17 May 2007
Lionel J. Milberger
REV = 3, 29 May 2009
NOTE:
1. The information contained herein is relative to Oil & Gas PBR type facilities normally found in rural areas, specifically and to other facilities in general.
2. Full compliance with TCEQ Rules does not insure safe residential living conditions, absence of nuisance conditions, or conditions that are free of dangers that can cause health problems. Serious “holes” exist in the TCEQ rules to insure such adequate conditions for residential areas.
OBSERVATIONS:
1. At the time of this writing, the author knows of NO toxic, hazardous, or harmful material that the TCEQ totally prevents or prohibits the discharge of into the air.
2. OXYGEN is the single gas in the atmosphere that is absolutely essential to all living beings that breathe the air, including humans. The quantity, or concentration (in terms of ppmv), is critical—too little can result in sickness or death–too much is likewise undesirable. The TCEQ has absolutely NO rules or regulations that control the amount of oxygen in the air for human consumption or sets the requirements thereof.
3. TCEQ does not prevent, limit, require the reporting of, nor require accounting of emissions to the air of the following materials. (106.4)
a. CO2, (carbon dioxide) A greenhouse gas & O2 lowering agent.
b. Water (and water vapors)
i. It must be noted that some toxins such as H2S are readily soluble in water.
ii. Toxins such H2S that are dissolved in water, water vapors, or steam are difficult to detect or measure.
iii. Toxins that are dissolved in water vapors or steam, are not required to be reported or included in permitted emissions.
c. Nitrogen (an O2 lowering agent).
d. Methane, CH4 (a greenhouse gas)
e. Ethane
f. Hydrogen
g. oxygen
4. Generally, the TCEQ does not concern itself with emissions from oil or gas well sites, including:
a. Air emissions. Emission sources can include scavengers, glycol dehydrators, phase separators, storage tanks, amine treaters, leaking or purposeful release of raw natural gas, blowers, coolers, or heaters.
b. Liquid emissions to the surface of the ground including open pits.
c. Subsurface emissions to the aquifer water in the event of oil or gas well component failure.
5. TCEQ does not concern itself with the following forms of pollution:
a. Sound or noise pollution.
b. Increased truck and vehicle traffic including emissions and noise.
c. Light pollution.
d. Visual pollution.
6. TCEQ allows the emission of H2S to the air. The amount is limited to 4 lbs./hr. (PBR 106.352) This quantity is per source. There are no specific spacing limitations for sources.
7. There is plenty more information available if anyone is interested. Comments are welcome.
About Sharon Wilson
Sharon Wilson is considered a leading citizen expert on the impacts of shale oil and gas extraction. She is the go-to person whether it’s top EPA officials from D.C., national and international news networks, or residents facing the shock of eminent domain and the devastating environmental effects of natural gas development in their backyards.
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A serious failure of environmental protection agencies generally seems to be their near-sighted approach to toxic emissions. Pollution is handled on a case by case basis, and the aggregate condition created by coincident emissions is ignored. That there is no monitoring of cumulative effects of multiple sources needs to be addressed! Our air, water and land is being negatively impacted, destroyed entirely in some cases and, with increasing momentum. The problem is enormous, the impact has become global. We need to begin correcting this problem, taking into account how terrain affects water coursing and atmospheric conditions, and how these in turn affect the land and sea. We need our representatives and legislators to wake UP to the accumulating serious damage being done and to wise UP and step UP to the plate and FIX IT!
At least the RRC has a mapping system where they map all kinds of wells and what type they are. The TCEQ does not map any of their permitted sources. Such deficiency is very dangerous. If you want to go buy a home, it would be nice to be able to look on a public mapping system to see where all the O&G wells and polluting source are and have been located in the past.
Do you have a link to the source for this information?
It’s the GIS mapping system on the RRC web site for public use. Try the following:
http://gis2.rrc.state.tx.us/public/startit.htm
"That there is no monitoring of cumulative effects of multiple sources needs to be addressed!" It has, in the Clean Air Act. 40 CFR 63. There should be about 159 of them now, with 20+ due by August.
"The TCEQ does not map any of their permitted sources" Yes they do. They are not available on the internet because of lack of funding. You can call the GIS department and request a map of all the PBR registrants, but you will have to purchase it.
#3 – That's because all those compounds occur naturally. A discharge of H2S in steam is regulated under 26.121 of the TWC as an unauthorized discharge.
#4 – There is a long standing feud between the RRC and the TCEQ. TCEQ is not allowed to regulate anything under the RRCs jurisdiction.
#5 Seriously? EPA and other agencies are for protecting health and the environment, not your opinion on aesthetics. That is a local issue and should be taken up at the city/county level.
#7 there is a distance limitation, no source can be closer than 1/4 mile from an off site receptor. They could cluster the stacks, but they all together have to have a 1/4 mile buffer. The 4lb/hr is for the whole facility whether they have one stack or 100. If they put out the max lbs/hr of SO2, sulfur compounds, and VOCs; they could only operate 130 24hour periods in a year.
People emit dozens of types of pollution every day. The more you let government regulate the companies you work for and buy from, the faster they will come for you. The companies should be held to a standard, but we all should pay double for fuel, water, and electricity; and 10x for sewer service. I'll write the check when you will.
You are correct – there is a lot of misinformation that goes on here and across the board. There are regs (Clean Air Act & Clean Water Act) in place that are enforced (I know some people refuse to believe this) and the TCEQ and RRC actually do a good job as far as bureaucracies go insofar as enforcement based on data and facts. They also do a good job of keeping the EPA in check in Texas.
I encourage more people to investigate these issues and focus on the facts – not the hype or fear-driven fallacies. To do otherwise does injustice to situations that actually need attention.
To anonymous post above, comments are as follows:
So far I have not been able to locate GIS maping for PBR facilities from the TCEQ–please guide me more.
Just for starters, your item #7 is not correct–look at 106.352–read paragraph (3) of the PBR. The spacing you mentioned only applies to facilities which are "handling sour gas"! Now what is your understanding of TCEQ's definition of "sour gas"? I know much more on this issue.
Furthermore, look at the last paragraph of 106.352–basically it says that if the facility is not handling sour gas(whatever that definition is)then a registration is not required before the facility starts operation–and it doesn't say when the registration must be filed!! If you say you are "sweet" and not "sour" than you can send in a registration when and if you ever feel like it!!
Nice rule.
In your number #5, thanks for confirming the original posting, the TCEQ does not concern itself with these items.
Will correct some more of your errors as time permits.
TAC 30:101.1(95) is the TCEQ's definition of sour gas.
To anonymous blogger above. This is nothing new. But, just for starters, tell us–if the 1.5 grains/100cubic feet of sour is gas is at STP, what will be the concentration of H2S in ppmv? Then we'll go from there.
I hope people's eyes don't glaze over from all this technical mumbo-jumbo.
You're presenting a straw man argument.
Your original post stated there is no spacing requirement for H2S sources – there is such a requirement.
You then "refuted" this point by implying there is no definition of "sour gas" – there is such a definition.
Either you're being disingenuous with your regulatory analysis, or you don't know how to read/comprehend the TAC.
To Anonymous above.
No such thing, straw man!
So know all, where is the spacing requirements between emitting sources in 106.352?
I specifically pointed out the definition of "sour gas". See above. Please comment on this point.
I'm what I am. And, I can read, can you?
Anyone know what is the air volume that results from mixing 4 lbs. of H2S, uniformly in air, so that the H2S concentration is 0.08 ppm?
最近TVや雑誌で紹介されている家出掲示板では、全国各地のネットカフェ等を泊り歩いている家出娘のメッセージが多数書き込みされています。彼女たちはお金がないので掲示板で知り合った男性の家にでもすぐに泊まりに行くようです。あなたも書き込みに返事を返してみませんか
Your conspiracy theory website keeps showing up in my Google search results. Thanks a lot.
Maybe I’ll try to put “-crazy, -pseudoscience” at the end of my search terms and see if that works.