Why Argyle Central doesn’t belong in a neighborhood: The Long Version
This week, we told TCEQ our concerns about the air permit application as submitted for the Argyle Central Facility, submitted by Mockingbird Pipeline LP, a subsidiary of Williams Gulf Coast Production.
The application includes a long list of equipment being installed at the site, including a glycol dehydrator, separators, 18 produced water tanks with a vapor combuster, a slop-water tank, stacks, fugitive emissions points, a stand-alone stack for blow-downs, and four compressors, which are within a few hundred feet of many homes. Other “temporary equipment” has been installed about 100 feet from a child’s bedroom window.
On its face, the combined 3,424 hp of the compressors suggests that this facility will be a major source of emissions and does not qualify for permit-by-rule. In addition, the company’s application uses many calculations that are based on operations from a “similar” facility. This unit, the Wilson unit, in Flower Mound, has emissions problems that have been well-documented. A Piccaro Inc. mobile monitor, over a period of several hours, mapped a methane plume in excess of 40 ppm at this “comparable” facility. In addition, ShaleTest recently recorded FLIR images of the facility, showing there has been little change.
Furthermore, we are concerned that the agency would allow this permit to proceed without the proper calculations. Specifically,
· The fugitive count is an estimate based on another facility, not engineering specifications for Argyle Central.
· Calculations for the compressors are based on manufacturer’s data, which has been well-documented for underestimating total emissions when compressors burn raw gas from the pipeline.
· When calculations are based on raw gas, the base sample provided is not from gas being produced at either the Blessing or Wright units – the two gas well pad sites this facility was ostensibly designed to serve.
Finally, this application does not include the many frack tanks set up at the site not long after the produced water tanks were installed this summer. Company officials claim these tanks are temporary, but they have been present for nearly six months. After a recent overflow and spill from these tanks, we have learned the frack tanks are there to handle excess production for the produced water tanks. Documented emissions from the area (as documented by Region 4 investigations division) would suggest these tanks are venting VOCs and other HAPs in a residential neighborhood, and therefore should not enjoy any exemption from the calculations – or controls, for that matter — as long as they are on site.
Here’s an example of a venting frack tank:
To sum: the ABCAlliance has called on TCEQ to deny this permit-by-rule and instruct the operator of Argyle Central to cease operations and resubmit its air permit application as a major source.
Why Argyle Central doesn’t belong in a neighborhood: The Short Version
Tuesday night. Neighboring property. Toxics Vapor Analyzer (TVA)reading: 15 parts-per-million.
Update: Today, Friday 11/12/10 TVA was reading as high 96 parts per million at neighboring property.