Tuesday, December 30, 2014

World-Wide Flight Traffic and Global Climate Change

Globally, about 8.3 million people fly daily (3 billion occupied seats per year), twice the total in 1999.  U.S. airlines alone burned about 16.2 billion gallons of fuel during the twelve months between October 2013 and September 2014. (Wikipedia)

Source: openi.nlm.nih.gov


World-wide now, December 30 2014 11:35 ET

AirTraffic Worldwide over 24h

US air traffic, now December 30 2014, 11:35 ET

 A Day in the Life of Air Traffic Over the United States

Even centered on Adrian, there are about 120 commercial air craft in the air at every given moment during the day!

Monday, December 29, 2014

The Reality of Having a 30-inch Pipeline Construction Site in your Backyard


An environmentally concerned citizen of Oceola Township sent me some videos that he shot while having a large pipeline construction in his backyard. These videos give a good idea what everybody whose property is located along the ET Rover track can expect when their land is taken away from them by "eminent domain".

Wednesday, December 17, 2014

New Pipeline between the Central processing Facility on Witt Farm and Various Wells on Frye Farm

For more than 2 weeks horizontal drilling under M52 and under Beaver Creek goes on to connect the central processing facility on Witt Farm with several wells on Frye Farm West of the Kiwanis Trail. As the central processing plant is only permitted for 10 wells and there were already 9 wells hooked up through the 3 present pipelines it is doubtful that all this is done to just add a single well on the old Frye Farm land. I will forward this question to Kristie Shimko.

News from Kristie Shimko - DEQ:  "Savoy Energy has bored a 6-inch poly disposal line under road and creek crossings between the Adrian 25 Facility (Witt Farm) to the Warner 22 Facility (off Tipton Hwy, North of Hunt Road).  This is an upgrade from their existing 3-inch poly disposal line. This is for salt water/brine disposal only."

Another Wave of Mass Postings to FERC Through Unions in WV, OH and PA

On December 5th, I reported about the abuse of the FERC e-filing system by people filing from WV. It turns out that the local unions in these economically depressed regions handed out sheets and asked the meeting attendees to write down what positive effects they anticipate (or rather hope and pray for) of the pipeline for their local economies. What is wrong with this? Several things, first of all wishful thinking is not reality - it is highly immoral of unions to misinform their members about the real number of jobs created and the real benefits for the local economy. Second, all of the arguments are purely economical arguments and have nothing to do with the environmental impact of the pipeline - which is the only concern of FERC in this process. Finally, as the pipeline will not run through West-Virginia, residents of WV should not have a say about it at all. In addition, flooding the system with these generic "prayer-sheets" is annoying for everybody, who subscribed the ET Rover process and waters down the legitimate input of farmers and residents, as well as townships and counties objecting the pipeline due to its environmental impact! I finally had to unsubscribe as the same union repeated its bad practice this evening again. Latest news - now also unions from Ohio started these mass postings. I attach a few examples with names and addresses removed below. There are literally hundreds of such postings there now - NONE say anything about the environment!






Monday, December 15, 2014

Sad News: Theo Colborn passed away, 1927-2014

One of my modern day heroes, who was both an outstanding scientist and a tireless activist passed away yesterday. Read a short obituary here - with links to more info on "The Rachel Carson of the 80s and 90s", and her fight against endocrine disruptors, chemicals used in oil and gas drilling, and pesticides.

http://endocrinedisruption.org/enews/2014/12/11/theo-colborn-1927-2014/


Friday, December 5, 2014

Complaint addressed to FERC about Generic Mass Comments submitted to FERC PF14-14-000

To whom it may concern,
I am just wondering what the flood of scanned comments of supporters of the project from WV has to do with FERC's approval process.
The pipeline does not travel through WV - therefore these people should not have a say on its approval.
In addition, all of these comments are written very carelessly and are very brief - 3 lines at the most - not even full sentences.
None of the comments mentions a single environmental aspect - it is all is about the supposed benefits for the economy.
I thought this process is about the environmental impact of the project - not about the promised and highly disputable impact on local economies!
It seems to me that somebody thinks if they gather 100 of these generic support letters they can counter objective scientific analyses of the environmental impact of the project, like the one I submitted, which cites 36 recent scientific research publications - or statements from entire townships in Ohio and Michigan opposing the pipeline.
If that is correct, the FERC process is a big farce and serves nothing else than pretending that the environmental impact of the project is seriously investigated!
A copy of this comment is published on my blog: adrianoil.blogspot.com
---------------------------------------
Thomas Wassmer, Ph.D.
Assistant Professor of Biology
Siena Heights University

________________________________________
From: 'FERC eSubscription' [eSubscription@ferc.gov]
Sent: Thursday, December 04, 2014 7:25 PM
Subject: Comment on Filing submitted in FERC PF14-14-000 by INDIVIDUAL
On 12/4/2014, the following Filing was submitted to the Federal Energy Regulatory Commission (FERC), Washington D.C.:

Filer: INDIVIDUAL
Docket(s): PF14-14-000
Lead Applicant: Rover Pipeline LLC
Filing Type: Comment on Filing
Description: Comments of Christopher D. Strait re the ET Rover Pipeline under PF14-14.
To view the document for this Filing, click here
http://elibrary.FERC.gov/idmws/file_list.asp?accession_num=20141204-0028

To modify your subscriptions, click here: https://ferconline.ferc.gov/eSubscription.aspx
------------------------------------------------------------------------
Please do not respond to this email.
Online help is available here:
http://www.ferc.gov/efiling-help.asp
or for phone support, call 866-208-3676.






Sunday, November 30, 2014

FERC: No reason to approve Rover

A few talking points for FERC scoping meetings.

This email is in response to comments made by the Michigan Chamber of Commerce, Rover, unions, and others at the FERC Rover scoping meeting in Chelsea (November 20). Comments such as:
· about 3,000 temporary jobs would be created in Michigan
· around $13.4 million in higher tax revenues for local governments
· Energy is the livelihood of Michigan's economy, and the Rover pipeline will inject new life into that economy. Michigan will need more gas.
http://www.heritage.com/articles/2014/11/21/chelsea_standard/news/doc546f7e75099d6298155091.txt?viewmode=fullstory

Future meetings will be held in Adrian (12/1), Flint (12/10) and Richmond (12/11). https://secure.sierraclub.org/site/SPageServer;jsessionid=7B623BE60E79ED0B9BF38304C28E8681.app201a?pagename=MINaturalGasPipelinesInterests&AddInterest=8275


Jobs and economic activity
3,000 temporary jobs is a token amount. (Michigan has over 4.4 million total jobs.) Plus, these temporary pipeline jobs would be created purely to support degrading our property and environment and enabling more fracking - one of the most polluting industries in the US.
More pipelines enable more fracking.

One Michigan study concludes at least 15,000 long term jobs would be created just by fixing Michigan roads. http://www.swmpc.org/downloads/michigans_roads_the_cost_of_doing_nothing_and_the_rewards_of_bold_action.pdf

A study by the Michigan Conservative Energy Forum concluded that by continuing the current Michigan energy efficiency program and increasing the State's renewable energy requirement to 20% by 2025 would add 100,000 jobs and $10 BILLION in economic activity to Michigan. http://www.micef.org/index.php/documents

Unlike stated at the meeting, energy is not a major industry in Michigan. It is much smaller in comparison to manufacturing, tourism, agriculture and many others.

Tax revenues and declining property values
Local tax receipts from Rover may be entirely offset by disfiguring and devaluing 12,147 acres of Michigan land and probably lowering tax revenues because of lower property values.

There are conflicting studies on lower property values and pipelines.
However it needs to be pointed out that landowners in Texas are WINNING millions in law suits because gas pipeline easements often cause significant damages to property beyond the easement area. http://www.prnewswire.com/news-releases/texas-landowners-win-21-million-judgment-against-pipeline-company-over-lower-property-value-251945191.html

Plus, possible problems with property insurance, mortgages, titles, resale and increased road damage, burden on local fire and police, etc.

Declining natural gas use in Michigan
Natural gas usage in Michigan has actually DECLINED over the past 40 years according to US Energy Information Administration. http://www.eia.gov/dnav/ng/ng_sum_lsum_dcu_SMI_a.htm

Even with additional coal plant retirements, higher energy efficiency and renewable energy requirements in Michigan will negate the need for more natural gas for electric generation, building and water heating.

President's commitment, methane, FERC and climate change
President Obama committed the US to cut greenhouse emissions. This includes considerable CO2 from burning natural gas and from methane emissions from leaks. Methane is 86 times more detrimental than carbon dioxide as a GHG during the two decades after it enters the atmosphere. In most cases, this makes natural gas worse for climate change than coal and oil.
As part of the US government, FERC must take serious steps to achieve the President's goals to reduce CO2 and methane emissions. This includes pipelines.

(More on Rover, GHG and FERC meetings in http://adrianoil.blogspot.com/ )

FERC, what is the GHG impact of the Rover pipeline including CO2 and methane leakage?

There is no need for Rover
Michigan already has considerable gas pipeline inflow and outflow capacity with considerable existing capacity to and from Ontario. There are at least 5 gas pipelines between Michigan and Ontario.
http://www.eia.gov/naturalgas/data.cfm#pipelines

DTE and CMS told a Michigan legislator that they did not request the Rover pipeline.

DTE is planning their own Nexus pipeline which will serve Michigan and Canada. Most of it is already built in Michigan.

Michigan has its own large natural gas reserves in the Antrim and Utica-Collingwood fields. http://www.greatlakesenergyforum.com/topics/michigan-shale

Michigan had more underground natural gas storage capacity than any other state in the nation with over 1 trillion cubic feet of capacity. This negates the need for extra pipelines to meet seasonal demands. http://www.eia.gov/state/print.cfm?sid=mi

Energy Transfer and FERC agreed in November 2013 that no additional natural gas pipeline capacity was needed in the Midwest
Energy Transfer stated there was excess pipeline capacity serving the Midwest region. https://elibrary.ferc.gov/idmws/doc_info.asp?document_id=14040896
FERC agreed to allow ET to abandon this gas pipeline in the Midwest stating, "Trunkline is not obligated to continue to operate capacity … for which there is no demonstration of market demand." CP12-491
https://elibrary.ferc.gov/idmws/common/opennat.asp?fileID=13392374

Canada has plenty of natural gas and gas pipelines and does not need Rover.
· Canada has more natural gas reserves that the US including considerable reserves Ontario, Quebec and Nova Scotia.
· There are at least eight existing pipelines crossing between Canada and Eastern US states. Many of them are already sending Marcellus/Utica shale gas to Canada.
· And at least six new pipelines and pipeline expansions planned to supply US gas to Eastern Canada. http://www.fossil.energy.gov/programs/gasregulation/border.html
http://www.eia.gov/pub/oil_gas/natural_gas/analysis_publications/ngpipeline/impex_map.html
· Even with coal plant retirements in Ontario, hydro and nuclear account for roughly 90% of total Ontario and Quebec electric generation and wind is a growing percentage of the total.

Drillers want more pipelines because of their profit desire to produce gas far in excess of final customer needs
Drillers/shippers like Range and Antero Resources and American Energy-Utica have spent billions to secure too many oil and gas leases in Marcellus and Utica and are rushing production way beyond demand before many of these leases expire.

Summary
"Public convenience and necessity" should be determined by the natural gas needs of the final customers who will use the gas and not by the profit objectives of shippers and pipeline companies.

Real need, the environment, people's rights, health and quality of life should take precedence as well as the CO2 and methane reduction goals of our country.

FERC please don't be a party to the excessive gas drilling madness.

Just because they are proposed, they don't have to be approved.

Saturday, November 29, 2014

Sunday, November 23, 2014

Why the ET Rover Pipeline should not be permitted

The ET Rover pipeline is currently planned as a 42 inch pipeline for the transmission of natural gas from the production site in Ohio and Pennsylvania to the final marketing site in Sarnia, Ontario (Fig. 1).
Fig. 1: The proposed course, dimensions, and market segments of the ET Rover pipeline. Source: energytransfer.com
My comment is in regards to the scoping process within the Environmental Impact Statement (EIS) to be prepared by the Federal Energy Regulatory Commission (FERC). There are better energy provisioning alternatives to the proposed pipeline available and the environmental impacts of the proposed pipeline outweigh its potential benefits by far.
My comment has 4 parts:
  1. The natural gas to be transmitted is produced by hydraulic fracturing (“fracking”), which is a highly insecure, inefficient, and polluting technology that should not be further promoted, which it would, if this transmission and distribution line is build.
  2. The transmission of natural gas in pipelines leads to substantial leakage of the potent greenhouse gas methane, which has a climate altering potential that is estimated to be 28-84 times higher than that of carbon dioxide.
  3. Serious incidents in the transmission of natural gas in pipelines are less common but if they occur they are often more serious (explosions) and often cause fatalities.
  4. Fossil fuels caused and continue to cause global climate change, which already leads to hundreds of human fatalities every year and will substantially impair the survival and well-being of human and non-human life forms for many decades to come. Renewable energy sources are the only energy sources able to cut greenhouse gases and are available right now providing enough energy for all current and future energy needs. The sooner we switch to renewable energy sources the sooner planet Earth will recover from the inevitable consequences of fossil energies. Every new investment into fossil fuels is unnecessary and unethical and should therefore be avoided.
Below, I will provide arguments and evidence for each of my four statements.
  1. Fracking is insecure, inefficient, and causes environmental impacts that outweigh its benefits by far. Workers on fracking sites are at risk of silicosis caused by the exposure to high levels of silica, found in dust particles from hydraulic fracturing sand (OSHA 2014). In addition, many oilfield workers involved in “fracking” lost their lives or endured serious injuries (Earthjustice 2014; Meyer and Stepans 2014; Mountainkeeper Catskill 2014).
Hydraulic fracturing is a high input technology and is therefore in many cases highly inefficient. A lot of energy and water is needed to frack a well and many wells do not pay back the investment. The only reason why the business stays profitable are tax incentives and subsidies, the 2005 exemption of hydraulic fracturing from the Safe Drinking Water Act – known as the “Halliburton Loophole”, the exemption of “smaller” oil and gas production sites from the National Emission Standards for Hazardous Air Pollutants (NEHAPS) within the Clean Air Act, the exemption from stormwater runoff permits within the Clean Water Act, the exemption of oil and gas production sites from the Resource Conservation and Recovery Act (RCAA) governing the disposal of solid and hazardous wastes, exemptions from the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), known as the “Superfund Law”, and the Toxic Release Inventory (TRI), which requires most industries to report toxic substances to the EPA (Earthworks 2014) – and the occasional high-output well. Most of the up to 5 Million gallons of water pushed underground in each well (Mielke and others 2014) is lost or cannot be used for anything else due to chemical contamination (Fontenot and others 2013).
The environmental impacts of the production end of fracking include ground- and surface water pollution (Fontenot and others 2013; Jackson and others 2013; Mall 2014; Vidic and others 2013), methane emissions (Field and others 2014; Howarth 2014; Schneising and others 2014), emissions of volatile chemicals, e.g. BTEX, formaldehyde, hydrogen sulfide and methylene chloride (Argo 2001; Colborn and others 2014; Macey and others 2014), and other concerns (Adgate and others 2014; Bamberger and Oswald 2012; Brittingham and others 2014; Colborn and others 2011). Most current comprehensive analyses of the environmental and social cost-benefit ratio of fracking come to the conclusion that the technology should be put on hold until its flaws are solved, or should not be continued because the production of shale oil and gas allows consumers to continue the wasteful use of fossil fuels and thus causing more severe global climate change (Newell and Raimi 2014; Sovacool 2014; Vengosh and others 2014).

  1. According to estimates by the EPA, most methane leakage occurs during the transmission of natural gas (0.7%).
Fig. 2: Picture credit: John Bellamy/Stanford University
While most independent studies consider the EPA’s estimates of the total amount of methane leakage from natural gas operations to be substantially below the real values (Brandt and others 2014; Field and others 2014; Howarth 2014), the allocation of leakage to be highest in transmission and distribution is undisputed (Alvarez and others 2012). Fugitive methane emissions from natural gas systems represent a significant source of global warming pollution in the U.S. (Bradbury and others 2014). In fact, compared to carbon dioxide, methane is considered to be 28x to 84x more potent as a greenhouse gas (Fig. 3) (Howarth 2014).
Fig. 3: Global Warming potential of methane compared to carbon dioxide. Picture credit: Allen (2014)
  1. Serious incidents in the transmission of natural gas in pipelines are less common but if they occur they are often more serious (explosions) and often cause fatalities. From 1994 until 2013, the PHMSA (Pipeline & Hazardous Materials Safety Administration) recorded 1236 significant incidences in gas transmission, causing 41 fatalities, 195 injuries and $1,717,072,424 of property damages (PHMSA 2013).
  2. Fossil fuels caused and continue to cause global climate change, which already leads to hundreds of human fatalities every year and will substantially impair the survival and well-being of human and non-human life forms for many decades to come (IPCC 2014). Renewable energy sources are available now and are capable to provide enough energy for all current and future energy needs (Becker and others 2014; Delucchi and Jacobson 2011; 2013; Jacobson 2009; Jacobson and Delucchi 2011). The sooner we switch to renewable energy sources the sooner planet earth will recover from the inevitable consequences of fossil energies (Jacobson and Streets 2009). Every new investment into fossil fuels should therefore be avoided.
Fig. 4: Technologically and financially feasible transition to a 100% renewable energy supply for Michigan. Picture credit: thesolutionsproject.org


References Cited

Adgate JL, Goldstein BD, McKenzie LM. 2014. Potential Public Health Hazards, Exposures and Health Effects from Unconventional Natural Gas Development. Environmental Science & Technology 48(15):8307-8320.
Allen DT. 2014. Methane emissions from natural gas production and use: reconciling bottom-up and top-down measurements. Current Opinion in Chemical Engineering 5(0):78-83.
Alvarez RA, Pacala SW, Winebrake JJ, Chameides WL, Hamburg SP. 2012. Greater focus needed on methane leakage from natural gas infrastructure. Proceedings of the National Academy of Sciences 109(17):6435-6440.
Argo J. 2001. Unhealthy Effects of Upstream Oil and Gas Flaring. Sydney, NS, Canada: SAVE OUR SEAS and SHORES (SOSS).
Bamberger M, Oswald RE. 2012. Impacts of gas drilling on human and animal health. New Solut 22(1):51-77.
Becker S, Frew BA, Andresen GB, Zeyer T, Schramm S, Greiner M, Jacobson MZ. 2014. Features of a fully renewable US electricity system: Optimized mixes of wind and solar PV and transmission grid extensions. Energy 72:443-458.
Bradbury A, Obeiter M, Draucker L, Wang W, Stevens A. 2014. Clearing the Air - Reducing Upstream Greenhouse Gas Emissions from U.S. Natural Gas Systems [Internet]. World Resources Institute. Available from: http://www.wri.org/publication/clearing-air
Brandt AR, Heath GA, Kort EA, O'Sullivan F, P├ętron G, Jordaan SM, Tans P, Wilcox J, Gopstein AM, Arent D et al. . 2014. Methane Leaks from North American Natural Gas Systems. Science 343(6172):733-735.
Brittingham MC, Maloney KO, Farag AM, Harper DD, Bowen ZH. 2014. Ecological Risks of Shale Oil and Gas Development to Wildlife, Aquatic Resources and their Habitats. Environmental Science & Technology 48(19):11034-11047.
Colborn T, Kwiatkowski C, Schultz K, Bachran M. 2011. Natural Gas Operations from a Public Health Perspective. Human and Ecological Risk Assessment: An International Journal 17(5):1039-1056.
Colborn T, Schultz K, Herrick L, Kwiatkowski C. 2014. An Exploratory Study of Air Quality near Natural Gas Operations. Human and Ecological Risk Assessment: An International Journal 20(1):86-105.
Delucchi MA, Jacobson MZ. 2011. Providing all global energy with wind, water, and solar power, Part II: Reliability, system and transmission costs, and policies. Energy Policy 39(3):1170-1190.
Delucchi MA, Jacobson MZ. 2013. Meeting the world's energy needs entirely with wind, water, and solar power. Bulletin of the Atomic Scientists 69(4):30-40.
Earthjustice. 2014. Fracking Across the United States [Internet]. Available from: http://earthjustice.org/features/campaigns/fracking-across-the-united-states
Earthworks. 2014. Loopholes for polluters - The oil and gas industry’s exemptions to major environmental laws [Internet]. Washington, DC: EARTHWORKS. Available from: http://www.shalegas.energy.gov/resources/060211_earthworks_fs_oilgasexemptions.pdf
Field RA, Soltis J, Murphy S. 2014. Air quality concerns of unconventional oil and natural gas production. Environmental Science: Processes & Impacts 16(5):954-969.
Fontenot BE, Hunt LR, Hildenbrand ZL, Carlton Jr DD, Oka H, Walton JL, Hopkins D, Osorio A, Bjorndal B, Hu QH et al. . 2013. An Evaluation of Water Quality in Private Drinking Water Wells Near Natural Gas Extraction Sites in the Barnett Shale Formation. Environmental Science & Technology 47(17):10032-10040.
Howarth RW. 2014. A bridge to nowhere: methane emissions and the greenhouse gas footprint of natural gas. Energy Science & Engineering 2(2):47-60.
IPCC. 2014. IPCC Fifth Assessment Report [Internet]. Intergovernmental Panel on Climate Change (IPCC); [accessed November 2014]. Available from: http://www.ipcc.ch/report/ar5/index.shtml
Jackson RB, Vengosh A, Darrah TH, Warner NR, Down A, Poreda RJ, Osborn SG, Zhao K, Karr JD. 2013. Increased stray gas abundance in a subset of drinking water wells near Marcellus shale gas extraction. Proceedings of the National Academy of Sciences 110(28):11250-11255.
Jacobson MZ. 2009. Review of solutions to global warming, air pollution, and energy security. Energy & Environmental Science 2(2):148-173.
Jacobson MZ, Delucchi MA. 2011. Providing all global energy with wind, water, and solar power, Part I: Technologies, energy resources, quantities and areas of infrastructure, and materials. Energy Policy 39(3):1154-1169.
Jacobson MZ, Streets DG. 2009. Influence of future anthropogenic emissions on climate, natural emissions, and air quality. Journal of Geophysical Research-Atmospheres 114.
Macey G, Breech R, Chernaik M, Cox C, Larson D, Thomas D, Carpenter D. 2014. Air concentrations of volatile compounds near oil and gas production: a community-based exploratory study. Environmental Health 13(1):82.
Mall A. 2014. Incidents where hydraulic fracturing is a suspected cause of drinking water contamination | Amy Mall's Blog | Switchboard, from NRDC [Internet]. Natural Resources Defense Council. Available from: http://switchboard.nrdc.org/blogs/amall/incidents_where_hydraulic_frac.html
Meyer S, Stepans P. 2014. Hydraulic fracturing oilfield accidents [Internet]. [accessed November 2014]. Available from: http://mss-lawfirm.com/oilfield-accidents-fracking/
Mielke E, Anadon LD, Narayanamurti V. 2014. Water Consumption of Energy Resource Extraction, Processing, and Conversion [Internet]. Energy Technology Innovation Policy research group, Belfer Center for Science and International Affairs, Harvard Kennedy School. Available from: http://belfercenter.ksg.harvard.edu/files/ETIP-DP-2010-15-final-4.pdf
Mountainkeeper Catskill. 2014. Gas Drilling Accidents [Internet]. [accessed November 2014]. Available from: http://www.catskillmountainkeeper.org/our-programs/fracking/whats-wrong-with-fracking-2/accidents/
Newell RG, Raimi D. 2014. Implications of Shale Gas Development for Climate Change. Environmental Science & Technology 48(15):8360-8368.
OSHA. 2014. HAZARD ALERT - Worker Exposure to Silica during Hydraulic Fracturing [Internet]. Occupational Safety & Health Administration (OSHA); [accessed November 2014]. Available from: https://www.osha.gov/dts/hazardalerts/hydraulic_frac_hazard_alert.html
PHMSA. 2013. PHMSA - Data & Statistics - Pipeline Incident 20 Year Trends [Internet]. PHMSA - US Department of Transportation Pipeline and Hazardous Materials Safety Administration. Available from: http://www.phmsa.dot.gov/pipeline/library/datastatistics/pipelineincidenttrends
Schneising O, Burrows JP, Dickerson RR, Buchwitz M, Reuter M, Bovensmann H. 2014. Remote sensing of fugitive methane emissions from oil and gas production in North American tight geologic formations. Earth's Future 2(10):2014EF000265.
Sovacool BK. 2014. Cornucopia or curse? Reviewing the costs and benefits of shale gas hydraulic fracturing (fracking). Renewable and Sustainable Energy Reviews 37(0):249-264.
Vengosh A, Jackson RB, Warner N, Darrah TH, Kondash A. 2014. A Critical Review of the Risks to Water Resources from Unconventional Shale Gas Development and Hydraulic Fracturing in the United States. Environmental Science & Technology 48(15):8334-8348.
Vidic RD, Brantley SL, Vandenbossche JM, Yoxtheimer D, Abad JD. 2013. Impact of shale gas development on regional water quality. Science 340(6134):1235009.

Sunday, November 16, 2014

ET Rover Pipeline through Adrian is up for Puplic Comment on December 1

Reblogged from a post of the Sierraclub Michigan that can be found here

 Southeast Michigan's Natural Gas and Oil Pipeline Boom:

What's happening and How to have your Say
Enbridge Line 6B oil pipeline construction, photo by Ron Kar
Proposed natural gas pipelines in SE Michigan will cause
as many local impacts as the replacement of the Enbridge
Line 6B oil pipeline (above) and keep pushing fossil fuels,
instead of clean energy alternatives. Photo by Ron Kardos

Southeastern Michigan communities have been confronting at least three proposed new or expanded massive natural gas pipelines designed to move Pennsylvania, West Virginia and Ohio fracked natural gas into and through Michigan to Ontario. Sierra Club opposes the massive ramp up in natural gas development around the nation through fracking that is one driver of these new pipeline proposals because the drilling, extraction and leakage in delivering this fossil fuel falls far short of being the "clean energy" the industry wants you to think it is. In addition, the construction of massive pipelines like these cause significant local environmental impacts as well.

Sierra Club leaders in the Michigan Chapter's Huron Valley, Crossroads, Nepessing and Southeast Michigan Groups are stepping up to the plate to fight pipelines and they encourage your engagement as well. Scroll down to find contacts for each of these four Groups who can help connect you with the fight in your area.  We also encourage you to sign up below so that we can follow up with you as each project develops.  These proposals are moving fairly fast, but there is time to weigh in now on at least one of the projects.
Three Natural Gas Pipelines Proposed:

Imagine a swoosh like the Nike logo aound the western end of Lake Erie and you'll have an idea of the maps showing three different proposed natural gas pipelines.  The proposed pipelines are the ET Rover Pipeline, the Nexus Pipeline (a partnership of DTE Energy, Enbridge Inc. and Spectra Energy) and the Utopia Project.  Each pipeline would start in eastern Ohio, western Pennsylvania or West Virginia, cross Ohio and Michigan before crossing the international border to enter Ontario, Canada.  Each project provides information on the links provided above including maps of the intended path.  But as has already been seen with the ET Rover project, the proposed location of the pipeline may be changed.  There are several critical hurdles for any additional construction of these pipelines, which include: acquisition of rights of way from private or public landowners; local permitting approvals if warranted; and approval by the Federal Energy Regulatory Commission (FERC), which must follow the federal National Environmental Policy Act (NEPA), in particular by provide for a public environmental review process.
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Public Input Opportunities on the ET Rover Pipeline
calltoaction.jpg

Currently, attention is focused on the ET Rover Pipeline which wants to build a new pipeline up to 42 inches in diameter from Defiance, Ohio, through Michigan to Sarnia, Ontario.  The company is seeking approval from the Federal Energy Regulatory Commission (FERC), which must prepare an Environmental Impact Statement (EIS) to weigh whether there are better alternatives to this proposal and whether the environmental impacts are too great to authorize the requested permits.

The first step in the EIS process for ET Rover is for FERC to take public comment under the Scoping Process.  Scoping is an initial step in the EIS in which the public needs to raise questions, concerns, provide information and other knowledge that ensures that the agency considers all the questions that need to be addressed.  The comments can be broad, such as this EIS needs to fully consider impacts of climate change related to the increased use of natural gas connected to increasing delivery of natural gas to Michigan and Ontario.  Or these comments can be very localized, for example indentifying sensitive ecosystems or raising specific, local health concerns. Most important is for ALL concerns or questions to be raised now, or they may not be considered in the EIS.  You don't need to be an expert to offer input, and asking questions about issues that concern you as part of your comments is just as valid as providing specific information in the Scoping Process.
Four Public Meetings in Michigan on ET Rover Scoping Process:

FERC has announced four public meetings to take public input on the Scoping process in Michigan (Google maps linked on the addresses):

November 20, 2014 at 6 p.m.
George Prinzing Auditorium
500 Washington Street
Chelsea, MI 48118

December 1, 2014 at 6 p.m.
Adrian High School Auditorium
785 Riverside Avenue
Adrian, MI  49221

December 10, 2014 at 6 p.m.
Holiday Inn Gateway Center
5353 Gateway Centre
Flint, MI  48507

December 11, 2014 at 6 p.m.
Maniaci Banquet
69227 North Main Street
Richmond, MI  48062


Written Comments on ET Rover Scoping Process:

 The public can also provide written public comments by December 18th through FERC's online comment system or through regular mail. Below are instructions on how to file a comment on the proposed ET Rover Pipeline with FERC. Filing just a written comment as an individual does not require you to register as a user.

                Go to the FERC eComment website. (www.ferc.gov/docs-filing/ecomment.asp)
                Click on the eComment button, which takes you to an authorization page.
                Enter your name and email address, and type in the “authorization” letters / numbers that appear.
                Click on authorize.
                FERC will send you an email. Click on the link in the email.
                You should be taken to a page on the FERC website with your name and email filled in.
                In the field for “Enter Docket Number” type PF14-14 (no spaces)
                Click on the Search button.
                Click on the blue cross in the far right column under the heading labelled “Select”
                Enter up to 6000 characters in the box for editing a comment.

Provide written public comments by US Mail by sending your letter and 14 copies to arrive before December 18th to:

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E. Washington 20426
.
Sierra Club Contacts:

Below you'll find Sierra Club volunteer leaders in each of the four regional Michigan Chapter Groups that are already tracking and working to stop the massive natural gas pipeline proposals coming through southeastern Michigan.  In addition and if you are outside of these Groups but wish to help, please provide us your information by linking below the contact info.  We'll do our best to keep you apprised of the new developments.

Nepessing Group (Genessee County, Lapeer County and Northwestern Oakland County)
Ellen Waara (ellenwaara (at) gmail.com) 

Southeast Michigan Group (St. Clair County, Macomb County, part of Oakland and Wayne Counties)
Jean Gramlich (jeangramlich (at) msn.com)

Crossroads Group (Livingston County and western Oakland County)
Ron Kardos  (rmichael (at) sbcglobal.net)

Huron Valley Group (Washtenaw, Lenawee, and Monroe Counties)
Nancy Shiffler




PLEASE USE THE LINK BELOW TO SIGN UP FOR UPDATES ON THESE PIPELINE PROPOSALS

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Sunday, November 2, 2014

Forum on the Dangers of Oil and Gas Operations, Industrial Agriculture and the Enabling Political System

CHANGE: Due to scheduling problems, only Prof. Kauffman will present!
I invite all readers of this blog to an event at the University of Michigan, Dearborn Campus, College of Arts, Sciences, and Letters (CASL) building, room 1030.on Tuesday, November 18, 4:30-6pm.



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Program:

C. W. Kauffman, Retired, Professor, Retired, Department of Aerospace Engineering, University of Michigan
"Fire and Explosion Hazards for Hydrocarbons" and a few words about "The Current Corrupt Political Environment".


Victoria Powell. Retired Pediatrician, "Health Risks Associated with the Fracking Process".

Thomas Wassmer, Ph.D., Assistant Professor of Biology, Siena Heights University, “Risks for Water, Soil and Air Integrity Caused by Oil and Gas Extraction from Deep Shale.”

Pam Taylor, retired high school teacher, International Baccalaureate program, business, and math teacher, "CAFOs – concentrated animal feeding operations".
 

And a representative of the Adrian Dominican Sisters on Ethical Issues of the Oil and Gas Extraction from Deep Shale.

Thursday, October 2, 2014

Oil Pump in Heritage and Flare in Witt Farm Cause Still Stink

Despite repeated comments by the Michigan Department of Environmental Quality that neither oil pumps nor the flare on Witt Farm should smell as this would indicate that something is not working properly, operations just go on as normal, and without any demands or repercussions for Savoy Energy - neither from the Michigan DEQ nor the EPA.

This confirms what I thought all along: There are no legal instruments to regulate this industry - they can basically do as they please.

Unfortunately, oil and gas operations are not the only effectively unregulated industries. The same is true for water pollution e.g. of the River Raisin. In 2008, the EPA found that most of the South Branch River Raisin has highly elevated coliform bacteria levels - way above the standards for safe partial body exposure (as in walking the river in protective waders). The law only required the river to be "flagged" for this dangerous condition - without anybody needing to come up with a solution or any steps towards fixing the problem.
Guess what? The problem does NOT vanish on its own with mega diary CAFO farms upstream and broken sewage systems everywhere. With my students I repeatedly measured more than 70,000 colony-forming-units of coliform bacteria two years in a row. That is more than 100x the safe levels for partial body exposure. Again, there are no legal instruments to pinpoint the culprits and fix the issue. Let us just wait until some flesh-eating strain of E. coli appear and somebody gets killed...

Does it really take that for people to wake up and realize that there is nobody to take care of you and rescue you if you do not take matters into your own hand??? It should be different - there should be laws protecting our health before commercial interest - but there aren't any - unless people demand them!

We would not have an EPA, a Clean Water Act and Clean Air Act today if there had not been massive protest in the 1970s. Since then, people went asleep - thinking all is fine now. Unfortunately, the EPA became an almost broken and powerless institution and the Clean Water Act and Clean Air Act were watered down and many exemptions were created. We are slowly in more need of a massive protest movement than in the 1970s but it seems people became more oblivious and delusional and it will probably take more than burning rivers and lakes to get them away from the latest sitcoms and newest sport scores and realize what happens every day. For heaven's sake, if not even the breakdown of Toledo's drinking water supply for several days due to agricultural wastes wakes up the masses - what does it take to wake people from this slumber?

Sunday, August 31, 2014

New pipeline from Witt Farm to Wells off Spielman Rd Under Way

Savoy seems committed to use up the maximum of 10 wells permitted to be processed on Witt Farm and builds a new pipeline crossing M52 and going below Beaver Creek by horizontal drilling. There are currently 7 wells connected to Witt Farm and most of the natural gas is still flared off...

Sunday, July 27, 2014

Flaring of the Majority of Natural Gas Continues on Witt Farm

I need to come back to this part of my comments of the EPA findings posted earlier as this matter might have gone under the findings of leaks.

On page 3, paragraph 4, is stated that in contrary to earlier statements, only propane, which is only 20% of the natural gas produced from 7 or 8 wells is captured and used (Savoy's own gas analysis reported here). The report further states: "Methane and ethane are pulled off the propane tank and used as fuel gas for various pieces of equipment at the facility." Methane and ethane together contribute to 47% of the natural gas harvested in the 7 or 8 wells connected to the central processing facility on Witt Farm. I doubt very much that all of this gas is put to good use - how much machinery needs to be powered day and night? I suspect that either machinery is running just to consume these gas components - constituting a waste of energy and unnecessary carbon dioxide production (global warming!). Alternatively, methane and ethane are still flared off quantitatively. This is the more likely scenario as the hidden flare still shows a lit of flickering and shimmering air showing a lot of heat production at all times.

The more than likely still ongoing flaring of almost half of the natural gas of 7 to 8 attached wells is a massive waste of energy and absolutely unnecessary production of  greenhouse gases increasing Adrian's impact on global warming! I hope we can trust the glycol dehydrator equipped with a condenser to trap VOCs (volatile organic compounds) especially BTEX (benzene, toluene, ethylbenzene and xylene), which are especially poisonous and cancerous and had driven my concerns in previous posts about the flaring on Witt Farm leading to a meeting of city and county officials, the DEQ, and concerned citizens on February 21 2014 reported here.
Even with these health threats being gone or reduced, the DEQ should not allow the ongoing waste of perfectly usable natural gas! I will especially inform Kristie Shimko about these concerns.

Reference:

According to CAUSE 18-2007, a order of the DEQ Supervisor of Wells, the allowable amounts and duration of flaring within the Trenton and Black River formations are specified. These procedures were agreed upon in a discussion between the DEQ and the following oil and gas companies: Continental Resources, Inc.; West Bay Group; Savoy Energy LP; Trendwell Energy Corp.; Matrix Exploration & Development, LLC and Titan Energy, LLC.
“Gas that is not reasonably marketable may be flared. The volume of gas flared is restricted to 100 MCFGPD (100,000 cft gas per day) for a 40-acre drilling unit or 50 MCFGPD for a 20-acre drilling unit, which shall be the net volume of gas flared not including gas used for reasonable and necessary lease fuel purposes. The permittee of a well that is flaring gas shall, within 30 days of a letter of request from the Supervisor, submit to the Supervisor data necessary to determine whether the well can economically market gas. If data is not timely submitted to the Supervisor, the Supervisor may require the permittee to cease the flaring of gas. Based upon the data supplied by the permittee and other information available to the Supervisor, and after meeting with the permittee as necessary, the Supervisor or his authorized representative shall determine whether gas from the well can be economically marketed and shall inform the permittee in writing of that determination. Within 90 days of a determination in the affirmative, or at such later date as the Supervisor may specify, the permittee shall cease the flaring of gas from the well. If the permittee disputes the Supervisor's determination, the permittee may file a petition and request a hearing; but the filing of such petition shall not stay the effectiveness of the determination. If the Supervisor determines that gas from the well cannot be economically marketed*, the permittee shall be allowed to continue flaring gas at the rate specified above. Permission to flare does not grant an exception to any other required permits or approvals.
*Marketing of gas be deemed not economic when an operator provides reasonable evidence to the Supervisor that the cost to connect a well to a pipeline or facility for the transportation and processing of gas will take in excess of two years to pay out based upon the average monthly natural gas production sales.
Get the full PDF-document here.

Friday, July 25, 2014

Results of EPA Findings Not Reported by the Daily Telegram and Toledo Blade

Despite my efforts to share the news-worthy information about leaks on Witt Farm with the two local news outlets Daily Telegram and Adrian Today, which should be of considerable public interest, nothing was reported to the public yet. I guess the City of Adrian's appearance in the light of development projects as the large assisted living complex on Witt Farm and the fear of declining property values are more important than health and environmental concerns. I wonder if this "Looking Away" strategy will continue when the findings will be openly and officially called violations of the Clean Air Act, adding Adrian and Savoy Energy to a short list of illustrious environmental violations.

Edit: Adrian Today reported about this topic on July 25: http://adriantoday.com/2014/07/25/epa-report-inspectors-found-vapor-leaks-at-adrian-oil-plant/1039
I also informed the Toledo Blade about the EPA findings and had a brief email exchange with their reporter Tom Henry but there is still no report about this in the Toledo Blade as well.

Monday, July 21, 2014

ARD Final Response

Today I received the below email from Natalie Topinka from the EPA in response to my email sent on 7/18 published at the bottom of my post: http://adrianoil.blogspot.de/2014/07/infra-red-videos-taken-by-epa-show.html


Tom,


Glad you received the report and were able to view the IR camera videos just fine.


To clarify, the inspection of Savoy Energy's Adrian 25 facility on 4/28/14 is one part in EPA's Clean Air Act enforcement process in which we gather information to assess a facility's compliance. Typically, after an inspection, the EPA inspector writes a report to document facts and observations gathered during the inspection. Within this report, a compliance determination (that is, a finding as to whether or not the facility is in compliance with or in violation of Clean Air Act requirements) is not made. We may gather more information through written requests to the company (to which the company is required to fully respond), conduct independent research, and review potentially applicable regulations. Then we compare our observations and information to the applicable regulatory requirements and determine if the company is violating any applicable regulatory provision. If so, we will write up the specific violations in a Notice or Finding of Violation and notify the company, then make the notice publicly available at: http://yosemite.epa.gov/r5/r5ard.nsf/fa120e741359b6cf8625759a00455537!OpenView.


For Savoy Energy, the case is presently in the information-gathering stage. Therefore, it would be inaccurate at this point to say "EPA found violations," since no such determination has been made. You'll note that this is contrary to a statement made by one of our FOIA officers in an e-mail to you. Your FOIA request asked for a "report on violations of the clean-air act," and I wanted the officer to clarify to you that because EPA had not yet made a compliance determination, technically there was no such report responsive to your request. However, I knew you were referring to the inspection report and videos so I produced those documents to be sent to you. Unfortunately, the FOIA officer (who is not involved in any way with enforcement investigations but simply helps to organize documents to be released under FOIA) misunderstood me and wrote, "[Even though EPA found violations at the site] a compliance determination has not yet been made, so there is no report on violations of the CAA." The part in brackets (my emphasis) is simply a clerical error. I apologize for the confusion.


At this time, we can't speculate or comment on possible future actions, as all investigations are considered enforcement confidential, but we are keeping up with your blog and are hearing your concerns loud and clear. Please feel free to give me a call any time if you have further questions.


Thanks,


Natalie

----------------------

Natalie M. Topinka

Environmental Scientist

U.S. Environmental Protection Agency, Region 5

Air Enforcement and Compliance Assurance Branch

77 West Jackson Boulevard (AE-17J)

Chicago, IL 60604

ph: (312) 886-3853

fax: (312) 692-2410


Protecting the environment is everyone's responsibility. Help EPA fight pollution by reporting possible harmful environmental activity. To do so, visit EPA's website at http://www.epa.gov/compliance/complaints/index.html

Saturday, July 19, 2014

My Comments of the EPA Report on Violations of the Clean Air Act by Savoy Energy on Witt Farm

On page 3, 2nd paragraph the EPA inspectors wrote: "Mr. Rokos [Savoy's Operations Manager] stated that the pilot light is checked two or three times per day to ensure that it remained lit."
I wonder why every home appliance needs to have a failure-proof pilot or a gas shutoff but industrial equipment used in oil processing does not - even if within a residential area.

Also on page 3 right below the above sentence it says: "Vapors from the tanks' headspace are piped to the flare at ambient pressure (no fan or pump is used to draw vapors from the tanks to the flare)."
Seems to me like cutting corners again just to make profit with the least investment / why is no such equipment used and why is this permittable?

Below the above sentence, still on page 3: "Since the system uses a common collection line, vapors from each individual tank can flow to the headspace of any other tank." Again, this sounds like a less than appropriate setup.

Also on page 3, paragraph 4, is stated that in contrary to earlier statements, the natural gas is NOT entirely used but only the propane portion, which is less than 20% by weight, and only 12% by molecular percent (Savoy's own gas analysis reported here). The report further states: "Methane and ethane are pulled off the propane tank and used as fuel gas for various pieces of equipment at
the facility."
Methane and ethane together contribute to 47% of the natural gas harvested in the 7 wells connected to the CPF. I doubt very much that all of this gas is put to good use and suspect that machinery is running to consume these gas components or they are still flared off if they are not gased off elsewhere. The report mentioned nonchalantly, that previous to April 8, 2014, all gas was flared off - which lasted for more than a year and was a scandalous waste and unnecessary air pollution just because Savoy could not make enough money from capturing the gas before the severe winter of 2013/14 raised the prices for natural gas and propane.

Before going to page 4, I want to state some principle shortcomings of all environmental inspections in Michigan and many (if not all) other states.
1.) Inspections have to be announced, giving the inspected companies more than enough time to fix shortcomings they are well aware of, thereby inspections show the best possible operation practices and are not representative to every day operations.
2.) Business owners have to permit access to their site. I suspect that the EPA could have applied for a court order to go in - thus adding additional time for companies to prepare unrealisticly good conditions before inspectors arrive.
3.) Compare 1.) and 2.) to unannounced inspections of small restaurants by the health departments. The difference in procedures make no sense!
4.) Findings during inspections can be held back by the companies declaring them as confidential business informations.
All these restrictions clearly undermine the public interest of immediate, unbiased inspections to prevent threats of human heath due to environmental pollution and threats to the environment and ecosystems.

Page 4, 1st paragraph: Savoy's operation's manager Jack Rokos was in charge to allow the EPA inspectors to use equipment solely used to detect leaks. I think the EPA should have the right to use this equipment even without permission!

Page 4, paragraph 2 states "a few small leaks at the compressor" shown in videos and photos. In paragraph 3, leaks in two of the four oil tanks were found. Again, remember that they are all connected - meaning that already one leak is sufficient to vent all 4 oil tanks into the "clean 100% pure Michigan air".

Page 4, paragraph 4 states leaks on 3 out of 4 water tanks, with massive venting of fumes that made the inspectors move out of the area.

To really value the significance of these leaks, I want to remind my readers that what you smell as bad odor is only a warning that with theses smelly fumes, odorless poisonous and cancerous volatile hydrocarbons are vented off into Michigan's Clean Air - and thus threaten the health of at least the closest neighbors. Refer to the legend of photo 1 on page 5: "Note the proximity of the house and public highway to the facility".

In paragraph 5 on page 4, the EPA inspectors state: "All leaking components at the compressor and
from the thief hatches and pressure relief device were pointed out to Savoy representatives."

The question now is: Did they do anything about it - or do they just continue to leak poisonous and cancerous compounds?

In the last paragraph of page 4 - under Closing Conference, the EPA inspector writes: "I expressed concern that the pressure relief valves and thief hatches were not properly weighted to ensure that
vapors are first directed to the flare, then to the Enardo pressure relief valves in the case of an overpressurization event, and then to the thief hatches, in that order."

Mr. Rokos of Savoy Energy stated that "he would have the thief hatch seals inspected and add additional weight to the hatches to ensure that they were not venting at pressures lower than necessary."
This does only seem to address some of the inspector's concerns - and what is meant by "not venting at pressures lower than necessary"? It seems to me that the system should direct any elevated pressure - and the causing gas and volatiles towards the flare and NOT vent them into the air. I hear some of the industry's typical arrogance - thinking that they can do whatever they want to do...

Even if Savoy does what Mr. Rokos indicated, how is this monitored or followed up with when the presented document is still a "internal report" and no official reporting was issued and passed on to Savoy Energy. For God's sake, this is 3 months after the inspection that objectively found VIOLATIONS. I wished I would have that much time to pay for a parking ticket or other MINOR issues compared to air pollution...

Even worse, when the EPA finally comes up with a fool-proof report (to avoid being sued by the wealthy oil and gas lobby given that the EPA is an almost bankrupt government institution) - the report will first go to Savoy before any fines or penalties are set. This sounds like Savoy is good to go and continue to improve Michigan's Clean Air for a long time to come. Maybe the City of Adrian should put a PURE MICHIGAN sign next to Savoy's Central Oil Processing Facility on Witt-Farm.

Infra-Red Videos Taken by the EPA Show Several Leaks on Witt Farm

In my last post I published the EPA's preliminary report about violations of the Clean Air Act by Savoy Energy on Witt Farm in Adrian. On the last page of the report is a table detailing some videos taken on sit showing several leaks in the equipment. I published all these videos on YouTube.

IR Video Log
Video ID number    Description
MOV 0442.mp4    Leaking Enardo valve above NW oil tank YouTube
MOV 0443.mp4    Leaking Enardo valve above NW oil tank YouTube
MOV 0444.mp4    Leaking thief hatch on oil tank YouTube
MOV 0445.mp4    Leaking thief hatch on oil tank, obscured YouTube
MOV 0446.mp4    Latter part of video show s leak on SE oil tank thief hatch YouTube
MOV 0447.mp4    Leaking thief hatch on SE water tank YouTube
MOV 0448.mp4    Leaking thief hatch on SE water tank YouTube
MOV 0449.mp4    Leaking thief hatch on SE water tank, viewed from ground level YouTube
MOV 0450.mp4    Leaking thief hatch on water tank YouTube
MOV 0451.mp4    Leaking thief hatch on water tank YouTube
MOV 0452.mp4    Flare YouTube
MOV 0453.mp4    Leaking thief hatch on water tank poor video quality YouTube
MOV 0454.mp4    Deleted - recorded in error - no image
MOV 0455.mp4    Leaking compressor component YouTube
MOV 0456.mp4    Leaking compressor component YouTube
MOV 0457.mp4    Leaking compressor component YouTube
MOV 0458.mp4    Leaking compressor component YouTube
MOV 0459.mp4    Leaking compressor component YouTube

I wrote to the EPA inspectors the following email:

I received the print version of the report and the CD. Thanks a lot!
Just to verify, the violations were found 4/28 but until today 7/18 no actions were taken and most probably the same kind of leaks are still going on. In addition, it is not certain that Savoy will ever receive a citation or fine for this and might not have to stop venting these fumes shown in the IR videos.

Thanks in advance for clarification!



Thursday, July 10, 2014

Preliminary Report of the EPA about Violations of the Clean Air Act on Witt Farm

I received the following today:

07/10/2014 11:00 AM
FOIA Request: EPA-R5-2014-007747
Mr. Wassmer:
Attached is the final response letter from the Air and Radiation Division. Your responsive document will be sent via postal mail which you will receive in the next few days. Even though EPA found violations at the site a compliance determination has not yet been made, so there is no report on violations of the CAA. We are sending the inspection report along with some videos since this is all we have. If you have any questions please feel free to contact our office.
 Here is the link to the documents:
I attach the PDF below:
 
 
I do not have access to the IR videos showing the leaks yet but will share them on Youtube ASAP.