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04-26 Minority Report, Gas Well Task Force (1)

04-26 Minority Report, Gas Well Task Force (1)

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Published by: larrymmcbride on Apr 25, 2012
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Minority Report of the City of Denton Gas Well Task ForcePresented to the City of Denton City Council 
by Thomas La Point and Vicki OppenheimMembers of the Denton Gas Well Task Force  April 24, 2012 
We are writing this “minority report” to provide the Denton City Council with viewpoints andinformation on important action items that were not approved by the Denton Task Force. Thecitizen input has overwhelmingly declared that several topics are of great importance to thecommunity: composition of the Task Force and procedures, air quality, water quality, noise,public notification, and facility location and distances. We assert that these topics will beincreasingly important to the Denton community, as gas wells and related facilities continueto locate in a highly urbanized area. The City of Denton population is projected to grow from113,383 people in 2010 and a density of 1194.8 persons per square mile to 207,334 people anda corresponding increasing density by 2030
.Gas production facilities are allowed to locate in all zoning districts, though some facilitiesrequire a Specific Use Permit and others are allowed “by right.” Gas drilling and productionfacilities are an industrial use. They are not treated, however, like most other industrial facilitiesthat would be predominantly restricted by use to industrial zoning districts, unless already inoperation prior to the ordinance or annexed to the City. Gas drilling facilities may locate inresidential neighborhoods and near protected uses, as long as they meet distance requirementsoutlined in the Denton Development Code.
 One other aspect important to development of a revised ordinance for the City of Denton hasbeen the recent concern expressed by the U.S. Environmental Protection Agency (USEPA) onthe contribution to overall poor air quality by natural gas development. It should be recognizedthat Denton is growing in population density. Hence, it is incumbent on the city administrationto seek to protect human health. The authors of this minority report recognize that each wellmust be individually managed by a proper ordinance. However, there must be thought givento the density of wells in an urban area. There should be thought given to optimizing (rather than maximizing) the number of production facilities within the City boundaries. Operationalconstraints, such as incorporating multiple well heads at one site, directional (horizontal) drilling,and such should be considered whenever possible. We suggest that great care should be taken in updating Chapter 22 of the Denton Development
Denton Economic Development Partnership website, accessed April 8, 2012.http://www.dentonedp.com/business_location/demographics_data_population.asp
See Discussion paper by Vicki Oppenheim.
Code to ensure that the best possible practices are implemented for all categories of actionitems, and especially since many wells are located in residential districts.
Issues for Further Consideration Task Force Composition and Procedures
 We feel that the Task Force should have consisted of more Denton citizens, and there shouldhave been more members. This would have allowed better representation from the citizens. A larger Task Force would also have led to more opportunities to learn about gas productionprocesses and fully vet citizen concerns. Task forces in other cities took the opportunities tohave field trips and presentations from both industry consultants and conservation groups. Allthis would be better for public education.
 Air Quality
  Air quality is one of the greatest concerns to the Denton community. We suggest that everypossible action should be taken to implement best practices to reduce emissions during the gasdrilling and production phases. Although the USEPA has just passed new regulations for air quality and gas drilling, most do not go into effect until 2015. Some regulations have caveatsthat only apply in certain instances:glycol dehydrator restrictions only apply for facilities that are classified as “major sources” andstorage tanks emissions reductions are limited to facilities with VOC emissions of 6 tonsper year.
 We suggest that the City of Denton should adopt air quality measures to protect public healthand reduce odor nuisances. 
Compressor Stations and Pipelines
 Large compressor station facilities are of great concern to the Denton community. Other nearbycommunities, such as Dish, Texas, have had considerable problems with such facilities. Wesuggest that either these facilities should not be allowed in residential districts or within asignificant distance from protected uses, or expanded regulations should be enacted to ensurethat air quality, water quality and noise levels are addressed. We propose that any new, largecompressor facilities should only be allowed to locate in industrial zoning districts and should belocated at least 2000 feet from any protected use. The rationale for this is that these facilitiesare the most problematic in the sense of noise, emissions, and community aesthetics. Wesuggest that there is further investigation into the types and sizes of compressor station facilitiesor complexes. (This is one of those situations where a field trip or presentation to the Task
New USEPA regulations, released April 17, 2012http://www.EPA.gov/airquality/oilandgas/actions.html
Force, for educational purposes, would have been highly beneficial) Where condensates are produced, emissions need to be minimized to legal limits using vapor recovery, dehydration units. These should be best available technology (BAT), includingrecovery units that recover BTEX. 
Well Integrity
  As gas wells continue to age in Denton, with many currently over 10 years old, the issue of wellintegrity over time will become more important. Most recently, well integrity monitoring andtesting has been brought to the forefront of national discussion in the USEPAs current nationalstudy on hydraulic fracturing. One definition in the USEPA case-study materials is: “WellIntegrity Narrowly Defined as the Prevention of Fluids Migration into Protected Water” In March2011, the USEPA held technical workshops on well integrity. Industry representative providedinformation on recommended practices.
 We suggest that well integrity factors and best practices, along with other measures, should beconsidered to ensure the preservation of well integrity and protect water resources in Denton.Redefine Permit We propose that a drilling permit be valid only for active drilling purposes. Should a wellbecome inactive (for a period of one to three years, for example), there should be notificationfor the re-start and a new permit should be required. The permit requirements, at the point of re-permitting, should require any new best available practices that have come about during theperiod of inactiviity. (See also Power Point presentation from Gas Well Task Force, Water Quality) Dormant wells Dormant Wells: if there has not been any drilling activity at a well pad or gas drilling productionfacility for a period of two years, the operators shall notify all residents, property owners, andbusiness owners within 1500 feet.
Water Quality
 There should be no releases to any surface waters (e.g., wetland, stream, river, etc.) fromsurface drilling ponds. There should be a mitigation plan for any such releases and suchreleases must be reported. The operators shall ensure that cleanup of any spill is quickly andfully implemented. We suggest that closed-loop drilling operations would be best for minimizingthe chances of both air and water pollution. 

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