1. UPDATE ON OIL AND GAS ACTIVITIES IN TEXAS TEXAS COMMISSION ON ENVIRONMENTAL QUALITY OFFICE OF COMPLIANCE AND ENFORCEMENT Susan Jablonski, P.E. Area Director Central Texas Area

2.  North Central and West Texas Area  Central Texas Area  Coastal and East Texas Area  Border and Permian Basin Area

3. OIL & GAS EXPLORATION AND PRODUCTION TCEQ’s 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.

4. MAP FROM THE RAILROAD COMMISSION OF TEXAS WELLS PERMITTED AND COMPLETED IN EAGLE FORD SHALE AREA – MAY 2008 TO MARCH 2015

5. EAGLE FORD SHALE INVESTIGATION ACTIVITIES Since September 1, 2012, the TCEQ has conducted over 1,500 investigations related to Eagle Ford Shale oil and gas activities: Complaints Routine Compliance Reconnaissance Fly-over follow-up

6. TCEQ INVESTIGATION TYPES There are several reasons why a regulated entity might be investigated: o Regularly scheduled investigation o Complaint response investigation o U.S. EPA or TCEQ initiative o Spill response o Referral from another governmental entity

9. COMPLAINT RESPONSE TCEQ responds to all complaints received under its jurisdiction: Considered a core mission of the agency Complaints are assigned a priority with corresponding investigation deadline, if required Alleged health related issues are considered our highest priority

11. ODOR COMPLAINTS When 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.

12. ODOR COMPLAINTS CONTINUED Complaints 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 hours—usually much sooner.

13. RECONNAISSANCE The TCEQ may conduct reconnaissance investigations in areas where one or more of the following criteria apply: o Historic complaints have been received; o Fly-overs (aerial surveys) of regulated facilities have been conducted; o Clusters of regulated facilities are located; o Follow-up of an ongoing investigation is required; and/or o Other factors that indicate the need for an on-site presence outside of a normal frequency.

14. EQUIPMENT GasFindIR ® camera Toxic Vapor Analyzer Summa canister Mini RAE

15. OPTICAL 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

16. IMAGING FOR VOLATILE ORGANIC COMPOUND (VOC) EMISSIONS

17. FOCUS ON POTENTIAL AIR ISSUES FROM OIL AND GAS ACTIVITIES

18. 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 MONITORING

19. AIR MONITORING - EAGLE FORD SHALE Karnes County, near courthouse in Karnes City Activated New Site: December 17, 2014 Automated Gas Chromatograph VOCs, H2S, NOx

20. INNOVATIVE APPROACHES The 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.

21. FLY-OVER INVESTIGATIONS TCEQ 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. o Effective screening tool o Evaluate large geographical areas o Allows TCEQ to focus resources on potentially problematic areas o Thousands of individual tanks have been surveyed

22. RECENT FLY-OVER INVESTIGATIONS December 2014-January 2015 Targeted well pad sites and central storage tank locations in Bexar, Dimmit, Karnes, and La Salle Counties Approximately 1,036 sites surveyed Included 2,500 individual storage tanks

23. RECENT FLYOVER INVESTIGATIONS CONTINUED Images reviewed and ranked to prioritize locations for on-the-ground follow-up investigations On-the-ground follow-up investigations conducted at facilities with observed emissions to determine compliance with authorizations and regulations

24. FLY-OVER IMAGERY

25. INVESTIGATIVE FINDINGS Generally, 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.

26. MULTIMEDIA ISSUES Investigations related to oil and gas activities are conducted in programs other than air. o Industrial Hazardous, and Municipal Waste o On-site Sewage Facilities o Public Water Supplies o Wastewater; Sludge o Stormwater o Water Rights o Underground Injection Control o Aggregate Production Operations

29. WASTE ISSUES

30. WATER ISSUES RV Parks“Oil Camps”

31. HAZARDOUS SPILLS/RESPONSE Which State Agency has Jurisdiction? Dependent on what is spilled and where  Texas Commission on Environmental Quality  General Land Office  Railroad Commission of Texas  Texas Department of State Health Services  Texas Parks and Wildlife Department  Texas Department of Public Safety  Governor’s Division of Emergency Management

32. OTHER AVENUES TO COMPLIANCE The 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.

33. APPROACHES 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.

34. QUESTIONS

35. Susan Jablonski, P.E., Director Central Texas Area Office of Compliance & Enforcement susan.jablonski@tceq.texas.gov 512-239-6731