17 May 2007
Lionel J. Milberger
REV = 3, 29 May 2009
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.
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)
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.