Preparing For A TCEQ Investigation and What To Do After A TCEQ
Investigation
Update on Oil and Gas Activities in texas
Texas Commission on Environmental Quality Office of Compliance
and EnforcementSusan Jablonski, P.E.Area DirectorCentral Texas
Area1North Central and West Texas AreaCentral Texas AreaCoastal and
East Texas AreaBorder and Permian Basin Area
2Oil & Gas Exploration and ProductionTCEQs Primary Role is
regulating air emissions and ensuring air quality, and any impact
to water .
There are additional investigations performed in response to oil
and gas activities in multiple programs, such as public water
supply, wastewater collection and treatment, air quality, solid
waste disposal, dust control, and surface water usage.
3
Map from The railroad commission of texaSWells permitted and
Completed in eagle ford shale area May 2008 to March 20154Eagle
Ford Shale Investigation ActivitiesSince September 1, 2012, the
TCEQ has conducted over 1,500 investigations related to Eagle Ford
Shale oil and gas activities:ComplaintsRoutine
ComplianceReconnaissanceFly-over follow-up
578Complaint ResponseTCEQ responds to all complaints received
under its jurisdiction:Considered a core mission of the
agencyComplaints are assigned a priority with corresponding
investigation deadline, if requiredAlleged health related issues
are considered our highest priority
910Odor ComplaintsWhen investigating a nuisance odor complaint,
we gather evidence to help us evaluate the characteristics of
odors, so any information a complainant can provide will assist us
in the investigation. We also need information regarding the
alleged source of the odor. The agency has created an odor log that
complainants may use for documentation purposes.In order to issue a
violation, we may ask the complainant to sign a written statement
or affidavit.
11Odor Complaints ContinuedComplaints concerning odors
associated with oil and natural gas activities require an expedited
response if the agency has substantiated odor nuisance conditions
in the previous 12 months at the alleged source of the complaint.
All other oil and natural gas related complaints within TCEQ
jurisdiction will be prioritized and investigated in accordance
standard operating procedures. As with all complaints, if the
situation is an imminent threat to health or to the environment, we
will respond within 24 hoursusually much sooner.12ReconnaissanceThe
TCEQ may conduct reconnaissance investigations in areas where one
or more of the following criteria apply: Historic complaints have
been received;Fly-overs (aerial surveys) of regulated facilities
have been conducted; Clusters of regulated facilities are
located;Follow-up of an ongoing investigation is required; and/or
Other factors that indicate the need for an on-site presence
outside of a normal frequency.
13Equipment
GasFindIR camera
Toxic Vapor Analyzer
Summa canister
Mini RAE14Optical gas imaging camera (OGIC)Using the OGIC, we
can potentially locate under reported or unrecognized VOC source
types
The camera is capable of locating and imaging emissions from
various sources of air pollution
Documented images of emissions for follow-up
15Imaging for Volatile Organic Compound (VOC) emissions
16Focus on Potential Air Issues FROM oil AND gas Activities
17
Canister Sampler - Collects samples for the analysis of more
than 80 VOCs (above)Continuous Air Monitoring Station with monitors
for ozone, nitrogen oxides, carbon monoxide, sulfur dioxide, PM10,
and PM2.5 (below)AIR MONITORING18Air Monitoring - Eagle Ford
Shale
Karnes County, near courthouse in Karnes CityActivated New Site:
December 17, 2014Automated Gas ChromatographVOCs, H2S,
NOx19Innovative ApproachesThe TCEQ has undertaken numerous projects
that use state-of-the-art science and technology to assess and
address emissions from oil and gas activities. These initiatives
have resulted and will continue to result in emissions reductions
as well as improved agency policy and guidance. 20Fly-over
investigationsTCEQ has conducted multiple contractor-led aerial
surveys or flyovers using a helicopter mounted with an optical gas
imaging camera (OGIC) capable of detecting sources of air
emissions. Effective screening toolEvaluate large geographical
areasAllows TCEQ to focus resources on potentially problematic
areasThousands of individual tanks have been surveyed 21Recent
Fly-over investigationsDecember 2014-January 2015Targeted well pad
sites and central storage tank locations in Bexar, Dimmit, Karnes,
and La Salle CountiesApproximately 1,036 sites surveyedIncluded
2,500 individual storage tanks
22Recent Flyover investigations ContinuedImages reviewed and
ranked to prioritize locations for on-the-ground follow-up
investigationsOn-the-ground follow-up investigations conducted at
facilities with observed emissions to determine compliance with
authorizations and regulations
23
Fly-over imagery24Investigative FindingsGenerally, corrective
actions amounted to replacing worn gaskets, closing open hatches,
and repairing stuck valves.
Nearly all of the issues documented arose from human or
mechanical failures.These items were quickly remedied and could
have been avoided through increased diligence on the part of the
facility operator.
25Multimedia issuesInvestigations related to oil and gas
activities are conducted in programs other than air. Industrial
Hazardous, and Municipal WasteOn-site Sewage FacilitiesPublic Water
SuppliesWastewater; SludgeStormwaterWater RightsUnderground
Injection ControlAggregate Production Operations
262728Waste Issues
29Water Issues
RV ParksOil Camps30Hazardous Spills/ResponseWhich State Agency
has Jurisdiction?Dependent on what is spilled and where
Texas Commission on Environmental QualityGeneral Land
OfficeRailroad Commission of TexasTexas Department of State Health
ServicesTexas Parks and Wildlife DepartmentTexas Department of
Public SafetyGovernors Division of Emergency Management
31Other Avenues to ComplianceThe Texas Audit Act is one avenue
to helping an entity achieve voluntary compliance
The TCEQ Environmental Assistance Division also offers
assistance through programs like the Compliance Commitment (C2)
Program and other compliance assistance options.
32Approaches to best utilize resources Additional stationary
monitors; The increased collection of ambient air canister samples;
Fly-overs using infrared imaging;Targeted mobile
monitoring;Conducting complaint-driven and routine investigations;
and A wide variety of outreach activities within communities across
the State.
33Questions
Susan Jablonski, P.E., DirectorCentral Texas AreaOffice of
Compliance & [email protected]
512-239-673135
