You gotta love it when the industry says it is already doing something that would be good for the health and safety of Denton citizens. For example, Eagleridge claims it already uses green completions and does not use fracking pits. Why is this not in the ordinance already if operators are doing it regardless?
Well, the same question can be asked about the use of low-bleed valves. Pneumatic devices are one of the largest sources of methane emissions in the gas industry. Methane is money. Listen to what the EPA has to say about the switch from high-bleed to low-bleed control devices (to control gas pressure, flow, temperature, and levels): “Natural Gas STAR Partners have achieved significant savings and methane emission reductions through replacement, retrofit, and maintenance of high-bleed pneumatics. Partners have found that most retrofit investments pay for themselves in little over a year, and replacements in as little as 6 months.” Devon Energy touts their use of such devices. Chesapeake also acknowledges that the use of such valves is standard practice.
It saves our environment. It saves money. Let’s put it in the ordinance: Operator must use low-bleed or no-bleed pneumatic valves, fittings, and other devices.
Another requirement to get in there is this, which comes from Southlake and Grand Prairie: “Low toxicity glycols, synthetic hydrocarbons, polymers and esters shall be substituted for conventional oil-based drilling fluids.”
The International Association of Oil and Gas Producers has a detailed report on the history of drilling fluids, showing how the number of chemicals added to water (which was the original drilling fluid) increased until it reached the thousands. Non-aqueous drilling fluids have also been developed. The report notes how some fluids are hazardous and how workers can be exposed (either through skin contact or through inhalation of vapors). It then states:
“A goal of all operations should be to avoid the use of hazardous substances, and to avoid procedures which may cause exposure. Various brands of additives and chemical products may be at hand for personal preference reasons or as recommended by a particular manufacturer in cases where an alternative common additive could be used. Numerous chemicals with identical properties and functions may therefore be available on site, which may be unnecessary and could impede risk management. Every operation should strive to reduce the number of chemicals being used to an absolute minimum.”
It is simple. Eliminate toxic chemicals. Replace them with non-toxic ones. This sounds like a good policy for us to support. This is especially true when low toxicity drilling fluids have demonstrated that they can deliver “excellent performance.” So, less toxins for no loss in performance with legal precedent from other municipalities. Another no-brainer.
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