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!

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:

https://foiaonline.regulations.gov/foia/action/public/view/request?objectId=090004d2802bc855

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.

EPA Found that Savoy Violated the Clean Air Act on Witt Farm

On April 27, Victoria Powell told me that the EPA will conduct a site visit on Witt Farm. Unfortunately, I did not hear anything else about it and there was no report about this in the local news. I therefore decided to write an email to the EPA on 5/12/2014:

"To whom it may concern,

It came to my knowledge that the EPA was called upon and visited what the Michigan DEQ calls Adrian 25, a central oil processing facility within city limits that flared off the natural gas of up to 7 oil wells for more than a year, mostly burning unclean. I reported about this on my blog, e.g. http://adrianoil.blogspot.com/2014/03/will-city-county-or-deq-do-something.html. I did not see any official confirmation of this site visit that supposable happened on 4/29/2014 and nobody contacted me about any details that could be added to a ongoing investigation.
My questions are now: was there a site visit and what if anything will happen? If you need a chronology of the violation, please consult with my blog or respond to this email.


Thanks in advance, Tom"


About two weeks later I received a voice mail from one of the EPA officers that were on site. I returned the call a few days later and was told that the EPA found violations of the Clean Air Act on site and that it was caused by leaks in the system - not as I expected from the flare. The officer did not want to provide me with more details but suggested that I file a Freedom of Information Act
(FOIA) request around June 15, when the final report should have been filed. This sounded reasonable and on June 24th I filed my request EPA-R5-2014-007747 asking for expedited processing due to potential health risks and my plans to inform the public. I was shocked that my request for expedited handling was refused 6/27. I was hoping that the report would still come in reasonable time but I am getting tired of waiting and therefore wrote the below email to the EPA today:

Subject: FOIA Request: EPA-R5-2014-007747 / RE: Fee Waiver and Expedited Processing Determination
 

"To whom it may concern,

I am very disappointed with the decision of the case officer. I clearly stated in my application that I intend to disseminate the information to the general public via my local blog adrianoil.blogspot.com that is subscribed by many Adrian citizens and any other channel that I have - including my media contacts. I also clearly stated that the report should be made available IMMEDIATELY (that means expedited!) as the EPA investigation found serious violations of the clear air act on the site and it is my understanding of democracy and environmental justice that people living close to the facility should know about existing health threats NOW and not half a year later!
As this is not the first and only clear misjudgement by environmental authorities that should safeguard our citizens and the environment I am slowly seeing how people can think that the Michigan DEQ and the EPA are biased or severely undermined by polluting industries.
I EXPECT to receive the report without further delay and without fees the latest by this Monday! I will disseminate this letter on my blog - and I will as well cite the officer from the EPA, who gave me the information on the findings of violations on site. I promised the officer to hold back until I receive the final report but due to your agency's policy of delaying information that the public has a right to know - I will now post what I was told more than a month ago!"

I am seriously hoping to get this report soon and I will disseminate it here and send copies to the media.

A tribute to a great man, Terry Greenwood - Reblogged from the Gasland II Newslist

Terry Greenwood was one of the most compelling people you could ever listen to.  There was just something about the way he spoke, there was a decency and a positivity that shone through every word no matter how distressing or disturbing the subject matter was.  It was as if when he spoke about the things that troubled him, he was still conferring a lightness to you, a gratitude to the person listening.

Some people just manage to bestow a great humanity and great respect onto you while they are talking.  Terry was one of those people.  When you listened to Terry you felt like a more generous person somehow, he just made you want to listen, and made you want to help.

Honesty, decency, generosity, care, love.  These are the words that spring to mind when you listen to Terry. And his wife Kathy, will crack you up and then will feed you and feed you until you can barely get up off the chair.  And those damn amazing red white and blue suspenders!  You know you are the genuine article if you can get away with those.

I've never released this interview I did with Terry Greenwood in 2009 or 2010 but I am sure you will hear the tone that I am talking about in his voice.  And i hope, it gives you a sense of the man and how much he loved his farm and his life.

  

VIDEO IS HERE:
https://vimeo.com/98104966

He had been speaking openly and publicly about how 10 of the 18 calves that his cows gave birth to died just after birth or were stillborn and how he was very worried that it had something to do with the fact that fracking fluids and other substances had leaked into the pond where his cattle drank.  I had head his story in the press and heard him speak about it in person, and I had heard of many stories of animals in heavily drilled areas from Arkansas to Colorado- of cows and goats who were failing to breed or who were having stillborn calves and kids.  Terry was deeply troubled at the loss of so many of his calves, but more than that he was troubled by the fact that he felt his well water and springs had been contaminated by drilling, spills, leaks and fracking.

The interview speaks for itself.  I am uploading it as a tribute to Terry and as a testament to everything he stood for.  One of my favorite moments in any interview I've ever conducted is when Terry says "Money, money money!  Our lifestyle wasn't about that.  We worked hard for what we got, we didn't need it handed to us."  It's a declaration of values that we can all only aspire to.  Terry was saying what so many of us know and what we wish was more prevalent, that there are some things worth more than money, and one of them is decency. 

When I heard, a few months ago that Terry had been diagnosed with brain cancer, I went to see him.  In late March, he was having some trouble speaking, he was a bit weak, but his eyes were still telling you everything.  He was still fighting, he was still positive, he was still going to find a way to make you smile.  And as usual Kathy fed us amazing food until we could barely get up and packed the car with Western PA special buffalo chicken and pretzels n that n that n that.

In the last days, recently, when Terry was in the hospital, we were all asking what we could do to help.  Terry simply said, "Tell my story."

So what does that mean?  Does it mean tell the story of how gas companies barged onto his land?  Does it mean speak about the water contamination they suffered, the insult added to injury when PA DEP ignored his complaints, the death of the cattle, his own death to cancer?  Of course, that is part of the story.

But the bigger part of the story, it seems to me is of the man himself and of his family.  To refuse greed.  To speak truth.  To act with such impassioned kindness, to try somehow to have some of that generous twinkle in the eye, to try to smile when you are talking and to make sure that you are appealing to that inside of us that is most sincere and honest.  That's telling Terry's story.

This was a man who was truly brave, truly courageous in walking out into the public eye to tell his own story.  And this was a man who did it without anger, although his anger would have been justified, who did it without self pity or depression, although no one would have blamed him for either.  This was a man who could never prove all of what was done to him, but could only prove himself to be a good man, and he proved it with each sentence and in every gesture and smile.  For us to tell it now is to try to be as brave, kind, straightforward and loving.

So when we tell Terry's story, try to find some of that mysterious positive charge, that brightness, that giving spirit that we will all miss so much.

We owe you Terry.  We'll miss you brother.
Thank you.
God Speed and I damn sure hope there's Harleys out there where you are.

Air Pollution and Odor Nuisance Continues

How could I believe that Savoy would be done polluting our air when they finally started marketing natural gas from the 7 wells attached to Witt Farm? I received notice of one massive incidence of gas odor and personally reported two other incidents yesterday (April 18) and the day before yesterday (April 17). Kristie Shimko (DEQ) looked into the causes for the April 17 complaint and reported that Savoy is redrilling the Witt Farm well and diverted the  natural gas to the flare. Yesterday (April 18) Savoy reported to have problems with their equipment. The flare did not seem to burn but the odor on Howell Hwy was horrible. Seems that lots of gas escaped their permitted dehydrator and compressor - and I guess that is OK...
Not really - but I wonder how much negligence has to be proven to an almighty energy company for the state to be able to fine them for their wrong-doing. My gut feeling is that the DEQ cannot do anything about it - Savoy could report to have problems forever and get away with it. This is absurd and unknown in most parts of the civilized world but not here in the State of Michigan, and The Land of the Free that should rather be called The Land of the free Corporations.

Fracking Rap

http://www.youtube.com/watch?v=_CXS1LO-gXk