Proposed Standard Permit for Oil and Gas Stakeholder Group

TCEQ needs your comments on the Proposed Standard Permit for Oil and Gas Stakeholder Group BY APRIL 16.

The following comments were submitted on behalf of all Texans by Texas Oil and Gas Accountability Project a project of EARTHWORKS

TCEQ Proposed Standard Permit

Tanks and Vessel Planned Maintenance, Start-ups and Shutdowns

Process vessels and equipment, depressurized, emptied, degassed, and placed in service

Under C. it is stated that “if it is necessary to drain liquid into an open pan or sump, the liquid must be covered or transferred to a covered vessel within one hour of being drained.” Additional requirements should be added that require the reporting of the quantity and chemical and physical characteristics of the liquid drained into an open pan or sump and the time period that the liquid was not contained.

Tank Loading Emission Control Options

Under #3, it is stated that “all lines and connections, shall be visually inspected for any defects prior to hookup. Lines and connectors that are visibly damaged shall be removed from service. Operations shall cease immediately upon detection of any liquid leaking from the lines or connections.” The proposal should have also included a requirement that the lines and connector be visually inspected the entire time loading as well as unloading operations take place. Frequently, during loading and unloading operations, no one is observing the lines and connections. Leaks occur and the operations are not suspended. The leaks results in contamination of surface soils and surface water resources during periods when visual observations of operations are not occurring.

Comments may be faxed to 512-239-2101