Central Park Area Neighbors Association (CPANA) this week received the second set of air quality screening results in its planned year-long benchmarking of Lewisville ambient air prior to the beginning of gas drilling activities in Southern Lewisville.
No concentrations were found to exceed any health-based comparison values. For conservative comparison, we used TCEQ's Long Term ESLs (LTESL)
- Benzene was detected at .08 ppb. LTESL is 1.4 ppb
- Pinene was the most abundent VOC detected, at .14 ppb. (This is a natural compound from pine trees, which are located near our sample box)
- Hexadecane was found at .10 ppb. This compound is a 16-carbon alkane also known as cetane. Hexadecane is a diesel component or additive. (LTESL 350 ug/m3 - no ppb value available)
- Dichlorodifluoromethane was found at .09 ppb, though our laboratory is not accredited on that compound. This CFC is otherwise known as Freon 12 or R-12. It was used in vehicle air conditioners made before 1994, and its manufacture has been banned. LTESL is 1000 ppb.
- Toluene was found at 0.06 ppb. Toluene is a solvent, but EPA says the principal source of toluene in ambient air is automotive emissions. LTESL is 330 ppb.
- Heptadecane was found at 0.06 ppb. TCEQ doesn't list a ppb LTESL for heptadecane, but the long-term ESL is listed as 10 ug/m3. We calculate our sample was about 0.56 ug/m3.
- p-Xylene was found at 0.06 ppb. LTESL based on odor is 42 ppb. STESL (health) is 58 ppb.
- Octadecane was found at 0.05 ppb. LTESL is 10 ug/m3
- o-Xylene was found at 0.05 ppb. LTESL based on odor is 42 ppb. STESL (health) is 380 ppb.
- Pentadecane was found at 0.04 ppb. No LTESL is found at this point, but we'll research this further. Pentadecane is a component of diesel fuel, and a fragrance agent.
Note that other compounds likely were present, but only the top 10 found are being quantified in our screening, and the laboratory has limits of detection. So any other compounds would have been at concentrations lower than the 0.04 ppb of Pentadecane.
This week, we received an open letter to the Barnett Shale Energy Education Council's director, Ed Ireland, regarding the recent Ambient Air Quality Report. Our own examination of the report was focused on benzene, but writer Andy Mechling raises concerns about the study's findings on reduced sulfur compounds like carbon disulfide, carbon dioxide, and carbonyl sulfide:
Ed, I know that you and your organization are well aware of the daunting nature of these long-term AMCV values for the sulfur compounds; (and I know you’d rather talk about benzene). TCEQ should also be well aware of the potential problem here, as the standards that are at risk of being exceeded are their own, and not federal EPA guidelines, in this case.
Because of the scope and design of this study, because the 24-hour concentration figures presented for carbon disulfide appear to be unreliable, and because there is no 24-hour data at all for carbonyl sulfide or hydrogen sulfide, this study fails to provide any meaningful comparisons of measured ambient concentrations of these three highly toxic compounds to their - very stringent - long-term Texas standards.
Ignoring a problem seldom makes it go away; and I honestly think this would have been a much stronger report had this elephant in the room at least been introduced.
It appears that the only reliable information we have about levels of the sulfur compounds come from the 21 sulfur gas samples analyzed with the ASTM method. These come in the form of 1-hour composite samples of some type, as has been discussed. The study’s authors make no attempt to extrapolate or calculate estimates of 24-hour ambient concentrations for these chemicals, based on these 1-hr results.
The most troubling aspect of the one-hour sulfur results, at least from my perspective, is that there doesn’t appear to be any information in the report that would give us reason to expect that accurate 24 hour monitoring of these same chemicals (sampled in the same fashion in the same locations) would result in measured concentrations that are any lower than those 1-hr average figures we have in hand.
Mechling generally thinks the study was well-constructed and very defensible, but raises several questions in his letter:
- Whether the summa canister method of sample collection is capable of getting accurate results on sulfur compounds. - Whether the study's protocol of gathering samples during periods of highest sustained wind would cause under-reporting of pollutants - Whether the sulfur compounds might actually be more important than the scary VOCs like benzene - Why the narrative explaining results hardly mentioned that levels of Carbon disulfide were at the long-term AMCV, even though this is more significant that some of the other things discussed.
Overall, the letter is very interesting, and has me thinking that I need to spend some time studying these compounds.
It has now been a year since the town of DISH performed our air study around the massive natural gas compression station located in our community. You may remember that this study showed several carcinogens and neurotoxins at some pretty disturbing levels. Over the past year we have had a permanent monitor installed, and several other tests performed. Although things clearly have improved, it is also clear that further improvements are needed before people can live here and enjoy their property. We have patiently waited for our state regulatory agencies to catch up with the facilities they have permitted here in DISH. However, that simply has not happened.
Maybe it was wishful thinking on my part, but I actually thought that things were getting better; however, that horrible odor returns just as it has so many times before. Unfortunately, the odor seems to also carry some pretty nasty chemicals along with it. This odor of course is coming from the natural gas dehydration units, and amine sweetening units that are also part of the compressor complex. It takes very little research to find that both of these processes causes horrendous odors, and even those within TCEQ are well aware of the odor issues associated with this equipment. However, when discussing the odor issues, they immediately act as though they have no idea about what could cause these odors, or at least I hope they are acting, because we are really in bad shape if they honestly don't know where the odor is coming from. But I have not pushed the issue, hoping that one of the TCEQ "back room deals" would result in some relief for us. However, after been given a year to fix the problem, we still have periodic odor that prevents us from enjoying our property. Someone from TCEQ has been to DISH numerous times for investigations, and on most every occasion, they have sent a letter acknowledging the presence of odors, and refused to take any action to prevent it from reoccurring. TCEQ has actually adopted a regulation the protect us from these sort of actions, but has refused to enforce it. It is found the Texas Administrative Code (TAC), and more specifically this requirement is outlined in 30 TAC § 101.4 which states:
No person shall discharge from any source whatsoever one or more air contaminants or combinations thereof, in such concentration and of such duration as are or may tend to be injurious to or to adversely affect human health or welfare, animal life, vegetation, or property, or as to interfere with the normal use and enjoyment of animal life, vegetation, or property.
Friday morning, there was a spill of about 190 barrels (Almost 8,000 gallons, or approximately 1,000 cubic feet) of flow-back water on the Cummings drill site in Flower Mound. Flow-back is basically the frack fluid and all of its chemicals, plus whatever salts and liquids it picked up while fracturing the formation.
From the Flower Mound Leader:
This is the third spill for Williams in the area this year. A faulty seal on a temporary storage tank resulted in a spill at the same Cummings site on March 17. In Argyle, a July 29 spill at the Wright drill site involved a tank overflow.
“We have taken corrective measures following the earlier spills – measures that included having contractors inspect tanks and other equipment every 15 minutes. At this point, we don’t believe that protocol was followed this morning,” Silvestri said. “There will be more corrective action taken once we finish reviewing this. We share everyone’s expectation that drilling should be done safely, reliably and responsibly.”
Wednesday afternoon, Chesapeake filed a permit application with the City of Lewisville for its "AD" unit natural gas well in Southern Lewisville, just east of Duncan Lane.
The well pad would be adjacent to the compressor unit Chesapeake already operates, and is about 1,500 feet West of the Creekside Mobile Home Park.
This is the first permit filed after the City Council narrowly rejected a suspension of permitting while changes to the ordinance are being considered. The Williams company has accelerated plans on 26 wells in Southern Lewisville, we are told.
Tonight I took a few minutes to address the Lewisville City Council in the citizens forum section regarding the council's 3/2 decision from meeting before last not to extend a temporary suspension of permitting.
Video below is from the City of Lewisville website, but I re-posted because the bookmarks in the city's version take you to near the end of my rant.
My name is Steve Southwell I live at 995 Downey Dr. in Lewisville
A few weeks ago, here in this chamber, we had a nice little dog and pony show. It was put on by a couple of representatives from local natural gas operators. In the ten minutes that each of these non-citizen non-taxpayers were given, plus the soft-ball followup, these representatives were happy to butter you up with nice warm fuzzy feelings. They talked about how responsible they are, and how they would never pollute. (But they just didn’t want you making it a law to do exactly what they told you they already do)
One of them gave you a very misleading presentation, refuting straw-man arguments about Benzene. What they did here was very clever in that they took on what was essentially a non-issue from the start, and tried to make it look like all was well. I sat here wondering if they were going to try to convince you that their operations somehow soaked up benzene out of the air to make us all safer.
I like to believe that elected officials would be a little more discerning than to simply buy industry claptrap at face value, so I spent an entire weekend pulling together some information for you. I brought some actual FACTS regarding Benzene and its emissions from natural gas.
Tonight, a group of Lewisville residents held an organizational meeting to deal with proposed natural gas drilling near their homes. Over 20 residents showed up for the initial meeting, but members say they expect more.
The group, which calls itself Lewisville Neighbors for Responsible Urban Drilling (LNRUD) consists mainly of residents immediately surrounding the proposed well site for Titan's Ingram Unit, on the Southeast corner of Corporate Drive and Valley Parkway. LNRUD has no formal leadership at this point, but is still in the process of organizing.
Members are concerned about a variety of issues surrounding natural gas production, including air and water contamination as well as noise and reduction of property values. Lewisville Resident Carol Tomkovich, the former owner of the property on which the well may be drilled, brought a map to show that depending on the definition of a city park, it may not be possible to drill on the property without a variance to the 500 foot setback required from protected uses such as homes and parks.
This group is not affiliated with Central Park Area Neighbors Association (CPANA), which had organized in 2008 to deal with financial and contractual issues related to the drilling, and that eventually negotiated a deal with some environmental and contractual concessions. Most of the members of LNRUD have not leased their mineral rights.
Members like Lewisville resident Ron Aljoe were most disappointed with a recent decision by the Lewisville City Council not to extend a brief suspension of permits while city staff review the oil and gas ordinance with respect to recent developments around the Barnett Shale. Since the Council made its vote, the Williams company has accelerated 22 permits for wells in Southern Lewisville, though none of those serve LNRUD's neighborhood. Once an operator has a permit, they operate under the rules in effect at that time, so in this way, Williams will avoid having to abide by any changes to the ordinance.
The group intends to reach out the the Council and emphasize the need for more protections in the ordinance for safety and the peaceful enjoyment of their property.
Flower Mound residents Virginia Simonson, board member of The Flower Mound Defense Fund, and Prakash Parameswaran, a homeowner in Town View Estates, are represented by Attorney Robert D. Hemphill. The suit was filed in Denton County on Friday.
“Plaintiffs are requesting the court to determine whether the Flower Mound oil and gas ordinance conflicts with state law and the town’s own zoning ordinances, both of which require notice and opportunity for public comment prior to zoning changes. Plaintiffs contend that the town’s current practices effectively enable oil and gas development to occur without citizen input and other protections required by state law,” Hemphill said.
I have to wonder whether this might backfire in some way and end up weakening Flower Mound's position with regards to regulating drilling.
I made an announcement shortly after Memorial Day weekend, that I would be putting my home in DISH on the market. This decision was made by my family after several instances of both of my children having nosebleeds during the night. These nosebleeds correlated with strong odors and spikes in the chemicals being emitted by the natural gas compression station a quarter mile from our home. We are still planning on putting our home on the market by the end of August. This is a tough decision, but to ensure the safety of my family, it is something that I will do.
A year ago, you essentially could not be outside for more than a couple of hours without being forced into your home by the noxious odors. In the few months prior to Memorial Day the odor events were limited to the late evening/early morning timeframe and happened a few nights a week for a couple of hours. After the Memorial Day incident, the TCEQ brought a canister for me to keep at my home for instances of the strong odor, I still have this canister. There have been periodic odor events over the past couple of months; however, they now only last for a brief time. By the time I get the canister ready to take the sample, the odor is gone. Unfortunately, my air conditioning system sucks the odor in the house, and the odor sometimes lingers longer inside than outside. So over the past year, the situation has improved tremendously. Is it enough? I am not sure.
Looking back through some of our posts on Oil and Gas, I realized a couple of things:
1. We have some really old, out of date posts that still get a lot of hits and comments. 2. We did not have one main page to tie it all together.
So here's my attempt at putting together a page with the history and status of Lewisville's oil and gas activity. You can bookmark this if you want, and I'll do my best to keep it up to date. I'm sure I'll still have blanks to fill in though.
Please feel free to post comments if you want something added or corrected, or if you have questions.
Map of Current and Proposed Gas Facilities in Lewisville
View Lewisville Gas Wells in a larger map (Note: You may have to zoom in quite a bit)