1. The Texas Commission on Environmental Quality and the Oil and Gas Industry An Overview

2. TCEQ Regulates: Air Air Waste Waste Water Water Construction Construction Processing Processing Treating Treating Exploration Exploration Production Production Texas Railroad Commission X

3. Air Permits by Rule Permits by Rule Chapter 106 Chapter 106 25 tpy of VOC or SO 2 or PM 10 25 tpy of VOC or SO 2 or PM 10 250 tpy of CO or NOx 250 tpy of CO or NOx Standard Air Permits Standard Air Permits Concrete Batch Plants, etc. Concrete Batch Plants, etc. State Permits State Permits PSD (Prevention of Significant Deterioration) PSD (Prevention of Significant Deterioration) General Operating Permits – Federal General Operating Permits – Federal Site Operating Permits - Federal Site Operating Permits - Federal

4. NSR and Title V Perspective NSR Title V NSR Title V PBR Standard Permit State Permit NNSR & PSD Federal Permit DM Minor GOP SOP

5. Upset Conditions Emission Events Emission Events Must notify regional office within 24 hours of discovery Must notify regional office within 24 hours of discovery For “affirmative defense” must include all information required in a timely manner For “affirmative defense” must include all information required in a timely manner Submit “Final” report within 2 weeks Submit “Final” report within 2 weeks Some emission events result in enforcement action, depending on the cause and or quantity of the release. Some emission events result in enforcement action, depending on the cause and or quantity of the release.

6. Emission Inventories Point sources Point sources reported emissions by Industry reported emissions by Industry Area sources Area sources TCEQ developed (Painting, gas stations, dry cleaners, etc. TCEQ developed (Painting, gas stations, dry cleaners, etc. Mobile sources Mobile sources TCEQ developed (On-road and non-road) TCEQ developed (On-road and non-road) Biogenic sources Biogenic sources TCEQ developed (trees, eatc.) TCEQ developed (trees, eatc.)

7. Point Sources Major or minor source under §116.12 (New Source Review) Major or minor source under §116.12 (New Source Review) Dependent on potential to emit (PTE) PTE and actual emissions thresholds for regulated pollutants Dependent on potential to emit (PTE) PTE and actual emissions thresholds for regulated pollutants Location of source Location of source Attainment vs Non-attainment Attainment vs Non-attainment Boilers and Heaters Boilers and Heaters Flares Flares Fugitives Fugitives Loading Operations Loading Operations

8. Permits by Rule Chapter 103.261/262 pertaining to Oil and Gas Facilities is currently being re-written to become more specific with regard to day-to-day operations Topics to include: Topics to include: Blowdowns Blowdowns Degreasing, Lubrication Degreasing, Lubrication Tank Cleaning Tank Cleaning Thief hatches Thief hatches

9. Common Air Violations Failure to obtain authorization for equipment that requires permitting or Permit By Rule registration Failure to obtain authorization for equipment that requires permitting or Permit By Rule registration Failure to operate the equipment as registered Failure to operate the equipment as registered Failure to submit reports in a timely manner Failure to submit reports in a timely manner

10. Waste O&G waste generated on the drilling site is RRC jurisdiction O&G waste generated on the drilling site is RRC jurisdiction Industrial Hazardous waste Industrial Hazardous waste Solvents, etc. Solvents, etc. Universal waste Universal waste Fluorescent light bulbs Fluorescent light bulbs Paint and paint related waste Paint and paint related waste Batteries Batteries Mercury – containing Equipment Mercury – containing Equipment Pesticides Pesticides

11. Common Waste Violations Notification Notification Hazardous waste identification (Class 1,2 &3) Hazardous waste identification (Class 1,2 &3) Generator Status Generator Status Annual waste Summary Annual waste Summary Hazardous Waste Management Hazardous Waste Management Tanks Tanks Container Storage Area Container Storage Area

12. Paperwork Violations Paperwork Violations Hazardous waste determinations Hazardous waste determinations Manifests Manifests Annual waste summaries Annual waste summaries Inspections Inspections Container Storage Areas – weekly Container Storage Areas – weekly Tanks- daily Tanks- daily Safety Safety Fire and Spill Equipment Fire and Spill Equipment Internal Communications or Alarm System Internal Communications or Alarm System Letters to Police, Fire and Hospitals Letters to Police, Fire and Hospitals Personnel Training Personnel Training Emergency Reporting Emergency Reporting

13. Water Public Water Systems Public Water Systems Serve 25 or more for at least 60 days per year Serve 25 or more for at least 60 days per year Waste water discharges Waste water discharges Discharge Monitoring Report (DMR) Discharge Monitoring Report (DMR) NetDMR highly encouraged (replaced eDMR) NetDMR highly encouraged (replaced eDMR) Multi-Sector General Permit Multi-Sector General Permit May be required if you have had a reportable spill at the site in the last 10 years May be required if you have had a reportable spill at the site in the last 10 years

14. Common Water Violations Microbiological Sampling Microbiological Sampling Inadequate or Non-Submittal of Disinfectant Level Quarterly and monthly Operating Reports Inadequate or Non-Submittal of Disinfectant Level Quarterly and monthly Operating Reports Inadequate Cross Connection Program Inadequate Cross Connection Program Non-Submittal of new facilities plans Non-Submittal of new facilities plans

15. Water violations, con’t No annual inspection of storage tanks (including pressure tanks) No annual inspection of storage tanks (including pressure tanks) Disinfectant residual (lots of issues) Disinfectant residual (lots of issues) Low distribution water pressure Low distribution water pressure Un-locked facility fencing Un-locked facility fencing Water Wells Water Wells Storage tanks Storage tanks

16. Storm Water Construction Permits EPA – National Pollutant Discharge Elimination System (NPDES) EPA – National Pollutant Discharge Elimination System (NPDES) Oil and Gas Exploration and Production Oil and Gas Exploration and Production TCEQ – Texas Pollutant Discharge Elimination System (TPDES) or Construction Storm Water Permit TCEQ – Texas Pollutant Discharge Elimination System (TPDES) or Construction Storm Water Permit O&G Processing and Treating O&G Processing and Treating TXR150000 TXR150000

17. SW Construction Permits Large construction site (>5 acres) Large construction site (>5 acres) Require Notice of Intent Require Notice of Intent Storm water pollution prevention plan Storm water pollution prevention plan Includes <5 acre sites that are part of a larger common plan of development Includes <5 acre sites that are part of a larger common plan of development Small construction sites (<5 acres) Small construction sites (<5 acres) Require Storm water pollution prevention plan Require Storm water pollution prevention plan Less than 1 acre, not regulated Less than 1 acre, not regulated

18. Compliance Assistance Small Business (<100 employees) Small Business (<100 employees) SBLGA Hotline 1-800-447-2827 SBLGA Hotline 1-800-447-2827 Site Visit Program Site Visit Program Environmentor Program Environmentor Program Large Businesses Large Businesses Pollution Prevention and Education Pollution Prevention and Education SAV+ SAV+ Clean Texas Program Clean Texas Program Environmental Management Systems Environmental Management Systems 512-239-3100 512-239-3100

19. Other Programs Dam Safety Dam Safety PE required for drilling <500 ft. from dam PE required for drilling <500 ft. from dam Portable “facilities” Portable “facilities” Use registered sludge transporter Use registered sludge transporter Water Rights (surface water) Water Rights (surface water) Temporary permits <1 acre-foot. One year Temporary permits <1 acre-foot. One year Regional approval, not renewable Regional approval, not renewable

20. Region 7 counties Andrews Andrews Borden Borden Crane Crane Dawson Dawson Ector Ector Gaines Gaines Glasscock Glasscock Howard Howard Loving Loving Martin Martin Midland Midland Pecos Pecos Reeves Reeves Terrell Terrell Upton Upton Ward Ward Winkler Winkler

21. Contact information TCEQ Region 7 3300 N. “A” St. Bldg 4 Ste. 107 Midland, TX 79705 432 570-1359 Fax 432 570 4795 Jeff Bertl, Regional Director Jeff Bertl, Regional Director Alice Cone, Air Section Work Leader Alice Cone, Air Section Work Leader Michael, Waste/Water Section Work Leader Michael, Waste/Water Section Work Leader

22. Contact Information Janet Prim Compliance Specialist Compliance Specialist Small Business and Local Government Assistance Small Business and Local Government Assistance 432-620-6116 432-620-6116 jprim@tceq.state.tx.us jprim@tceq.state.tx.us jprim@tceq.state.tx.us

23. Contact Information Christine Hammit, PG IHW Investigator Midland Regional Office Midland Regional Office (432) 570-1359 (432) 570-1359 chammit@tceq.state.tx.us chammit@tceq.state.tx.us