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Scheduled Compliance Investigations

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by

Aimi Tanada

on 13 April 2017

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Transcript of Scheduled Compliance Investigations

TCEQ Oil & Gas Investigations
On-Site Investigation
Meet with regulated entity personnel and discuss course of investigation
Request brief tour/explanation of the site
Monitor on-site & fenceline readings with air monitoring equipment
Find & assess any leaks or issues at the site
May collect air samples, take videos, or photographs for follow-up
Brief Exit Interview of site and what to expect next
Infrared Video
Mission
Pre-Investigation
On-Site Investigation Type
Reconnaissance
Complaint
Scheduled Compliance
Title V
Find a Site
Gather Background Info
Check previous investigations
Contact Regulated Entity
Request Compliance Documents
Gathering Information
Determining Sites
Contact the Regulated Entity & Request Documents
30 Texas Administrative Code
§106.352 Permit By Rule
Date, Time, Location(s)
Compliance Documents Request
Toxic Vapor Analyzer (TVA)
RAE Equipment
Summa Air Canister
Optical Gas Imaging Camera (OGIC)
Previous Investigations
Risk-Based Prioritization
Proximity to population
Site investigation history
Potential to emit
Location & Customer
Central Registry
Air Permits Database
Check Site Investigation History
Any investigations?
Complaints?
Violations?
EXAMPLE
Oil & Gas Facilities
Registration/Notification Requirements
Historical Notification
Level 1 or Level 2 Registration
Exemptions
Emission Calculations
< 250 TPY NOx or CO
< 25 TPY VOC, SO2, H2S
Certified Emissions
Best Management Practices
Monitoring & Records Demonstrations (106.352(m), Table 8)
Post-Investigation
Review submitted compliance documents
Determine applicable & reviewable rules
30 TAC §106.352 Permit By Rule (O&G Sites)
30 TAC §106.512 Stationary Engines & Turbines
30 TAC Chapter 117 (NOx Testing/Engines)
40 CFR Part 60 Subpart JJJJ (Engines)
40 CFR Part 63 Subpart ZZZZ (HAPs)
40 CFR Part 60 Subpart OOOO (Equipment)
Air Standard Permits
Additional rules for different sites (ex. Title V, Saltwater Disposal Well, Processing Plant, etc.)
Conduct follow-up information requests
Determine compliance
Write up Investigation Report
Cite violations/areas of concern/additional issues as necessary
Engine Testing
Determine Applicability
Stationary Combustion Engines
Manufacture Date & HP
Location/County
Testing Methods & Compounds
NOx, CO, O2, and/or VOC
Three 1-hour test runs or Portable Analyzer Check
Initial Testing
Within 30-180 days after becoming applicable
Subsequent Testing
Quarterly, Annually, Biennially, Every X Run Hours
Testing Notification & Report Submittal
Notify X days before and within X days after engine test
Maintenance
Conduct required maintenance
Conduct testing as necessary after any major modifications
Recordkeeping
Records must be kept for 2-5 years minimum
Registration
(if applicable)
Follow-Up Information
OGIC Video Questionnaire & Infrared Video
Cause & Process Description
Estimated Emission Calculations
Corrective Action
Compliance with applicable rules
Air Sample Lab Analysis
Chain of Custody
Analyze air quality compounds
May require follow-up sampling
Exit Interview Form
Missing Information & Additional Records Request
Alleged Violations
Report Submittal & Approval
Submit Completed Investigation Report
Report Review & Approval
Final Actions Letter
General Compliance
Notice of Violation or Enforcement
Alleged Source (Complaints)
The Texas Commission on Environmental Quality strives to protect our state's public health and natural resources consistent with sustainable economic development. Our goal is clean air, clean water, and the safe management of waste.
Flame Ionization Detector (FID)
Measures hydrocarbons
Measures Carbon Monoxide (CO), Lower Explosive Limit (LEL), Volatile Organic Compounds (VOC), Hydrogen Sulfide (H2S), Oxygen (OXY), and Gamma
Can detect heat signatures, temperature differences, and organic compounds
Photo Ionization Detector (PID)
Long-term Health-Based AMCV for Benzene is 1.4 ppb-V
Full transcript