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, <hq

publicaffairs@usace.army.mil>, <in fo@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.s tate.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 t o 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 b e 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 evapora ting 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.

T his 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 ar e 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 fr om 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 indust ries 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, t he 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 demons trated 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!

T HANKS



### ----- 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 lowhydrocarbons 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 th is matter.
Kim Feil



### ----- Original Message

----- From: Boerner, Brian

To: 'Kim & Ken Feil'

Sent: Tuesday, August 24, 2010 4:14 PM Subject: RE: Vaporiz ation 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 encounter ed 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, CHM M Director of Environmental ManagementFrom: 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: R E: 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.co m/ . 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.comCc: Undisclosed

- Recipient:;@smtp108.sbc.mail.mud.yahoo.com;; ; Tony Rutigliano ; info@crzo.net ; Andy.Agosto@crzo.ne t ; 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 e very 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 participati on 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 Jul y 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 Wort h. 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 all owed 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 Fo rt 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" v aporization. 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 Cali fornia), 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 t he 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 fu nctions. 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.

Id eally, 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 evenlabeled as toxic, hazardous material. The amount of matter going into injection sites would greatly be reduced to the crystallized sludge.

We could use som e 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 m e 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 F eil

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

- County

101232229.html Ten times the benzene level for ambient readings/Wise count y. 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

- flower

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 ."

----- 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 , <hq

publicaffairs@usace.army.mil>, <info@northtexasair.org>, "Michael Honeycutt" <MHoneycu@tceq.state.tx.us>, <michael.o'quinn@rrc.state.tx.us>, Nick Parsons/RTP/USEPA/US@EPA, "Sid Slocum" <SSLOCUM@tceq.state.tx.us>, "Walker, Tony" <TWALKER@tceq.state.tx .us>, <bshaw@tceq.state.tx.us>, "Shannon Ethridge" <SEthridg@tceq.state.tx.us>, "Alyssa Taylor" <ATAYLOR@tceq.state.tx.us>, <MABAKER@tceq.state.tx.us>, "Danielle Nesvacil" <dnesvaci@tceq.state.tx.us>, <kcauble@tceq.state.tx.us>, eyesondrilling@EPA, Timothy Herfel/R6/USEPA/US@EPA, <jwessel@tceq.state.tx.us>, "Winona Henry" <WHENRY@tceq.state.tx.us> 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 wa ter. 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 oth ers, 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 evapo rated 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 no t 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 humid ity 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

fro m 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 t he 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 indust ries 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, t he 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 demons trated 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 Brentwoo d/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 c oncentrations 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 hydro carbons 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 ar senic 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 f or 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
Clea n 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 F t 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 are as 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 no ticed 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 PMSubject: 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 P M

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

----- Orig inal 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 p ilot 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 Jul y 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 Coun cil, 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 towhether the moratorium should be lifted or a complete disposal ban should be enacted within

the

City limits of Fort Worth;..."
The r ecycling 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

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

http://www.intevras.com/downloads/Evras/technical/EVRAS_

- _ADA_White_Paper.pdf

Pleas e 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 th ermal 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 syst ems 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 ris ky 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 Feilhttp://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

- County

101232229.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

flower

- mo und.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 relati vely 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 allegati ons.
State Police have also restricted access within a mile of the blowout ."