Below are questions and comments that arose from the meeting at the County Health Department. Questions were answered by Kristie Shimko and Sersena White from the DEQ or followed from documents provided by Kristie Shimko. Some answers are edited or extended by me.
- Q: Are flares permitted to burn 100,000 cft per well and per day?
A: 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. - Q: There is no permit needed to flare off natural gas for as long as it takes, even if the flare gas contains benzene and other toxic and cancerous compounds.
A: No answer by DEQ – I guess this answers that there is no additional permit needed as follows from 1.) above. My search for the name the industry uses for flares enclosed in open oil tanks, I found several commercial combustion tools that ensure better and cleaner burns (e.g. mrw-tech.com, abutec.com). It seems that the Michigan DEQ does not require such cleaner technologies. - Q: There should not be any odors (and no elevated levels of volatile/gaseous pollutants) from any well-burning flare, oil well, or oil pump. A well-burning flare should also produce no soot. Flares should be maintained so the burn at least 96% of the combustible compounds.
A: No odors should occur and should be reported. If odors occur it indicates a less than proper burning rate of at least 96% and thus more unburned pollutants that might not have an odor at toxic levels (such as benzene). The Witt Farm flare smells almost every day and is thus most of the time burning way below 96% efficiency. - Q: The current air quality application is only concerned with Savoy's plans to send off the currently flared gases to the tank farm on Tipton for commercial use?
A: Savoy applied for a permit to finally capture and market the gases coming in to the Witt Farm (Adrian 1-25) from currently 7 wells. The current air quality application is concerned with the proposed installation of any piece of equipment that will emit an air contaminant. And those pieces of equipment are a glycol dehydration unit and an internal combustion engine. The company is also proposing a refrigeration unit but it is totally enclosed and thus has no emissions to the ambient air. - Q: The current application might be held back because the presence of benzene, too much water and to high BTU. The levels of toxins that I received from you in a table are levels that only matter for the permit process of marketing gas - not for flaring?
A: The current application will be evaluated with respect to the presence of benzene in the gas intended to be marketed, its relative high water content and a higher than permissible BTU to determine if their proposal will comply with applicable rules. This might delay the marketing of the gas and keep the flare going. - Q: Flaring will still go on even after marketing the gas if there is more gas then can be send to commercial use or if there is a technical problem preventing to send off the gas?
A: The flare will remain at the site for any of the following reasons:
* flaring off gas in the event of an emergency
* flaring off gas for equipment maintenance
* it may possibility be needed as a control device to ensure compliance with a rule (this will be determined in the upcoming technical review). - Q: The DEQ does not and will not monitor the Adrian 1-25 (Witt Farm) flare and discouraged the county, city or an independent monitoring due to the difficulty to relate potentially high levels of benzene 500 meters away from the flare to actual health issues.
A: DEQ-AQD did not intend to discourage the county, city or any independent monitoring entity from pursuing air emission risk assessment monitoring. AQD only intended to inform those present of the types of details and the length of the project for conducting a risk assessment monitoring project. The allowed air emissions of benzene as identified in the air toxics attachment is 0.1 µg (micro grams = 1 millionth of a gram) per cubic meter of air at or beyond the property boundary on annual averaging time. An approved permit to install for regulated emission units at this site would require this limit is met.
Reference: Michigan Department Environmental Quality - Air Quality Division List of Screening Levels (ITSL, IRSL and SRSL) in Alphabetical Order. - Q: What are the costs for a well permit, a tank farm permit, a brine disposal permit? Are there any independent and unannounced water and air monitoring procedures done or initiated by the DEQ that Savoy has to pay for? If yes when? Baseline, every month???
A: The cost for an oil well/brine disposal well permit is $300. There is no cost for a tank battery [like Witt Farm or Adrian 1-25]. A permittee of a well shall submit secondary containment plans, for approval before construction of a facility. After construction completion and before the facility can be put in operation, the permittee must submit: a statement certifying that the facility was constructed in accordance with the approved plan; the results of initial pressure testing of the piping; approved spill or loss response and remedial action plan; a water sample to establish ground water quality. Testing of the flow lines and underground piping is required annually. Secondary containment (ground water) monitoring is required every six months. Savoy contracts the flow line pressure testing and ground water sampling to qualified, independent third parties. DEQ can and will collect soil, groundwater and/or gas samples if deemed necessary. - Q: How much money does Savoy have to put into an emergency escrow account to pay for the cleanup and containment of well, pipeline, or trucking spills?
A: Savoy has a $250,000 bond on file with the Office of Oil, Gas and Minerals. [This money will not reach very far in case of a major spill – and who will pay for the rest? I am sure that will be the tax payer…Another example of corporate irresponsibility and the principle of externalization that takes advantage of everything true and trustworthy and undermines what we all learned as kids: if you make a mess you clean it up!] - Q: Are there any drills and exercises between all involved agencies and departments to make sure that the emergency responders are well prepared to contain and cleanup spills and other accidents?
A: OOGM encourages the oil company to equip/relay knowledge of the wells and facilities with the local fire department/responders. [I guess this is a good thing but it does not seem to be reinforced and might not happen in most cases making emergency situation even more dangerous…] - Q: What are the rules about drilling wells close to rivers and lakes? I already know that pipelines up to 5 inches diameter do not need a permit to go under a river or through wetlands.
A: As long as the well pad does not encroach upon a river/lake, it can be constructed. As long as sediment does not enter the water/stream/lake, they can construct the drill pad. [This seems to also just waiting for an accident to happen that will leave many people without potable water – actually something we saw happening in West Virginia this year, and something that happens for many people in Texas, Colorado, Wyoming and other states where hydraulic fracturing (fracking) adds to the problems we are facing here in Adrian and SE Michigan.
Are you a petrol engineer? I think not, so stop your blathering Mr. Wassmer. You have long ago lost whatever credibility you had on the subject matter with the banal tones and unscientific presentation of this so-called blog.
ReplyDeleteFirst of all - who are you to judge that my dealing with these topics is not credible and banal and blathering. What is your expertise, Mr. or Mrs. Anonymous? I actually regret to allow this comment through as it is in all reality an attack on my integrity and does not make any substantial argument and case and neglects as such the blog rules. I guess I am so pleased if posts like yours at least follow normal netiquette in terms of correct use of the English language and avoiding cursing...
DeleteA last point: you might think that only petrol engineers are eligible to make comments and discuss what the petroindustry does but that is not so. In contrary, most petroengineers are biased in environmental issues as they fear to lose their jobs if they are known to criticize current oil and gas operations. Environmentalists, on the contrary, do not gain from their activism and are thus more trustworthy!
Tom
Mr. Anonymous, Professor Wassmer's Integrity is what drives him to be a leader on this subject. Ms. Shimko and White although good people, MUST say what the Corrupt DEQ Management tells them to or lose their jobs. I worked for the DEQ for 31 Years and my honesty and outspokenness made me a target for Management's abuse, as did a number of other DEQ senior scientists who opted to retire to escape the abuse. If I can smell the gas from the Wittmer Farm location driving by at 55 MPH , there are DEFINITELY health and enviromental dangers!! ~Allison MacArthur-Ruesink
ReplyDeleteMs. MacArthur-Ruesink...Please detail the gas smell from the Witt Farm processing site that you have experienced...Thanks.
ReplyDeleteShe can't because it doesn't exist. I have driven by many times in different times of day and weather conditions and there is nothing.
ReplyDeleteThis is a great article on why the oil booms are good for the economy...keep an open mind. This type of entrepreneurship is what makes our county great...not socialist over regulation....
ReplyDeleteOil booms have always been transitory affairs.
In 1859, thousands followed "Colonel" Edwin Drake into the Pennsylvania forest after America's first major oil well was discovered near Titusville. In 1901, people flooded Beaumont, Texas, when Spindletop gushed.
In 2010, Amy Savage migrated from her native Michigan to western Pennsylvania, chasing the Marcellus Shale boom.
The plan was to move to Pennsylvania and expand the small trucking company she ran with her boyfriend in Michigan. Four years later, she sells millions of dollars worth of fireproof clothing and safety equipment out of two retail stores, with a third on the way.
How she started: Back in Michigan, Savage, 32, and her boyfriend owned a company that specialized in moving oil field equipment from well to well. They had three flatbed trucks and a handful of employees.
But Michigan isn't a huge oil-producing state, and things were relatively sleepy. The Marcellus -- the vast, gas-rich geologic formation under the Appalachian Mountains -- was a whole different story. Fracking had unlocked vast new energy supplies, and a boom was in full swing.
The boom has been an economic jolt not only to Western Pennsylvania but parts of Texas, Colorado, North Dakota and Ohio. And it isn't just big oil companies that benefit. The conservative Manhattan Institute estimates that 20,000 small and midsized firms related to the oil industry have injected $300 to $400 billion into the U.S. economy over the last few years.
Savage was well-poised to take advantage of that. The idea for her new business hit her while she was trying to buy fireproof hooded sweatshirts to give her trucking employees for a training event.
"There just wasn't a store around that offered this clothing at worker prices," she said. Later, a customer told her he'd driven two and a half hours to find proper work boots.
She moved quickly. In January 2012, she wrote a business plan, and then used $50,000 in savings to rent space in a former hair salon and buy inventory -- hard hats, gloves, safety glasses, work boots and flame-resistant clothing. In April 2012, she opened Oil and Gas Safety Supply in Washington, Pa.
How it grew: Sales were brisk from the start. The hard part was figuring out what the workers wanted and keeping up with inventory. She polled friends, asked customers for advice, and looked in field manuals for the type of gear oil and gas companies required. She wanted to carry name brands like Carhartt, but didn't have the $10,000 required for an initial order. That would soon change.
Savage sold $500,000 in her first year. She put all of it toward inventory and opening a second, larger location 40 miles away in St. Clairsville, Ohio. In 2013, sales topped $2 million. She's opening a third store in April and expects sales to hit $3.5 million this year. She continues to invest the profits into inventory and expansion.
Savage has made a point to cater to what her customers need. For example, she now has a truck that delivers orders directly to the job site and she designed her own line of specialized clothing.
She also only hires women in her stores, because she says they "better connect with the clientele."
Savage knows that someday the boom will end. The wells will be drilled, the workers will move on. She doesn't let it get her down.
"I figure we have at least another 10 years," she said.
View this article on CNNMoney
On Monday March 10th ~5:30 pm driving north on M-52. Moderate wind, you could check weather records for more specifics. I have noted gas odors at this location many times returning home after babysitting a grandchild on Wednesday evenings, and at other times.
ReplyDelete~Allison MacArthur-Ruesink