Wednesday, April 28, 2010

Tank Setbacks

There are two variance requests concerning tank setbacks. The first variance requested is for the rule of 114.12(A)(24)(j) which states that tanks must be located a minimum of 600 feet from any protected use. Another variance for 114.12(A)(32)(c) which sets the minimum distance of waste disposal tanks from any protected use to 600 feet also.

Reviewing the site plan, I believe there are locations on the site that would put the tanks in question (both types) at least 600' from any residences that have not already agreed to have the well or well support equipment at less than 600'.

The operator states that there is no alternative to the variance. I disagree, and will need the operator to prove that statement before I could agree to grant this variance.

The operator also states that 150' is an "industry standard" for setbacks from hydrocarbon tanks. While that may be true, that is a flammability/explosion safety issue, and does nothing to address adjacent property owner's rights, particularly to maintain the value of their property.

The operator does not address the hydrocarbon emission issue at all, and as recent TCEQ investigation of complaints around North Texas have shown, there are real issues with emissions of volatile compounds dangerous to human health.

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