jim Ashford 

<jimashford@sbcglobal.ne

t>

09/01/2010 08:49 PM

To Kim & Ken Feil <kimfeil@sbcglobal.net>

cc "Anne Inman" <ainman@tceq.state.tx.us>, "Annette Maxwell" 

<AMaxwell@tceq.state.tx.us>, CCG-ONG@EPA, David 

Bary/R6/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA, 

Jeannine Hale/R6/USEPA/US@EPA, Edward 

Hanlon/DC/USEPA/US@EPA, <hqpublicaffairs@usace.army.mil>, <info@northtexasair.org>, 

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

<michael.o'quinn@rrc.state.tx.us>, Nick 

Parsons/RTP/USEPA/US@EPA, "Sid Slocum" 

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

<TWALKER@tceq.state.tx.us>, <bshaw@tceq.state.tx.us>, 

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

Taylor" <ATAYLOR@tceq.state.tx.us>, 

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

<dnesvaci@tceq.state.tx.us>, <kcauble@tceq.state.tx.us>, 

eyesondrilling@EPA, Timothy Herfel/R6/USEPA/US@EPA, 

<jwessel@tceq.state.tx.us>, "Winona Henry" 

<WHENRY@tceq.state.tx.us>

Subj

ect

Re: Clarification on Ft Worth evaporation station-no scrubbers 

needed

The drilling companies and the ones they are associated with should not be trusted about 

anything, and I don't. How many times are we told one thing and then when it comes time for it 

to be demonstrated, it isn't quite the way we understood it was going to be. It is amazing that 

everything that has asked about has been explained, "in the the Barnett Shale, it isn't here." I say 

bull to that, of course it is. There may be more in some places and less in others, but it is still 

here.

It is important to be aware of different sources that may have an impact on the 

atmosphere. 

For example, the proposed Salt Water Recycle facility in East Fort Worth is where 

the produced water from numerous wells is to be evaporated into the air using the 

heat Generated from many Natural Gas Powered Compressor engines.

Even though they call it recycling of produced water, it is not a recycling facility 

where the produced water is recycled or reused.

How much water is recycled? The answer is -0-. There is nothing being reused.
it is simply a way to cheaply dispose of a lot of produced water for the owner 

Chesapeake, 

by putting water vapor and many other chemicals into the air we breath.

The evaporating process simply does not remove an adequate amount of harmful 

contaminates from the produced water being evaporated, to be harmless or safe. 

Chesapeake estimates that 50,400 gallons of water is to be evaporated into the air 

everyday from the site. 

This will increase the humidity in the nearby parks and residential areas, promoting 

disease carrying insects and mold along with discomfort for residents. 

There are other methods for truly recycling and reusing 80% or more of the water. 

These methods are much more environmentally friendly without the massive 

pollution. 

Some gas drilling companies are already using this process. 

The use of electric motors to power all of the compressor stations in Fort Worth to 

help reduce emissions should be required.

During the recent gas drilling task force meetings, the industry acknowledged the 

use of electric powered compressors would produce fewer emissions than gas 

powered compressors. 

The industry would however prefer to use unprocessed natural gas directly from 

the wells to run their compressors. It is cheaper for them. 

the unprocessed natural gas, when burned as a fuel, like in a gas engine for the 

compressors, will include many harmful chemicals which go directly into the air as 

exhaust. 

They do not use the refined natural gas that is advertised as clean burning. 

The gas from the wells is only filtered enough to protect the gas motor from 

physical damage.

Since the heat required for this proposed recycling process is being generated from 

the compressors for evaporation, there is no incentive to use electric powered 

compressors by the industry, in fact just the opposite. 
There will be more need for heat to be generated and therefore more emissions in 

the air. 

One recent example to illustrate the industries lack of concern about emissions is 

the "parrot" Natural Gas compressor station located near my house in East Fort 

Worth that was powered by two electric motors.

When the compressors were enclosed to reduce excessive noise to the nearby 

neighborhood, the two electric motors were replaced with three compressors that 

now use gas-powered engines. 

That doesn’t seem like an industry trying to reduce emissions in the city. 

The gas drilling industry will do what it is required to do, 

but it has been demonstrated over and over, they will not do more than is required 

of them.

It is important the health and quality of life for the residents in Fort Worth be 

regained.

Jim Ashford

On Sep 1, 2010, at 2:55 PM, Kim & Ken Feil wrote:

OK who can help and "reply all" to the others so that you do not duplicate efforts? First one to 

respond gets kudo's !!!!

Air tests needs on the Arc Park/Brentwood compressor evaporation station for produced water.

Stick that canister right there too!

THANKS

----- Original Message -----

From: Kim & Ken Feil

Sent: Wednesday, September 01, 2010 2:51 PM

Subject: Clarification on Ft Worth evaporation station-no scrubbers needed

Mr Harris of Intevras was able to clarify that the air stripper/scrubbers he described to me in the 

Evras evaporators are available when needed like in California, but that they are not needed and 

are not being used here at the Ft Worth Chesapeake Brentwood/arc park site because of the low 
hydrocarbons associated with the Barnett Shale. Also the air is not blended (as I reported earlier 

in this email string) unless it comes from the scrubber.

He also mentioned that unconventional shale gas has less VOC concentrations than the standard 

oil and gas reservoirs and that the Barnett is not heavy in metals. 

He said that 50-60 ppm is what the Barnett Shale VOC has been although he's seen an average

of 30 ppm and also he sees areas that have little to no hydrocarbons in the produced water. 

He said that radon is not a problem here compared to the North East areas of the Marcellus. Mr 

Harris didn't elaborate if there was any detriment to the air in incinerating arsenic, the 

conversation was limited to that arsenic occurs naturally.

In California, they did air testing on his units (with scrubbers) and found no problems when 

comparing baseline air tests to the incineration of hydrocarbons when that (scrubbed) air was run 

to the engines which was used as fuel for the engine as it is burned off. 

We should get TCEQ to measure the air coming from the EVRAS engines before and during the 

air flow to be combusted.

I am still unclear if the flowback water that contains fracturing fluids go to the EVRAS incinerator, 

so an air test when evaporating flowback water is also in order.

If our air tests prove no detriment to our air, surely this system is to be promoted as a best 

available technology to take the truck fracing traffic off our highways and get us into Clean Air 

federal compliance.

I copied Mr Harris so that if he needs to further clarify, he can "reply all" and add comments.

Thanks for your attention to this matter.

Kim Feil

----- Original Message -----

From: Boerner, Brian

To: 'Kim & Ken Feil'

Sent: Tuesday, August 24, 2010 4:14 PM

Subject: RE: Vaporization of produced water at Brentwood compressor station in Ft 

Worth to greatly reduce truck traffic to injection well sites

Titan’s study did not include a test for NORM (naturally occurring radioactive material). Norm 

has not been historically encountered in drilling this part of the Barnett Shale. The only areas 

that I am aware of where NORM has been detected is far north Denton and Wise counties 

Also, the first Evras unit was put online in June 2009. While they have been put online and 

taken off line over the past year (to allow for equipment upgrades and system maintenance), it is 

my understanding that at least one unit was online during the TCEQ test. I do not know if the 

unit was online the day of Titan’s sampling.

Brian K. Boerner, CPM, CHMM

Director of Environmental Management
From: Kim & Ken Feil [mailto:kimfeil@sbcglobal.net] 

Sent: Tuesday, August 24, 2010 4:06 PM

To: Boerner, Brian

Subject: Re: Vaporization of produced water at Brentwood compressor station in Ft Worth to 

greatly reduce truck traffic to injection well sites

I noticed the Titan air study at this site did not include radionuclides...can you comment on if the 

Ft Worth air study will test for radon?

Also, was the Evras unit on line at the time of the Titan air study in June? I do not know how 

long this system has been in place.

Thanks

Kim

----- Original Message -----

From: Boerner, Brian

To: 'Kim & Ken Feil'

Sent: Tuesday, August 24, 2010 3:28 PM

Subject: RE: Vaporization of produced water at Brentwood compressor station in Ft Worth to 

greatly reduce truck traffic to injection well sites

Ms. Feil:

I would urge you to revisit the Itevras Website http://www.intevras.com/. The operations I 

described are consistent with the operations of this piece of equipment and the program that 

Chesapeake is operating at the site. 

Regarding the response from the Chemical engineer, I do not know the source of their 

information so I can not respond as to their opinion. My conclusions are based on the qualified 

testing which has been completed around the site. Additionally, the City of Fort Worth’s air 

quality study will continue to evaluate potential emissions from this site.

Brian K. Boerner, CPM, CHMM

Director of Environmental Management

From: Kim & Ken Feil [mailto:kimfeil@sbcglobal.net] 

Sent: Tuesday, August 24, 2010 3:18 PM

To: Boerner, Brian

Subject: Re: Vaporization of produced water at Brentwood compressor station in Ft Worth to 

greatly reduce truck traffic to injection well sites

I had a similar response from a chemical engineer doubting that the toxins are not being 

scrubbed before incinerated. Burning toxic waste went on for decades at our cement factories 

south of us...how is this any different? Why is your explanation different from what I thought I 

heard from a phone convesation with the inventor?

Kim

----- Original Message -----

From: jim Ashford

To: Kim & Ken Feil ; eyesondrilling@epa.gov ; NFWMLTF Task Force ; 

nctca@googlegroups.com
Cc: Undisclosed-Recipient:;@smtp108.sbc.mail.mud.yahoo.com;; ; Tony Rutigliano ; 

info@crzo.net ; Andy.Agosto@crzo.net ; Elizabeth Gasca ; doug_agee@xtoenergy.com ; 

chris.sanders@yahoo.com

Sent: Tuesday, August 24, 2010 8:23 AM

Subject: Re: Vaporization of produced water at Brentwood compressor station in Ft Worth to 

greatly reduce truck traffic to injection well sites

I hope you aren't buying this nonsense. It does't happen that way when evaporating 

50,400 gallons of water every day. It physically won't be done. 

The hydrocarbons still go in the air, the compressors still burn the gas from the ground 

that contains radium, mercury, lead along with the other hydrocarbons that go into the 

air as exhaust.

Jim

On Aug 23, 2010, at 11:24 PM, Kim & Ken Feil wrote:

vaporization of produced water at Brentwood 

compressor station in Ft Worth to greatly reduce 

truck traffic emissons in delivering to injection well 

sites

http://www.fortworthgov.org/uploadedFiles/City_Secretary/City_Council/Official_Documents/20

10_Ordinances/19234-07-2010.pdf

"WHEREAS, the City is continuing its participation in the pilot program 

with

Chesapeake Operating Company, Chesapeake has now acquired all but two tracts needed for the

Right-of-way for the salt water pipelines, and will be installing the recycling equipment in the

near future. In order to provide staff additional time to evaluate the operations of the salt water

pipelines and the recycling efforts, an extension to July 31, 2011, is advised; and

WHEREAS, adoption of this Ordinance would extend the moratorium 

from July 31,

2010, until July 31, 2011, and maintain the status quo while the staff continues the pilot program

with Chesapeake at the Brentwood site located on East First Street next to the old Arc Park; and
WHEREAS, at the direction of the Mayor and City Council, staff is 

working with the

community to identify a contractor to perform testing to accurately assess the source, area, and

ambient air quality impacts of gas operations within the City of Fort Worth. As part of this

assessment, disposal and recycling operations will be examined. The Brentwood site is currently

the only operational saltwater disposal and recycling site within the City of Fort Worth. By

extending the moratorium, operations will be allowed to continue so that appropriate data can be

collected to determine the impacts from this site and a fact based decision may be made as to

whether the moratorium should be lifted or a complete disposal ban should be enacted within the

City limits of Fort Worth;..."

The recycling of produced water will be a pilot program for Ft Worth using the EVRAS (by 

Intervas) system at the Brentwood compressor station. I heard that site will begin receiving 

produced water from 30 different gas well sites for "safe" vaporization. The remaining, 

crystallized solid waste will then be trucked to an injection site.

http://www.intevras.com/downloads/Evras/technical/EVRAS_-_ADA_White_Paper.pdf

Please go to flow chart and see that the "Humid Air Outlet" does not have a filter or a vapor 

recovery system. In calling the inventor of the process, Jeff Harris (who lived in Granbury at 

one time, and has experience with this system in California), explained that the Barnett shale 

VOC averages 30 ppm and has no barium. This is low in comparison to the Marcellus Shale 

(which is full of barium) and averages 500ppm of VOC's. So we are at an advantage starting 

with low voc's. I do not know if the ppm being quoted includes the fracing fluid flow back 

chemical vapors. 

In taking notes while talking to Mr Harris, the EVRAS system solidifies cold, produced water 

when it is warmed up by the introduction of an unmixable "heat transfer liquid" (HTL). The HTL 

is warmed by the wasted heat from the existing compressor station at the Brentwood site in Ft 

Worth. The cold, produced water keeps getting recycled from cold to hot to cold until it 

crystallizes.

The air flow directs the aromatic/pollution/condensate through a thermal reactor air stripper 

which scrubs the hydrocarbons when it passes through an air column. The extracted VOC's 

are then blended with the combustion air at a ratio of 100 parts of air to 1part of hydrocarbon 

condensate. This reduces our original 30ppm down to .03 ppm. This .03ppm is then burned off 

in the compressor engines that have more efficient catalytic converters than our cars. The 

crank case captures exhausts like a carburetor functions. The Nox and Co is burned up in the 

catalytic engines. The 99.9% clean is better for the environment than the 100lb of Nox and 32 

tons of carbons per year due to onroad trucking emissions in delivering produced fluids to an 

injection site. 

Ideally, piping the produced water from drill sites to the EVRAS systems would further 

decrease onroad trucking emissions in bringing the fluid to the evaporation site. 

I'm a little squirrelly when it comes to pipelines carrying toxic water and having any kind of 

ground water leak, but trucks carrying waste water are risky and those trucks aren't even 
labeled as toxic, hazardous material. The amount of matter going into injection sites would 

greatly be reduced to the crystallized sludge.

We could use some good news of natural gas extraction having a process improvement that 

others could follow if this is truely more environmental friendly.

I sent Mr Harris a copy of this email so that he can correct any mis interpretations of his verbal 

explanation to me over the phone...so more than likely I may have some corrections to this 

explanation of how the EVRAS is "safely" evaporating produced water for 30 pad sites here 

within city limits.

Please send comments or corrections to this email, thank-you.

Kim Feil

http://www.youtube.com/watch?v=e-4R4cfaspw

music vid "Can't You See It's Acid Raining" dedicated to City Council and Mayor Cluck

http://www.wfaa.com/news/local/New-well-linked-to-new-smell-in-Wise-County101232229.html Ten times the benzene level for ambient readings/Wise county.

With one inspector per every 3,300 wells in TX, how do we prevent this in Arlington?

We also need to test the air for formaldehyde-TCEQ doesn't.

http://www.crosstimbersgazette.com:80/local-news/988-drilling-fluid-spill-reported-in-flowermound.html

Drilling fluid spill reported in Flower Mound - This is the third spill for Williams in the area this year.

http://www.2theadvocate.com/news/101206889.html "The well, in a relatively isolated sugar cane field 

north of La. 70 and northwest of Paincourtville, has prompted odor complaints and at least two lawsuits over air 

emissions and other allegations. State Police have also restricted access within a mile of the blowout."

----- Forwarded by Greg Nizich/RTP/USEPA/US on 08/23/2011 07:59 AM -----
jim Ashford 

<jimashford@sbcglobal.ne

t>

09/01/2010 09:07 PM

To jim Ashford <jimashford@sbcglobal.net>

cc Kim & Ken Feil <kimfeil@sbcglobal.net>, "Anne Inman" 

<ainman@tceq.state.tx.us>, "Annette Maxwell" 

<AMaxwell@tceq.state.tx.us>, CCG-ONG@EPA, David 

Bary/R6/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA, 

Jeannine Hale/R6/USEPA/US@EPA, Edward 

Hanlon/DC/USEPA/US@EPA, <hqpublicaffairs@usace.army.mil>, <info@northtexasair.org>, 

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

<michael.o'quinn@rrc.state.tx.us>, Nick 

Parsons/RTP/USEPA/US@EPA, "Sid Slocum" 

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

<TWALKER@tceq.state.tx.us>, <bshaw@tceq.state.tx.us>, 

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

Taylor" <ATAYLOR@tceq.state.tx.us>, 

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

<dnesvaci@tceq.state.tx.us>, <kcauble@tceq.state.tx.us>, 

eyesondrilling@EPA, Timothy Herfel/R6/USEPA/US@EPA, 

<jwessel@tceq.state.tx.us>, "Winona Henry" 

<WHENRY@tceq.state.tx.us>

Subj

ect

Re: Clarification on Ft Worth evaporation station-no scrubbers 

needed

The Future of Water Recycling.webarchive 

Why is it that Chesapeake is always the company that always wants to do what is the cheapest 

for them with little regard for the nearby residents. There are companies that are trying to do 

some things right, even if it costs a little more. That isn't Chesapeake, even though they are the 

ones disrupting the residents of Fort Worth the most.

I have attached an article that was published last year about getting rid of produced water. Why 

can't or won't chesapeake be required to do than better than industry standard, since they tend to 

be the standard around here? That is best described by saying "quick and dirty".

Jim AShford

On Sep 1, 2010, at 7:49 PM, jim Ashford wrote:

The drilling companies and the ones they are associated with should not be trusted about 

anything, and I don't. How many times are we told one thing and then when it comes 

time for it to be demonstrated, it isn't quite the way we understood it was going to be. It 
is amazing that everything that has asked about has been explained, "in the the Barnett 

Shale, it isn't here." I say bull to that, of course it is. There may be more in some places 

and less in others, but it is still here.

It is important to be aware of different sources that may have an impact on 

the atmosphere. 

For example, the proposed Salt Water Recycle facility in East Fort Worth is 

where the produced water from numerous wells is to be evaporated into the 

air using the heat Generated from many Natural Gas Powered Compressor 

engines.

Even though they call it recycling of produced water, it is not a recycling 

facility where the produced water is recycled or reused.

How much water is recycled? The answer is -0-. There is nothing being 

reused.

it is simply a way to cheaply dispose of a lot of produced water for the 

owner Chesapeake, 

by putting water vapor and many other chemicals into the air we breathe 

The evaporating process simply does not remove an adequate amount of 

harmful contaminates from the produced water being evaporated, to be 

harmless or safe. 

Chesapeake estimates that 50,400 gallons of water is to be evaporated into 

the air everyday from the site. 

This will increase the humidity in the nearby parks and residential areas, 

promoting disease carrying insects and mold along with discomfort for 

residents. 

There are other methods for truly recycling and reusing 80% or more of the 

water. 

These methods are much more environmentally friendly without the massive 

pollution. 
Some gas drilling companies are already using this process. 

The use of electric motors to power all of the compressor stations in Fort 

Worth to help reduce emissions should be required.

During the recent gas drilling task force meetings, the industry 

acknowledged the use of electric powered compressors would produce fewer 

emissions than gas powered compressors. 

The industry would however prefer to use unprocessed natural gas directly 

from the wells to run their compressors. It is cheaper for them. 

the unprocessed natural gas, when burned as a fuel, like in a gas engine for 

the compressors, will include many harmful chemicals which go directly 

into the air as exhaust. 

They do not use the refined natural gas that is advertised as clean burning. 

The gas from the wells is only filtered enough to protect the gas motor from 

physical damage.

Since the heat required for this proposed recycling process is being 

generated from the compressors for evaporation, there is no incentive to use 

electric powered compressors by the industry, in fact just the opposite. 

There will be more need for heat to be generated and therefore more 

emissions in the air. 

One recent example to illustrate the industries lack of concern about 

emissions is the "parrot" Natural Gas compressor station located near my 

house in East Fort Worth that was powered by two electric motors.

When the compressors were enclosed to reduce excessive noise to the 

nearby neighborhood, the two electric motors were replaced with three 

compressors that now use gas-powered engines. 

That doesn’t seem like an industry trying to reduce emissions in the city. 

The gas drilling industry will do what it is required to do, 

but it has been demonstrated over and over, they will not do more than is 

required of them.
It is important the health and quality of life for the residents in Fort Worth be 

regained.

Jim Ashford

On Sep 1, 2010, at 2:55 PM, Kim & Ken Feil wrote:

OK who can help and "reply all" to the others so that you do not duplicate efforts? First 

one to respond gets kudo's !!!!

Air tests needs on the Arc Park/Brentwood compressor evaporation station for produced 

water.

Stick that canister right there too!

THANKS

----- Original Message -----

From: Kim & Ken Feil

Sent: Wednesday, September 01, 2010 2:51 PM

Subject: Clarification on Ft Worth evaporation station-no scrubbers needed

Mr Harris of Intevras was able to clarify that the air stripper/scrubbers he described to me 

in the Evras evaporators are available when needed like in California, but that they are 

not needed and are not being used here at the Ft Worth Chesapeake Brentwood/arc 

park site because of the low hydrocarbons associated with the Barnett Shale. Also the 

air is not blended (as I reported earlier in this email string) unless it comes from the 

scrubber.

He also mentioned that unconventional shale gas has less VOC concentrations than the 

standard oil and gas reservoirs and that the Barnett is not heavy in metals. 

He said that 50-60 ppm is what the Barnett Shale VOC has been although he's seen an 

average of 30 ppm and also he sees areas that have little to no hydrocarbons in the 

produced water. 

He said that radon is not a problem here compared to the North East areas of the 

Marcellus. Mr Harris didn't elaborate if there was any detriment to the air in incinerating 

arsenic, the conversation was limited to that arsenic occurs naturally.

In California, they did air testing on his units (with scrubbers) and found no problems 

when comparing baseline air tests to the incineration of hydrocarbons when that 

(scrubbed) air was run to the engines which was used as fuel for the engine as it is 

burned off. 

We should get TCEQ to measure the air coming from the EVRAS engines before and 

during the air flow to be combusted.
I am still unclear if the flowback water that contains fracturing fluids go to the EVRAS 

incinerator, so an air test when evaporating flowback water is also in order.

If our air tests prove no detriment to our air, surely this system is to be promoted as a 

best available technology to take the truck fracing traffic off our highways and get us into 

Clean Air federal compliance.

I copied Mr Harris so that if he needs to further clarify, he can "reply all" and add 

comments.

Thanks for your attention to this matter.

Kim Feil

----- Original Message -----

From: Boerner, Brian

To: 'Kim & Ken Feil'

Sent: Tuesday, August 24, 2010 4:14 PM

Subject: RE: Vaporization of produced water at Brentwood compressor station 

in Ft Worth to greatly reduce truck traffic to injection well sites

Titan’s study did not include a test for NORM (naturally occurring radioactive material). 

Norm has not been historically encountered in drilling this part of the Barnett Shale. The 

only areas that I am aware of where NORM has been detected is far north Denton and 

Wise counties 

Also, the first Evras unit was put online in June 2009. While they have been put online 

and taken off line over the past year (to allow for equipment upgrades and system 

maintenance), it is my understanding that at least one unit was online during the TCEQ 

test. I do not know if the unit was online the day of Titan’s sampling.

Brian K. Boerner, CPM, CHMM

Director of Environmental Management

From: Kim & Ken Feil [mailto:kimfeil@sbcglobal.net] 

Sent: Tuesday, August 24, 2010 4:06 PM

To: Boerner, Brian

Subject: Re: Vaporization of produced water at Brentwood compressor station in Ft 

Worth to greatly reduce truck traffic to injection well sites

I noticed the Titan air study at this site did not include radionuclides...can you comment 

on if the Ft Worth air study will test for radon?

Also, was the Evras unit on line at the time of the Titan air study in June? I do not know 

how long this system has been in place.

Thanks

Kim

----- Original Message -----

From: Boerner, Brian

To: 'Kim & Ken Feil'

Sent: Tuesday, August 24, 2010 3:28 PM
Subject: RE: Vaporization of produced water at Brentwood compressor station in Ft 

Worth to greatly reduce truck traffic to injection well sites

Ms. Feil:

I would urge you to revisit the Itevras Website http://www.intevras.com/. The 

operations I described are consistent with the operations of this piece of equipment and 

the program that Chesapeake is operating at the site. 

Regarding the response from the Chemical engineer, I do not know the source of their 

information so I can not respond as to their opinion. My conclusions are based on the 

qualified testing which has been completed around the site. Additionally, the City of 

Fort Worth’s air quality study will continue to evaluate potential emissions from this site.

Brian K. Boerner, CPM, CHMM

Director of Environmental Management

From: Kim & Ken Feil [mailto:kimfeil@sbcglobal.net] 

Sent: Tuesday, August 24, 2010 3:18 PM

To: Boerner, Brian

Subject: Re: Vaporization of produced water at Brentwood compressor station in Ft 

Worth to greatly reduce truck traffic to injection well sites

I had a similar response from a chemical engineer doubting that the toxins are not 

being scrubbed before incinerated. Burning toxic waste went on for decades at our 

cement factories south of us...how is this any different? Why is your explanation 

different from what I thought I heard from a phone convesation with the inventor?

Kim

----- Original Message -----

From: jim Ashford

To: Kim & Ken Feil ; eyesondrilling@epa.gov ; NFWMLTF Task Force ; 

nctca@googlegroups.com

Cc: Undisclosed-Recipient:;@smtp108.sbc.mail.mud.yahoo.com;; ; Tony Rutigliano ; 

info@crzo.net ; Andy.Agosto@crzo.net ; Elizabeth Gasca ; 

doug_agee@xtoenergy.com ; chris.sanders@yahoo.com

Sent: Tuesday, August 24, 2010 8:23 AM

Subject: Re: Vaporization of produced water at Brentwood compressor station in Ft 

Worth to greatly reduce truck traffic to injection well sites

I hope you aren't buying this nonsense. It does't happen that way when 

evaporating 50,400 gallons of water every day. It physically won't be done. 

The hydrocarbons still go in the air, the compressors still burn the gas from the 

ground that contains radium, mercury, lead along with the other hydrocarbons 

that go into the air as exhaust.

Jim

 
On Aug 23, 2010, at 11:24 PM, Kim & Ken Feil wrote:

vaporization of produced water at Brentwood 

compressor station in Ft Worth to greatly reduce 

truck traffic emissons in delivering to injection 

well sites

http://www.fortworthgov.org/uploadedFiles/City_Secretary/City_Council/Official_Docum

ents/2010_Ordinances/19234-07-2010.pdf

"WHEREAS, the City is continuing its participation in the pilot 

program with

Chesapeake Operating Company, Chesapeake has now acquired all but two tracts needed for 

the

Right-of-way for the salt water pipelines, and will be installing the recycling equipment in the

near future. In order to provide staff additional time to evaluate the operations of the salt water

pipelines and the recycling efforts, an extension to July 31, 2011, is advised; and

WHEREAS, adoption of this Ordinance would extend the 

moratorium from July 31,

2010, until July 31, 2011, and maintain the status quo while the staff continues the pilot 

program

with Chesapeake at the Brentwood site located on East First Street next to the old Arc Park; and

WHEREAS, at the direction of the Mayor and City Council, staff is 

working with the

community to identify a contractor to perform testing to accurately assess the source, area, and

ambient air quality impacts of gas operations within the City of Fort Worth. As part of this

assessment, disposal and recycling operations will be examined. The Brentwood site is 

currently

the only operational saltwater disposal and recycling site within the City of Fort Worth. By

extending the moratorium, operations will be allowed to continue so that appropriate data can 

be

collected to determine the impacts from this site and a fact based decision may be made as to
whether the moratorium should be lifted or a complete disposal ban should be enacted within 

the

City limits of Fort Worth;..."

The recycling of produced water will be a pilot program for Ft Worth using the EVRAS 

(by Intervas) system at the Brentwood compressor station. I heard that site will begin 

receiving produced water from 30 different gas well sites for "safe" vaporization. The 

remaining, crystallized solid waste will then be trucked to an injection site.

http://www.intevras.com/downloads/Evras/technical/EVRAS_-_ADA_White_Paper.pdf

Please go to flow chart and see that the "Humid Air Outlet" does not have a filter or a 

vapor recovery system. In calling the inventor of the process, Jeff Harris (who lived in 

Granbury at one time, and has experience with this system in California), explained 

that the Barnett shale VOC averages 30 ppm and has no barium. This is low in 

comparison to the Marcellus Shale (which is full of barium) and averages 500ppm of 

VOC's. So we are at an advantage starting with low voc's. I do not know if the ppm 

being quoted includes the fracing fluid flow back chemical vapors. 

In taking notes while talking to Mr Harris, the EVRAS system solidifies cold, produced 

water when it is warmed up by the introduction of an unmixable "heat transfer liquid" 

(HTL). The HTL is warmed by the wasted heat from the existing compressor station at 

the Brentwood site in Ft Worth. The cold, produced water keeps getting recycled from 

cold to hot to cold until it crystallizes.

The air flow directs the aromatic/pollution/condensate through a thermal reactor air 

stripper which scrubs the hydrocarbons when it passes through an air column. The 

extracted VOC's are then blended with the combustion air at a ratio of 100 parts of air 

to 1part of hydrocarbon condensate. This reduces our original 30ppm down to .03 

ppm. This .03ppm is then burned off in the compressor engines that have more 

efficient catalytic converters than our cars. The crank case captures exhausts like a 

carburetor functions. The Nox and Co is burned up in the catalytic engines. The

99.9% clean is better for the environment than the 100lb of Nox and 32 tons of carbons 

per year due to onroad trucking emissions in delivering produced fluids to an injection 

site. 

Ideally, piping the produced water from drill sites to the EVRAS systems would further 

decrease onroad trucking emissions in bringing the fluid to the evaporation site. 

I'm a little squirrelly when it comes to pipelines carrying toxic water and having any 

kind of ground water leak, but trucks carrying waste water are risky and those trucks 

aren't even labeled as toxic, hazardous material. The amount of matter going into 

injection sites would greatly be reduced to the crystallized sludge.

We could use some good news of natural gas extraction having a process 

improvement that others could follow if this is truely more environmental friendly.

I sent Mr Harris a copy of this email so that he can correct any mis interpretations of 

his verbal explanation to me over the phone...so more than likely I may have some 

corrections to this explanation of how the EVRAS is "safely" evaporating produced 

water for 30 pad sites here within city limits.

Please send comments or corrections to this email, thank-you.

Kim Feil
http://www.youtube.com/watch?v=e-4R4cfaspw

music vid "Can't You See It's Acid Raining" dedicated to City Council and Mayor Cluck

http://www.wfaa.com/news/local/New-well-linked-to-new-smell-in-Wise-County101232229.html Ten times the benzene level for ambient readings/Wise county.

With one inspector per every 3,300 wells in TX, how do we prevent this in Arlington?

We also need to test the air for formaldehyde-TCEQ doesn't.

http://www.crosstimbersgazette.com:80/local-news/988-drilling-fluid-spill-reported-inflower-mound.html

Drilling fluid spill reported in Flower Mound - This is the third spill for Williams in the area this year.

http://www.2theadvocate.com/news/101206889.html "The well, in a relatively isolated sugar cane field north of La. 70 

and northwest of Paincourtville, has prompted odor complaints and at least two lawsuits over air emissions and other allegations. 

State Police have also restricted access within a mile of the blowout."