Trinity East SUP Concerns: Luna South Processing Facility

Prepared by Dallas Residents at Risk Two of the Trinity East SUP applications are for pad sites with up to 20 gas wells each. The third contains the same type of pad site, but also contains a proposal for a separate area identified as the Luna South Gas Processing Facility. Unfortunately, the nature of this facility is being misrepresented by the applicant and city staff. However, a simple examination of its site plan leads to a clear understanding of these falsehoods. http://dallasdrilling.files.wordpress.com/2013/01/tegascompressor1.jpg

What is the Luna South Processing Facility?

Lets start with an understanding about exactly what is being proposed at this facility. The site plan shows equipment such an incinerator, an amine contactor, an amine reboiler and an amine reflux condenser/cooler. What is all this for? Amine gas treating refers to a group of processes that use aqueous solutions of various alkanols (commonly referred to as simply "amines") to remove hydrogen sulfide (H2S) and carbon dioxide (CO2) from gases. It is a common process unit used in petroleum refineries, natural gas processing plants, petrochemical plants and other industries. The process is also known as acid gas removal and gas sweetening. Processes within petroleum refineries or natural gas processing plants that remove hydrogen sulfide are commonly referred to as sweetening processes because they result in products which no longer have the sour, foul odors of hydrogen sulfide. http://www.eoearth.org/article/Amine_gas_treating?topic=74180 The site plan also illustrates three enclosed 3,200 horsepower compressors, which is why the common term for this type of facility is a compressor station. To ensure that the natural gas flowing through any one pipeline remains pressurized, compression of this natural gas is required periodically along the pipe. This is accomplished by compressor stations, usually placed at 40 to 100 mile intervals along the pipeline. The natural gas enters the compressor station, where it is compressed by either a turbine, motor, or engine. In addition to compressing natural gas, compressor stations also usually contain some type of liquid separator, much like the ones used to dehydrate natural gas during its processing. Usually, these separators consist of scrubbers and filters that capture any liquids or other unwanted particles from the natural gas in the pipeline. The liquid separators at compressor stations ensure that the natural gas in the pipeline is as pure as possible, and usually filter the gas prior to compression. http://www.naturalgas.org/naturalgas/transport.asp Indeed, the site plan for this facility shows filters, separators and dehydration equipment (glycol contactor). The purpose of the equipment described in this SUP is clearly to refine, process and transport natural gas. The CEO of Trinity East described it this way to the Dallas Observer: We have a master plan for pipelines and transportation of the gas. It all runs through this part of our project. http://blogs.dallasobserver.com/unfairpark/2012/05/trinity_east_largest_dallas_ga.php

What do City staff and Trinity East say?

Lets go back to the current gas drilling ordinance and its definition of the activities it is meant to regulate: Gas drilling and production means the activities related to the extraction of any fluid, either combustible or noncombustible, that is produced in a natural state from the earth and that maintains a gaseous or rarefied state at standard temperature and pressure conditions, or the extraction of any gaseous vapors derived from petroleum or natural gas. City staff and the applicant are claiming that the Luna South Processing Facility fits into this definition. Even the most basic examination of the proposed facility indicates that it does not. As a result, the current SUP application is against both the current city ordinance and the Gas Drilling Task Force recommendations. The Chair of the Task Force, as well as City Council member Linda Koop, have both stated that compressor stations should not be allowed in Dallas. The current gas drilling ordinance contains no legal definition of a compressor stationit only defines gas drilling and production. As a result, the facility is not allowed under the current gas drilling ordinance without a planned development district or a separately defined zoning use. City staff included this in their matrix of current ordinance rules vs. Task Force recommendations: Compressors would require a planned development district because no defined use; or must create a use in zoning districts. But now city staff and the applicant are claiming this does not apply because the facility qualifies as gas drilling and production. In fact, they are claiming that three 3,200 HP compressors, as well as the refining tanks, boilers and flare, make up the normal equipment that would typically found on each individual pad site. They claim this equipment has been moved to a central location in order to reduce the impact of the other two sites that are in floodplain/parkland areas. However, all three SUP site plans also include smaller lift compressors and phase separators on each pad site. These three pad site compressors and separators are described as production in all three SUP applications, and yet city staff claim the larger refining and transportation equipment on the compressor station site is also production. But the 3,200 HP compressors are many times larger than lift compressors (usually only a few hundred horsepower at most) that are typically found on each pad site and that are indeed planned for each of these. This begs the question: What types of equipment and facilities would NOT qualify as gas drilling and production? How large would the compressors need to be, how many chemical storage and refining tanks and compressors would there need to be? If this facility is production, what isnt? When we asked the Assistant City Attorney and the Director of Sustainable Development and Construction these questions, they simply said we do not know. They said the city does not have a legal definition for anything other than gas drilling and production, and this facility fits the definition. They admitted that there are large, industrial refining and transportation facilities that would not qualify and would not be allowed without a planned development districtbut they insisted this facility isnt one of them. Their argument boiled down to this: We dont know what a compressor station is, but we do know this is not a compressor station.

How has City staff handled similar proposed facilities?

We have uncovered records of another gas drilling proposal that did in fact define this type of facility as a use other than gas drilling production. In 2008, Chief Oil & Gas submitted SUP applications for five gas drilling sites at North Lake. One of these also included an adjacent facility described on site plans as a compressor area. In the SUP application itself, it is referred to as a gas gathering station. City staff used the following definition: A Gas Gathering Station is a facility that is designed to clean, dehydrate free water and condense gas, thereby allowing for transfer into high pressure gas lines. In their SUP, the applicant describes a compressor station nearly identical to the Trinity East facility: The gathering station will use up to three electric drive compressors. The compressor facility will be encased in a noise abatement structure. This large equipment enclosure will be 20 feet in height. Just like the Trinity East proposal, the gas gathering facility was only found near one of the drilling sitesall the other pad sites were meant to send their gas to this facility before it could enter the sales pipeline. Just like the Trinity East SUPs, all of the other pad sites were meant to have their own small lift compressors and separators at the wellhead areas as well. But in this case, the SUP application contained several sub-areas, and different uses were to be allowed on different sub-areas. Gas drilling and production was one such use, and the gas gathering station was a separate use. The site plan for one sub-area contained illustrations of the gas drilling equipment and wells. Another sub-area was shown as the compressor area. The SUP contained the following language: Uses Permitted (a) Sub-area I. The following uses are the only uses permitted: -- Gas drilling and production (SUP) -- Gas metering station -- Open space -- Local utilities -- Tower/antenna for cellular communication (b) Sub-area II. The following uses are the only uses permitted: -- Gas drilling and production (SUP) -- Gas metering station -- Gas gathering station -- Open space -- Local utilities -- Tower/antenna for cellular communication City staff and the applicant defined the facility as a compressor area and gas gathering station in this instance, but as gas drilling and production for Trinity East. They required the authorization of a planned development district for Chief Oil & Gas, but allowed Trinity East to simply include this in their gas drilling and production SUP application. Were city staff wrong about the Chief facility, or are they wrong about Trinity East?

How will this affect Dallas residents?

During the Dec. 20th City Plan Commission hearing, Trinity East representatives stated that the three proposed compressors alone would release 75 tons of air pollution each every year. That number would immediately place the facility among the city's ten largest air polluters, according to the latest state emission totals from 2010. It would join power plants, asphalt and roofing materials manufacturers, and chemical plants as one of the city's ten biggest stationary sources of air pollution. However, Trinity East could be underestimating their total air pollution impacts by not including other onsite refinery sources like its battery of storage tanks and amine equipment. The company will be submitting an application with the state environmental agency, but since it has not yet done so, we currently have no way of knowing how much pollution will be released at this site or what types of chemicals nearby residents will be exposed to. Under state law, this facility will be allowed to release far more pollution than Trinity East representatives have claimed: Total actual emissions authorized under permit by rule from the facility shall not exceed 250 tons/year of carbon monoxide (CO) or nitrogen oxides (NOX ); or 25 tons/year of volatile organic compounds (VOC) or sulfur dioxide (SO2 ) or inhalable particulate matter (PM); or 15 tons/year of particulate matter with diameters of 10 microns or less (PM10 ); or 10 tons/year of particulate matter with diameters of 2.5 microns or less (PM2.5 ); or 25 tons/year of any other air contaminant except carbon dioxide, water, nitrogen, methane, ethane, hydrogen, and oxygen. If this facility were to follow the state-allowed limits, it would be the single largest stationary source of EPA-regulated air pollution in Dallas. And although Trinity East claims it will stay far under these limits, the City has no jurisdiction to enforce its own maximum limits for these types of air pollution. The Trinity East estimate doesn't reflect the release of greenhouse gas pollution either, which could be enormous for a facility of this size. Gas processing plants can release 20,000 to 80,000 tons of greenhouse gases a year. By comparison, the entire inventory of greenhouse pollution from all Dallas industrial sources in 2005 was 25,000 tons a year. All of this is 600 feet from the largest outdoor recreational area in Dallas, a huge new soccer complex thats meant to attract thousands of kids for hours every week. There is a larger compressor station facility with roughly twice the horsepower-capacity in Dish, TX. Scientific testing has shown that it has released toxic, cancer-causing chemicals at levels that exceeded health and safety limits set by the state environmental agency. http://www.earthworksaction.org/files/publications/Subra_Dish_Analysis.pdf There is a smaller facility with about 1/3rd the horsepower in Argyle, TX. It is regulated by the state environmental agency as a compressor stationand it has been cited by the federal EPA for violating the Clean Air Act. http://abcalliance.org/wp-content/uploads/2012/04/Mockingbird-Pipeline-Letter-and-ACO1.jpg

Simply put, this is not what we want near our recreational areas. The Task Force didnt want this type of facility anywhere in Dallas, let alone 600 feet from soccer fields. Even for a simple gas drilling pad site, the Task Force recommended 1,000-foot setbacks for recreational uses. This proposal fails both requirements and should be flatly rejected.