Read the Extra Safeguards Plan Commission Is Considering for Dallas's First Gas Drilling Site
After hearing from the public and discussing the issue at great length last Thursday, the City Plan Commission stopped short of recommending an SUP for XTO Energy to drill for gas at Hensley Field. It would be the first drill site for natural gas in Dallas proper, and while XTO's Walter Dueease argued that his company is incredibly experienced with safe drilling -- with more than 15,000 wells already in place -- the commission wasn't ready to just rubber-stamp their application.
Commissioner Michael Davis had tough questions for XTO, and let Dueease know Dallas is no pushover. "We don't want to end up a Clearfield, Pa. We don't want to end up a San Bruno. We don't want to end up a DISH, Texas," Davis said last week. "This is Dallas, and we take our zoning permits very seriously."
Commissioner Sally Wolfish grilled Dueease on specifics of a study by then-SMU professor Al Armendariz (and now our regional EPA director), suggesting bigtime pollution from Barnett Shale drilling operations. Gloria Tarpley was concerned about opening the door to drilling in Dallas amid the "existential crisis" the country's facing over gas drilling.
But Commissioner Mike Anglin -- an appointee of Dave Neumann, whose district includes the Hensley Field drill site -- distinguished himself as the commissioner who seemed to have taken the most time to get smart about the issue and its potential pitfalls, and presented an amendment with a handful of extra environmental safeguards. Anglin told Unfair Park by email that those conditions "were, in my own view of the case, sufficient to provide for adequate safety assurance at the proposed drill site at Hensley Field," when combined with the recommendations already made by city staff, plus regulations spelled out by the Railroad Commission, TCEQ, the city's drilling ordinance.
While the commission postponed a decision on the SUP until their October 21 meeting, they're taking the month to consider Anglin's amendment in particular, and whether or not it's got the teeth to satisfy their safety concerns. From leak prevention to noise management, read Anglin's amendment for yourself after the jump.
CHEMICAL ADDITIVE REPORTS. At least 10 days prior to commencement of drilling or hydraulic fracturing operations, the Operator will deliver to the Gas Inspector (both as defined in Sec. 51A-12.102.b) a completed Material Safety Data Sheet ("MSDS") containing an accurate inventory of chemicals to be injected into the well bore for the purpose of drilling or hydraulic fracturing, or related well bore activities. Such MSDS reports shall disclose every chemical to be used, including quantities, concentrations, combinations, and formulations, sufficient to satisfy the Gas Inspector that full disclosure has been made. All such reports shall be reasonably available to the public upon request. Any failure or refusal to provide such MSDS reports to the Gas Inspector as provided herein shall be a violation as defined in Sec. 51A-12.105(h) and Sec. 51A-12.109.
EVAPORATION AND LAND FARMING. No open holding or evaporation pits or "land farming" processes (as that term is commonly understood in the industry) shall be allowed on the site, and all operations shall be conducted on a "closed loop system" basis, as that term is defined in Sec. 51A-12.102(5).
DEHYDRATION OPERATIONS. Unless other equivalent means are proposed by Operator and approved by the Gas Inspector, all gas dehydration operations shall be handled by zero-emission separators to minimize fugitive emissions.
WATER HANDLING. Within a reasonable time (to be determined by the Director) the Operator shall transmit a certified disclosure to the Gas Inspector stating the amounts and sources of all water actually used in any hydraulic fracturing operation. Within a reasonable time (to be determined by the Director) the Operator shall transmit a certified disclosure to the Gas Inspector stating the quantity of all flow-back or produced fluids recovered from each will. Within a reasonable time (to be determined by the Director) the Operator shall transmit a certified disclosure to the Gas Inspector stating the final destination of all fluids, slurries and muds removed from the site for disposal or reprocessing.
NOISE MANAGEMENT PLAN. Prior to the issuance of a gas well permit and the commencement of operations, the Operator shall submit a Noise Management Plan detailing how the equipment used in the drilling, completion, transportation, or production of the well(s) complies with the maximum permissible noise levels set forth in the applicable city ordinance. The noise management plan must (a) identify operation noise impacts, (b) provide documentation of a professional 72-hour study establishing the ambient noise level prior to construction at the site (c) detail how noise impacts will be mitigated (e.g., the providing of acoustical absorption walls around the site to shield neighboring uses), considering specific site characteristics, including, but not limited to, the nature and location, proximity and type of adjacent development, seasonal prevailing weather patterns, including wind directions, vegetative cover on or adjacent to the site, and topography of the site.
The Operator shall be responsible for verifying to the Gas Inspector compliance with this condition and with the noise management plan after the installation of noise generating equipment. Approval of such Noise Management Plan by the Gas Inspector shall be a prerequisite to issuance of a gas well permit for the site.
LEAKS. All flow lines, compression equipment and shut-off valves shall be inspected for leak detection at least annually, using infrared cameras, filtered and tuned for the wavelengths of sunlight absorbed and re-emitted by natural gas hydrocarbons, or other equally effective detection devices. Reports of such inspections shall be delivered to the Gas Inspector within 15 days of inspection, and no later than one year following the date of the preceding annual report.
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