAA where natural gas with little or no VOC content is mostly produced.

A. Table 3-1 1 of the proposed rulemaking lists VOC emissions for the 2006 base year as 72.1 tpd with 40.6 tpd as VOC emissions from condensate tanks. Projected 2012 total VOC emissions are 113 tpy in 2012. The 40.6 tpd 2006 estimate of VOC emissions from condensate storage tanks is demonstratively wrong.

On page 4-28 of the 2010 ERG report, it states that “Emissions from oil and condensate storage tanks were calculated using the methodology and emission factor developed in the 2009 TERC study “VOC Emissions From Oil and Condensate Storage Tanks” (TERC, 2009). These emission factors were multiplied by county-specific oil and gas production data obtained from the TRC. The calculations assume that venting emissions are uncontrolled by flares or vapor recovery units.” (Emphasis added). Table 4-15 on page 4-29 lists the VOC emission factor as 33 lb/bbl. This emissions factor has come to be known as the “HARC H5 1 C emissions factor” and has been used in multiple places by TCEQ despite the fact that it is based on a faulty study. Please see Appendix A, which was part of earlier comments made to TCEQ regarding the proposed VOC Flash Emissions Guidance document. Appendix

A is a general technical critique of the HARC study. Also, please see the attached May 16, 2011 Environ memorandum “Review and Analysis of HARC H5IC Condensate Production VOC Emission Factor.” This memorandum is a review of the HARC study results based on statistical analysis of the data.

It is worth noting here that the January 26, 2009 report “Emissions from Natural Gas Production in the Bamett Shale Area and Opportunities for Cost Effective Improvements”, prepared by Dr. Al Armendariz for Ramon Alvarez with the Environmental Defense Fund, also relied on the HARC study for estimating VOC flash emissions from oil and gas activities in a 21-county Barnett Shale area. To calculate VOC emissions from condensate production during the summer months, Dr. Armendariz relied on a VOC emissions factor of 48 lb/bbl of condensate throughput that was derived from the north Texas well site data in the 2009 HARC study. Use of this erroneous emissions factor resulted in a projected 2009 estimate of VOC emissions from condensate storage of 146 tpd for the peak summer months. This was an increase of 116 tpd or almost 400% over the projected 2009 annual VOC emissions of 30 tpd calculated as an annual average. This result made no sense from a technical standpoint as the higher storage temperature of condensate during summer months significantly affects only the working and breathing emissions from condensate storage tanks, which are typically insignificant compared to VOC flash emissions from condensate (the amount of VOC flash emissions
Unfortunately, this faulty emissions factor has now also been used by the EPA in proposed NSPS rulemaking to suggest that 1 BOPD of condensate production, regardless of the separator pressure that the condensate is let down to atmospheric storage from, emits over 5 TPY of VOC and should require controls.

B. The 21.5 tpd estimate of VOC emissions from pneumatic devices is demonstratively wrong.

The 2010 ERG report (page 4-43 to 45) relies on the methodology used in the 2008 CENRAP study (Bar-Ilan, et al., 2008) to estimate VOC emissions from pneumatic devices. The CENRAP study assumes all sites had pneumatics with high bleed rates and based those rates on Natural Gas STAR data (13.6

— 31 scf/hr). The Barnett Shale production facilities are relatively new and low bleed pneumatics are the norm. In addition, many companies are using best management practice (BMP) and replacing existing high bleed pneumatics with low bleed or no bleed devices. Also, the 2008 CENRAP study assumed a VOC content of 10 wt% to 15 wt% for onshore gas production. This high VOC content is not representative of gas production in the core area of the Barnett Shale, especially in the dry gas production areas of the counties in the DFW NAA.

To their credit, TCEQ seems to have recognized that the VOC emissions inventory for pneumatic devices is much too high for counties in the DFW NAA and is seeking additional information from operators via a supplemental Barnett Shale Special Inventory request.

C. While not directly relative to the proposed ozone SIP revision, we note that estimated statewide inventory of n-hexane, benzene, toluene, ethylbenzene and xylene (BTEX) emissions are also overestimated since they are based on the erroneous VOC emissions estimates and a possible error on the speciated HAP content of vapor emitted during loading of condensate.

1. In the 2009 ERG report, Table 4-15 on page 4-29 lists the HAP emission factors for condensate storage. These are based on the VOC emissions factor of 33 lb/bbl and storage tank vapor sampling data from the 2009 TERC (HARC) study. The vapor analysis of vapors from storage tanks appear to be reasonable other than the one noted exception (see Appendix A). However, the faulty VOC EF of 33 lb/bbl should not be used for HAP emissions inventory.
HAP/VOC ratio factors shown in Table 4-17 on page 4-34 of the 2009 ERG report: 0.28 for benzene, 0.48 for toluene, 0.027 for ethylbenzene, and 0.21 for xylenes. These ratios appear to be in error as they should most likely be percentages; i.e., mass HAP/VOC ratios for vapors emitted during the loading of condensate would typically be no more than 0.04 for n-hexane (which should be listed as a HAP in the inventory), 0.002 for benzene, 0.003 for toluene, 0.0002 for ethylbenzene and 0.002 for xylenes. It is not known if the actual emissions inventory was based on the ratios

as shown in Table 4-17 or on correct values.

D. TCEQ has accurate VOC emissions data from the Barnett Shale Special Inventory which should demonstrate how much the November 2010 ERG study overestimates VOC emissions from counties in the DFW NAA.

Data collected from seven of the largest independent producers in the Bamett Shale (Chesapeake Energy, Devon Energy, EOG Resources, Encana Natural Gas, Quicksilver Resources, XTO Energy and Pioneer Resources) indicates that emissions of VOC from oil and gas production equipment within the 9-county DFW NAA average 0.7 tpy per well. (Note that many well pad sites contain multiple wells; therefore, VOC emissions from a single well pad site could be multiples of 0.7 tpy). Extrapolating this average value to all 10,700 wells in the DFW NAA gives a total VOC inventory of approximately 7,500 tpy or 21 tpd. This is less than one-third of the 2006 base year inventory.

The recently released ERG study of emissions from oil and gas activities in the City of Ft. Worth verifies these low VOC emissions numbers. In that study, total VOC emissions were estimated to be 929 tpy from 388 sites with a total of 1,140 wells. That is an average of 2.4 tpy per site and 0.8 tpy per well. The average VOC emissions from a well pad with no compressor engine located on site was estimated to be 0.07 tpy. Average VOC emissions from

a well pad with

a compressor engine(s) (usually a small 175 to 215 Hp rich-burn engine) were estimated to be 2 tpy.

E. Part of the reason that the present VOC inventory for oil and gas production equipment in the DFW NAA is overestimated is that the substantial use of best management practices (BMPs) by most operators is not considered. Operators in the Barnett Shale typically practice BMPs, such as low or no bleed pneumatics, vapor recovery units where teclmologically and economically feasible, flares. etc to control VOC emissions. These

may not be considered in some top down emissions inventory estimates, but can achieve substantial VOC emissions reductions of 90% to 99%. These types of controls are required to keep large sites below the 25 tpy threshold if an operator chooses to permit the site under the TCEQ Permit by Rule, which is typically the case for well pad sites. In
the 9

county DFW NAA before even considering additional mandatory controls on operators.

Based on the emissions estimates given above, there is little VOC reduction that can be obtained from mandatory controls on VOC emissions from condensate storage tanks located in the 9-county DFW NAA. This is because the vast majority of production in this area is dry natural gas with little to no VOC content. Therefore, there is little condensate storage in the area. In fact, the vast majority of storage tanks present on well pads in this area are produced water storage tanks, which emit very little to no VOC.

Note that the Texas Railroad Commission may show some condensate production from gas wells in the area that does not really exist. This is because the TRC allocates condensate recovered by salt water injection operators back to the wells where the produced water was generated. Since salt water injection operators have no way to determine which of the many wells that they service produced the “skim” condensate, it is often allocated to all wells contracted for water disposal by a salt water disposal operator. For dry gas wells with little or no VOC, this produced water does not contain any significant amount of condensate. There can be some ‘skim” condensate in the water produced at a wet gas well such as those in Wise, western Denton and Parker Counties.

III. In any ozone SIP rulemaking, TCEQ should include a section on the reactivity of the VOC species typically emitted by the various sectors. The public should be informed that not all VOCs are equal when ozone formation is the central theme. A December 2004 paper by TCEQ highlights the reactivity of different VOC species: 1

Looking at the VOC part ofthe Iozonej equation, not all VOcc are created equal some VOC’s make ozone much more eJjctively than others. We can define reactivity as the potential ofa given compound to make ozone.

This paper cites the Maximum Incremental Reactivity (MIR) scale which measures the maximum amount of ozone that can formed by adding a particular VOC into NOx-laden air. The vast majority of VOC emissions from oil and gas production equipment are propane butanes and pentanes, which have lower reactivity. In the MTR scale, it is notable that propane is at the bottom and that some VOC species are more than 20 times more effective than propane at forming ozone. In contrast, VOC emissions from on-road vehicles contain multiple compounds with a high reactivity index.

Emissions Modeling o/5pecic High/v Reactive ?‘httile Organic Compounds (HRI MC’) in the Houston-Ga/veston-Brazoria Ozone bonattainment Irea. R. Thomas et ci!. ([‘(TO), December 2004
would make adoption of new SIP requirements on condensate storage tanks in the DFW NAA area a moot point.
Re: Review and Analysis of HARC H5IC Condensate Production VOC Emission Factor

Dear Mr. Campbell:

As requested by Chesapeake Energy Corporation (Chesapeake”), ENVIRON has performed a technical review of the October 31, 2006, report prepared by URS Corporation (“URS”) entitled “VOC Emissions From Oil and Condensate Storage Tanks” (hereafter referred to as the “HARC H51C Report”). 1 Following is

a summary of ENVIRON’s review specifically related to the derivation of the 33.3 lb VOC/bbl emission factor.

As presented within the HARC H51

C Report, average VOC emission factors were derived from emission tests conducted on 21 tank batteries. 2Figure 1 shows the relationship between the estimated VOC emission factor and production rate for these 22 sites. 3 As shown, 9 test sites had condensate production of less than 5 bbl/day. 4

Derived tank battery-specific VOC emission factors ranged from 0.7 lb/bbl to 215.1 lbJbbl. Figure 1 presents the relationship between condensate production and estimated VOC emission factor for the 21 condensate storage tank batteries used by URS in the derivation of the VOC emissions as a function of condensate production emission factor.

For this data set, the mean VOC emission factor was 33.3 lb/bbl with a standard deviation of 53.3 Ib/bbl. 5 As can be seen from Figure 1, there are two sites with much higher VOC emission factors compared to the other sites. These two sites are denoted with red diamonds. The emission factors and condensate production rates for these two sites are:

• 215.1 lb/bbl at

a production rate of 1 bbl/day, and

• 145.1 Ib/bbl at a production rate of

2 bbl/day.

I httr://files.harc.edu/Proiects/AirQuality/Proiects/H051 C/H051 CFinalReport.pdf

2 Results from testing conducted at a 22,d site, Tank Battery 26 with a derived emission factor of 1,218 lb/bbl, was discarded from the analysis with the reason given that the vent gas flow rate measurement was taken during non- representative conditions. Per the HARC H-51C Report, for Tank Battery 26, 97 percent of the measured vent gas was released during the first 8 hours of the 24-hour sampling period. The report attributed this condition to fracking at an adjacent well.

Detailed HARC H-51C data is presented in Attachment

A of this review.

“Based on our review of the report, it is our understanding that production rates were not measured during testing. Rather, URS requested and obtained production estimates from operators at a later date.

The standard deviation, which is the variation around the mean, is approximately 1 .6 times the mean for this data set, indicating high variability in the data. When the standard deviation exceeds the mean, it can imply that the data set is either too small to accurately determine the true mean value and/or there may not be a strong relationship between the two variables considered. Caution should be exercised when using a mean value derived from this data set.
U- 150

C

0

100 -

50.

> 0

—.

0 20 40 60 80 100 120 140 160

Condensate Production (bbl/day)

Figure 1. VOC Emission Factor as a Function of Condensate Production,

Excluding Tank Battery 26

(Derived from HARC H5IC Report)

To put these values into context:

• Condensate production of 1 bbl/day is equal to approximately 22.4 teaspoons per minute of condensate production. In other words, a fast drip.

• A production rate of 5 bbl/day is equal to about 18.7 fluid ounces per minute. At that rate, on average, it would take about 39 seconds to fill a 12 ounce soft drink can.

• A typical condensate storage tank is 12 feet in diameter with a cross-sectional area of approximately 113 ft2. Adding 5 barrels to a tank of this size will raise the liquid level in the tank approximately 3 inches.

• Assuming a condensate specific gravity of 0.70, a barrel of condensate weighs approximately 245 lbs. An emission rate of 215.1 lb/bbl means that, on a mass basis, nearly as much VOC is being emitted as is being collected and recovered. Note that VOC already excludes emissions of methane and ethane.

Based on ENVIRON’s experiences in managing tank testing programs as well as observations provided by natural gas liquids producers, making accurate measurements of condensate production at very low production levels is problematic.

Presented as Figure 2 is a “box-and-whisker” plot of the 21 data points used in deriving the 33.3 lb/bbl VOC emission factor. The box-and-whisker plot is a useful way of depicting observations graphically and also to identify outliers. The lower and upper limits of the central gray box represent the 251h and 75th percentiles, also known as the lower and upper quartiles of the data. The thin white band within the gray box is the median of the data. The red diamond is the mean of the data. The whiskers’ (short horizontal end cap lines) represents the lower and the upper extreme quartiles. The red circles represent data points that are at least 3 times the difference between the upper and lower quartiles (also called the intra-quartile range) above (or below) the median. Statistically, these red circles are “outside outliers.” “Inside outliers are data points that
2001

Outliers

150

100

:1_

Figure 2. Box-and-Whisker Plot for All Data Points Used in

Deriving 333 Ib/bbl Emission Factor

(Derived from HARC H5IC Report)

The two red circles in Figure 2 representing 215.1 lb VOC/bbl and 145.1 lb VOC/bbl emission factors for Tank Batteries 25 and 17, respectively, are outside outliers and, most likely, should be excluded from the analysis.

If the outside outliers identified in Figure 2 are excluded from the data set, the average VOC emission factor is 17.9 lb/bbl with a standard deviation of 19.5 lb /bbi. By excluding these two outliers, the standard deviation becomes smaller relative to the mean: 1.1 times the mean

versus 1.6 times the mean when these two data points are not excluded. Therefore, the data shows better agreement when these two data points are excluded.

As noted, it is difficult to obtain accurate measurements of condensate production at low levels. If 5 bbl/day is used as the threshold for making reasonably accurate measurements of condensate production, then eight of the sites used in deriving the 33.3 lb/bbl emission factor should be excluded from the analysis. Figure 3 presents the relationship between VOC emission factor and condensate production for the 13 sites with measured production rates greater than or equal to 5 bbl/day.

The mean VOC emission factor for this data set is 13.8 lb VOC/bbl with a standard deviation of 18.3 lb VOC/bbl (1.3 times the mean). While showing less variability than the data set presented in Figure 1, the data shown in Figure 3 does demonstrate variability due to the three points shown as red diamonds.
0

1.)

0

in

E

c)0

>

50

0

4-’

U

C

0

inin

E

U-I

c-I

0

>

S ‘p— .

40

30

20 -

10 -

0

0 20 40 60 80 100 120 140 160

Condensate Production (bbl/day)

Figure 3. VOC Emission Factor as a Function of Condensate Production, Tank Batteries with Production ? 5 bbllday (Derived from HARC H5IC Report)

Figure 4 is a box-and-whisker plot for derived VOC emission factors for 13 tank battery sites with condensate production greater than or equal to 5 bbl/day. As explained earlier in this

summary, the box-and-whisker plot is a useful way of identifying outliers. The red circle in Figure 4 is an outside outlier. This represents the derived VOC emission factor for Tank Battery 32. The red stars in Figure 4 are inside outliers. The two stars represent the derived VOC emission factors for Tank Batteries 20 and 29.

70

60

40

30

2010

0

Figure 4. Box-and-Whisker Plot for Derived VOC Emission Factors,

Tank Batteries with Production 5 bbllday (Derived from HARC H51C Report)
If, in addition to the one outside outlier, the two inside outliers are excluded from the analysis,

the average VOC emission factor is 5.1 lb/bbl with a standard deviation of 3.5 lb /bbl. By

excluding these three points, the standard deviation becomes smaller relative to the mean: 0.7

times the mean versus 1.1 times the mean when just the outside outlier is excluded.

Note that, in this statistical analysis, the lowest derived emission factors — Tank Batteries 4 and

5 at 0.78 and 0.67 lb VOC/bbl, respectively — are not outliers. Thus, it is would not be

appropriate to exclude them from the analysis.

A standard deviation lower than the mean indicates that the data are closely grouped around

the mean. Assuming a “normal” distribution, 68% of the tank battery sites would have a VOC

emission factor within one standard deviation of the mean and 95% of the tank battery sites

would have a VOC emission factor within two standard deviations of the mean. Only the last

data set considered exhibits a “normal” distribution. 6

Table 1 presents a statistical analysis of various datasets presented in this review.

Dataset Condensate Mean VOC Standard Number of Tank . Production Emission Factor Deviation No. Battery Sites (bbllday) (lb VOCIbbI) (lb VOCIbbI) Iba 21 All 33.3 53.3

lcb 19 All 17.9 19.5

3a 13 5 13.8 18.3

3bc 12 5 9.6 11.0

3bd 10 5 5.1 3.5

“Original HARC H51C data set. b Original data set excluding the two outside outliers. C Condensate production 5 bbl/day, excluding the one outside outlier. d Condensate production 5 bbl/day, excluding the one outside and two inside outliers.

For comparative purposes, the Colorado Department of Public Health and Environment

(CDPHE”) recommends VOC emission factors that range from 3.0 lb VOC!bbl to 13.7 lb

VOC/bbl, for condensate storage tanks, depending on the location of the facility. 78

6 This data set consists of 10 tank batteries: 2, 3, 4, 5, 6, 15, 18, 23, 28 and 30.

http://www.cdphe.state.co.us/ap/sbap/SBAPoilgastankguidance.pdf

CDPHE recommends that these emissions factors should only be used if the total uncontrolled VOC

emissions due to condensate tanks at the site are less than 80 tons per year. CDPHE recommends site- specific sampling and analysis to estimate emissions for sites having uncontrolled VOC emissions greater than 80 tons per year.

Table I. VOC Emission Factors — Statistical Analysis
Using the 3b dataset (condensate production 5 bbl/day, excluding the one outside and two

inside outliers), derived emission factors for “high pressure” separators (operating atapproximately 200 psi or greater) and “low pressure” separators (operating at less than 50 psi)

are as follows.

• “High Pressure” Separators:

- Data points = 3 - Mean VOC Emission Factor = 16.6 lb/bbl — Standard Deviation = 12.2 lb/bbl

• “Low Pressure” Separators: - Data points = 7

- Mean VOC Emission Factor = 4.0 lb/bbl — Standard Deviation = 2.5 lb/bbl

While these data subsets most likely have an insufficient number of test data points to

accurately derive emission factors (especially for the high pressure separator subset), it is

interesting to note that these subsets show better data correlation than do any of the larger

datasets. For the low pressure separator data subset, the standard deviation is 0.6 times the

mean. As previously noted, for the 3b dataset as a whole, the standard deviation is 0.7 times

the mean.

Please let us know if you have any questions.

Best Regards,

Steven H. Ramsey, P.E., BCEE Shagun Bhat, PhD

Principal Consultant Senior Associate
Attachment A:

HARC H5IC Report Site Data
Attachment A

(Derived from HARC H-51C Report)

Tank Battery Sites

Separator Condensate Der

Tank Discharge API Production Emiss

Battery County Area Pressure (psi) Gravity (bbllday) (

2 Montgomery Houston-Galveston-Brazoria 41 42 105 

3 Montgomery Houston-Galveston-Brazoria 38 41 87 

4 Montgomery Houston-Galveston-Brazoria 34 40 120 

5 Montgomery Houston-Galveston-Brazoria 46 43 100 

6 Montgomery Houston-Galveston-Brazoria 33 39 130 

13 Denton Dallas-Fort Worth —200 61 2 

14 Denton Dallas-Fort Worth —200 59 4 

15 Denton Dallas-Fort Worth —200 61 5 

16 Denton Dallas-Fort Worth —200 61 2 

17 Denton Dallas-Fort Worth —200 58 2 

18 Denton Dallas-Fort Worth —200 58 10 

19 Denton Dallas-Fort Worth —200 58 2 

20 Denton Dallas-Fort Worth —200 59 10 

23 Parker Dallas-Fort Worth 39 48 27 

24 Parker Dallas-Fort Worth 36 41 1 

25 Denton Dallas-Fort Worth —200 58 1 2

27 Denton Dallas-Fort Worth —200 59 2 

28 Brazoria Houston-Galveston-Brazoria 38 46 30 

29 Brazoria Houston-Galveston-Brazoria 41 42 61 

30 Brazoria Houston-Galveston-Brazoria 36 42 15 

32 Galveston Houston-Galveston-Brazoria 121 48 142 
average VOC emissions factor of 33 lb/bbl of condensate to calculate an estimate of

total VOC emissions from storage tanks for the East Texas Region. For Denton County

only the results from the report give

a VOC emissions factor of 48 lb/bbl. We believe

that the methodology used in the report to arrive at these two emission factors is flawed.

We are also concerned that these inaccurate numbers may be used in VOC emissions

inventory estimates for future nonattainment areas. Therefore, we offer the following

analysis to demonstrate why the results from the 2006 HARC Report for VOC emissions

from condensate storage are unreliable and should be revised or discarded. We would

welcome the opportunity to discuss this analysis with TCEQ, especially since

a second

VOC emissions report is already in the works for release in 2009.A. It is obvious from looking at the reported measurements for tank battery #25 that

gross errors in measurements occurred. Both the reported vent gas MW of 89 and

the VOC fraction of 0.99 are impossible values for gas flashed from condensate at

a

natural gas production site. The calculated VOC flash emissions factor of 215 Ibfbbl

would require that 82% of the condensate flashed when reduced in pressure from

200 psig. This is simply not possible at this separator pressure. At

a minimum, the

TCEQ should reject this data point and recalculate the average VOC flash emissions

factor from the remaining 20 tank batteries. Recalculation would give

a factor of 24.2

lb/bbl,

a reduction of 27% from the one reported.

B. For tank battery #17, the calculated VOC flash emissions factor of 145 lb/bbl would

require that 55% of the condensate flashed when reduced in pressure from 200 psig.

This is simply not possible at this separator pressure. Since the other measured data

for the vented gas (MW of 36.6 and VOC fraction of 0.65) are reasonable numbers,

the error is most likely due to the low condensate production rate of

2 BOPD used in

the calculations. The TCEQ should reject this data point and recalculate the average

VOC flash emissions factor from the remaining 19 tank batteries. Recalculation

would give

a factor of 17.8 lb/bbl,

a reduction of 53% from the one reported.

C. The report lists data for 10 condensate tank batteries (in Montgomery, Parker, and

Brazoria Counties) with

a range of separator pressures from 33 to 46 psig and with

a

range of API gravity from 39° to 48°. The test results for tank battery #29 (33.7

lb/bbl), tank battery #4 (0.78 lb/bbl), and tank battery #5 (0.67 lb/bbl) appear to be

statistical “outliers.” Since there are no obvious data errors and the condensate flow

rates are high,

a statistical analysis of the data would have to be conducted to

determine if any of these three test results are “outliers” that should be discarded.

We have no specific recommendation on that point.
the sample, plus benzene, toluene, ethyl benzene, xylene (BTEX) and other C6+

VOC will be multiplied by the flow rate (averaged over 24-hours) to produce

measurements of mass emission rates for each of the reported gas constituents and

other C6+ VOC in units of pounds per hour. The mass emission rates will then be

divided by the number of barrels produced during the 24-hour flow measurement

period to produce emission factors in units of pounds per barrel. Criticalmeasurements for this approach include the following:

• Vent gas composition;• Vent gas flow rate; and• Oil or condensate production rate”

Further down on the same page, when discussing selection of well sites to be

tested, one of the stated criteria is that “The oil or condensate production rate is at

least 2 barrels per day.”

Lastly, Section B5 (Quality Control) states “The greatest source of uncertainty in the

calculated emission factors is likely to be the estimation of oil or condensate

produced over the sampling period. The accuracy of the emission factors derived

from these tests will be limited to how accurately the production volumes can be

determined during the sampling episode. While such production information is

readily available on a monthly or annual basis from the Texas Railroad Commission,

accurate production data over a 24-hour period is generally not available (emphasis

added), and will have to be estimated from reading the tank level gauges (if

present), manually gauging the tank level, or from production meters at the site if

available. The specific methods and instruments used to estimate daily throughput

will be recorded in the field sampling log; however, the sensitivities of these devices

to oil or condensate throughput over 24-hours is unknown.”

1. We agree that the critical measurements for this study were the vent gas

composition, vent gas flow rate, and oil or condensate production rate.

2. We do not agree that obtaining data from a well site that is only producing 2

barrels of condensate per day is appropriate when the goal is to calculate a

VOC emissions number in lb/bbl based on a 24-hr test period. Using

emissions data based on this low amount of production lends itself to largesampling errors that can result in large variability in reported numbers (which

is exactly what occurred). In addition, on page 1 of Section B2 (Sampling and

Measurement Methods), it is stated that “The liquid production rates will be
feet), the storage capacity of the tank would be around 15 bbl per foot. To

gauge a 24-hr production rate of 2 barrels would mean taking two

measurements to obtain a difference of about 1 4 inches. For a tank heightof 12 feet, measurement of a difference of 1 inch would be necessary. In

addition, all of the sites had at least two tanks. Therefore, to measure 2

barrels of production would take two measurements to obtain a difference of

1/2 to 3/4 of an inch. It is easy to see that this technique would lead to large

errors in condensate production rate, and in fact, it appears that the

researchers abandoned this concept at some point (see Item 5).

3. We believe that the researchers used proper techniques for obtaining vent

gas compositions and have no reason to question that data, other than theobvious errors for tank battery #25 previously mentioned.

4. We believe that the researchers used proper techniques for measuring vent

gas flow rate, using a Fox Model 1OA Flow Meter, although some of those

measurements may be questionable due to the low rates attempted to bemeasured from test sites with low condensate production.

5. Our greatest concern is with the methodology used to come up with

condensate production rates for the 24-hr test periods. Evidently, the

researchers rightly determined that an accurate measurement of condensate

production during the test periods from tank gauging was not possible basedon the concerns expressed in Item 2. It appears that in place of measured

condensate production, the researchers substituted 2005 daily averagecondensate production numbers for each tested site obtained from the RRC

database (footnote “f’ for Table 3-3 on page 3-4 “Daily average condensate

production for 2005 from www.rrc.state.tx.us/interactive data.html”). Using

daily average condensate production numbers from a historical database, forwhich only monthly and yearly totals are reported, to calculate a VOC

emissions factor from actual 24-hr test data for a specific tank battery can

introduce large errors in the calculation of the flash VOC emissions factor as

evidenced by the results from tank battery #17.

E. We believe this flawed methodology renders the results of the report meaningless

and urge TCEQ not to rely on them for any inventory analysis or as the basis against

use of the VBE method for estimating flash VOC emissions. If an average flash VOC

emissions factor must be used by TCEQ until a more rigorous study can be made,

then that factor should be 17.8 lb/bbl as discussed in Item B above. Another option
an u

(

g

Report).

F. We urge TCEQ to check the results of the 2006 HARC Report for condensate tank

batteries against data provided from industry for actual sites that used process

simulator programs, E&P Tanks, or the GOR method with

a flash gas analysis and

condensate analysis. TCEQ should have access to site specific data with

a wide

variety of separator pressures and API gravities. We believe such

a comparison will

show that the reported average VOC flash emissions factor of 56.6 (lb/bbl) for

Denton County are out of line with values calculated from actual site data using

methodologies that are known to be fairly accurate. When added to the two battery

sites for Parker County, the report gives an erroneous average VOC flash emissions

factor of 48.0 lb/bbl for counties in the DFW nonattainment area. Unfortunately, this

factor has already been used in another draft report dealing with VOC emissions in

the DFW nonattainment area (see Emissions from Natural Gas Production in the

Barnett Shale Area and Opportunities for Cost Effective Improvements, Peer-Review

Draft September 30, 2008, by Dr. Al Armendariz, Ph.D.)

G. We gather from the language at the top of page 8 that TCEQ has commissioned or

will commission another study on VOC flash emissions from oil and condensate

storage tanks that is scheduled for completion in 2009. We request that TCEQ allow

industry and/or

a third party consultant to review the proposed testing procedures

and proposed procedure for obtaining accurate condensate production rates for the

sites to be tested. Otherwise, it is likely that the same errors produced by the 2006

HARC Report will be repeated.

The most critical issue is the method used to measure actual condensate production

during

a test period. We believe that to calculate an accurate VOC flash emissions

factor in lb/bbl requires total condensate production of at least 10 barrels during thetest period. Therefore, any test site should be one with either

a high condensate

production rate (> 10 BOPD) or the test period must be extended to 48-hr or longer

to obtain data from at least 10 barrels of production. The condensate production

should either be measured directly with the use of

a liquid meter or from

a minimum

tank gauging measurement of

4 inches. This is needed to give

a reasonably

accurate condensate production number.

TCEQ may want to consider whether

a testing program that proposes to provide

actual VOC emissions from multiple test sites (i.e., tries to measure the condensate

rate or uses

a historical condensate production rate) is really necessary and worth
production numbers can then be used to g

the site if that information is needed. This method does away with the potential for

large errors due to measurement of low condensate production rates or the use of

historical information for calculating a VOC flash emissions factor. It should also be

much less costly than a project that requires actual measurement of flash gas and

condensate flow rates.
increasing understanding of the environmental, economic and national security benefits of clean, abundant, dependable and efficient North American natural gas. ANGA’s31 memoers include North America’s largest independent natural gas exploration and production companies —the leading developers of theshale plays that aretransforming the clean energy landscape and allowing communities across the country to advance economically, create sustainable joos, stay competitive globally, and embrace a cleaner environment.

We need reliable energy to meet our growing needs. We need clean energy to protect our environment. Natural gas bridges both of those needs vkile also providing energy security and domestic jobs. Discovery ofU.S. shaleplayscombined with advancesin drillingtechnology have resulted in game-changing projections of our supply of affordable domestic natural gas. Respected academics, gornment agencies, and expert bodies —from the Energy Information Association to MIT to the National Petroleum Council-- are all coming to the same conclusion. We ha abundant, domestic supplies of economically recoverable natural gas to power our nation for generations to come.

We see a growing role for natural gas in the nation’s energy mix, in particular because of the environmental advantages of its use as a power generation and transportation fuel. When used to generate electricity, natural gas burns cleaner than many other fuel sources, virtually eliminating S02, particulate, and mercu ry emissions and significantly reducing NOx emissions. Vehicles running on natural gas also emit significantly less NOx, VOCs and particulate matter than vehicles running on gasoline or diesel.

The natural gas community is keenlyaware that with the opportunities presented by North Americas vast supplies of naturalgas comes the responsibility to be dedicated environmental

stewards. We firmly believe that people do not have to choose between pro tecting their natural resources and reaping the benefitsof this abundant energy source. To that end, we hope to work with EPA to ensure these regulations protect the environment in a manner that is

consistent with our commitment to safe and responsible development without adding

unnecessary burdens that would impede our Nation’s ability to take full advantage of the tremendous potential of American natural gas. ANGA intends to submit detailed written

comments to the Agency,and

v nope to have a continued dialogue with the Agency as it develops the final rulemaking. In the meantime, v. offer the following thoughts on the proposed requirements.

In the natural gas production process, there are already significant incentis in place for operators to reduce air emissions. Lost emissions equate to lost renues, aswe strive to cost-
prescribed schedules if there isno need from an emissionsstandpoint to undertake an actvty at a particular time. In the instances where ve believe the requirements are largely capturing existing good operating practices because of the incentives mentioned above, we encourage the agency to recognize that and to aid creating unnecessary and orIy-burdensome recordkeeping and reporting requirements. Finally, we look forward to discussing further the agency’s regulatory impact analysis. We believe a better understanding of existing operating practices will help the agency produce a more accurate cost-benefit estimate associated with

the rulemaking.

Again, ANGA and its member companies appreciate the opoortunity to comment here today. We look forward to rking with the agency to ensure the dual goals of resource development and environmental protection are met so that Americans can continue to benefit from the

development of our vast domestic natural gas resource.
p

p

p

p

development of the clean-burning natural gas in the Barnett Shale.

I would like to focus on two points regarding the proposed New SourcePerformance Standards or NSPS rules. First, a “one-size fits all” approach toregulating VOC emissions from natural gas wells is not appropriate because

VOC emissions vary widely due to geologic factors and operating conditions. For

example, the dry gas areas of the Barnett Shale have very low VOC emissions.This also suggests that it is not appropriate for the EPA to use natural gas

emissions as a surrogate for VOC emissions (NSPS Proposed Rules, Federal

Register, page 52760).

Second, the proposed new NSPS rules for the oil and natural gas sector are so

extensive and complex and the comment period so short that the EPA should

extend the comment period and delay implementation of the rules until sufficient

review is performed and comments can be made.

Regarding VOC emissions from Barnett Shale natural gas wells, the TCEQrecently released the data collected from their Phase 2 Special Inventory in

which operators were required to report the actual VOC, NOx and HAP

emissions from all 49,021 pieces of equipment listed in the Phase 1 inventory.Those data revealed that the TCEQ significantly overestimated VOC emissions

from Barnett Shale natural gas wells in its State Implementation Plan (SIP) forthe 9-county DEW non-attainment area.

TCEQ’s Phase 2 emissions data showed that VOC emissions in the 9-county

EPA non-attainment area of the Barnett Shale were actually 23.2 tons per day(TPD) in 2009. This compares to TCEQ’s SIP estimate of 101.8 TPD for 2010

(after backing out the 10% growth rate that TCEQ assumed from 2010 to 2012—

see page 3-28 of “Revisions to the State of Texas Air Quality Implementation

Plan for the Control of Ozone Air Pollution,” Proposal, June 8, 2011). Even

allowing for the modest growth in the number of wells in operation between 2009and 2010, it is obvious that the TCEQ has been over-estimating the VOCemissions from Barnett Shale natural gas wells by many orders of magnitude.

One basis for the over-estimation of VOC appears to be TCEQ’s assumption that

substantial amounts of VOC emissions are emitted from condensate storage

tanks. TCEQ has cited certain studies and findings as support for its assumption

as to the level of VOC emissions from condensate storage tanks, As explained in
and gas sector (see attached: Ed Ireland

s August 8, 2011 written comments on

TCEQ’s proposed revisions to the Chapter 115 Volatile Organic Compounds

storage rules).

The recent City of Fort Worth ERG Study provides additional evidence that prior

estimates, such as in the current TCEQ SIP (cited above) and the January 26,

2009 Armendariz report “Emissions from Natural Gas Production in the Barnett

Shale Area and Opportunities for Cost Effective Improvements”, haveoverestimated VOC emissions from the oil and gas sector. Unfortunately, the

faulty 33 Ibs./bbl. emission factor from these studies has reappeared in this EPA

rulemaking and appears to underlie the EPA’s VOC calculations on which

subpart 0000 is based.

In summary, the EPA should recognize that a “one-size fits all” regulatory

approach to regulating VOC from natural gas wells is not appropriate because

such emissions vary widely depending on geologic factors and operating

conditions. This also suggests that it is not appropriate for the EPA to use

natural gas emissions as a surrogate for VOC emissions. Since both TCEQ and

EPA have overestimated VOC emissions, the costs of these proposed NSPSrules may be underestimated and the benefits overestimated. The EPA needs to

be encouraging, not discouraging, the development of clean-burning natural gas.

This was highlighted in a study released this week by well-known economist Dr.

Ray Perryman that noted the huge economic benefits and jobs that Barnett Shale

activity is providing to north Texas and the entire state of Texas. The EPA

should proceed with caution so as not to damage this powerful economic engine

unnecessarily.

Finally, the EPA needs to provide more time for affected companies to review the

rules and prepare comments. There must be a reasonable time period for

companies to avoid non-compliance by being able to properly prepare for

implementation of these new regulations.

Thank you.
By the dog park. Along the River. Behind the 7

11. Next to the Waffle House. Beside

the highschool sports field. Practically in people’s frontyards. I also can’t help but

notice how concentrated the operations are in the less affluent sections of town.

Unsurprisingly. It scares me so much that I do my best to avoid Berry Street and Beach

Street and Lancaster Ave.

I know that powerful people with deep pockets have tried to hide this industry

technique from any and all regulation. I know that academics and scientists who have

spoken out against the dangers of fracking (not to mention URBAN fracking) have

been systematically silenced or undermined.

As far as I can tell, the NatiaI Gas industry and our Quote Un Quote Representatives

and So-called Leaders have decided to gamble on the health and safety of myself, my

family, and my fellow citizens. Why? I guess because they had Big Money to make. I

can think 4tno other plausible reason.The question I ask myself — that I don’t want to ask myself, but I can’t help it — is “Am I

amb y living here? in an urban tracking field? How much am I increasing my

I risk of cancer? hould I grab my family and run away from my mortgage to someplace ‘1 else. Where would that even be?”

-‘ I know that since coming here last year I have headaches.everyday and a weird flutter

e,tsois?1w

Passing a Lancaster Aven çhesapeake operation one day the smell was so intense

that it gave me an instanCheadache and left an acrid taste in my mouth for a day. TheTCEQ seems remarkably toothless. I am not even sure that my call generated an

actual report.

This is all to say that I call upon the EPA to regulate this industry as they would any

other with strong, health and science-based rules. This country can ill afford to clean

up the mess that the industry will certainly leave behind. This country can ill afford theresultant health costs that will sadly come in our future.

And please, d9-P1elet existing fracking operations off the hook.

That would meri that you are writing me off.Writing off mn9nighborhood, and my community. Because there are already

hundreds, if not thousands of wells here.Thank you
should do much to provide clarity to industry and stakeholders and reduce air pollution

from oil and natural gas operations.

It’s a worthy effort, and one that despite some state leaders’ long-running feud with EPA is

welcomed here by many in the public, community leaders, conservationists and

environmental organizations like mine. Balancing market needs and demands with public

health and safety concerns is an essential role of government.

The National Petroleum Council’s (NPC) recently released report, Prudent Development

(Sept. 2011, www.npc.org), suggests that if natural gas development is done right, our state

and our nation’s vast natural gas reserves could be — in the words of the NPC itself—

“transformative for the American economy, energy sector and environment.”

The pivotal point in this is that we do it right. Doing it right means leveraging reasonable

regulations and effective available technologies to reduce emissions. Doing so means a

truly win-win-win situation for the environment, consumers and industry.

Texas has been a leader in improving drilling practices from hydraulically fractured wells,

passing the nation’s first mandatory disclosure law for hydraulic fracking fluids this year.

Improving air quality controls for gas and oil drilling is a necessary next step in advancing

drilling practices.

1
gas compressors, pneumatic devices, and storage tanks.

TLCV feels strongly that the EPA’s proposal significantly improves the New Source

Performance Standards (NSPS) under the Clean Air Act. By requiring the use of reduced

emission completions, for example, we would be working to reduce the emissions of

volatile organic compounds, though further clarity of the specific terminology and

applicability of the rule to “workover” wells and liquid unloading would do much to help

address the environmental community’s concerns and, no doubt, provide a level of clarity

to benefit both public and industry alike.

Regardless of the EPA regulations ultimately adopted, TLCV strongly believes that Texas on

the whole must do a better job of policing drilling — which means better funding of the

Texas Railroad Commission — and establishing clarity between the Railroad Commission

and the Texas Commission on Environmental Quality. Improved stakeholder and

constituent input and response are also needed.

And, it’s a resource with such an abundant supply here in Texas that if it is safely produced

and properly regulated, that it’s production could stand to generate significant severance

tax revenue—supplying much needed general revenue during very difficult economic times

and providing potentially more revenue for the critical state regulatory needs.

TLCV is confident this can be accomplished in a way that benefits and addresses the

environmental and public health concerns, while providing reasonable regulatory

measures and considerable savings to the industry.

Thank you for the opportunity to testify today.

2
g

y

From: Clean Water Action

Re: Docket EPA-HQ-OAR-2olo-o5o5, Oil and Natural Gas Sector: New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants Reviews

On behalf of Clean Water Action’s 35,000 Texas members and our one million across the

country, I want to thank EPA for coming to Arlington and for their strong proposal to restrict air

emissions from oil and gas extraction operations. EPA regulations of these large pollution sources

are urgently needed here in Texas and in many other communities across the country. State

governments including Texas have so far done little to manage gas drilling, and we need the

federal government to step in and play a strong role here in protecting public health and the

environment.

It is important for EPA to understand that fracking operations in Texas and elsewhere are

frequently occurring quite literally in people’s backyards. We have over 1,000 gas facilities within

the city limits of Ft Worth alone, a city of more than half a million residents. Any rules on air

emissions must take into account that people are living extremely close to these pollution sources.

We should not he protecting people ‘on average’. We need to protect everyone living near gas

drilling.

Another important point for EPA to consider is that these rules are urgently needed and

should be implemented as soon as possible. EPA should not delay or extend the comment period

or the effective date of any of these new rules. Many of Texas’ major metropolitan areas, including

the DFW metropolitan area, are already in non-attainment tinder the federal Clean Air Act. New

air pollution rules can take a long time to be enacted, and we need these rules in place as soon as

possible. There is no moratorium at the state level on permits for new frack wells here in Texas.

Thousands of wells have already been drilled here, and many more thousands are planned for the

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V. V. tIraIioII.oIg
Finally, we urge EPA to ensure that these rules are as strong as they can be. Best available

control technology should be a standard requirement for all oil and gas operations. All significant

sources of air emissions must be included in the rules, such as the thousands of open air frac pits

that accompany drilling sites. Remember that these pits can also be only a couple hundred feet

from where people live. All relevant pollutants should be directly controlled including methane

and hydrogen sulfide. Finally, flaring should be completely prohibited. It is simply irresponsible

to allow the gas industry to start production at a well, before they have a way to safely control the

flow of hazardous emissions.

In closing, I would like to again thank EPA for coming to Texas and for issuing these

important rules, and I urge you to implement them without delay. We are looking towards federal

agencies such as EPA to step up to the plate and provide the protect we all deserve.

Respectfully,

David Foster

Texas Program Director

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Leaking Money

Potential Revenues from Reduction 

of Natural Gas and Condensate Emissions 

in North Central Texas 

Melanie Sattler, Ph.D., P.E.

May 2011

Downwinders at Risk Education Fund 
 

About the Author - Dr. Melanie Sattler has over 15 years of professional 

experience with air quality issues, including experience in consulting, academia, and 

government. She has published 50 peer-reviewed conference proceeding papers and 

journal articles related to air quality and other aspects of environmental engineering. 

Dr. Sattler earned her Ph.D. in environmental engineering, with a focus on air quality, 

from the University of Texas at Austin. She is a registered professional engineer in the 

State of Texas.

Founded in 1995, the Downwinders at Risk Education Fund is dedicated to research 

and public outreach on issues of public health, air pollution and the environment.

PO Box 763844 Dallas TX 75376 

972-230-3185 info@downwindersatrisk.org 
 

SUMMARY

The objective of this study was to estimate the amount of money that the natural gas industry in the 

Dallas-Fort Worth 9-county ozone non-attainment area could earn by reducing emissions of natural gas 

and condensate that currently escape into the atmosphere. Natural gas prevented from leaking could 

be sold as fuel. Recovered condensate can be used as a chemical feedstock or refined into gasoline and 

other products. Reducing such emissions would be a win-win: increased revenues for the natural gas 

industry, and lower ozone-forming volatile organic compound (VOC) emissions for the citizens of 

North Central Texas.

This study considered emissions 

from the following natural gas 

sources:

 •Gas fugitives

 •Gas well completions

 •Gas well blowdowns

 • Pneumatic devices

 • Condensate tanks

 • Condensate loading.

VOC emission estimates for each 

of the above categories for 2012 

were provided by the Texas 

Commission on Environmental 

Quality (TCEQ). Methane and 

ethane emissions, which also have 

commercial value, were estimated 

by multiplying the VOC emission 

estimates by the ratio of the weight 

percent of methane or ethane in 

natural gas or condensate to the 

weight percent of VOCs. 

 

Significant conclusions include the following:

 • By installing equipment to recover natural gas and condensate emissions in North Central 

 Texas, natural gas companies could earn up to $51.9 million a year in new revenues, and 

 at the same time reduce VOC emissions. 

 • Emissions from pneumatic devices account for the largest percent of emissions with economic 

value (70%), and thus should be targeted first. Addressing the “low-hanging fruit” of pneumatic 

devices could save up to $35 million in the current 9-county non-attainment region plus Wise 

County, and reduce VOC emissions by 71 tons per year (tpy). 

 •Technology for reducing emissions from pneumatic devices has already been successfully 

 demonstrated by many companies in the field. Most retrofit investments pay for 

themselves in little over a year, and replacements in as little as 6 months. 

An image captured from a Texas Commission on 

Environmental Quality film using an infrared camera. The black plumes are Volatile Organic Compounds escaping from a Barnett Shale gas field tank 

battery. These plumes are normally invisible to the 

naked eye. 

Capturing this pollution instead of allowing its 

release into the atmosphere could bring millions in 

new profits to gas field owners, shareholders and 

mineral rights property owners.

Leaking Money page 1
1. Study Objective

The objective of this project was to estimate the amount of money that the natural gas industry in the 

Dallas-Fort Worth 9-county ozone non-attainment area could earn by reducing emissions of natural gas 

and condensate that currently escape into the atmosphere. Although some initial investment in replacing 

or retrofitting equipment would be required, much of this investment would pay for itself in 6 months 

to a year. Natural gas prevented from leaking could be sold as fuel. Recovered condensate can be used 

as a chemical feedstock or refined into gasoline and other products. Reducing such emissions would be 

a win-win: increased revenues for the natural gas industry, and lower emissions of ozone-forming volatile 

organic compounds (VOCs) for the citizens of North Central Texas. Wise County emissions were also 

included because of the concentration of gas industry VOCs there and the probability that a new federal 

ozone standard is likely to draw that County into the designated DFW non-attainment area in the near 

future.

2. Study Scope

VOC emission reductions of 140 tpy are required as part of the region’s rate-of-progress State 

Implementation Plan (SIP). According to TCEQ (Boyer, 2010), oil and gas drilling and production together 

will release 103 tons per day (tpd) of (VOC) emissions in the 9-county Dallas Fort Worth (DFW) nonattainment area in 2012 (see Figure 1). 

Figure. 1 DFW 9-County Non-Attainment Region Oil & Gas Production and Drilling VOC Emissions, 2010 (TCEQ, 2010)

 

Leaking Money page 2

Although oil drilling 

and production 

releases VOCs, 

this study limits itself 

to natural gas drilling 

and production. Of 

the 103 tpd of VOC 

emissions due to oil 

and gas facilities, only 

0.7 tpd (0.7%) is 

attributable to oil 

drilling and 

production (well 

blowdowns, oil well 

completions, oil loading, crude tanks, and 

oil fugitives). 
Of the categories of natural gas drilling and production emissions identified by TCEQ, this study considers only the following:

 • Gas fugitives • Pneumatic devices

 • Gas well completions • Condensate tanks

 • Gas well blowdowns • Condensate loading.

For explanations of the processes, the reader is referred to Bar-Ilan et al. (2008).

The categories listed above account for 87% of oil and gas VOC emissions in the DFW 9-county nonattainment area, according to the TCEQ data. Emissions from pumpjacks, dehydrators, gas heaters, 

compressor engines, drill rigs, and produced water are not considered. Emissions from most of these 

pieces of equipment are post-combustion (ERG, 2010), and would have little commercial value, since 

organics have been largely converted to carbon dioxide and water. 

The TCEQ definition of volatile organic compound (VOC) excludes methane and ethane, which are less 

reactive than other organics in forming ground-level ozone. These compounds, however, still have 

commercial value and are, in fact, the primary constituents of natural gas. This study thus includes 

emissions of VOCs, methane, and ethane. Natural gas and condensate emissions also contain a small 

fraction of carbon dioxide (2-3% by weight). Although carbon dioxide has commercial value in the food, 

oil, and chemical industries, its value is not considered here.

3. Regional Emissions of Compounds with Commercial Value

Table 1 shows emissions from natural gas drilling and production facilities with a commercial value. 

Emission estimates are given for VOCs, methane, and ethane, as discussed above. Emission estimates are 

provided for the 9-county DFW non-attainment area, as well as for Wise County, which equals over half 

the VOCs of the 9-county total.

Table 1. Emissions with Potential Commercial Value from Natural Gas Facilities in North Central Texas

In Table 1, emissions from gas fugitives, gas well completions, gas well blowdowns, and pneumatic devices 

are lumped into the general category of “produced gas” emissions. According to a report prepared by 

Eastern Research Group for TCEQ (2010), emissions from these categories are assumed to have the 

same species composition as produced natural gas. Emissions from condensate tanks and loading, which 

have a different species composition, are lumped into the general category “condensate”.

Leaking Money page 3
The data in Table 1 are summarized in Figures 2-4 below. As shown in Figures 2-4, reducing emissions from 

pneumatic devices would recover the greatest amount of compounds with commercial value: 73%, 62%, and 

70% for the 9-county non-attainment area, Wise County, and the combined 10-county region, respectively. 

Capturing emissions from condensate tanks would recover the second largest amount of compounds with 

commercial value: 12%, 28%, and 17% for the 9-county non-attainment area, Wise County, and the combined 10-county region, respectively. VOC emissions could be reduced by up to 52 tons per day by 

addressing pneumatic devices in the 9-county non-attainment area alone.

Figure 2. Sources of Natural Gas Emissions with Potential Commercial Value – 9-County DFW Non-Attainment Area

Figure 3. Sources of Natural Gas Emissions with Potential Commercial Value – Wise County

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Figure 4. Sources of Natural Gas Emissions with Potential Commercial Value – 9-County Non-Attainment 

Area and Wise County Combined

VOC emissions in Table 1 were taken directly from TCEQ estimates for 2012 (Boyer, 2010; Maldonado, 

2011). Methane and ethane emissions were estimated by multiplying the VOC emission estimates by the 

ratio of the weight percent of methane or ethane in natural gas or condensate to the weight percent of 

VOCs, as shown in Table 2. 

Table 2. Weight Percents of Components of Natural Gas and Condensate in North Central Texas

Leaking Money page 5
The weight percent of methane and ethane in natural gas in Table 2 were taken from a permit application 

for the Havener well site. This was the only complete natural gas speciation data specific to the North 

Central Texas Barnett Shale that the author could find. According to Armendariz (2009), natural gas 

producers in the North Central Texas region reported unprocessed natural gas composition to be 8.2% 

VOCs and 74% methane on a mass % basis. Using these alternative numbers would actually increase the 

estimate of revenue-producing emissions, because the ratio of the weight percent of methane to the 

weight percent of VOCs would increase.

Condensate weight percents in Table 2 were taken from Hendler et al. (2009). Average weight percents for 

North Central Texas were used. T-tests showed that methane, ethane, and VOC weight percents for 

condensate tanks in DFW differed from other parts of the state, to 95%, 85%, and 98% levels of confidence, respectively. These t-test results are included in the appendix. Species with weight percents <1% 

were not included.

Table 2 also shows incremental reactivities (moles of ozone formed per mole of carbon added to the 

VOC mix in an air mass) for some of the compounds (Carter, 1991; Russell et al, 1995). For comparison, 

an urban mix has an average reactivity of 0.28 mol ozone/mol C (Carter, 1991). Although the VOCs listed 

in Table 2 are alkanes, and not highly reactive VOCs (HRVOCs), they still contribute to ozone formation. 

Released in large quantities, the amount of ozone that they form would be significant on a regional basis

4. Potential Revenues from Reduced Emissions

As discussed above, the emissions in the category “produced gas” have a composition like that of natural 

gas. If these emissions were captured, it is assumed that they could be sold as natural gas. According to the 

U.S. Energy Information Administration, the average commercial price of natural gas in Texas was $7.24 per 

thousand cubic feet for February 2011, the latest month for which information is available. The commercial 

price is the price of gas used by nonmanufacturing establishments or agencies primarily engaged in the sale 

of goods or services such as hotels, restaurants, wholesale and retail stores and other service enterprises; 

and gas used by local, State and Federal agencies engaged in nonmanufacturing activities. The commercial 

price is higher than the industrial price, but lower than the residential price, so represents an intermediate 

sales price. A price of $7.24 per thousand cubic feet was accordingly used in Table 3 to calculate potential 

revenues from capture of produced gas, based on the emission values from Table 1.

Natural gas condensate is a mixture of hydrocarbon liquids that are present as gaseous components in the 

raw natural gas. At temperatures below the hydrocarbon dew point of the raw gas, they condense out of 

the raw gas. Natural gas condensate can be used as a chemical feedstock for production of ethylene and 

propylene. It can also be refined into gasoline and other products. According to the Energy Information 

Administration (EIA), in 2006 refineries in the USA used 5563 million barrels of crude oil (15.24 million 

barrels per day) and 180 million barrels of natural gas liquids, or around 3% of the crude oil input volume. 

The price of condensate fluctuates with the prices of natural gas and crude oil. Devon Energy reported 

in May 2011 that their average realized natural gas liquids price for the first part of 2011 was $37.39 per 

barrel. This number, along with a mid-range condensate density of 0.65 g/cm3, was used to compute the 

potential revenues from condensate shown in Table 3.

As shown in Table 3, potential revenues from capture of natural gas and condensate emissions in North 

Central Texas exceed $51 million per year for the 9-county non-attainment area and Wise County. 

Potential revenues from the combined 10-county region are summarized in Figure 5.

Leaking Money page 6
Table 3. Potential Revenues from Capture of Natural Gas and Condensate Emissions in North Central Texas

Figure 5. Potential Annual Revenues from Capture of Natural Gas and Condensate Emissions in the 9-County Non-Attainment 

Area and Wise County

5. Methods of Reducing Emissions

Pneumatic devices and condensate tanks should be targeted first for emission reductions, since they 

represent 70% and 17% of emissions, respectively, for the 10-county region including Wise County. 

5.1 Pneumatic Devices

Pneumatic devices, used for various natural gas processes, are powered mechanically by high-pressure 

produced gas as the working fluid. Pneumatic devices include control devices that automatically operate 

values and control pressure, flow, temperature or liquid levels (EPA, 2006). As part of normal operation, 

these devices leak the working fluid, which is produced gas (Bar-Ilan, 2008). In the U.S. natural gas 

production sector, it is estimated that 400,000 pneumatic devices are used to control and monitor gas 

and liquid flows and levels in dehydrators and separators, temperature in dehydrator regenerators, and 

pressure in flash tanks (EPA, 2006). In the U.S. natural gas transmission sector, around 85,000 pneumatic 

devices actuate isolation valves and regulate gas flow and pressure at compression stations, pipelines, and 

storage facilities.

Leaking Money page 7
Pneumatically-operated devices became the standard in the oil and gas industry since electricity was not 

available at remote production sites (EPA, 1996); this, however, is not the case with drilling and 

production in urban areas. Emissions could be reduced, and valuable natural gas saved, by (EPA, 2006; 

Armendariz, 2009):

1. Replacing high-bleed devices with low-bleed devices, 

2. Installing low-bleed retrofit kits on high-bleed devices, 

3. Improving maintenance practices, 

4. Ensuring that all natural gas actuated devices discharge into sales lines or closed, loops, instead 

of venting to the atmosphere; 

5. Convert gas pneumatic devices to instrument air (see EPA’s document, “Lessons Learned: 

 Convert Gas Pneumatic Controls to Instrument Air” available at http://www.epa.gov/gasstar/docu 

ments/ll_instrument_air.pdf), or replace them with non-pneumatic devices (electric). 

Options for reducing gas-bleed emissions by controller type are shown in Table 4. Enhanced maintenance 

can include repairing/replacing leaking gaskets, tubing fittings, and seals, as well as cleaning and tuning; such 

measures can save 5-10 standard cubic feet of gas per hour (scfh) per device (EPA, 2006). Eliminating 

unnecessary valve positioners can save up to 18 scfh per device. Pressure control valves with a selfcontained spring/diaphragm can be used; such controls discharge to the downstream gas line, resulting in 

no bleeding of gas to the atmosphere (EPA, 1996). 

Table 4. Options for Reducing Gas-Bleed Emissions by Controller Type (EPA, 2006)

Natural Gas STAR partners are natural gas companies who voluntarily partner with EPA to adopt costeffective technologies and practices that improve operational efficiency and reduce emissions of methane. 

According to EPA (2006):

Natural Gas STAR partners have achieved significant savings and methane emission reductions through replacement, retrofit, and maintenance of high-bleed pneumatics. Partners have found that most retrofit investments pay 

for themselves in little over a year, and replacements in as little as 6 months. To date, Natural Gas STAR partners 

have saved 36.4 Bcf by retrofitting or replacing high-bleed with low-bleed pneumatic devices, representing a savings of $254.8 million worth of gas. Individual savings will vary depending on the design, condition and specific 

operating conditions of the controller.

Payback times for replacement, retrofit, and maintenance of pneumatic devices are shown in Table 5, and 

range from immediate to 13 months. 

Leaking Money page 8
Table 5. Payback Times for Options for Reducing Natural Gas Emissions from Pneumatic Devices (EPA, 2006)

Savings from reduced emissions can range from $315 to $1820 per year per device, based on a natural gas 

price of $7 per thousand cubic feet (EPA, 2006). EPA’s field experience with Natural Gas STAR partners 

has shown that up to 80% of all high-bleed devices can be replaced with low-bleed equipment or 

retrofitted.

Union Pacific Resources provides one example of successful retrofit and replacement of high-bleed pneumatic devices. Union Pacific replaced 70 high-bleed pneumatic devices with low-bleed devices and 

retrofitted 330 high-bleed devices. The retrofits and replacements cost $166,300, but will save $347,200 

annually (at $7 per Mcf natural gas prices), resulting in a payback of less than one year.

In addition to saving money and reducing emissions of ozone-forming VOCs, the retrofit or replacement 

of worn high-bleed pneumatic devices can improve system-wide performance and reliability, and provide 

better monitoring of gas flow, pressure, liquid level, and other parameters.

The EPA brochure “Lessons Learned from Natural Gas STAR Partners: Options for Reducing Methane 

Emissions from Pneumatic Devices in the Natural Gas Industry,” available online at http://www.epa.gov/

gasstar/documents/ll_pneumatics.pdf, provides additional information about replacing, retrofitting, and 

maintaining pneumatic devices.

5.2 Condensate Tanks

Vapor recovery units (VRU) are estimated to capture over 98% of emissions from condensate tanks 

(Hendler, 2009). Gases and vapors from the tanks are directed to the inlet side of a compressor, which 

increases the gas pressure so that many of the moderate and high molecular weight compounds condense back into liquid form. Methane and other light gases are directed to the inlet (suction) side of the 

compressors to join the main flow of natural gas. In this way, VRUs increase the total production of gas at 

the well. In addition, liquids produced by the VRU are directed back into the condensate tank, increasing 

condensate production and potential revenue (Armendariz, 2009). 

Leaking Money page 9
5.3 Other Processes

Enhanced leak detection and repair can be used to reduce fugitive emissions, which represent 8% of 

emissions with commercial value in the 10-county region. “Green completions” to capture methane and 

VOC compounds during well completions, which represent 3% of emissions with commercial value in 

the 10-county region. For additional discussion of enhanced leak detection and repair, and green completions, see Armendariz (2009). 

6. Conclusions

 • By installing equipment to recover natural gas and condensate emissions in North Central Texas, 

natural gas companies could save up to $51.9 million a year, and at the same time reduce VOC 

emissions that contribute to ground-level ozone formation. 

 • Emissions from pneumatic devices account for the largest percent of emissions with economic 

value (70%), and thus should be targeted first. Addressing the “low-hanging fruit” of pneumatic

 devices could save up to $35 million in the current 9-county non-attainment region plus Wise 

County, and reduce VOC emissions by 71 tpy. 

 •Technology for reducing emissions from pneumatic devices has already been successfully

 demonstrated by many companies in the field. Most retrofit investments pay for themselves in 

little over a year, and replacements in as little as 6 months.

7. References

Armendariz, Al. “Emissions from Natural Gas Production in the Barnett Shale Area and Opportunities for Cost-Effective Improvements.” Report for Environmental Defense Fund, January 2009. Available online at http://www.edf.org/documents/9235_

Barnett_Shale_Report.pdf .

Bar-Ilan, Amnon; Parikh, Rajashi; Grant, John; Shah, Tejas; Pollack, Alison K. “Recommendations for Improvements to the 

CENRAP States’ Oil and Gas Emissions Inventories.” Report prepared by ENVIRON International Corporation for the 

Central States Regional Air Partnership. November 13, 2008. Available online at http://www.wrapair.org/forums/ogwg/documents/2008-11_CENRAP_O&G_Report_11-13.pdf

Boyer, Doug. “2006/2012 DFW Modeling Update.” Presentation prepared by Texas Commission on Environmental Quality for 

the DFW Photochemical Modeling Technical Committee, November 5, 2010.

Carter, William P. L. “Development of the SAPRC-09 Chemical Mechanism and Updated Ozone Reactivity Scales.” Report to 

the California Air Resources Board, Contracts No. 03-318, 06-408, and 07-730, Revised January 27, 2010.

Hendler, Albert; Nunn, Jim; and Lundeen, Joe. “VOC Emissions from Oil and Condensate Storage Tanks.” Final Report prepared for the Texas Environmental Research Consortium, April 2, 2009. Available online at http://files.harc.edu/Projects/

AirQuality/Projects/H051C/H051CFinalReport.pdf .

 “Permit by Rule for the Havener Tank Battery” located in Tarrant County, Texas. Attachment #7. Submitted by XTO Energy, 

Inc. to the TCEQ on May 24, 2010.

Pring, Mike; Hudson, Daryl; Renzaglia, Jason; Smith, Brandon; and Treimel, Stephen. “Characterization of Oil and Gas Production Equipment and Develop a Methodology to Estimate Statewide Emissions.” Final Report prepared by Eastern Research 

Group for Martha Maldonado of the Texas Commission on Environmental Quality, Air Quality Division, November 24, 2010.

Texas Commission on Environmental Quality. Texas Air Emissions Repository (TexAER), http://www.tceq.texas.gov/airquality/

areasource/TexAER.html, accessed May 2011. 

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U.S. Energy Information Administration. “Natural Gas Prices.” Independent Statistics and Analysis, Texas, http://www.eia.doe.

gov/dnav/ng/ng_pri_sum_dcu_STX_m.htm, accessed 5/11.

U.S. Environmental Protection Agency. “Lessons Learned from Natural Gas STAR Partners: Options for Reducing Methane 

Emissions from Pneumatic Devices in the Natural Gas Industry.” http://www.epa.gov/gasstar/documents/ll_pneumatics.pdf, 

October 2006.

U.S. Environmental Protection Agency. “Methane Emissions from the Natural Gas Industry: Volume 12: Pneumatic Devices.” 

National Risk Management Laboratory, EPA-600/R-96-0801, June 1996.

APPENDIX A

Table A1. Weight Percents for Condensate Tank Emissions in North Central Texas vs. Other Parts of the State

Leaking Money page 11
Denton, TX 76209Honorable Senator Nelson,

I am writing with concerns regarding the need for stronger laws and

oversight to protect the public health related to the practice of horizontal drilling.

First, know that I am not unilaterally against oil and gas drilling and that I

understand the benefit of increasing domestic energy production and of the

potential for gas to be a cleaner fuel than say coal. I like turning on my light switch

and having reliable power. However, I also believe that we must assure that theextraction of that gas is not placing undue burden on those of us living on top of it.

My family has a small farm in the far south western corner of Cooke County

with a hundredsof-year-old live oak tree whose branches arc gracefully to theground before rising again, somewhere between 100 and 150 old growth native

pecan trees, more than a dozen grandfather black walnut trees, a handful of willowtrees, and many persimmon, post oak, burr oak and red oak trees among others. It’snorth eastern boundary borders on Clear Creek (which eventually finds it’s way tothe municipal water supply via Lake Lewisville) and it has a large pond andwaterway close to the front of the property that collects runoff from several nearbyfarms during heavy rainfall. It is a multigenerational venture started when my father

decided he could not keep up with his farm in central Texas and my youngest sonapproached him asking if he could help him farm it. Instead dad decided to sell thatfarm and buy one up here, essentially gaining two extra farm hands in my husbandand I. We have been steadily improving the farm, drilling a well, building a barn andtending to pasture and woodland alike. It is currently predominantly producing hay

but we are clearing the underbrush from the pecan trees and have built the firstphase of an irrigation system and planted our first 38 chestnut trees.

There have been a few oil and gas wells evident here and there but this year

they have been increasing exponentially. Imagine our shock when our neighborfound out on the Railroad Commission (RRC) website that there were seven (7)horizontal fracturing wells to be completed under our farm. I initially had somedifficulty navigating the RRC website but when I inquired, found their staff to be

very helpful. They began to educate me not only on the website but also on the

processes involved in “fracking”. Sure enough, there are 7 wells under our property.

They helped me figure out where they are in relation to our water well. They alsohelped me figure out that the large “socks” that suddenly appeared in Clear Creek at

8/28/2011

C Fette, Page 1
inspectors referred me to as well as through reports such as the August 11, 2011SEAB Shale Gas Subcommittee 90 day report and between what I have learned and

my experiences to date as a stakeholder, I have several recommendations to putforth:

1. There must be better public information made available to include:

a. The upcoming disclosure of information regarding chemicals used

to make the water “slick” for fracking is a good first step but I amnervous about waiting until next summer to know what I havepotentially been exposed to. I would like to see that timeline

shortened.

b. Information needs to be readily available regarding spills — especially to those landowners, residences and businesses within

5 miles of the spill or who border affected waterways.

c. There should be accurate public accounting for each of the oil

companies in a given oil field or play that reports on all incidentsincluding spills, leaks, substitutions of expected chemical

constituents, issues with seals, failed inspections, faulty

workmanship, inferior concrete work etc.

d. There should be easy access to public education sites that teach

about basic geology such as what the layers in given regionsconsist of and the depth of various layers as well as how fluids

travel through them (direction and rate) so that informed

inferences can be made to assess risk by those of us for whom

geology is not our field of expertise.

e. As the industry develops Best Available Technology (BAT)

standards (I am shocked that this is only now being discussed),

this should be part of the above education site as well as part of

well by well and company by company information tracked and

publically disclosed.

2. We must immediately increase staffing at the agencies charged with

oversight of drilling and well operations.

a. I understand that much of what needs to be inspected in terms of

critical processes occurs at night and from all published reports

we barely have enough inspectors to cover the day shift. Policy for

inspections needs to include critical activities to assure thatvertical bores are appropriately completed using BAT and that all

fracking and cleanup activities render no risk to the environment

C Fette, Page 2
no leaks and that public safety is adequately protected. I did notsign away my right to clean water and the oil and gas industrydoes not have the right to jeopardize my water, trees or livestockeven a little bit.

c. First the plan should be written to determine what monitoring

needs to occur to keep my farm and other surface ownersproperty and health safe — then figure out what staffing needs tooccur for that to be assured and hire as many qualified persons asneeded. It is a cost of doing business if they want to be myneighbor.

d. Water and air quality must be monitored. Currently this occurs at

the surface land-owner’s expense which is inappropriate. I did not

create the threat to water and air quality and I should not bepaying for monitoring. Oil and gas industry entities should setaside resources into a fund to pay for monitoring that landownerscan access for routine monitoring and lab fees.

e. Increased staffing and monitoring should be funded with

increased fees charged to the companies benefiting from oil and

gas production. ft is a cost of doing business.

3. Surface land owners rights need to be increased to allow us some say in

what occurs on our land and where. It is no longer possible to purchase

land with mineral rights which was not on our list of concerns becausewe wanted to farm the land. But regardless of mineral rights, we bought

our nearly 100 acre farm with real money and have continued to investreal money and sweat into it. Oil companies may have more money than Ibut they did not choose to spend their money buying that piece of land

when it came up for sale. We did and there are rights that common sense

dictates should come with our having made that choice when they didnot. It is not OK to bully landowners and disregard our health, safety andright to the pursuit of happiness. They could have bought that land if they

wanted to ruin it. But I should be able to protect the acreage that I paid

for. The law must be changed to reflect increased respect for surfacerights.

4. Attend to air quality:

a. The SEAB report recommends developing capacity to measure

methane and to track the release of air pollutants as a result of

shale gas operations.

C Fette, Page 3
process.

b. I am concerned that we are removing billions of gallons of water

from the water cycle entirely. It is either pumped from the Trinity

Aquifer or is surface water whether they buy it from the City of

Denton, FT Worth or wherever. They put whatever toxic

substances that they add along with the propellant (to keep the

fractures open) then once it is used for fracking they are generallydisposing of it in deep injection wells (there is one just to thenortheast of our farm) that go below the water table into a salt

water layer that they call “the ocean” that is meant to not return to

the water table. At the least, they should be reusing the dirty waterthat they recover to frack another well instead of pulling more

from the water table and increasing deep pressure that is being

considered as a prime suspect in the increased earthquake activity

around drilling plays. There is a company in Roanoake TX who hasfigured out how to reuse fracking water but their process is only

being used outside of Texas because our regulations are so lax andcompanies doing business here do not have to consider waterconservation.

c. Then there are the large evaporation pools that there are

documented incidences of leakage from (they are clearing a spaceacross FM 922 from my farm that looks frighteningly like this is

their intention, but who knows because they tell us NOTHING).

d. For both air and water quality, there have to be best practices

developed and as they improve, wells and equipment must be

retrofitted. See the SEAB report recommendations athttp://thehilI.cornjjmagejstories/bIogJçpergy/su bcornrnrpt.pdf

This summer I completed my dissertation on the use of student strengths for

successful transition from elementary to middle school and this year has been abusy one between that work and my day to day work with children in schools. I

watched this past legislative session, largely from the sidelines, noting the effects of

our budget cuts on Texas children and telling myself that the most productive thing

that I could do for the kids right now is to sustain my research on their behalf and

focus on each child in front of me. This farm was to be a respite rather than anothercrusade. My husband and I hope to build the house on this farm that we lost when

we were desperately trying to save the child that led me into child advocacy. His

youngest brother whose strengths are also not those typical to his cohort but are

C Fette, Page 4
Sincerely,

Claudette Fette940-367-6937cc: Senator Estes

Representative Crownover

Representative Burgess

Senator Cornyn

Denton Record Chronicle

C Fette, Page 5
issue which personally impacts me and so many others. I also spoke as an advocate for breathable, healthy air at EPA hearings on March 16 and August 2, of 2010. The August one was specifically related to air issues and the oil and gas industry. Similarly I have commented at TCEQ hearings on air issues June 24, 2010 and July 14,2011.

I am

a native Texan of 7-plus decades, residing in the Metroplex since 1949. If you want someone who knows the history of environmental efforts

— you are looking at

one. My history with air issues began in Dallas. My earliest clipped cartoon on air quality is dated 1971. 1973 is the earliest letter in my files addressed to the EPA. I moved to Arlington and by the late 1980’s began attending meetings at the North Central Texas Council of Governments on Air Quality and other environmental issues.

That was almost 25 years ago. Why is it taking so long to get breathable, healthy air? The latest hurdle has been thrown by the gas industry with its emissions virtually unabated. In fact they were specifically exempted from all the federal environmental laws for their horizontal fracking in the 2005 Energy Bill, in

a section

commonly known as the Halliburton Loophole. That marked the beginning of the

recent phenomenal growth in the gas industry. Yet, as

a Nov. 3, 2009 New York Times editorial said: “But if hydraulic fracturing is as safe as the industry says it is, why should it fear regulation?” Or is this all just about turf wars and not public health?

I have four gas well complexes within 3/8 to 1 2/3 miles of my home

— with probably

2 dozen

+ wells, plus

a compressor complex

% mile away. Two more gas well complexes are just

2 miles away.

My personal costs for medications due to asthma are currently $1,827

a year. I use Singulair, ProAir and Advair. None are generic. Please note that “AIR” is in each of

these drugs to help me breathe. That $1,827 is money which I don’t have to spend in our local economy

— the money ends up in companies in Kansas or California. I’m

not even figuring the cost of Dr. visits in insurance and co-pays. If you start quantifying the costs to society/citizens - paid by themselves, or partly through drug plans that they pay for, or partly through donations made to the many social service
too have been downwind of that problem for 24 years. I have attended meetings along with hundreds of other breathers, written so many letters, made lots of phone calls over the years to get relief for North Texans from air pollution, not just from the cement kilns but from all the other sources. So now how long will it take to get meaningful regulation of the newest polluter - gas wells? Another 25 years? I hope not. I won’t be here and I don’t want to leave a damaged planet behind as my legacy.

Any business plan has two paramount themes: Maximize profits and minimize costs. It is imperative under such a system that there be a government agency charged with acting in the interest of the public to see that the industries play fair.

YOU ARE THE PEOPLE’S ENVIRONMENTAL PROTECTION AGENCY.

I am eternally grateful that your agency was created in December, 1970 — the Year of the First Earth Day.

I NEED YOU. WE ALL NEED YOU!

Thank you for this hearing.

Respectfully submitted,

:yJulia Burgen, 2312 Winewood Lane, Arlington, TX 76013

BA, SMU, 1956, Magna cum laude, Phi Beta Kappa; MS, UTA, Interdisciplinary Studies, 1986, emphasis on science and education. President of Arlington Conservation Council, 1993 — 1997; Member of Arlington City Council, 1997 — 2003; 40 year member of national Sierra Club and Audubon Society; recipient of three statewide awards and one national award for conservation activities.
1. Gas Treating Facilities: Sulfur dioxide will be regulated by 40 CFR Part 60 Subpart LLL for Facilities with a sulfur feed rate of at least five long tons per day. What is the 502 preferred control method? In Freestone COUfltVf Texas. we have permits for facilities that burn the

hydrogen sulfide via flaring. The resultant sulfur dioxide is uncontrolled and not measured. Flaring of H2S is not acceptable for control of the sulfur.

2. Natural Gas Compressor Stations: Compliance with New Source Performance Standards, Page 52751, Paragraph E.2; Title

V permits are not required for gas compressor stations, only a permit by rule is required in Texas. However, with a significant number of compressor stations in one county, the air emissions allowed can exceed those of a large coal fired electric power plant. There are 130 compressor stations in Freestone County, Texas alone that are allowed to emit 32,500 tons per year of nitrogen oxides and 3,250 tons per year of sulfur dioxide. How can

we address this issue? Maybe a corporation having enough aggregate facilities in a given county that exceed the NSPS standards should be required to obtain a Title

V permit for the aggregate of facilities

3. NAAQS Compliance:

A county’s NAAQS compliance is undeterminable without air monitors. There are few air monitors in central Texas and most all areas with less than 100,000 population do not have an air monitor. Rural towns and counties need protection of our air quality also. We believe that air monitoring must not depend on population, but by existence of major sources of air pollution in an area. Air monitoring is a must to insure compliance with the NAAQS.

a. In Freestone County, we have two large coal fired electric power plants, one large gas fired power plant, 130 natural gas compressor stations, several gas treating facilities not to mention

numerous industrial facilities having air emissions. Just south of us are two more large coal fired electric power plants with another one approved. Our county is classified as Attainment/Unclassified. Therefore, the uncontrolled issuance of air permits continues for any facility that may want to locate in our area. We are in a continuous battle trying to protect our air. Air monitors must be installed within 40 miles of any major source of air pollution.

4.

A major area not addressed in any EPA rules is the Noise issue. Noise from gas compressor stations is causing havoc all across the country. People are dying, being run out of their homes, suffering body damage such as brain damage, ruptured ear drums, and heart damage, restless leg syndrome, vertigo and other symptoms. This is named Vibro-Acoustic Disease by the Portuguese who have studied this whole body pathology for 25 years. The EPA delegated authority to state and local governments in 1982 as a cost cutting measure. However, only six
Citizens for Environmental Clean-Up (CEC)

P.O. Box 1534Fairfield, Texas 75840

(903)389-5616
explained, brain damage due to severe lack of blood flow to the brain. Why? Morgan had lived

on his cattle ranch east of Dew, Texas for 21 years in near perfect health. Then came a naturalgas compressor station that gradually built up to eleven 1,340 horsepower compressors with no

noise abatement installed.

A series of visits to doctor specialists including neurologist, heart and pulmonary specialist,found brain and heart damage, but they could not explain the cause. Morgan believed the

damage was caused by the Low Frequency Noise (LFN) and began researching this issue trying

to find the relationship between body damage and LFN. Morgan followed up on two major

sources of research, Canada and Portugal. A subsequent review of papers presented by Lisbon,

Portugal’s Human Development Center revealed that environmental LFN can indeed causenumerous symptomsjust while sitting in ones home. The Lisbon Center named the disease,

Vibro-Acoustic Disease (VAD).

Another Internet source, Health Effects of Noise, revealed the basic relationship of LEN to body

damage. The LFN causes the adrenaline glands to secrete adrenaline throughout the human

body. The adrenaline in turn causes the blood vessels to constrict (vasoconstriction).

From Morgan’s experiences, the body’s extremities are usually affected first with numbness in

ankles and hands. Then the genital area begins to hurt and then the top of ones head. Beforeones head starts to hurt, the neck veins usually feel like they are burning. Morgan has suffered

a ruptured ear drum twice as have children in the neighborhood. The hearing loss has been

substantial. Other neighbors have reported severe dizziness. This is vertigo. One man now has

restless leg syndrome and must wear socks to bed to keep the sheets from wearing the skin off

his toes because his legs jerk so much when trying to sleep. They could not hear the LFN, but

called Mr. Morgan after their weird symptoms. He had previously recorded 102.5 decibels of

25 cycles per second noise at the couple’s driveway using a rented noise meter. At 70 dBA

hearing protection is required according to EPA rules. Only five percent of the population can

hear the LEN since its frequency (25 to 500 cps) is below normal human hearing.

Mr. Morgan and persons living in the Lanely Community five miles east of Dew are being

tortured daily by very loud LFN in their homes. Vasoconstriction is causing high blood pressure

as high as 214/113. When out of the LFN, Mr. Morgan’s blood pressure is around 127/70.
are safe. Mr. Morgan has traveled 150 miles south past Houston to Friendswood, east to

Nacogdoches (two hours drive from his home), north to Dallas and west to Waco. The LFN was

still present. Adjacent states have similar natural gas development. He has received e-mails

,L..; 4 v-...I, ••,I.. ,.,I,1,.. ii vfli t.S.I ,iiiO, VCILCrn rtnii\iiIcii lid di IU idtVV I UI I\ II ILdIi ii i VVIIcIL L.di I Ut UVI e LU

alleviate the situation. This is a national issue.

There is a federal law concerning noise, the 1972 Noise Control and Abatement Act that is still

in effect. The EPA was tasked to develop guidelines for noise limits. Low Frequency Noise was.,..# -I..,..-.,..1 ...-... ;.. ICV7A i.. 1flo +1..,.. EflAI IUL pti..Ilii..ciIIy IIUUI ttU. I.JIIly ci UI It JdC UIUtIIl It VVcI .1i UUUL.tU III .LJI t. Ill .LOL, Lilt L?inoise control office was closed and authority to regulate noise was delegated to state and local

governments. The local level will not do anything without a state law. Only six states out of

50 have a state law on noise control. They are California, Illinois, New York, Maine,

Massachusetts and just recently Colorado.

A person can initiate a legal suite in federal district court at a cost of about $50,000. Mr.

Morgan has contacted and provided data to 26 large law firms who will not take his case on a

contingency basis. They state that too much money is required up front or statutes of

limitations are a question. No one enforces the federal law and few states have noise laws, somost of us are just out of luck and must put up with the torture and will probably die an early

death.

••

i ne compressor station can oe ixeu w anate me noise. riowever, tne gas pruouction

companies do not want to spend a dime. They must be forced to clean up their problem.

Meanwhile, our children are faced with learning and reading problems due to lack of

concentration, hearing loss, body damage and even death. Numerous children have died ofheart attacks in Ft. Worth, Texas but no one knows why. Channel 8 NEWS in Ft. Worth

interviewed a doctor there in December 2008. He stated they were doing electro-cardiograms

on area children. This is the wrong tool and will not detect the problem. An echo-cardiogram is

required and a doctor who knows what to look for. As stated above, they are scarce. Recently,

two persons died of brain aneurisms and a third, a young lady, almost died of two brain

aneurisms. They all lived in Freestone County, Texas.
y 

g 

g

y 

r..J ...I c........... n.-....I i-..-.. Ircor i.-.l.,.. -. .+L......:#.. ... ..... .I:...... I.....i.I. ;-i-.-.#, reuei cii ciieiy neulaLuI y LUIIIIIIIIUII rLiw...) Ldle dULl IUI IL UVCI ICUldLIUll UI UJULII IIILldLdLCnatural gas facilities as well as interstate gas facilities. The FERC regulates only interstate gas

facilities at present.We can expect catastrophic damage to and deaths of our citizens and no one will know the

cause due to ignorance of the LFN problem.

President Obama’s address: President Barack H. Obama,

United States of America

The White House

1600 Pennsylvania Avenue NW

Washington, District of Columbia 20500

Best4egarJs, -. c_! (- L.

Charles E. Morgan, P.E., Inactive

Major, USAF, RetiredExecutive Director,

Citizens for Environmental Clean — Up (CEC)e-mail: cemorgan75831@yahoo.com
Copyrighted page(s) removed. Copyrighted 

material is not available in Regulations.gov since 

it may not be reproduced without consent of the 

copyright holder. 

Removed pages can be viewed at the USEPA 

Docket Center, Public Reading Room. 

Address: 1301 Constitution Ave, NW 

Room 3334 

Washington, DC 20004 

Telephone: 202-566-1744 

Email: docket-customerservice@epa.gov
Some symptoms of Vibro-Acoustic Disease (VAD),

due to exposure to Low Frequency Noise include:

head hurting, numbness in fingers and toes, back pain

deep inside the back, enlarged aorta ofthe heart, brain

damage, fibrosis ofthe lungs, sharp pain n various

parts of the body, restless leg syndrome, incontinence

(regardless of age). ruptured ear drums, ear ringing,

nervousness & nausea.

The LFN causes adrenaline to be released that in turn

causes blood veins to constrict, thus causing most of

the above symptoms.

More symptoms ofthis disease are, (but not limited

to), mood swings, indigestion & heartburn,

mouth/throat infections & bronchitis. In later stages,

the individual tends to recognize the existence of

memoiy lapses. Neurological disorders include

epilepsy, balance disorders and a marked increase in

cognitive impairment.

Studies show only about 5 percent of people can

actually hear the LFN, but it still causes bodily

damage. Since the LFN can travel at least 5 miles (in

all directions) from these 130 compressor stations in

Freestone County, more people than ever before are

being exposed to the dangers ofthe LFN.

We and our

children

deserve a safe,

Low Frequency

Noise free

environment.

Most industrialized countries ofthe world, such as the

United Kingdom, Canada, The Netherlands, Australia,

Japan, New Zealand, Germany, France and many others,

recognize the effects of Low Frequency Noise. Most have

rules governing LFN to control its effect on people.

The EPA developed some noise rules, but did not include

LFN controls. Authority given EPA by the 1972 Noise

Control Act has been delegated by the EPA to state & local

governments. However, only six states have implemented

their own laws and rules based on the EPA guidelines.

Texas did not! We Texans are in dire need of a state law

on noise control, especially LFN. People all over central

and north Texas where gas drilling and compressor stations

exist are exposed to this new danger to our health.

You can write Senator Steven Ogden at Capitol Building,

P.O. Box 12068, Capitol St., Austin, Texas 78711-2068

and/or Congressman Byron Cook at Capitol Building, P.O.

Box 2910, Austin, Texas 78768 -2910 and attach this

document.

This document is provided by

Citizens for Environmental Clean - Up (CEC),

P.O. Box 1534, Fairfield, Texas 75840.

Please help us spread the word

about this insidious disease.

All donations are appreciated & may be mailed to

the above address with checks made out to CEC.

Charles E. Morgan, P.E., Inactive,

Executive Director

Citizens for Environmental Clean-Up (CEC)

VAD

Vibroacoustic Disease

ibroacoustic Disease

(VAD)

Low Frequency Noise

(LFN)

A

Is caused by

It Lc a whole-body

noise-inducedpathology,

that is not particularly

related to the ear.
I’’ibro—.’I eous’tic Disease (F ID) is a

i i’Ii ole—body I)(11h o/ogr cu u.s ed hr

e.VeL’ssi)‘e expostire to L o,i’ Frequeiic

.‘s’oise (LFN).

Vibro-Acoustic Disease (VAD) is a

whole-body pathology caused by excessive

exposure to Low Frequency Noise (LFN).

It was initially identified among aeronautical

technicians. VAD has also been observed in

military and commercial pilots and aircrew.

Now millions of people world wide are

suffering from VAD.

Noises with a dominant content of

frequencies in the range of 20 to 500 hertz

(Hz) (low frequency noise) are emitted by a

large range ofsources in our society.

With the natural gas drilling boom in Texas

we have an ever increasing source of low

frequency noise from GAS COMPRESSORS

STAT! \ ‘. There are 130 such stations in

Freestone County that are causing this

insidious VAD. This disease has been

studied and recognized in other countries

more than the U.S.. Very few doctors in the

U.S. are knowledgeable about it..

When driving around on the country roads, you

might notice the large structures that have large

fans on the ends. You can hear the low pitch, but

loud and annoying hum of these stations.

Many ofthese large Compressor Stations are

built on property set back off the road, so people

can not see them. However, the LFN can travel

at least five miles from the stations in all

directions and penetrates all structures.

People can get VAD by just being in their

homes.

Not everyone can hear the LFN at their

residence. One member of a household may

hear it and another may not. The noise has its

affect on all persons, only to varying degrees.

The ill health affects can be immediate, but

can also accumulate with time, depending

on the person and the intensity ofthe noise.

The longer one is exposed, the more

damage it can cause.

Many people have health problems and

dont realize they are due to this exposure.

Some people are more susceptible to have

problems than others. Pregnant women and

children are especially susceptible.

Learning ability in children is affected.

Some local children, who live near a

compressor station, are having headaches

and others ruptured ear drums. One local

lady suffered vertigo for two weeks so bad

she could not get out of bed and stand up.

One gentleman in Freestone County has a

host of severe health problems due to the

compressor station 0.9 miles of his property

after living here for 21 years in near perfect

health: heart damage, brain damage,

constriction of blood vessels, ruptured ear

drum (twice) and now permanent hearing

loss. When his head hurts too much, he is

regularly forced to leave his home in an

effort to escape the ill effects ofthe LFN.

When he gets out of range ofthe LFN,

about five miles, his head stops hurting and

burning blood vessels ceases. He has been

diagnosed with VAD.

IJ

Photo of a gas compressor station.

(Some are larger.)
Q

R

2010

0505 1200 Pennsylvania Avenue, N.W.

Washington D.C. 20503

Comments ofthe League of Women Voters of Texas

On

New Source Performance Standards and National Emissions Standards for Hazardous Air Pollutants Reviews For the Oil and Natural Gas Sector

Agency

The League of Women Voters of Texas (LWV TX) applauds the Environmental Protection

We

(EPA) for proposing national air emission standards for the oil and natural gas industry. are particularly gratified that these proposed standards cover the process ofrecovering natural gas through hydraulic fracturing, commonly known as fracking. These proposed

gas

regulations

drilling

are in conformance with LWVUS’s support for strengthening federal regulation of in

a manner consistent with the preservation of

a healthy environment. Obviously, the oil and gas industry has

a huge economic and environmental pleased impact on Texas, and we are that the EPA chose Texas as the site of one ofthe three hearings on these proposals.

We

The standards listed below are especially important to the League of Women Voters of Texas. strongly endorse their adoption:

•

VOCs

Source performance standards for volatile organic compounds (VOC5), which would cut by nearly one-fourth across the oil and gas industry, including

a nearly 95 per cent

The

reduction in VOCs emitted from new and modified hydraulically fractured gas wells. process to meet the new standard captures natural gas, thus saving the industry nearly $30 million annually.

• Source performance standards for sulfur dioxide.

• Air toxics standards for oil and natural gas production, which includes reducing air toxics

major

from all large dehydrators by 95 per cent and requiring crude oil and condensate tanks at sources to control 95 percent oftheir air toxics emissions.

• Air toxics standards for natural gas transmission and storage that are estimated to reduce the maximum risk level for cancer from 90 per million to 20 per million.

• Elimination of exceptions for startup, shutdown, and malfunction events since many of the highest levels of hazardous emissions occur at these times.
Thank you,

,?L’A

) /-Karen Nicholson, President

- League of Women Voters ofTexas

1212 Guadalupe St.. Suite 107 * Austin, Texas 78701 * 512-472-1100 * 512- 472-4144 fax * lwvtexasal%’,texa5. ore * wwwlwvtexas.or
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ng the Exploration / Drilling / Production Industry

Data Confirm Safety Of Well Fracturing

By Kevin Fisher

HOUSTON—North American oil and

gas companies and energy services providers are following with a keen and vested interest the news coming out of Washington regarding the “Frac Act,” a congressional proposal to amend the Safe Drinking Water Act to remove a 2005 Energy Policy Act exemption on hydraulic fracturing and effectively give the U.S. Environmental Protection Agency the au thority to regulate fracturing operations. A year or two ago, no one outside of the upstream oil and gas industry even knew what a hydraulic fracture was.

FIGURE 1

Today, senators, congressmen and jour nalists arc discussing fracturing as if they were career frac engineers. A number of key questions are central to the debate over the Frac Act. Ts there a cleaner fossil fuel available than natural gas? Is natural gas abundant in North America and many other parts of the world? Has the growth of unconventional

gas in the past decade, primarily ftom shale, materially added to the recoverable

gas (and sometimes oil) reserves in North America, eliminating the need for natural

gas imports? Does this improve our energy security? Does incremental production create new sources of tax revenues and

local jobs? Is there a more impacting service in low-pcnncahility reservoirs than hydraulic fracturing? Does hydraulic fracturing imperil groundwater supply? Whoa, let’s park the pump trucks here for a moment.

On March 17, 1949, a team comprised of Stanolind Oil Company and Halliburton personnel converged on a well about 12 miles east of Duncan, Ok., to perform the first commercial application of hy draulic fracturing. Later the same day, Hallihurton fractured another well near Holliday, Tx. The technique had been developed and patented by Stanolind and

an exclusive license was issued to HalBarnett Shale Mapped Fracture Treatments (TVD)

Reproduced for Halliburton Pinnacle with permission from The American Oil & Gas Reporter

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Email: docket-customerservice@epa.gov
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Carl Dimon 972 264 1848
My name is Angie Burckhalter. I represent the Oklahoma Independent Petroleum

Association (OIPA). OIPA has approximately 2,100 small to large independent crude oil

and natural gas producers that operate in Oklahoma that will he significantly impacted by

EPA’s oil and gas NSPS and NESIIAP rule.

• Nationwide, independent oil and gas operators drill approximately 95 percent of the oil and gas

wells in the U.S., and produce 85 percent of U.S. natural gas and 56 percent of U.S. crude oil.

• We appreciate the opportunity to provide input into EPA’s proposed oil and gas NSPS and

NESHAP rules, and we submit the following comments for your consideration.

• Many oil and gas operators in Oklahoma are small businesses (similar to small family farms).

These small independent oil and gas companies are ill-equipped to bear the costly burdens of

more and more air requirements. Over the past 3 years, EPA alone has come out with

significant rules that impact our members. For example, EPA’s engine rules i.e. Part 60 Subpart

J.TJJ, Part 63 Subpart ZZZZ, and the GHG Reporting Rule, Subparts C and W.

• Many small operators/businesses of production facilities have limited staff. Forty-six percent of

OIPA’s members have less than 19 employees. Their tolerance for more complex and costly

regulations is significantly different, and significantly less, as compared to larger companies.

These truly are small businesses that are struggling to stay in business.

• Oil and gas facilities vary significantly across the country. For example. there are drastic

differences in the characteristics of the fluids and gases produced, the volumes initially

produced, the production volume drop-off rates, the economics of each well, the locations of

wells (most are typically located in rural areas -miles from cities and towns), the availability of

infrastructure, the availability of consultants and equipment to support compliance efforts, and

other like issues. The proposed regulation does not provide the tiexibility that the different oil

and gas sectors and facilities need nor does it address costly and burdensome issues for small

business.
y 

agement systems in place or the staff to address these issues. EPA proposes to

reduce the burden by the use of an electronic database and/or third-party compliance

verification. Instead, we request EPA re-evaluate the need for this information, greatly simplify

and streamline the various notices. recordkeeping, monitoring, annual reports, and other various

submittals, and utilize a general duty clause that would allow operators of production sites to

keep records without the data submittals. If EPA or the states want to check compliance they

can with a site inspection or a specific data request.

• Another area problematic for small operators would be the compliance deadlines. Small

businesses/operators won’t be able to meet the immediate Federal Register publication

compliance date. They need time to fully understand the final rule, determine applicability to

their operations, program funding. train staff or hire consultants, establish procedures and

protocols to comply, and purchase/rent control equipment. Our members are greatly concerned

with access to available consultants and control equipment as they will have to compete with

larger companies. Once the proposed rule is final, the demand for these resources and

equipment will be great, the supply will be low, and the costs will quickly increase which will

negatively impact all operators, especially the smaller ones. We request an I 8-month delay to

comply with the requirements applicable to production sites.

• EPA’s NESHAP requirements have become so technical that only a person with significant

knowledge and experience with those rules are able to evaluate and understand them. Even the

most sophisticated air person struggles with the MACT requirements. We are very concerned

that most small businesses that operate production facilities will struggle to comply with the

storage tank and dehydrator requirements which will lead to costly violations. We request EPA

streamline and simplify those requirements.

• EPA proposes to reduce the compliance burden to industry, state and local governments by

proposing to exempt certain sources from Title

V permitting requirements that would be

triggered by the proposed rule; however, EPA does not consider limiting minor source permits.

Again the impacts on smaller operators will be costly and burdensome, not to mention the

2
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p

ate production sites easily determine

applicability, know what data to collect and report, easy understandable methodologies to

calculate emissions, and the identification of specific compliant control technologies to be able

to comply with the requirements. In addition, EPA should conduct specific outreach and

education efforts that walk small oil and gas operators through the rule and how to comply.

• Finally, we request a 60-day extension to the comment period to allow smaller operators more

time to review, evaluate, and comment on EPA’s proposed requirements.

• We appreciate the opportunity to provide input into the rulemaking process. Thank you.

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ore you today to address this very important topic.

And, second, thank for your time today and your willingness to listen to all of us and for what has to be a very long day.

For the sake of brevity and to, hopefully, avoid repetition of comments made by previous speakers, both for and against these new regulations, I will offer only some general observations and comments as a concerned citizen on this issue.

I have taken the time to read the basic information provided by the EPA on its proposed suite of regulations that would reduce the harmful air pollution from oil and natural gas industry, while allowing continued, responsible growth in U.S. oil and natural gas production. The proposed updated rules, as I read them, would rely on proven technologies and best practices that are in use today to reduce emissions of smog-forming volatile organic compounds into our air.

While I am not a scientist or even an expert in the oil and gas industry I am concerned on two levels about the quality of the air that we breathe here in the Dallas-Ft. Worth Metroplex and why I am supporting the proposed EPA Oil and Natural Gas Pollution Standards as proposed.

One of my professional responsibilities, and privilege, is to serve as a council member on the Hurst City Council, Place 2 for the past ten years. In that capacity it is my duty to become informed on issues that come before our council for consideration. Obviously with the recent development gas exploration and production in the Barnett Shale area this is an issue in which we have spent much time in consideration. Consideration of the economic benefits and the rights of land owners to have reasonable access to their mineral rights and rights of those who live in the immediate area of gas wells to be protected from harmful pollutants.

Recently our city council updated our city ordinance as it relates to gas drilling operations in our city by strengthening our testing requirements. These changes were reflective of proven industry standards and of similar actions being taken by other councils on this issue. While I am not speaking for our council today, I think it safe to state that our council strongly believes that testing is important to the environment and in the protection of our citizens and is allowed under state and federal law — and is the right thing to do. The best proof that a company is not harming the environment is regular and systematic testing for pollutants in the air, water and soil. We feel our testing requirements are responsible and reasonable in meeting our obligations to protect our citizens and at the same time provide companies who wish to engage in gas drilling in neighborhoods a way to reasonably accomplish their goal.

This seems to be the goal of the proposed Oil and Natural Gas Pollution Standards.
This means increased costs in health cared an issue not to be taken lightly.

On a more personal note, it is an issue that directly touches my family. My wife suffers from asthma.

On Orange pollution days it is not safe for her to venture outside. Her doctor has even suggested that

one way to avoid the asthma attacks is to move away from the Dallas-Ft. Worth area. ln fact, when we

go to our cabin on Lake Whitney which is only 85 miles south of here, within an hour of arriving she is

able to breathe better and she can feel the relief of pressure on her lungs when she tries to breath.

My goal, my hope, is that the EPA will stay the course with these proposed changes. I am very much

aware of the pressures being made by the oil and gas industry, by lobbyists for the industry, and by

politicians who express fear this will be too expensive and cost jobs. In fact it probably will create more

jobs and provide a better environment for all of us. I would submit to you that it is in the best interests

of all of us — the oil and gas industry and those who live in areas of oil and gas production — that we

protect the quality of our air and ensure a place safe to raise our families and a place for our children’s

children to raise their families.

I am not opposed to oil and gas exploration and drilling. I would love to enjoy the economic benefits of

a monthly check from a gas company. What I am in favor of is a reasonable and responsible way of

ensuring our future in energy and at the same time a safe place to live to enjoy those benefits. It is my

belief that the proposed regulations proposed by the EPA move us in that direction. I encourage the

EPA and our political leaders to do the right thing and to stay the course in protecting our environment.

Recently, a top executive of one of the companies involved in the gas operations in the Barnett Shale

made a statement at a conference that critics of shale drilling are fear mongering extremists who want

Americans to live in a world where” it’s cold, it’s dark, and we’re all hungry.” May I suggest that if we

have all the energy in the world at our disposal and live in an uninhabitable place — we will find

ourselves in a place that’s ‘cold, dark, and we will all be hungry.’Thank you for your attention today and for what you are doing for all of us.

Contact Information:

Larry Kitchens

917 Henson Drive

Hurst, Texas 76053

(817) 284-6353 H

(817) 257-6123 0

(187) 308-6667 C
September 29, 2011

Rep. Burnam Applauds EPA’s Proposed Rules to Reduce Emissions

from Oil and Gas Operations

Recommends the rules be strengthened and apply to existingfacilities

(Arlington, Texas) — I applaud the EPA for proposing these common sense rules to reduce

dangerous emissions from proliferating oil and gas facilities around the country. These longoverdue improvements to the New Source Performance Standards will do what the Texas

Legislature and state agencies that oversee oil and gas production have failed to do: protect

public health by placing reasonable limits on air pollution that will both reduce emissions and

increase industry revenues.

Below are my comments regarding four components of the rule that will have the greatest impacton public health in Fort Worth.Green Completions

While green completions are already required under Fort Worth’s Gas Drilling Ordinance, thisrule will extend the requirement to the un-incorporated areas and to the municipalities around the

Barnett Shale lacking such a requirement. Requiring green completions to include all gas wellsin the Bamett Shale will significantly reduce emissions in the D-FW non-attainment area.I recommend that:

• regardless of comments provided by industry, the green completion requirement not be

limited to apply only to gas wells with a certain VOC content, but rather to all

hydraulically fractured well completions;

• with increasing production of oil from the Barnett and other shale formations in Texas,

the requirement be extended to include new and existing oil wells that co-produce

gas, instead of only applying to gas wells.

Pneumatic Control DevicesRequiring that new or replaced pneumatic devices be “no-bleed” or “low-bleed” is an important

step, but the improved rules would have no impact on the emissions from the thousands of valves

already in operation around the Barnett Shale.

Committees: Environmental Regulation --Public Safety
As of last year, there were almost 5,000 oil and condensate storage tanks in the Barnett Shale and

almost 15,000 produced water storage tanks. With so many polluting tanks already in existence.

I rCcOiTllflCfld that the vapor recovery requirement be expanded to include:

• produced water tanks, in addition to oil and condensate tanks, and• existing oil, condensate, and produced water storage tanks, as opposed to just new

tanks.

Leak Detection at Gas Processing Plants

‘[he proposed rules strengthen the leak detection and repair standard (LDAR) by lowering the

detection threshold from 10,000 parts per million (ppm) to 500 ppm. I strongly support this

prOViSion.

I recommend, though, that the new LDAR requirement be extended to apply to older,

existing processing plants as well as to new plants.

In summary, the proposed rules are an extremely important step fonvard, and the EP.4 is to be

roivnie;ided/or these significant improvements that will protect public health. I encourage the

EPA to strengthen the rules and improve consistency around the country by extending the

:mad5rds to esisting facilities as well as new ones. If the EPA opts not to extend the rules to all

existing fmcilitics, it could extend the requirements to existing facilities in areas that are in or

iear ozone non-attainment.

Committees: Environrnen[a I Regulation —— [‘ubik Safety
815 Brazos, Suite 600

Austin, Texas 78701

www.EnvironmentTexas.org (512) 479-0388

statewide,

Good morning,

citizen-funded

my name is Luke Metzger and I am the Director of Environment Texas, a advocate for clean air, clean water and open spaces.

health

Today’s

warning,

hearing is especially timely. The DFW is suffering from another orange ozone

outdoor

where electronic billboards on the highways advise us to limit our activities. Incredibly, Texas. those warnings are all too common here and around

exceeding

Last year, there were 48 days when at least part of Texas experienced smog levels

illnesses

the national health standard. Children, the elderly, and people with respiratory

develop

suffer the most on these days. Children who grow up in smoggy areas may

life. And

diminished lung capacity, putting them at greater risk of lung disease later in children exposed to smog in the womb can experience lower birth weight

damages

and growth retardation. Even for healthy adults, repeated exposure to smog pollution

asthma,

lung tissues, decreases the ability to breathe, exacerbates chronic diseases like and can even cause premature death.

which

Texas also recently finished the hottest June-August summer in recorded U.S. history, the Texas State Climatologist attributed

— an appointee of Gov. Perry, mind you

— has

year dry

in part to global warming pollution. In addition, our drought - the worst onehistory spell in recorded history

— and the recent wildfires

— also the worst in Texas

— are consistent with scientific predictions about global warming.

Arlington

Texans deserve clean air. But on far too many days, children and seniors here in

are suffering

and across Texas are exposed to dangerous smog and toxic air pollution and

every day

the impacts of global warming. For the sake of our children, we must make

a safe day to breathe.

and

I am

gas

here

drilling,

today to

which

commend EPA for taking steps to reduce air pollution coming from oil

cars and trucks according to the TCEQ, will soon surpass the emissions of all the in the DFW area.
g plants, compressor stations, pipelines and storage tanks leak about 2.2 million tons of smog-causing gases annually, as well as greenhouse gases such as methane, and countless toxic and carcinogenic gases like benzene. All have serious effects on the health of Texans and their environment. 2

Natural gas and oil operations in the Barnett Shale counties alone produce as more harmful gas emissions as all of the cars, trucks and airplanes in the DFW metro area, over 103 tons per day. 3This massive air contamination has tangibly affected North Texans in recent years.

A study of Dish, Texas in Southern Denton County found that 61

% of its citizens suffered from health problems ranging from dizziness and nasal irritation to brain disorders, severe nervous system problems, and cancerous lesions that the study linked to 16 harmful chemicals produced by local oil and gas facilities. The chemicals were all found in the communities’ air in unsafe levels, as well as urine and blood samples.

A similar slew of health problems have been seen in nearby Argyle and Bentonville. In these communities, 7 harmful gasses were found in ambient air before the oil and

gas boom. Recent tests at their high school’s band practice lot found 65 of the 84 air contaminants tested for by the EPA. The rise in air pollution was accompanied by health problems among schoolchildren, including severe asthma, dizzy spells, and chest pain. 4

Furthermore, a study from The City of Fort Worth reported this year that metro-area oil and gas exploration produces over 20,000 tons of gases annually, including dozens of harmful pollutants, often due to faulty equipment such as open hatch tops and corroded tanks. The study also found highly toxic henzene in 94% of air samples. 5

Meanwhile, Texas-based oil companies that participate in hydraulic fracturing are among Fortune 500’s top earners, raking in billions of dollars of profit per year to shareholders, while leaking toxic and polluting chemicals into Texas’ air. Company profits should be based on hard work and smart management, not irresponsible policies that put citizens and the environment in peril. The oil and gas companies are making a killing with all this drilling. They can certainly afford to install pollution controls. We Texans have to pay to get emissions inspections for our cars and pay to repair them if they pollute. It’s only fair that the oil and gas industry do their part to help reduce air pollution.

1 http: //www.rrc.state.tx.us/barnettshale/drillingpermitsissuedl993-2010.pdf 2 http://www.epa.gov/airquality/oilandgas/basic.html http://www.edf.org/sites/default/files/9235_Barnett_Shale_Report.pdf

4http://www.earthworksaction.org/FLOWBACK-TXOGAP-HealthReport-lowres.pdf http://www.scribd.com/doc/600463 62/Air-Quality-Study-Final
compressors and storage tanks, and does not hold up to the strict standards of some states, such as Wyoming. 6

These new standards represent a significant step in reducing air pollutants from the oil

gas industry, a strong involvement of the EPA to create meaningful, broad regulations, and a tangible reduction of harmful air pollutants. They show that environmental and public health laws can also be cost-beneficial for the private sector, and should be used as

a standard for even more stringent policies that significantly cut air and water pollutants that put our health and environment at risk.

6 Environmental Protection Agency: “EPA’s Proposed Air Pollution Standards for the

Oil and Natural Gas Sector”. Preliminary Analysis. September 2011
This focus is important because hydraulic fracturing operations are critical to U.S.

energy development. Without this technology

— or without the ability to employ it cost- effectively

— natural gas and oil development could be discouraged, delayed or reduced. Oil and gas are

a vital part of our nation’s energy landscape today and are expected to continue to be in our future. The EIA energy projections show that oil and natural gas are expected to supply most of our nation’s energy for decades.

Unfortunately, unless properly crafted, these rules could hamper our ability to supply the oil and natural gas that we know will be needed. And making the rules work could be difficult. The comment period for these extensive, detailed rules is too short. Controls would be imposed on the industry with inadequate lead time. This would make it

difficult for operators to prepare to implement the controls and would increase the risk of unintended consequences.

In the worst case, the result could be requirements that would hinder hurt job creation, federal and state revenue generation, and harm our nation’s energy future.

We have prodigious reserves of oil and natural gas here in the United States. Oil will continue to be vital for supplying transportation fuels. And there are large and growing markets for natural gas related to electricity generation, manufacturing, transportation, and home consumption. We need to be able to meet this demand. Natural gas is more affordable today relative to just

a few years ago, largely because of the shale gas boom

now underway.

More domestic oil and natural gas development is crucial for job growth. The industry has

a strong track record of creating jobs as evidenced by what is happening in North Dakota, Texas, Pennsylvania and many other states. The industry now supports 9.2 million jobs, and continues to create them. More than 9,000 oil and gas related jobs were created this summer according to BLS, at

a time when new job creation in the

economy was sorely needed. Perhaps

a million or more new U.S. jobs could be created over the next seven years if common sense changes to energy policy were implemented, according to recent research conducted by the energy consulting firm Wood Mackenzie, assuming new regulations do not have unreasonable provisions.
requirements by including

a significant extension of time for their full implementation.

Specially designed equipment that is time consuming to build is required to safely perform reduced emission completions. There is insufficient emission control

equipment currently available and it cannot be constructed before the expected second

quarter 2012 compliance date.

Furthermore, the proposed regulations do not account for challenges relating to several

current completion technologies and known reservoir properties. For example, there

are challenging technical issues regarding certain coal bed methane technologies, lowpressure reservoirs, and reservoirs with very low volatile organic compound content.

The final rules should also recognize that thousands of “tank emission combustors” will

need to be certified and manufactured to reduce emissions. These combustors will not

be available early next year. The final rules should recognize that additional time is

necessary before this requirement is imposed.

Lastly, EPA should simplify the overly burdensome aspects of the notification, recordkeeping, monitoring, reporting and performance testing requirements in the proposed rules to reflect that many of the industry’s sources are at remote and

unmanned facilities.

In closing, we believe the Agency should allow an additional 60 days for the public to provide comment on this important rulemaking for the following reasons:

• The proposed rules are expansive and complex. This is

a set of five complex and interconnected rules. Indeed, the proposal spans over 100 pages in the Federal Register and the docket contains many times more pages of supplemental analyses and materials. Preparing comments on any one of these rules would be

a challenge within 60 days. Preparing thorough and meaningful comments on all five within 60 days is not reasonable or practicable.

• The proposed rules are not being implemented in

a vacuum

— EPA has

numerous other rules under development that demand time and attention from this sector.
Again, we do not fundamentally oppose reduced emission completions where they make sense and the operators have sufficient time to implement the controls. However, given the complexity of the issues, the many competing demands on Agency resources, and the time that will be needed to respond to public comment and complete interagency review of the draft final rules, we also believe that

a one-year extension of the final rule deadline for completing these rules is appropriate and justified.

API will be submitting detailed comments before the comment period closes and API looks forward to working with the EPA on safe, achievable, and cost-effective final rules.

That concludes my comments. Thank you.
The length and complexity of Fort Worth’s recent air quality study make it difficult to

decipher and its infirmation thus virtually unavailable to most residents. While we now

have information that we did not have before, we do not have the clear-eyed answers that

we need.

We must do far more. I encourage the mayor and City Council to not place this report on a shelf as a question answered but instead use it as a foundation to address emission controls

for natural gas production activities over the long term.

The value of royalty income will prove fleeting if we discover all too late that the health of

our young and old was diminished because we were unwilling to press this issue.

The Si million cost of the air quality study was enormous for the results that were provided. The city stafffailed to take a sufficiently aggressive approach in managing the work and thecontractor and allowed the final cost to run significantly over budget.

Credibility was key for this work. After the protocol was developed and Eastern Research

Group selected to do the work, the city staff folded back into a behind-the-scenes process of developing the contract. The process was not open to the Air Quality Study Committee or the public.

Eastern Research was asked to conduct air quality sampling to determine the existence and

prevalence of harmful emissions from natural gas operations citywide. The ambient air monitoring report revealed relatively consistent signs of important air quality issues.

Benzene, the contaminant that has drawn much of the current attention on air quality, was detected 94 percent of the time. it is the best marker of an emission problem.

Seven other volatile organic compounds were detected at rates higher than 90 percent. That these values were collected citywide underscores the gravity of the situation.

The report identified seven key pollutants for Fort Worth. Eastern Research’s analysis

appears to judge the presence of the pollutants only by whether they produce an “urgent health hazard.” That leaves open a very important question about Fort Worth’s overallnear- anti short-term air quality.

This may be too simplistic for air scientists, but if we find henzene 94 percent of the time,

we have a problem.
Stunningly, the report reflects raw averaging and even wholesale assumptions that

nontested equipment was not leaking. That is not what the city asked or paid for.

NoPvithstanding the consultant’s assurances, the report acknowledges that not all of the

sites’ emissions were even tested.

For example, certain parts of storage tanks, wastewater and condensate loading equipmentand flaring were not tested.

The report highlights compressors as well as gas treatment plants as the greatest sources of

obvious emissions. The reported values for the one gas treatment plant examined are

ç significant. The city should inventory all gas treatment plants that are just outside city ri , A boundaries and produce emissions that can or do (Irift into the city.

\ C)

Cettain emissions were &tected b infraied camera at a well completion site but weie not measured otherwise. The evaporative units at the city s waste disposal pilot project were not tested for emissions.

( Despite requests, testing in heavy condensate production areas outside of Fort Worth was not done.

We have no sense of the volume of emissions that drift into our city from production areas that are known to emit volatile organic compounds.

The real question facing the city and its residents concerns Barnett Shale natural gas development’s cumulative effect on air quality and good health. The answer still eludes us.

.Jim Bradbury is a Fort Worth attorney practicing environmental law and a member of the

city’s Air Quality Study Committee.
j

g

discharged

I became an Orderly in the hospitals and my work in allied health care spans 14

years. I left California

because of the lack of natural water supply, and bad air. I remember driving north

through the

San Bernadino Valley and not being able to see the rig line around the city. The

Haze in the air

was so thick. I can remember [ even on the clear days] it was still a hazy yellow. Ivoted to

approve the peripheral canal. It was a measure that was supposed to improve the

volume of

water supplied to the millions and millions of people in Southern California. It

didn’t pass so

between that and the poor air quality, lfelt trapped, so I left. There was plenty of

work here in Texas and

My grandparents had a home in Ft Worth so I stayed with them till I got on my

feet. I guess according

to social statistics I would be considered working class or a working poor person.

I’ve earned my EMT twice

and worked in hospitals in California and Texas. Along with the millions of people

here in north Texas
to become a professional because there was always employment.

As long as the rent was paid and food in the refrigerator I was happy.

Like everyone else of my status I’ve paid

thousands of dollars in sales taxes, purchasing cars and light bulbs and

brooms and books, shoes andfurniture. It’s a long list. I’ve lived at my current location(1119 South

Davis Drive]for 22 years. I raised a family here. Exceptfor the extreme heat and

the bugs in the

summer times, it’s been a good experience. I been noticing though over the last 6years or so, the air

quality is getting worse. I started to notice that drilling rigs were popping up everywhere. Towers with lights at night. I thought

they were cool looking. They have American flags on them. I consider myself a patriot. The lighted towers at night

had a sparkle that made the landscape less dull and dark. It made me happy to know that people were

working. Then one day I noticed exhaust coming from one of them/smoke. As I traveled over the Fielder bridge on my

way to work every morning I would look to the west and some days I couldn’t even

see the buildings inft Wi’44’

D (CH
p

g

seen people struggle to get

a breath. I’ve recently mentioning to friends that the air is getting bad here, The

kind of bad that

I remembered when I use to live in southern California. The air in Southern

California is better now thanks

to the EPA and courageous leaders in the community who fought against big

business and their lobby. Insouthern California now a days the brown skies have all but vanished. I’m told

there were mistakes when

California and the EPA undertook the tasks and procedures to get good air quality.

But Texas and theEPA can do this right, rightfrom the beginning. I live near a busy Street and there

is a private school in

my neighborhood. Although at times in the past I did

notice the faint smell of car exhaust I never notice an issue with my breathing

before the gas wells came.

Since the drilling began[within the last 4 years] my breathing is not as good.

Sometimes when I wake up

in the early mornings my chest hurts, way before the school s’ are open or the

daily commute.

cp E1c4-( )
g

d of N Davis Drive, and numerous others, all within 2

miles of where I stay. I’m

going to see a doctor next month to ask about it. I do NOT believe that the reports

on T orthatthe

testing that was done in Ft Worth on air quality, was correct or accurate. I know

that what the television

weather people sometimes report as “good” quality air, is not true for me. I am

not a smoker. The air

that I breath is bad. I know it’s true because I can tell. As a hobby I like to sing. Lately my abilities to sing

long phrases have diminished. In the last 2 years I’ve mourned to myself and my friends that I’m not able

to hold a note for as long or with as much volume, as I used to. I believe it is due to

the exhaust caused

by drilling gas wells. Based on what I’ve seen and felt here in Arlington; I’d like to charge these drilling

companies, adhere to the air-pollutants & air quality rules! If you lived here. If you lived around these

drilling sites, like me, you would want the highest quality air to breath, for yourself and your children.

Thanksfor you time, I hope and pray you will impose the strictest rules.

Ed Eichinger tech support 11 years Arlington TX 76013

() /q/A//-

Ms. Sandra Denbraber

114 Ray Street

Arlington, Texas 76010-2724

Re: Complaint against Carrizo Oil & Gas, Inc.Dear Ms. Denbraber:

On July 27, 2010 and August 2, 2010, the Texas Commission on Environmental

Quality conducted air quality investigations in response to complaints that odorsfrom burning diesel fuel were creating a nuisance condition at the Carrizo UTAfacility. After thoroughly reviewing all available sources of information including the

investigator’s report, medical records, affidavits and monitoring data, e have

decided to close our file on this matter and will not be pursuing formal enforcement

action against Carrizo Oil & Gas, Inc. We will however, continue the agency’s efforts

to monitor air quality as part of the agency’s initiative to complete a network of air

monitors in the Barnett Shale to better serve residents of North Texas. We do thank

you for your courtesies.

Sincerely,

2 /1

Bryan SinclairDirëctor, Enforcement Division

Texas Commission on Environmental Quality

cc: Mark Vickery, Executive Director

Richard A. Hyde, P.E., Deputy, Office of Compliance and Enforcement

Stephanie Bergeron Perdue, Deputy, Office of Legal Services

P.U. Lu:: • ,\:s:1i.. f.uus i-.::S7 • 512—2-UDO • w-vw.tceq.texas.gov

IL: v is nu jsIu mv smr uv v. a.texa.g gotn’custornersurvey
Public Information & Assistance Division,, MC

027

P.O. Box 12548Austin, TX 78711-2548

Dear Attorney General Greg Abbott,

I am asking that you please have the TCEQ follow the law in enforcing the following:

Texas Administrative Code Title 30 Part 1

Chapter 101 Subchapter A Rule

101.4 States

“No person shall discharge from any source whatsoever one or more air

contaminants or combinations thereof, in such concentration and ofsuch

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.”

This law is very clear it is not based on the TCEQ’s air sample but upon what thecontaminants do to my health. The TCEQ’s air samples show that there was no other

source for the drilling chemicals in my blood. The TCEQ’s air samples are based on a 1

hour exposure not the almost 3 years of 24/7 drilling, fracking and a compressor stationthey had installed and then later removed. The TCEQ filed a violation with enforcement

against Carrizo Oil and gas using this code then Bryon Sinclair decided to close this caseand not follow the law and the intent ofthe laA6

Tn case law there are 2 cases that are important to Texas Administrative

Code Title 30 Part 1 Chapter 101 Subchapter A Rule 101.4 and you need to

see how the courts have ruled.Westlaw 180S.W.2d 959 City ofTemple v. Mitchell 1944 and Westlaw 781

S.W.2d 646 Manchester Terminal Corporation, appellant, v. Texas TX TX

Marine Transportation 1989

both cases are based and support the Texas Administrative Code listed above

and were won in a court oflaw. The older the case the longer it haswithstood time the better the case. These Cases are available from the Texas State LawLibrary.
Sandra K DenBraber
114 Ray St.

Arlington, TX 76010

Dear Ms. DenBraber:

We are in receipt of your recent letter to the Office ofthe Attorney General. Please understand that this

office is prohibited by law from providing legal advice, counsel, representation or interpretations ofthe

law to private individuals.

The policies and procedures ofthe Texas Commission on Environmental Quality (TCEQ) are developed

and overseen by the administrators ofthat agency and are not subject to review by the Office ofthe

Attorney General. You may wish to continue working with TCEQ regarding your issue.

Ultimate oversight ofstate agencies is maintained by the Texas Legislature. You may wish to contact

your legislators regarding your concerns. If you need assistance in determining who your legislators are,

you may wish to contact your county tax assessor/collector’s office or use the “Who Represents Me”

feature on the Texas Legislature Online website at www.capitol.state.tx.us.

Finally, you may wish to discuss this matter with a private attorney. The Lawyer Referral Service oftheState Bar of Texas can assist you in contacting an attorney in Texas with relevant expertise. The Lawyer

Referral Service can be reached at (800) 252-9690 or (512) 463-1463.

Thank you for writing.

Sincerely,

Andreea Flores

Public Information & AssistanceOffice ofthe Attorney General of Texas

POST OFFICE Bo 12548. AUsTIN. TExAS 78711-2548 TEL: (512) 463-2100 WWW.TEXASATTORNEYGENERAL.GO’

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Here is additional research that supports why I was made ill from the

Carrizo Oil and Gas drill site on UTA property. It is sad you do not follow

Texas Law and what research is finding and documenting. Please let me know

if you looked up the case law cases that I gave you to show you that you did

not follow the Texas Admininstrative Code.

Sandra DenBraber

News Plume

Why UT Southwestern’s Gulf War Syndrome Research is a Threat to The Way TCEQ

Does Business

Thursday, September 15, 2011

Dr. Charles Haley at UT Southwestern has been studying Gulf War Syndrome

almost since its inception as a condition in the early 1990’s. Downwindershas been following his work for the better part of two decades. Why? Becausehis theories about how our service men and women were inflicted with this

illness closely correspond to the perspective of citizens living next door

to industrial polluters. That is, constant low-level exposures to chemicals

can have serious life-long health effects, even ifthe exposures are below

“levels of regulatory concern.”

Like citizens battling cement kilns, gas facilities, lead smelters, orrefineries, those who suffer with GWS drew scorn and ridicule from their

opponents. They were accused of having “psychological issues” that were notgrounded in human physiology because no high levels of toxins were everrecorded during official sampling or monitoring. There just wasn’t enough

crap in the air to make you sick according to industry and their apologistsat the Texas Commission on Environmental Quality.Today’s amiouncement that Dr. Haley’s ground-breaking, outside-the-boxresearch, along with Downwinder-like persistence has produced landmark

definitive results is not good news for the TCEQ or the polluters it

protects through antiquated theoretical risk-assessment exercises that have

little to do with reality.

The agency depends on the hypothesis that long term exposure to smallamounts of poisons will not cause harm - not even short term acute harm,

much less life-long conditions. You may have heard this approach described

as the “the dose makes the poison.” You only have to worry about high-levelexposures, and a person’s response to the poison is “linear” - the larger

9/28/2011
What ifsome ofthem caused harm even at low levels previously thought to be

“safe?” What ifthe dose-effect was “non-linear,” meaning it did more harm

at low levels over a long period of time than in short large bursts of

exposures? Then the way the TCEQ currently regulates the public risk to

exposure to these chemicals would be not just wrong, but completely, utterlywrong.

From Today’s Dallas Observer piece on Dr. Haley’s work:

“There’s no denying it now: Gulf War Syndrome, characterized by memory

loss, lack of concentration, neuropathic pain and depression, is a

physiological illness, not a psychological one.

A UT Southwestern study, published in the journal Radiology, used a

specialized MRI that specifically measures blood flow in the brain and

detected marked abnormalities in the brains ofthose with Gulf War Syndrome.

Not only have those abnormalities persisted for 20 years, but in some cases

they’ve worsened.

The findings mark a significant advancement in our understanding ofthe

syndrome, which was for years written off by the Defense Department and the

Department of Veterans Affairs as a form of combat stress rather than an

objectively diagnosable injury. Dr. Robert Haley, chief epidemiologist at UT

Southwestern, and a cadre of clinicians and researchers, have struggled with

the government for some 18 years for research funding and to have the

syndrome recognized as a legitimate war injury caused by chronic exposure to

minimal amounts ofsarin gas.”

(injury caused by chronic exposures to minimal amounts” of poison. Those

are the words that make the way the TCEQ does business instantly obsolete.

They won’t say so of course. They’ll attempt to limit this conclusion very

narrowly. And there’s this - it took 18 years and numerous fights over

funding to get this conclusion. How many years might we have to wait until

J all 80,000 chemicals on the marketplace get this kind ofrigorous attention

Lto their public health effects?

But Dr. Haley has produced the kind of research that’s a chink in the wall,

that eventually leads to a crack that produces more cracks until the entire

thing comes down for lack ofstructural integrity. For now, take heartcitizens. There’s new science that says it’s not your imagination, it’s

their pollution.

9/28/2011
Carrizo Oil & Gas to help pay for new day care at UT Arlington

Posted Monday, Aug. 08, 2011 0 Comments Print Reprints

ShareBy Susan Schrocksschrock(dstar-telegram.com

ARLINGTON --The company that has drilled 22 natural gas wells at theUniversity of Texas at Arlington is now helping build a new child-care \‘9’ ç

center on a quieter corner of campus.The YWCA Arlington Child Development Center is expected to move into alarger, $2 million building next year away from the rapidly developing

eastern edge of UTA, where a 6,500-seat special-events center and major

mixed-use development will soon open. Carrizo Oil & Gas has agreed to pay

$1.12 million to rebuild the child-care center on a tree-lined lot on South

Davis Drive at the northwest edge of campus.

-

—

“It’s a sizable investment, but UTA has been very generous to Carrizo

allowing us to use their property,” said Rusty Ward, Carrizo’s vice

president of regulatory affairs. “This is something the company wanted tohelp with.”

The YWCA serves children from low-income families and those staying in

homeless shelters, in addition to families who pay the full child-care rate.

YWCA Executive Director Carol Kiocek said the existing 8,000-square-footcenter that it owns is more than 20 years old and needs significant

renovations.

The new building is expected to be about 10,000 square feet and surroundedby trees next to a community garden.

“It’s really gorgeous,” Kiocek said. “We’re pretty excited about it.”

The current center is difficult to access and is next to the busy ContinuingEducation and Workforce Development building and faculty parking lots, UTA

spokeswoman Kristin Sullivan said. The College Park Center special-events

building and a mixed-use development that will house 600 students are also

set to open along Center Street next year, so officials said they wanted to

move the child-care center to a less congested, more visible area of campus.

9/29/2011
drilling activity.Carrizo officials say the Texas Commission for Environmental Quality has

repeatedly tested the site in response to residents’ concerns.

“That is the most heavily scrutinized drill site in the Barnett Shale,” Ward

Carrizo has no immediate plans to drill more wells on campus, but the

child-care center’s relocation would free up space for future drilling

activity, Ward said.

The university, which will spend nearly $800,000 on the new center, will

lease the building back to the YWCA. The lease agreement will giveuniversity students, faculty and staff priority use of the child care centerand will allow students and faculty to use it as a learning laboratory,school officials said.

Susan Schrock, 817-390-7639

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9/29/2011
1612 K St., NW, Suite 808

Washington, D.C. 20006

www.earthworksaction.org

940-389-1622

swiIsinearthworksaction.org

Before the

U.S. Environmental Protection Agency

Oil and Natural Gas Sector

Arlington, TX

September 29, 2011
y

examples of health effects, environmental

Barnett

damage, diminished property value and how family and community wellbeing has suffered in the Shale.

We already have over 15,000 existing wells in the Barnett Shale. [Show map of destruction]

direction,

Although you

without

seemed to have heard our cries for help, and the new rules are

a step in the right

The

including existing sources these rules are little help to drilling saturated areas. very same people whose stories you heard will continue to suffer.

You can ease their suffering by strengthening EPA’s proposed New Source Performance

and

Standards

existing

and

wells

National Emission Standards for Hazardous Air Pollutants to include all new and storage tanks, compressor and processing facilities and all related equipment.

Weneed

hear/have heard from industry about all the jobs they provide and in today’s economy, we

of our

all the jobs we can get. But how much is

a job worth? Is

a job worth sacrificing the health children? Are these our choices then—jobs or health?

On EPA’s Natural Gas STAR Program website you list nearly 100 different proven, cost- effective

reduce methane

industry-developed technologies and practices that improve operational efficiency and

Yet,

emissions. Methane is

a surrogate gas that carries toxic compounds with it. from all those technologies, EPA has chosen only 5 for these new rules.

make

If this industry

a profit, then

can’t employ its own technologies to protect public health AND provide jobs AND they need

a new business model.

Stop coddling this industry. Help them step into the 21st requiring century and operate more efficiently by

production

all the best available technologies for all emissions sources at all stages of and processing.

their

Argyle

air

and

before

Bartonville citizens organized to conduct baseline” testing to measure the quality of large-scale gas development the 84 air took hold. Baseline testing, detected only seven of

gas facilities

contaminants

moved

typically tested for by TCEQ. As drilling, fracking and additional oil and

from

into the area, TCEQ testing

— on the high school band practice lot /2 mile

TCEQ.

the offending facility— detected 65 of the 84 air contaminants usually tested for by the

As

chemicals

scientists, can you tell us what are the increased risks when children go from breathing 7 to breathing

a cocktail of 65 different chemicals?
are

loophole in the Clean Air Act so that oil and gas emissions aggregated.

sources,

We support the draft rules as a first step and request that you go further to include existing employ all available technologies, emissions. include all emission sources and aggregate

Thank you for being here.
descended on our community of over 2,000 homes without warning in June

2010 even though our Westchester Association of Homeowners had

decided that we would not (as a group) sign a lease back in 2007.

In the meantime, one site — the Corn Valley A (there’s a B, too) Pad Site,850 feet from the Joe Pool Lake Dam, and 537 feet from homeowners, had

been permitted by the Texas Railroad Commission in 2009 and our city was

ready to permit it. We held a community-wide meeting on July 19, 2010,

attended by more than 500 Westchester neighbors, thinking that we might

stop it. But even with so many opposed to all of it, our City permifted

this pad site the very next day.

Soon, we realized that there had NEVER been any public discussion aboutany of it and that this was because we had no SUP for Gas Drilling.

Meaning: With few exceptions, all gas drilling permits submitted through

the Texas Railroad Commission were being approved “administratively,”

by the Grand Prairie, TX Environmental Services Dept.

After attending Planning and Zoning Commission Meetings, wediscovered that this Commission knew less than we did about shale gas drilling. And they had never had any presentations about any of it.

It didn’t take long to realize we were in serious trouble. Through meetings and a lot of hard work we realized that our city’s Gas Drilling Ordinance was basically an open door for gas drilling in our

neighborhoods. Then we got to work.

Page 1 of 3
(Pause) Then Chesapeake began their Campaign.

That Campaign included a Public Meeting held on December 7th, 2010 that

requested all those “Lessors” the landowners who had signed leases with

them Chesapeake wanted everyone to go to City Hall and protest this

Moratorium and the 1,000 setback that might be part of a Revised and New

Ordinance.

To see a Corporation telling a community to come together and go against

protective actions that our Community Group had worked so hard to make

happen. . .well, it was unbelievable to see this. They even told this large

gathering of well over 700 or 800 people stuffed into a community building

that they could invoke “Force Majeure,” if necessary and if the City kept

this Moratorium in place very long. They mentioned that we probably didn’t

even know what that teas.. .but they would explain it to us.When one of our group yelled out from the Center of the room, “What

about the Process,” the response back was,

“Oh, we’re not going to address the process tonight. And we won’t be

taking am, guestions, either.”

One young man came up to me after this meeting trying to convince me

and others that there wasn’t anything wrong with hydraulic fracturing.

Page 2of3
the Moratorium only 2 months later.. .it was to have been a 6-monthMoratorium, but pressure from the industry was too great for our City.

What we have here are HUGE GAPS in the regulation of the very

dangerous shale gas drilling industry. Our communities are under siege

by these people physically, psychologically and economically.After seeing that our city and state are firmly in the grip of the O&G

Industry, our community group, the Westchester-Grand PrairieCommunity Alliance has come to the conclusion that the EPA is our last

hope for change.

We thought that the very name of the oil and gas regulation agency (TheTexas Railroad Commission) would finally get a new name in this last

legislative session. . . and our state legislature could not even get thatchanged. This is unbelievable in America.

People are suffering. And will suffer more and more in the very near

future unless we can STOP this industry’s rampage. More shale gas

drilling infrastructure is going in as we sit here tonight. They do all their

work ahead of time and by the time they ask for the rubber stamp from thestate regulators. . .it’s a Done Deal.

We will do whatever we can, as a group and as a community, to support the efforts of the EPA to gain regulation of this industry. It’s a matter of

life and death. And we need help NOW. Thank you.

Page 3of3
ARE EXACERBATING MY RESPIRATORY AFFLICTION.

SO OFTEN I HAVE SPOKEN HERE AND PLEADED FOR CLEAN AIR

TO BREATHE AND CLEAN WATER TO DRINK. BOTH ARE

NECESSITIES OF LIFE. NONE OF US CAN LIVE WITHOUT THEM -

NOT GLOBAL WARMING DENIERS, NOT EVEN OFFICIALS OF OIL

AND GAS COMPANIES.

I AM STAGGERED THAT FRACKING IS ALLOWED. JOSH FOX, THE

DIRECTOR OF THE MOVIE GASLAND, SAYS THAT 596 DIFFERENT

CHEMICALS ARE USED IN THE FRACKING PROCESS AND THAT

THE GAS INDUSTRY IS EXEMPT FROM REVEALING THEIR NAMES,

BECAUSE THE INFORMATION IS PROPRIETARY.

EMISSIONS FROM LEAKS ARE FEARFULLY POISONOUS, ANDLEAKS ARE KNOWN TO OCCUR.

HUMAN HEALTH SHOULD BE CONSIDERED THE FOREMOST

PRIORITY. THEIR RIGHTS END WHERE MY AIR SPACE BEGINS!HOW SAD IT IS THAT THEIR PROFIT MOTIVE IS SO HIGH THAT

THEY ARE WILLING TO JEOPARDIZE THE HEALTH OF HUMAN

BEINGS AND ESPECIALLY CHILDREN, TO COMPOUND THE

PROBLEMS OF RESPIRATORY DISEASES, TO CAUSE HIGH RATES

OF CANCER IN COMMUNITIES LOCATED NEAR GAS PIPELINES.

AND THEY ARE SO CALLOUS ABOUT THE POSSIBILITY OF

POISONING OUR PRECIOUS WATER SOURCES.

THE AMERICAN LUNG ASSOCIATION, WHICH OBTAINS ITS DATA

FROM THE EPA’S AIR QUALITY SYSTEM DATABASE,

CONSISTENTLY RATES TEXAS WITH A GRADE OF E FOR FAILURE.
OWING 

SK 

MPLICATIONS

FOR OUR AREA, DUE TO THE HIGH OZONE AND CHEMICAL ANDPARTICULATE POLLUTANTS IN OUR AIR:

• PEDIATRIC ASTHMA -- 56,000

• ADULT ASTHMA— 113,000

• CHRONIC BRONCHITIS-71,000

• CARDIOVASCULAR DISEASE — 566,000

• 211,000 ADULTS ARE AT RISK

• 690,000 CHILDREN UNDER 18 ARE AT RISK

WHEN THESE NUMBERS TRANSLATE TO HUMAN BEINGS, THE

EFFECT IS STAGGERING.

NO PROFIT, NO CORPORATE GREED, IS WORTH THESE

COLOSSAL RISKS TO LIFE ITSELF.

THE SIERRA CLUB REPORTS THAT, IN DALLAS/FORT WORTH,

POLLUTION FROM OIL AND GAS FIELDS IS WORSE THAN THE

EXHAUST OF ALL THE CARS IN SOME OF OUR BIGGEST CITIES.

REDUCING OIL AND GAS POLLUTION WILL PROTECT OUR

COMMUNITIES, CREATE JOBS, AND WILL OFTEN PAY FOR ITSELF

AS COMPANIES STOP LEAKS AND KEEP NATURAL GAS IN THE

PIPELINE AND OUT OF OUR AIR.

IT FURTHER SAYS: EACH NEW OIL OR GAS WELL CONTRIBUTES

TO THE MILLIONS OF TONS OF HARMFUL POLLUTANTS SPEWED

INTO THE AIR FROM THIS INDUSTRY AND THAT THE DIRTY OIL

AND GAS INDUSTRY IS THE SECOND LARGEST STATIONARY

SOURCE OF GLOBAL WARMING POLLUTION IN THE U. S. EVEN

WORSE, EVERY YEAR THE INDUSTRY EMITS MORE THAN 300

MILLION TONS OF POLLUTANTS, LIKE METHANE AND SULFUR

DIOXIDE.
IS OUR ONLY HOME.

I WHOLEHEARTEDLY SUPPORT THE EPA IN REGULATING THESEINDUSTRIES. REGULATIONS MUST BE IMMEDIATE, STRINGENT

AND STRICTLY ENFORCED.

EPA, WE NEED YOU. THIS PLANET EARTH NEEDS YOU. AND MYBRONCHITIS AND I NEED YOU. THANK YOU.

SUSAN TURITZ COOPER

1116 GREENCOVE LANE

RICHARDSON TX 75081-3715

972 238-8653susanjack@juno.com
the Texas Independent Producers and Royalty Owners Association, also known as TIPRO. TIPRO has over 2,300 members, including small family-owned companies, the largest publicly traded independents, and large and small mineral estates and trusts.

Let me first state, TIPRO and its member companies are in favor of clean air. People in the oil and gas industry live and work around

their facilities, and they want to protect the air their families

breathe just as much or more than the EPA does. But new

regulations, particularly in the current economy, must be reasonable and based on sound science.

Oil and gas producers operate like any other business. All businessowners will tell you that, when all is said and done, they are in business to turn

a profit. Profitability allows businesses to reinvest

capital to grow their business, retain and reward their currentemployees, and hire new employees to grow their workforce. There

are approximately 5,000 oil and gas well operators in Texas, many of them small independents with limited capital resources. These

operators work hard at maintaining

a positive bottom line, and that

includes examining and implementing every possible scenario by which they may invest in new technology, equipment, or strategies to improve profitability. Green completions are

a strategy recommended by EPA and often evaluated by operators. The EPA is

correct; it makes economic sense to perform these types of completions where possible because it results in greater quantities of saleable product. For this reason, many operators will opt for

green completions when circumstances permit; however,

a lack of

readily available gathering lines often prohibits them from performing one, and the alternative practice of flaring is often

1
TIPRO is in favor of clean air, but we believe that one 

does 

fit all with regard to which wells should have green completions

performed on them and the practice should continue to beencouraged, but not mandated.

Secondly, EPA’s residual risk review found that the current

maximum individual cancer risk from oil and natural gasproduction is 40 in 1 million, which falls within a range EPA

considers acceptable. The agency’s residual risk review of air toxics

standards for natural gas transmission and storage is 90 in 1million, also a level which the EPA finds acceptable. The dictionary

defines the word acceptable as “able to be agreed on; suitable;

adequate; satisfactory; pleasing; welcome.” If the risk as it exists

today is acceptable, then why pass regulations that will needlessly

harm businesses and jobs? TIPRO believes that a primary reason

standards are reviewed periodically is so that agencies need not try

to regulate based on every scenario they can imagine. When the

average American leaves for work, they know that any number of

scenarios could happen that may cause them harm. A meteor could

fall from the sky; they might be attacked by animals escaped from

the zoo; it is possible that they will be struck by lightning. But themere existence of these possibilities is not sufficient reason to stay

home from work. Instead, people take action to reduce risk to

acceptable levels. They look both ways before crossing the street;

they put on seatbelts; they hold tightly to the strap on the subway.

Regulation should be based on actual facts and evidence, not

theories or projections. If current evidence shows that risk from oil

and gas is acceptable, then no additional regulation should be

required until the next review period. Regulation for regulation’s

2
than good; TIPRO urges the EPA to not present solutions to

problems that do not currently exist.

Finally, this proposed rule package is extremely complicated and

will require very extensive technical and economic review in order

for stakeholders to properly address the operational and cost

consequences that will arise as a result of the rulemaking. Many

TIPRO members are small businesses that do not have in-house

staff with the proper knowledge or expertise to conduct such a

comprehensive review. The very short 60-day timeframe for review

and comment, even with the pre-publication version of the rule

available, will pose a significant hardship to TIPRO members.

EPA’s proposed timeline, with a final action date mandated by

February 2012, will not allow for TIPRO members to prepare to

implement the rules, and could therefore place TIPRO members in

the untenable position of operating out of compliance, as well as

causing economic hardship because these businesses will not have

had the opportunity to prepare to incorporate the costs of the rule

requirements into their operating budgets.

The Railroad Commission of Texas (RRC) has unparalleled

knowledge of the oil and gas industry. The Texas Commission on

Environmental Quality (TCEQ) has successfully reduced harmful

emissions at a greater rate than any other state in the country.

Together, these agencies continue to ensure compliance and provide

proper oversight based on verifiable science and, although the EPA

is well intentioned, TIPRO believes that regulation of oil and gas

operations in Texas should reside at the state level. However, if this

rule package is going to continue to move forward regardless of that

3
extension to the comment period scheduled to end on October 31,

2011, as well as an extension of the final action date by six months,

in order to allow stakeholders the opportunity to properly reviewand comment on this very significant rule package, as well as to

make plans for its implementation.

Thank you for the opportunity to address you today, TIPRO intends

to submit more detailed written comments on the specifics of the

proposed rule before the comment deadline.

4
EPA TESTIMONY — SEPTEMBER 29,

2011

nia Simonson, virginia.simonson@us.army.mil

Bottom Line Upfront

Fully Support New Source

Performance Standards

And Air Toxics Standards!

1
W 

a 

serious

nonattainment area for ozone

VOCs contribute to ozone formation

• High levels of ozone and VOCs adversely impact

human health

• Consistent standards of protection are needed — Different rules in different states — Different rules within states in different cities

TCEQ Daily Air Quality Force-casts

Ozone Levels

• Daily Emails

— Sep 28, 2011 — Unhealthy for Sensitive Groups — Sep 27, 2011 - Unhealthy for Sensitive Groups — Sep 26, 2011 — Moderate or possibly higher levels — Sep 25, 2011 — Moderate or possibly higher levels — Sep 24, 2011 — Unhealthy for Sensitive Groups — Sep 23, 2011 — Unhealthy for Sensitive Groups

2
Houston

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V

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o 100 ODes

.I. • .1

1II.-2 I3IZ

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PeakAQI-Sep2l,2011

rCombined AQI

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ppI’1i Norman - Memphis

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1 - .

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las Jackson

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Austin

Houson •3._

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0 II 100 01

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y

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Forect /

It y, Seç*embqr 29, 2011

Daily Peak AQI — Sep 28, 2011

ned PMd

4
—FM Gas Wells Permit Status

TCEQ Monitor

5
r

1I I V_____1

34!

._______________

y 

y 

The January (2011) ambient air observations are not

indicative of significant releases or fugitive emissions from

the nearby natural gas activities in and/or surrounding

Flower Mound.”

• This conclusion is included in the Town’s Proposed Oil & Gas

Ordinance

• Supports the questionable conclusion that current air quality

doesn’t require any vapor recovery or emission controls forexisting fracking and compression operations

Benzene Levels (ppb)

Monthly Highs in Metroplex

hill

FloMo Highest

Benzene Reading in

Metroplex (xc, far)

In 2011 (8.63 ppb

On lan 29, 2011,

Wind at 183 deg) r—._. j 1/>

I1

FloMoODish•FtW

• Eagle Mt.

LI Decatur

LJjft

•Dallas

Nov Dec Jan Feb Mar

Effects Screen:ng Levels are chemical-specific air concentrations set to protect human health and welfare.

Rnncene Long Term E5L 1.4 ppb

6
E of HWY 377 Clear Creek FM 2499

1CS 5C5 13C5

Carbon - 14 18 9.6

Disulfide

(ST ESL 10)Carbonyl 44 74 17

Sulfide

(STESL55)

Wind was blowing from CCF to 5 Cs ->1 mile away

Conclusions

• Our cities and our state do not place a high priority

on clean air, clean water or citizen’s health

• Air Testing can be manipulated so that the actual

levels of VOCs inhaled by residents is never really

known

• The EPA needs to do what the state and our cities

have failed to do

Pass the New Source

Performance Standards

And Air Toxics Standards Now!

7
EPA TESTIMONY — SEPTEMBER 29,

2011

Virginia Simonson, virginia.simonson@us.army.mil

Good Afternoon, My name is Virginia Simonson. I reside in Flower Mound, Texas. I

became involved with efforts to promote responsible drilling about 2 years ago as gas

drilling activities significantly expanded near my area.

As a career Army Officer, I have always worked through “the system’ whatever that

system may have been. As an activist, I have continued to work through the

established systems. In 2010, I helped lead a citizen referendum drive that led to a

temporary moratorium on new drilling permits and the appointment of an O&GAdvisory Board that developed recommendations to improve our city ordinances

related to gas drilling activities. I have also spent significant amounts of time directlylobbying my city, state and federal representatives pushing for more responsible

drilling regulations and advocating for the rights of surface owners.

I could speak all day on the roadblocks to justice I, and other activists, faced & still

face every day, trying to get our local and state reps to do the right thing... Trying toget them to take adequate steps to protect our air, our water and our health. It has

become painfully apparent to me that our state and local representatives just do nothave the where with all to take the necessary steps. And that is why I have asked to

--

,.—
Fully Support New Sc rce

Performance Standards

And Air Toxics Standards!

This is about as clear as I can be. When the state and municipal governments fail to

protect their citizens, it is incumbent upon the Federal Government to step in.

2
• VOCs contribute to ozone formation

• High levels of ozone and VOCs adversely impact

human health

• Consistent standards of protection are needed — Different rules in different states — Different rules within states in different cities

I have become jaded and tone-deaf to cries for states rights. To me, states rights in

Texas means the sanctioned elevation of corporate rights over my individual rights to

breathe clean air, drink clean water and be relatively protected from toxic chemicals.

The Clean Air Act, The Clean Water Act, the Super-Fund Clean-Up Act and the Civil

Rights Act all illustrate how the federal government has had to step in when cities

and states failed to protect their citizens.

We are at the point now where it is clear that the O&G industry has become such an

overwhelming force in Texas, that we need the EPA to dictate improvements for O&G

drilling, production, storage & transmission activities.

3
— Sep 28, 2011 — Unhealthy for Sensitive Groups — Sep 27, 2011 - Unhealthy for Sensitive Groups

— Sep 26, 2011 — Moderate or possibly higher levels — Sep 25, 2011 — Moderate or possibly higher levels — Sep 24, 2011 — Unhealthy for Sensitive Groups — Sep 23, 2011 — Unhealthy for Sensitive Groups

I subscribe to the TCEQ Air Quality notification system. Everyday, I get emails telling

me what type of ozone levels we will face. These are a few from the last week.

When you receive these emails on a regular basis, you understand why asthma rates

have soared in our area over the last decade.

4
And when you look at the daily maps provided by the EPA and TCEQ on Air Quality,

you are reminded of the relationship between air quality & gas drilling activities.

0 .00 0: — :l-:8-:5

5
o eoo O;

201t 6.39.28Z

6
?23 t7

7
8
Don’t the residents of the DFW non-attainment area deserve a shot at better air

quality?

9
Before I close, I want to show a few quick slides to illustrate how gas drilling impacts

me locally in Flower Mound, Texas. These slides are indicative of residents experiencein other cities, most notably Ft. Worth.

All of the white circles represent gas pads, which can have from 1-20 wells on them).

Flower Mound is lucky to have a TCEQ Air Monitor which is depicted by the blue

cloud in the middle of the map. The blue insert is a depiction of historical wind

patterns in our area which predominate from the South.

10
The January (2011) ambient air observations are not

indicative of significant releases or fugitive emissions from

the nearby natural gas activities in and/or surrounding

Flower Mound.”

• This conclusion is included in the Town’s Proposed Oil & Gas

Ordinance

• Supports the questionable conclusion that current air quality

doesn’t require any vapor recovery or emission controls for

existing fracking and compression operations

Based on city ordered air testing and selected TCEQ air monitor readings, the Town

of Flower Mound concluded that we have no issues related to gas drilling operations.

The city feels so strongly that we have no air quality issues related to gas drilling that

they put that so-called fact in our brand new O&G ordinance.

11
And yet, even within the limitations of ambient air monitoring, we still experienced

high levels of hazardous VOCs. Note here, the benzene reading 8.63 ppb in ian 2011.

riii

EJDish

Ft.W• Eagle Mt.

Decatur

Dallas

Nov Dec Jan Feb Mar

Effects Screenng ese;s ae chemcal-specific air concentrators set to protect heman health and welfare.

Berzene Long rerm ESL 1.4 ppb

12
M 2499

Also note the high levels of carbon disulfide and carbonyl suflide in the same month.

‘Cs

Carbon 14Disulfide

(ST ESL 10)

5CS

18

13 CS

9.6

Ca rbonyl

Sulfide

(ST ESI 55)

17

Wind was blowing from CCF to 5 CS - >1 mile away

13
on clean air, clean water or citizen

s health

• Air Testing can be manipulated so that the actual

levels of VOCs inhaled by residents is never reallyknown

• The EPA needs to do what the state and our cities

have failed to do

Pass the New Source

Performance Standards

And Air Toxics Standards Now!

14