We all work for the TCEQ.

This is the Bucci Lease, another Aruba Petroleum well. …different well, same thing day after day, time after time.

TCEQ has a find and fix plan where they want industry to find leaks and fix them instead of the TCEQ regulating. It doesn’t work, as you can see above, because industry has no real motivation to find or fix leaks. That means we have a new full-time job for as long as we live in the Barnett Shale.

I’ll let Christine explain it.

TODAY 07/08/2011, Aruba Petroleum received the attached letter from the TCEQ regarding an investigation that took place on 07/02/2010 at the Bucci Lease. Here is the TCEQ video taken of the event on 07/02/2010.

http://www.youtube.com/watch?v=naTDP-tZj-w

The recommended corrective action on the TCEQ’s part: “Maintain the dump valves at the site.”

The TCEQ’s accepted resolution: “The dump valve was overhauled on 7/3/10 resolving the violation.”

Is the TCEQ taking the “if a tree falls in the forest” stance?

Was that after you pointed out to them, via a citizen complaint, that there was a problem? I guess a tree fell.

I wonder if the dump valve would have been overhauled if a citizen hadn’t complained. Perhaps prior history at other sites for the same operator might have helped in answering that question, but after a year since the complaint was filed, I guess it is irrelevant now.

Did the TCEQ even consider who complained? Was it the operator’s employees or a subcontractor? Was it a “voluntary disclosure” as part of a Supplemental Environmental Project? Or was it someone independent of the operation entirely, but living close to it?

Did the TCEQ determine how often the operator or operator’s subcontractor’s visited the site on a daily basis to determine whether a citizen complaint was even necessary? Or is it the TCEQ’s stance that citizens are responsible for monitoring the operations of operators and their subcontractors rather than the operators themselves or the TCEQ.

I have been told many times by TCEQ investigators that they don’t work for me. I find this interesting as I don’t expect them to work for me. I just want them to do their job. Apparently that makes it my job.

I have already accepted this as a new role by default, though I disagree with it. The TCEQ needs to spell it out for everyone.

You need to tell every citizen that they are responsible for pointing out the deficiencies of facilities near their homes. You need to tell them that the TCEQ does not require the operator to identify deficiencies on their own and they will not be held accountable by the TCEQ if they don’t, Supplemental Environmental Project or not.

The TCEQ will not use common sense and say, “why didn’t the operator or its subcontractors “Find” it on their own and “Fix” it before a citizen had to complain?”

You need to tell citizens that when they do point out deficiencies, the operator will not be held accountable for their failure to point them out, but the TCEQ will make them “Fix” it. The operator is not required to “Find” after all.

Citizens are the “Find” part of the TCEQ equation.

Please let people know this. I didn’t, but after learning it the hard way, and after my final disappointment with this investigation report. I get it. I and others like me…, private citizen, wife, and mother, are the “Find” in the TCEQ “Find and Fix” Program.

I think you need to spell it out so other’s aren’t so shocked when they are forced into the same situation. Just tell them that they are the “Find” part and it is an additional role. Wife, mom, employee, and … TCEQ monitor/”Finder”…

I think that you also need to point out to the public that every facility is a unique “individual” regardless of compliance history for that same operator at another site. It doesn’t matter if an operator has a violation or history at another site.

The TCEQ needs to tell the public that it is their responsibility to point out operator violations. They also need to know that once they do, the only thing the TCEQ will do is point it out to the operator, regardless of compliance history at other sites.

The operator will “Fix” the citizen “Find” and that is all that matters. The fact that a citizen had to “Find” is irrelevant to the TCEQ. After all, the TCEQ doesn’t work for the citizen.

I guess we all work for the you.

I cannot begin to tell you how disappointed I am.

Sincerely,

Christine Ruggiero

We have to be the finders but no matter what we find and no matter how often we find it, not much happens.