Wednesday, August 7, 2013

14 hours of venting + 1,281 Pounds of VOCs = No Violation

The TCEQ has just issued its Final Investigation report regarding the April 19 “emission event” at the Smith-Yorlum 7H (old Bradford 1, on Jim Christal Road, API 121-32229) well operated by EagleRidge. This is a well that was originally drilled vertical and is one of several that EagleRidge is converting to horizontal. By the way, EagleRidge begins operations today on a couple of wells right next to UNT property by Apogee Stadium.

You should find the TCEQ report linked here on the City of Denton Gas Well Inspection page. TCEQ officials took two summa canister air samples, each for 30 minutes. The first was taken during the event and the second after the event.

Their main finding from this analysis was: “no compounds exceeded the Air Monitoring Comparison Values (ACMVs) for long term or short term exposures.” Therefore, TCEQ concludes: “No violations associated to this investigation.” Case closed.

So, what happened and what should we make of it?

Here is a timeline of events compiled partly from the report, my conversations with an official at TCEQ, and from the investigation done by Peggy Heinkel-Wolfe at the DRC (prior to the report’s release):

 • 1 a.m. – Contractors had fracked the well and all the plugs were pulled. They were lifting out some pipe when a segment broke off above the last check valve in the well, allowing air and frack water to rise uncontrolled and under pressure. [from report]

• 5:30 a.m. – EagleRidge calls Cudd Remediation (well control). [from DRC]

• 6:30 a.m. – Pam Brewer, whose house is very close to the site, takes this video of the incident. (She would later leave for work and notice the contractors sitting in trucks far from the site. Her daughter and granddaughter were later evacuated). [from DRC]

• 8:00 a.m. – Leak is determined to be uncontrollable and EagleRidge calls 911 and CUDD [from report].

• 10:30 a.m. – EagleRidge contacts the Texas Railroad Commission. [from DRC]

• 10:45 a.m. – EagleRidge calls Denton’s Fire Inspector [from DRC] – fire team evacuates six homes and establishes a no fly zone. [from report]

• 11:00 a.m. – the RRC inspectors and well control team arrive on the scene. [from DRC]

• 2:52 p.m. – TCEQ investigators arrive on scene.[from report]

• 3:21 – 3:51 p.m. – First summa canister sample is taken.[from report]

• 3:39 p.m. – well is capped. [from report]

• 4:11 – 4:45 p.m. – Second summa canister sample is taken. [from report]

• 9:50 p.m. – Initial notification is posted on State of Texas Electronic Reporting System. [from report]

• 10:52 p.m. – Someone notifies the National Response Center. [from DRC]

Ok, now what to make of this.

1. The lack of monitoring is a problem. As the report notes, there were no monitors present during the event and no data were available. EagleRidge estimated 1,281 pounds of natural gas VOCs were emitted and TCEQ accepted that estimate. But it was just that, an ESTIMATE – a guess. We don’t really know what came out of the well.

2. The slow response by TCEQ is a problem. They did not arrive until more than 12 hours after the incident started. Their first summa canister is supposedly ‘during’ the event, but the well was capped half way through their sample. They got some data but they are from one summa canister (a notoriously limited monitoring device) in one location at the very end of the release event. But it is on the basis of this that they determine there was no violation.

3. It’s a reminder that gas well pad sites (and pipelines and other related infrastructure) are prone to normal accidents. Just like any complex technical system, things can go wrong. Arguably, we were lucky in this case that there was not a fire – TCEQ did pick up over 200 ppm of hydrocarbons in the air and evacuees were told to avoid doing anything that might cause a spark.

4. There is no state violation involved in this incident. We are yet to see if there is any city violation. I scanned through our ordinance and could find nothing in there that EagleRidge violated. So, it would appear that this was not only a normal accident but a legal one.


  1. The last part of your information causes me great concern because there is logically no such thing as normal or legal accident otherwise it be considered a normal event. When the state and the city appear to believe this is what they consider an abnormal and/or illegal accident what has to happen? What would it take to cause a state violation? When I reported an event at the Razyor Ranch site I was told by a TCEQ inspector " we never find anything, ever". How many of these accidents have caused a state violation? The answer is less than 1%. I find it hard to believe that 99% of all incidents reported to TCEQ are violation free. The same analogy would be that out of 100 people the police pull over for a motor vehicle violation are innocent but one person.

  2. They at least violated local and state nusiance ordinances, but I’ve never seen it enforced yet.

  3. That is a long time that this drilling rig was going for. The contractors that had to work those 14 hours straight to make sure things ran well, really did a great job. They got everything done without any complications or violations either.