Bryan W. Shaw, Ph.D., P.E., Chainnan Toby Baker, Commissioner Zak Covar, Commissioner Richard A. Hyde, P.E., Executive Director ·. 1:..: 

### i"'UL

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## 11, JUL. 18 

## Prl 6:03 TEXAS COMMISSION ON ENVIRONMENTAL QUALI1Y Protecting Texas by Reducing andPreventing Pollution 

### July 16, 2014

Ron Curry Regional Administrator U.S. Environmental ProtectionAgency- Region 6 1445 

### Ross Avenue Dallas, Texas 75202-2733 

### Dear Mr. Curry: Docket No. 2013-1682-SIP Project No. 2013-016-SIP-NR

On July 2, 2014, 

### the Texas Commission on Environmental Quality (Commission) adopted a revision to the State Implementation Plan (SIP) for the 2008 

### Eight-Hour Ozone National Ambient Air Quality Standard (NAAQS) for the Houston-Galveston-Brazoria (HGB) and Dallas-FortWorth (DFW) Areas. The Commission adopted revisions to the SIP that include a baseline emission inventory (EI) for the 2008 

### Eight-Hour Ozone NAAQS for the HGB and DFW areas to satisfythe Federal Clean Air Act (FCAA), §172 

### and §182 

### EI requirements for the nonattainment areas. Enclosed are the proposed revisions to the SIP, a public hearing certification, a complete record ofthe public hearings, andthe accompanying order. I lookforward to your expeditious approval ofthis SIP revision. Sincerely,**~**

# -1:~'!::~. p E 

### Chairm BWS/ts Enclosures

cc: The**Honor~ble** 

### Rick Perry, Goven;wr**ofT~¥** 

### . Mr. Nate Hickman, Office. of. Budget;·Planmng and Policy, Office ofthe Governor Mr. Richard A. 

### Hyde, P.E., Executive Director, Texas Commission on Environmental QualityP.O. Box 13087 • Austin, Texas 78711-3087 • 512-239-1000 • tceq.texas.gov How is our customer service? tceq.texas.govjcustomersurvey

ll'•'

### TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

THE STATE OF TEXAS COUNTY OF TRAVIS Docket 

### No. 2013-1682-SIP Project 

### No. 2013-016-SIP-NR



### This is to certify thatthe attached electronic file is included andthat the electronic file is a true and correct copy ofdocuments for a revision to the Texas State Implementation Plan, adopted onJuly 2, 2014, pursuantto 40 Code ofFederal Regulations§ 51.104. I amthe records administrator for theAir Quality Division oftheTexas Commission on Environmental Quality (Commission).



### 0

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# DaVli:l rymer, Director Air Quality Division Texas Commission on Environmental QualityTexas Commission on Environmental Quality Public Hearings January 14 and 16, 2014 Concerning Revisions to the State Implementation Plan Regarding Emissions Inventory Reporting Requirements for the HGB and DFW Nonattainment Areas Under the 2008 Eight-Hour Ozone NAAQS Project No. 2013-016-SIP-NRINTRODUCTION

The Texas Commission on Environmental Quality (commission) held public hearings in Houston

on January 14, 2014; and in Arlington on January 16, 2014, to receive testimony regarding proposed revisions to the state implementation plan (SIP).

The SIP revision will satisfy Federal Clean Air Act, §172(c)(3) and §182(a)(1) emissions inventory reporting requirements for the Houston-Galveston-Brazoria and Dallas-Fort Worth nonattainment areas under the 2008 eight-hour ozone National Ambient Air Quality Standard. States are required to submit a comprehensive, accurate, current inventory of emissions from all

sources in nonattainment areas within two years of the July 20, 2012 effective date of designations.

The comment period closed on January 27, 2014. All testimony and comments have been reviewed and seriously considered. This hearing record contains a complete record of the public hearings and is divided into the following four sections:

o Public Notification and Proposal

o Written and Oral Testimony

o Evaluation of Testimony

o Staff Recommendations/Order

Additional copies of this hearing record are maintained in the TCEQ central office at 12100 Park 35 Circle, Austin, Texas 78753. For further information, please contact Brian Foster at (512) 239-1930.

# NOTICE 

# & PROPOSALPUBLIC NOTIFICATION

Notification to the public of the proposed revisions was conducted by the following procedures:

1. Publication of notice of public hearings in the following newspapers on the date listed: Austin American-Statesman: December 13, 2013 Fort Worth Star- Telegram: December 13, 2013 Houston Chronicle: December 13, 2013

2. Publication of the Notice of Public Hearings in the December 27, 2013, issue of the Texas Register(38 TexReg 9666).

3. Correspondence forwarding the notice of public hearings to the following officials and agencies: Speaker of the House Lieutenant Governor Alamo Area Council of Governments Capital Area Planning Council City of Arlington, Mayor's Office City of Dallas, Department of Environmental Quality City of Dallas, Department of Aviation City of El Paso, Environmental Services City of Fort Worth, Environmental Management Department City of Houston, Department of Health and Human Services City of Houston, Mayor's Office East Texas Council of Governments El Paso Metropolitan Planning OrganizationFederal Highway Administration Galveston County Health District Harris County Judge Harris County Pollution Control Services Department Harris County Public Health and Environmental Services Houston-Galveston Area Council North Central Texas Council of Governments South East Texas Regional Planning Commission Tarrant County Judge Texas Department of Transportation Victoria Metropolitan Planning Organization Arkansas Department of Pollution Control and Ecology Louisiana Department of Environmental Quality New Mexico Environmental Department Oklahoma Department of Environmental Quality United States Environmental Protection AgencyExample of Newspaper Classified Ad Austin American-Statesman, December 13, 2013

NOTICE OF PUBLIC HEARINGS BY THE TEXAS COMMISSION ON ENVIRONMENTAL QUALITY ON PROPOSED REVISIONS TO- THE STATE IMPLE·

MENTATION PLAN The Texas Commission on Environmental Quality (TCEQ or com- mission) will conduct public hearings to re- ceive testimony re- garding proposed revisions to the state implementation plan (SIP) under the re- quirements of Texas Health and Safety Code, §382.017; Texas Government Code, Chapter 2001, Subchapter B; and 40 Code of Federal Regulations §51.102 of the United States Environmental Protection Agency con- cerning SIPs. The proposed SIP revision would satisfy Fed· eral Clean Air Act, §172(c)(3) and §182(a) (1) emissions inventory reporting requirements forthe Houston- ' Galveston-Brazoria ' and Dallas-Fort Worth nonattainment areas under the 2008 eight- hour ozone National Ambient Air Quality Standard (NAAQS). States are required to SIJbmit a comprehen- SIVe, accurate, current inventory of emissions from all sources in nonattainment areas within two years of the July 20, 2012 effective date of designations. Public hearings on this proposal will be held in Houston on January 14, 2014 at 2:00 p.m. in Conference room A at the Houston-Galveston Area Council, 3555 Tim- mons Lane; and in Arlington on January 16, 2014 at 2:00 p.m. in the Council Chambers at the Arlington City Hall Building, 101 W. Abram Street. The hearings are structured for the receipt of oral or written comments by interested persons. Individuals may present oral statements when called upon in order of registration. Open discussion will not be per- mitted during the hearings; however, TCEQ 

# I staff members will be available to discuss the proposal 30 min- ' (Jtes priorto each hear-

! mg. Persons who have spe- cial communication or other accommodation needs who are. plan- ning to attend the hearings should con- tact Joyce Spencer- Nelson, Air Quality Division at (512) 239- 5017. Requests should be made as far in ad- vance as possible. Written comments may- be submitted to Nina Castillo, MC 206, Air Quality Division, Office of Air, Texas Commission on Environmental Quality, P.O. Box 13087, Austin, Texas 78711-3087, or faxed to (512) 239-6188. Electronic comments may be submitted at http:/ /wwwS.tceq. texas. go v/rules/ ecomments/. File size restrictions may apply to comments bemg submitted via the eCoiriirierits system: All comments pertain- ing to the El SIP revF sian for the 2008 eighthour ozone NAAQS should reference SIP Project Number 2013- 016-SIP-NR. The com- ment period closes !anuary 27, 2014. Cop- Ies of the proposed rulemaking can be obtained from the TCEQ's Website at http:/**/~ww.** tceq. tex-as.gov/alrquality/sip/criteriapollutants/sip-ozone. For further information, please contact Nina Castillo, Air Quality Planning Section, (512) 239-4415.

--to (512) 239-4808. Ele tronic comments may be submitted at: http://www5.tceq.texas.gov ru/es/ecomments/ File size restrictions may apply to comm nts being submitted via the eComments system. All comments should reference Rule Project Number 2014-008-114-AD. The c mment period closes January 27, 2014. Copies of the proposed rulemaking can be obtained from the commission's Web site a http://www.tceq.texas.gov/navlruleslpropose _adopt.html. For furth r information, please contact Joe Briseno, Pollution Prevention and E ucation, (512) 239-6781. TRD-201305929 Robert Martinez Director, Environmental La Division Texas Commission on Envi nmental Quality Filed: December 13, 2013 

# • • 

# • Notice ofPublic Hem·in on Proposed Revisions to 30 TAC Chapter 305 The Texas Commission on nvironmental Quality (commission) will conduct a public hearing t receive testimony regarding proposed revisions to 30 TAC Chapter 305, Consolidated Permits, Subchapter P, §305.541, under the require ents ofTexas Government Code, Chapter 2001, Subchapter B. The proposed rulemaking v ould adopt by reference 40 Code ofFederal Regulations Part 449, ich establishes technology-based effluent limitation guidelines and ne source performance standards to control discharges ofpollutants fro airport de-icing operations. The commission will hold a ublic hearing onthis proposal in Austin on January 23,2014, at 10:00 am. in Building E, Room 201S, at the commission's central office Joe ed at 12100 Park 35 Circle. The hearing is structured for the receipt f oral or written comments by interested persons. Individuals may p esent oral statements when called upon in order ofregistration. Open iscussion will not be permitted during the hearing: however, commiss on staffmembers will be available to discuss the proposal 30 minut prior to the hearing. Persons who have special ommunication or other accommodation needs who are planning to attend the hearing should contact Sandy Wong, Office ofLegal Ser ices, at (512) 239-1802. Requests should be made as far in advance possible. Written comments may b submitted to Patricia Duron, MC 205, Office of Legal Service Texas Commission on Environmental Quality, P.O. Box 130, 7, Austin, Texas 78711-3087 or faxed to (512) 239-4808. Electronic comments may be submitted at: http://www5.tceq.texas.gov uleslecomments/ File size restrictions may apply to comm nts being submitted via the eComments system. All comments hould reference Rule Project Number 2013-052-305-0W. The c ment period closes January 27, 2014. Copies of the proposed ulemaking can be obtained from the commission's Web site a http://www.tceq.texas.gov/navlrules/propose_adopt.html. For furth information, please contact Laurie Fleet, Wastewater Permitting Sec on, at (512) 239-5445. TRD-20 1305925 Robert Martinez Director, Environmental La Division Texas Commission on Envir nmental Quality Filed: December 13, 2013 

# • • • Notice ofPublic Hearings on Proposed Revisions to the State Implementation Plan The Texas Commission on Environmental Quality (TCEQ or commission) will conduct public hearings to receive testimony regarding proposed revisions to the state implementation plan (SIP) under the requirements ofTexas Health and Safety Code, §382.017; Texas Government Code, Chapter 2001, SubchapterB; and 40 Code ofFederal Regulations §51.102 ofthe United States Environmental Protection Agency concerning SIPs. The proposed SIP revision would satisfy Federal Clean Air Act, §172(c)(3) and §182(a)(l) emissions inventory reporting requirements for the Houston-Galveston-Brazoria and Dallas-Fort Worth nonattainment areas under the 2008 eight-hour ozone National Ambient Air Quality Standard (NAAQS). States are required to submit a comprehensive, accurate, cmTent inventory ofemissions from all sources in nonattainment areas within two years of the July 20, 2012 effective date ofdesignations. Public hearings on this proposal will be held in Houston on January 14, 2014 at 2:00p.m. in Conference Room A at the Houston-Galveston Area Council, 3555 Timmons Lane; and in Arlington on January 16, 2014 at 2:00p.m. in the Council Chambers at the Arlington City Hall Building, I0I W. Abram Street. The hearings are structured for the receipt oforal or written comments by interested persons. Individuals may present oral statements when called upon in order ofregistration. Open discussion will not be permitted during the hearings; however, TCEQ staffmembers will be available to discuss the proposal30 minutes prior to each hearing. Persons who have special communication or other accommodation needs who are planning to attend the hearings should contact Joyce Spencer-Nelson, Air Quality Division, at (512) 239-5017. Requests should be made as far in advance as possible. Written comments may be submitted to Nina Castillo, MC 206, Air Quality Division, Office of Air, Texas Commission on Environmental Quality, P.O. Box 13087, Austin, Texas 78711-3087 or faxed to (512) 239-6188. Electronic comments may be submitted at http://www5. tceq. texas.govlrules/ecomments/ File size restrictions may apply to comments being submitted via the eComments system. All comments pertaining to the EI SIP revision for the 2008 eight-hour ozone NAAQS should reference SIP Project Number 2013-016-SIP-NR. The comment period closes January 27, 2014. Copies ofthe proposed rulemaking can be obtained from the TCEQ's Website at http://www.tceq. texas.gov/airquality/siplcriteria-pollutants/sip-ozone. For fmiher information, please contact Nina Castillo, Air Quality Planning Section, (512) 239-4415. TRD-201305978 Robert Martinez Director, Environmental Law Division Texas Commission on Environmental Quality Filed: December 17, 2013 

# • • • Notice ofReceipt ofAp lication and Intent to Obtain Municipal Solid Waste imited Scope Major Permit Amendment Permit Nm ber 2274 APPLICATION. City ofL lefield, P.O. Box 1267, Littlefield, Lamb County, Texas 79339, a nicipal solid waste disposal facility, has applied to the Texas Com ission on Environmental Quality (TCEQ) for a Type I-AE and Typ IV-AE Municipal Solid Waste Limited Scope Major Permit Arne dment to obtain authorization to conve1i the designation of six Typ I-AE landfill cells to Type IV-AE land

### 38 TexReg 9666 December 27, 

### 2013 Texas RegisterBryan W. Shaw, Ph.D., Chairman Toby Baker, Commissioner Zak Covar, ExecutiveDirector



### TEXAS COMMISSION ON ENVIRONMENTAL QUALITY Protecting Texas byReducing andPreventing Pollution 

### NOTICE OF PUBLIC HEARINGS BYTHETEXAS COMMISSION ON ENVIRONMENTAL QUALITY ON PROPOSED REVISIONS TO THE STATE IMPLEMENTATION PLAN The Texas Commission on Environmental Quality (TCEQ or commission) will conduct public hearings to receive testimony regarding proposed revisions to the state implementation plan (SIP) underthe requirements of Texas Health and Safety Code, §382.017; Texas Government Code, Chapter 2001, Subchapter B; and40 Code of Federal Regulations §51.102 ofthe United States Environmental ProtectionAgency concerning SIPs. The proposed SIP revision would satisfy Federal Clean AirAct, §172(c)(3) and §182(a)(1) emissions inventory reporting requirements for the Houston-Galveston-Brazoria and Dallas-Fort Worth nonattainment areas under the 2008 eight-hour ozone National AmbientAir Quality Standard (NAAQS). States are required to submit a comprehensive, accurate, current inventory ofemissions from all sources in nonattainment areas within two years ofthe July 20, 2012 effective date ofdesignations. Public hearings on this proposal will be held in Houston on January 14, 2014 at 2:00 p.m. in Conference room A at the Houston-Galveston Area Council, 3555 Timmons Lane; and inArlington on January 16, 2014 at 2:00p.m. in the Council Chambers at the Arlington City Hall Building, 101 W. Abram Street. The hearings are structuredfor the receipt oforal orwritten comments by interestedpersons. Individuals may present oral statements when called upon in order ofregistration. Open discussion will notbe permitted during the hearings; however, TCEQ staffmembers will be available to discuss the proposal 30 minutes priorto each hearing. Persons who have special communication or other accommodation needs who are planning to attendthe hearings should contact Joyce Spencer-Nelson, Air Quality Division at (512) 239-5017. Requests shouldbe made as far in advance as possible. Written comments maybe submittedto Nina Castillo, MC 206, Air Quality Division, Office ofAir, Texas Commission on Environmental Quality, P.O. Box 13087, Austin, Texas 78711-3087, or faxed to (512) 239-6188. Electronic comments maybe submitted at 

### http:jjwwws.tceq.texas.govjrulesjecommentsj. File size restrictions may apply to comments being submittedvia the 

### eComments system. All comments pertaining to the EI SIP revision for the 2008 eight-hour ozone NAAQS should reference SIP Project Number 2013-016-SIP-NR. The comment period closes January 27, 2014. Copies ofthe proposed rulemaking can be obtainedfrom the TCEQ's Website at 

### http:jjwww.tceq.texas.govjairqualityjsipjcriteria-pollutantsjsip-ozone. Forfurther information, please contact Nina Castillo, Air Quality Planning Section, (512) 239-4415. P.O. Box 13087 • Austin, Texas 78711-3087 • 512-239-1000 • tceq.texas.gov How is our customer service? tceq.texas.govjgotojcustomersurvey printed on recycled paperREVISIONS TO THE STATE OF TEXAS AIR QUALITY IMPLEMENTATION PLAN FORTHE CONTROL OF OZONEAIR POLLUTION

EMISSIONS INVENTORY FORTHE 2008 EIGHT-HOUR OZONE STANDARD NONATTAINMENT AREAS

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY P.O. BOX 13087 AUSTIN, TEXAS 78711-3087

EMISSIONS INVENTORY STATE IMPLEMENTATION PLAN REVISION FORTHE 2008 EIGHT-HOUR OZONE NATIONALAMBIENT AIR QUALITYSTANDARD FORTHE

HOUSTON-GALVESTON-BRAZORIAAND DALLAS-FORT WORTHAREAS

Project Number 2013-016-SIP-NR

Proposal December 11, 2013

### Thispage intentionally left blankEXECUTIVE SUMMARY The Federal Clean Air Act (FCAA) requires states to submit emissions inventory (EI) information for all relevant sources for areas that are designated nonattainment for any ofthe NationalAmbientAir Quality Standards (NAAQS) for each area designated nonattainmentfor a NAAQS. On March 12, 2008, the United States Environmental ProtectionAgency (EPA) lowered the eight-hour ozone NAAQS from o.o8 parts permillion (ppm) to 0.075 ppm. Under the 0.075 ppm (75 parts perbillion) standard, the EPA designatedthe Houston-Galveston-Brazoria (HGB) area nonattainment with a marginal classification and the Dallas-FortWorth (DFW) area nonattainment with a moderate classification, effective July 20, 2012. The eight-county HGB areaincludes Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties and the ten-county DFW area includes Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, Tarrant, andWise Counties. According to FCAA, §172(c)(3) and §182(a)(1), states are required to submit "a comprehensive, accurate, current inventory ofactual emissions from all sources," within two years ofthe effective date ofnonattainment designations for the ozone NAAQS. Through the proposed implementation rule for the 2008 eight-hour ozone NAAQS, the EPA interprets these FCAA requirements to be due within two years ofthe July 20, 2012 effective date ofdesignations for the 2008 eight-hour ozone NAAQS (78 FR 34178). This proposed revision to the state implementation plan would satisfythe FCAA, §§172 and 182 requirements for the HGB and DFW nonattainment areas under the 2008 eight-hour ozone standard. As reinforcedbythe EPA's proposed 40 Code ofFederal Regulations §51.1115, the nonattainment areabaseyear EI submission is due no later than 24 months from theJuly 20, 2012 effective date ofdesignations under the 2008 eight-hour ozone standard (July 20, 2014) and then every threeyears thereafter (2017, 2020, etc.). The EPA specified that states use 2011 as a base year in the proposed implementationrule for the 2008 eight-hour ozone NAAQS. An EI submission is also required under the existing Air Emissions Reporting Requirements (AERR) Rule. The 2011 AERR EI has been developed for many pollutants including ozone precursors (volatile organic compounds and nitrogen oxides) from point, area, on-roadmobile, non-road mobile, andbiogenic emissions source categories. This EI SIP revision submittal is the baseline EI for the 2008 eight-hour ozone NAAQS andAERR EI submittals every three years thereafterwill satisfy the periodic EI requirements.

ES-1SECTIONV-A: LEGALAUTHORITY General The Texas Commission on Environmental Quality (TCEQ) has the legal authorityto implement, maintain, and enforce the National AmbientAir Quality Standards (NAAQS) and to control the quality ofthe state's air, including maintaining adequate visibility. The first air pollution control act, known as the Clean Air Act ofTexas, was passedbytheTexas Legislature in 1965. In 1967, the Clean Air Act ofTexas was supersededby a more comprehensive statute, theTexas Clean Air Act (TCAA), found in Article 4477-5, Vernon's Texas Civil Statutes. The legislature amendedtheTCAA in 1969, 1971, 1973, 1979, 1985, 1987, 1989, 1991, 1993, 1995, 1997, 1999, 2001, 2003, 2005, 2007, 2009, 2011, and 2013. In 1989, theTCAA was codified as Chapter 382 oftheTexas Health and Safety Code. Originally, theTCAA statedthattheTexas Air Control Board (TACB) is the state air pollution control agency andis theprincipal authority inthe state on matters relating to the quality ofair resources. In 1991, the legislature abolished theTACB effective September 1, 1993, andits powers, duties, responsibilities, andfunctions were transferredto theTexas Natural Resource Conservation Commission (TNRCC). With the creation oftheTNRCC, the authority over air quality is found inboththeTexas Water Code and the TCAA. Specifically, the authority ofthe TNRCC is found in Chapters 5 and 7· Chapter 5, SubchaptersA- F, H- J, and L, include the general provisions, organization, and general powers and duties oftheTNRCC, and the responsibilities and authority ofthe executive director. Chapter 5 also authorizes theTNRCC to implement action when emergency conditions arise and to conduct hearings. Chapter 7 gives the TNRCC enforcement authority. In 2001, the 77th Texas Legislature continuedthe existence of theTNRCC until September 1, 2013, and changedthe name oftheTNRCC to theTCEQ. In 2009, the 81st Texas Legislature, during a special session, amended section 5.014 oftheTexas Water Code, changing the expiration date oftheTCEQ to September 1, 2011, unless continued in existencebytheTexas SunsetAct. In 2011, the 82ndTexas Legislature continued the existence oftheTCEQ until 2023. The TCAA specifically authorizes theTCEQ to establish the level ofquality to be maintained in the state's air and to control the quality ofthe state's airbypreparing and developing a general, comprehensive plan. The TCAA, Subchapters A- D, also authorize theTCEQ to collect information to enable the commission to develop an inventory ofemissions; to conduct research and investigations; to enter property and examine records; to prescribe monitoring requirements; to institute enforcement proceedings; to enter into contracts and execute instruments; to formulate rules; to issue orders taking into consideration factors bearing upon health, welfare, social and economic factors, andprttcticability and reasonableness; to conduct hearings; to establish air quality control regions; to encourage cooperation with citizens' groups and other agencies andpolitical subdivisions ofthe state as well as with industries andthe federal government; andto establish and operate a system ofpermits for construction or modification offacilities. Local government authority is found in Subchapter E ofthe TCAA. Local governments have the same power as the TCEQ to enter property and make inspections. They also may make recommendations to the commission concerning any action ofthe TCEQ that affects their territorialjurisdiction, maybring enforcement actions, and may execute cooperative agreements with theTCEQ or otherlocal governments. In addition, a city ortown may enact and enforce ordinances for the control and abatement ofair pollution not inconsistent with theprovisions of theTCAA andthe rules or orders ofthe commission.

iiSubchapters G and H oftheTCAA authorize theTCEQ to establish vehicle inspection and maintenance programs in certain areas ofthe state, consistent with the requirements ofthe Federal Clean Air Act; coordinate with federal, state, and local transportation planning agencies to develop and implement transportation programs and measures necessaryto attain and maintain the NAAQS; establish gasoline volatility and low emission diesel standards; and fund and authorize participating counties to implementvehicle repair assistance, retrofit, and accelerated vehicle retirement programs. Applicable Law The following statutes and rules provide necessary authorityto adopt and implement the state implementation plan (SIP). The rules listed below have previouslybeen submitted as part ofthe SIP. Statutes All sections ofeach subchapter are included, unless otherwise noted. TEXAS HEALTH & SAFETY CODE, Chapter 382 TEXAS WATER CODE Chapter 5: Texas Natural Resource Conservation Commission SubchapterA: General Provisions September 1, 2013 September 1, 2013 Subchapter B: Organization oftheTexas Natural Resource Conservation Commission Subchapter C: Texas Natural Resource Conservation Commission Subchapter D: General Powers and Duties ofthe Commission Subchapter E: Administrative Provisions for Commission Subchapter F: Executive Director (except §§5.225, 5.226, 5.227, 5.2275,5.231, 5.232, and 5·236) Subchapter H: Delegation ofHearings Subchapter I: Judicial Review SubchapterJ: Consolidated Permit Processing Subchapter L: Emergency andTemporary Orders (§§5.514, 5.5145, and 5.515 only) Subchapter M: Environmental Permitting Procedures (§5.558 only) Chapter 7: Enforcement SubchapterA: General Provisions (§§7.001, 7.002, 7.0025, 7.004, and 7.005 only) Subchapter B: Corrective Action and Injunctive Relief (§7.032 only) Subchapter C: Administrative Penalties Subchapter D: Civil Penalties (except §7.109) Subchapter E: Criminal Offenses and Penalties: §§7.177, 7.179-7.183

Rules All ofthe following rules are found in 30Texas Administrative Code, as ofthe following latest effective dates: Chapter 7: Memoranda ofUnderstanding, §§7.110 and 7.119 December 13,1996 and May 2, 2002 Chapter 19: Electronic Reporting Chapter 35: Subchapters A-C, K: Emergency andTemporary Orders and Permits; Temporary Suspension orAmendment ofPermit Conditions

iii March 15, 2007 July 20, 2006Chapter 39: Public Notice, §§39-402(a)(1)- (6), (8), and (10)- (12), 39-405(±)(3) and (g), (h)(1)(A)- (4), (6), (8)- (11), (i) and G), 39.407, 39.409, 39-411(a), (e)(1)- (4)(A)(i) and (iii), (4)(B), (5)(A) and (B), and (6)- (1o), (11)(A)(i) and (iii) and (iv), (11)(B)- (F), (13) and (15), and (±)(1)- (8), (g) and (h), 39.418(a), (b)(2)(A), (b)(3), and (c), 39-419(e), 39.420 (c)(1)(A)- (D)(i)(I) and (II), (D)(ii), (c)(2), (d)- (e), and (h), and 39.601- 39.605 June 24, 2010 Chapter 55: Requests for Reconsideration and Contested Case Hearings; Public Comment, §§55.150, 55.152(a)(1), (2), (5), and (6) and (b), 55.154(a), (b), (c)(1)- (3), and (5), and (d)- (g), and 55.156(a), (b), (c)(1), (e), and (g) June 24, 2010 Chapter 101: General Air Quality Rules June 12, 2013 Chapter 106: Permitsby Rule, SubchapterA May 15, 2011 Chapter 111: Control ofAir Pollution from Visible Emissions and Particulate Matter February 16, 2012 Chapter 112: Control ofAir Pollution from Sulfur Compounds July 16, 1997 Chapter 113: Standards ofPerformance for Hazardous Air Pollutants and for Designated Facilities and Pollutants May 14, 2009 Chapter 114: Control ofAir Pollution from MotorVehicles September 13, 2012 Chapter 115: Control ofAir Pollution from Volatile Organic Compounds December 29, 2011 Chapter 116: Permits for New Construction or Modification August 16, 2012 Chapter 117: Control ofAir Pollution from Nitrogen Compounds May2, 2013 Chapter 118: Control ofAir Pollution Episodes March 5, 2000 Chapter 122: §122.122: Potential to Emit December 11, 2002 Chapter 122: §122.215: Minor Permit Revisions June 3, 2001 Chapter 122: §122.216: Applications for Minor Permit Revisions June 3, 2001 Chapter 122: §122.217: Procedures for Minor Permit Revisions December 11, 2002

Chapter 122: §122.218: Minor Permit Revision Procedures for Permit Revisions Involving the Use ofEconomic Incentives, Marketable Permits, and Emissions Trading June 3, 2001

ivSECTIONVI: CONTROL STRATEGY A. Introduction (No change) B. Ozone (Revised) 

### C. Particulate Matter (No change) D. Carbon Monoxide (No change) E. Lead (No change) F. Oxides ofNitrogen (No change) G. Sulfur Dioxide (No change) 

### H. Conformitywith the National AmbientAir Quality Standards (No change) I. Site Specific (No change) 

### J. Mobile Sources Strategies (No change) K. Clean Air Interstate Rule (No change) L. Transport (No change) M. Regional Haze (No change)

vTABLE OF CONTENTS Executive Summary Section V-A: Legal Authority Section VI: Control Strategy Table ofContents List ofAcronyms List ofTables List ofAppendices Chapter 1: General 1.1 Background 1.2 Introduction 1.3 Health Effects 1.4 Public Hearing and Comment Information 1.5 Social and Economic Considerations 1.6 Fiscal and Manpower Resources Chapter 2: Emissions Inventories (EI) 2.1 Introduction 2.2 Point Sources 2.2.1 Point Source EI Development 2.2.2 HGB Point Source EI 2.2.3 DFW Point Source EI 2.3 Area Sources 2.3.1 Area Source EI Development 2.3.2 HGB Area Source EI 2.3.3 DFW Area Source EI 2.4 Non-road Mobile Sources 2-4.1 Non-road EI Development 2.4.2 HGB Non-road Source EI 2-4.3 DFW Non-road Source EI 2.5 On-road Mobile Sources 2.5.1 On-road Mobile Source EI Development 2.5.2 HGB On-road Mobile Source EI 2.5.3 DFW On-road Mobile Source EI 2.6 Biogenic Sources 2.7 Emissions Summary

viAEO AERR ASLRRA CFR CMV DFW EDMS EI EIQ EPA FCAA FMVCP FR GIS HGB I/M MOVES NAAQS NEI NOx PEl ppb ppm RRC SIP STARS TAC TCAA TCEQ TDM TexN TNRCC tpd LIST OFACRONYMS Annual Energy Outlook Air Emissions Reporting Requirements American Short Line and Regional RailroadAssociation Code ofFederal Regulations commercial marine vessel Dallas-FortWorth Emissions and Dispersion Modeling System emissions inventory emissions inventory questionnaire United States Environmental Protection Agency Federal CleanAirAct Federal MotorVehicle Control Program FederalRegister Geographic Information System Houston-Galveston-Brazoria inspection and maintenance MotorVehicle Emissions Simulator NationalAmbientAir Quality Standard National Emissions Inventory nitrogen oxides periodic emissions inventory parts perbillion parts per million Railroad Commission ofTexas state implementation plan State ofTexas Air Reporting System Texas Administrative Code Texas CleanAirAct Texas Commission on Environmental Quality (commission) travel demand model Texas NONROAD Model Texas Natural Resource Conservation Commission tons per day

viitpy TxLED VMT 

## voc tons peryear Texas Low Emission Diesel vehicle miles traveled volatile organic compounds

viiiLIST OFTABLES Table 1-1: Public Hearing Information Table 2-1: HGB 2011 NOx and VOC Emissions for Point Sources (tons per day and tons peryear) Table 2-2: DFW 2011 NOx andVOC Emissions for Point Sources (tons per day andtons per year) Table 2-3: HGB 2011 NOx andVOC Emissions for Area Sources (tons per day andtons peryear) Table 2-4: DFW 2011 NOx andVOC Emissions for Area Sources (tons per day and tons peryear) Table 2-5: HGB 2011 NOx and VOC Emissions for Non-road Categories (tons per day and tons peryear) Table 2-6: DFW 2011 NOx andVOC Emissions for Non-road Categories (tons per day and tons peryear) Table 2-7: HGB 2011 NOx and VOC Emissions for On-road Mobile Sources (tons per day and tons peryear) Table 2-8: DFW 2011 NOx andVOC Emissions for On-road Mobile Sources (tons per day and tons peryear) Table 2-9: SummaryofHGB 2011 NOxandVOC Emissions (tons per day and tons peryear) Table 2-10: Summary ofDFW 2011 NOxandVOC Emissions (tons per day and tons peryear)

ixAppendix Appendix A Appendix B Appendix C

Appendix D Appendix E Appendix F Appendix G AppendixH Appendix I

AppendixJ LIST OFAPPENDICES Appendix Narne Characterization ofOil and Gas Production Equipment and Develop a Methodology to Estimate Statewide Emissions Condensate Tank Oil and Gas Activities Development of2008 Annual and Ozone Season Daily Emissions Inventories andActivity Data for Non-road Sources within theTexas NONROAD Model (TexN) Development ofStatewideAnnual Emissions Inventory andActivity Data for Airports Development ofAnnual Emissions Inventories andActivity Data for Airports inthe 12-County Dallas-Fort WorthArea Development of2011 Statewide Toxics andActual Annual and Ozone Season Weekday Emissions Inventories for Commercial MarineVessels Development ofTexas Statewide Drilling Rigs Emissions Inventories for theYears 1990, 1993, 1996, and 1999 through 2040 2011 Texas Railroad Emission Inventory Report Development of2011 On-road Mobile SourceActual Annual and Summer Weekday Emissions Inventories for All Texas Counties (Except for 12 Counties in the Dallas-Fort Worth Area), andWinter Weekday Emissions Inventories for El Paso: Houston-Galveston-BrazoriaArea Development of2011 On-road Mobile Source Actual Annual and Summer Season Weekday Emissions Inventories for 12 Counties in the Dallas-Fort Worth Metropolitan StatisticalArea-Amendment

X

### CHAPTER1: GENERAL 1.1BACKGROUND "The History ofthe Texas State Implementation Plan (SIP)," a comprehensive overview ofthe SIP revisions submittedto the United States Environmental ProtectionAgency (EPA) bythe State ofTexas, is available onthe Introduction to the SIP Web page (http:/ /www.tceq.texas.govjairquality/sip/sipintro.html#History) on the Texas Commission on Environmental Quality's (TCEQ) website (http:/ jwww.tceq.texas.gov).

1.2 INTRODUCTION On March 12, 2008, the United States Environmental ProtectionAgency (EPA) lowered the eight-hour ozone standard from o.o8 parts per million (ppm) to 0.075 ppm. Under the 0.075 ppm (75 parts perbillion) standard, the EPA designated the Houston-Galveston-Brazoria (HGB) area nonattainment with a marginal classification and the Dallas-Fort Worth (DFW) area nonattainment with a moderate classification, effective July 20, 2012. The eight-county HGB area includes Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties and the ten-county DFW area includes Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, Tarrant, andWise Counties. This proposed SIP revision would satisfy the Federal Clean Air Act (FCAA), §§172 and 182 emissions inventory (EI) requirements for the nonattainment areas under the 2008 eight-hour ozone National AmbientAir Quality Standard (NAAQS). Through the proposed implementation rule for the 2008 eight-hour ozone NAAQS, the EPA interprets the FCAA requirements that states submit a comprehensive, accurate, current EI from all sources, as described in FCAA, §172(c)(3) and §182(a)(1) to be due within two years ofthe July 20, 2012 effective date of designations for the 2008 eight-hour ozone NAAQS. The FCAA requires that Eisbe prepared for nonattainment areas generally, andprovides for specific requirements that apply in ozone nonattainment areas. Because ozone is photochemicallyproducedin the atmosphere when volatile organic compounds (VOC) emissions are mixed with nitrogen oxides (NOx) in the presence ofsunlight, states are required to compile information on the important sources of these precursor pollutants. The Eis provide data for a variety ofair quality planning tasks including establishingbaseline emission levels, calculating federally required emission reduction targets, emission inputs into air quality simulation models, and tracking emissions over time. The total EI ofVOC, NOx, and other pollutants for an area are summarizedfrom the estimates developed for five general categories ofemissions sources: point, area, on-road mobile, non-road mobile, andbiogenic. The EPA specified that states use 2011 as a base year in the proposed implementation rule for the 2008 eight-hour ozone NAAQS for this EI SIP to address the EI requirements. Theyear 2011 is also a year for a required EI submission under the existingAir Emissions Reporting Requirements (AERR) Rule. In accordance with the EPA's AERR, the National Emissions Inventory (NEI) is a comprehensive and detailed estimate ofair emissions ofboth criteria and hazardous air pollutants. As directed by theAERR, the NEI includes statewide coverage. Annual and summer day emissions are reported on a three-year cycle for theAERR. States can rely on periodic AERR EI submittals to satisfy ongoing SIP EI submission requirements every three years. The periodic EI SIP revision submission requirements would fall in the same years as the AERR submittals.

1-11.3 HEALTH EFFECTS In 2008, the EPA revised the primary ozone standardto 0.075 ppm. To support the 2008 eighthour primary ozone standard, the EPA provided information that suggestedthat health effects may potentially occur at levels lower than the previous o.o8o ppm standard. Breathing relatively high levels ofground-level ozone can cause acute respiratory problems like cough and respiratoryirritation and can aggravate the symptoms ofasthma. Repeated exposures to high levels ofozone can potentially make people more susceptible to respiratory infection and lung inflammation and can potentially aggravate preexisting respiratory diseases, such as bronchitis and emphysema. Children are at a relatively higher risk from exposure to ozone when compared to adults, since theybreathe more air per pound ofbody weight than adults andbecause children's respiratory systems are still developing. Children also spend a considerable amount oftime outdoors during summer and during the start ofthe school year (August through October) when high ozone levels are typically recorded. Adults most at risk from exposures to elevated ozone levels are people working or exercising outdoors and individuals with preexisting respiratory diseases.

1.4 PUBLIC HEARINGAND COMMENT INFORMATION The commission will hold public hearings for this proposed SIP revision atthe times and locations listedbelow. 

### Table 1-1: 

### Public Hearing Information

d"' City**Oat~** 

### Tirne location Houston January 14, 2014 2:00p.m. Houston-Galveston Area Council Conference Room A 3555 Timmons, Suite 120 Houston, Texas 77027 Arlington January 16, 2014 2:00p.m. Arlington City Hall Building Council Chambers, 1't Floor 101 W. Abram Street Arlington, Texas 76010 Thepublic comment period will open on December 13, 2013 and close onJanuary 27, 2014. Notice ofpublic hearings for this SIP revision will be published in the 

### Texas Register and various newspapers. Written comments will be accepted via mail, fax, orthrough the eComments system. All comments should reference the "Emissions Inventory State Implementation Plan Revision for the 2008 Eight-Hour Ozone Standard" and Project Number 2013-016-SIP-NR. Comments maybe submittedto Nina Castillo, MC 206, State Implementation Plan Team, Office ofAir, Texas Commission on Environmental Quality, P.O. Box 13087, Austin, Texas 78711-3087 orfaxed to (512) 239-6188. Ifyou choose to submit electronic comments, they mustbe submittedthrough the eComments (http:/ jwww5.tceq.state.tx.usjrules/ecomments) system. File size restrictions may apply to commentsbeing submittedvia the eComments system. Comments mustbe received byJanuary 27,2014. An electronic version ofthis proposed SIP revision and appendices can be found at theTCEQ's SIP HotTopics Web page (http:/ jwww.tceq.texas.govjairqualityjsip/Hottop.html).

1-21.5 SOCIALAND ECONOMIC CONSIDERATIONS Because this SIP revision does not create new obligations for sources to report EI information, there are no changes that would have an impact on society or the economy. 1.6 FISCALAND MANPOWERRESOURCES The TCEQ has determined that its fiscal and manpower resources are adequate and will notbe adversely affected through theimplementation ofthis plan.

1-3CHAPTER 2: EMISSIONS INVENTORIES (EI)

2.1 INTRODUCTION The Federal Clean Air Act (FCAA) requires that Eis be preparedfor ozone nonattainment areas. Tropospheric ozone is producedwhen ozone precursors, volatile organic compounds (VOC) and nitrogen oxides (NOx), undergo photochemical reactions inthe presence ofsunlight. TheTexas Commission on Environmental Quality (TCEQ) maintains an EI ofcurrent information for sources ofNOx andVOC thatidentifies the types ofemissions sources present in an area, the amount ofeach pollutant emitted, andthe types ofprocesses and control devices employed at each plant or source category. The EI provides data for a variety ofair quality planning tasks, including establishingbaseline emissions levels, calculating federally required emission reduction targets, developing emissions inputs for air quality models, and tracking emissions reductions over time. The total inventory ofNOx andVOC emissions for an area is derived from estimates developed for five general categories ofemissions sources: point, area, non-road mobile, on-roadmobile, andbiogenic. The federal Air Emissions Reporting Requirements (AERR) rule requires states to develop and submit periodic Els to the United States Environmental ProtectionAgency (EPA) every three years. The 2011 inventorywas thefirst periodic emissions inventory (PEl) submittedunder the AERR. PertheAERR, the 2011 PEl was reportedto the EPA's National Emissions Inventory (NEI) as a comprehensive and detailed estimate ofair emissions, including ozone precursors (NOx andVOC). As directed bytheAERR, the Texas PEl includes annual emissions for the entire state and ozone season daily emissions for the 2008 eight-hour ozone nonattainment areas in Texas.

2.2 POINT SOURCES 2.2.1 Point Source EI Development Stationarypoint source emissions data are collected annuallyfrom sites that meet the reporting requirements of 30Texas Administrative Code (TAC) §101.10. To collect the data, theTCEQ mails emissions inventory questionnaire (EIQ) courtesy notification letters to all sites identified as meeting the reporting requirements of 30TAC §101.10. Companies are required to report emissions data and to provide samples ofcalculations usedto determine reported emissions in accordance with detailed guidance. The guidance documents are available at the TCEQ Point Source Emissions InventoryWeb page (http:/jwww.tceq.texas.gov/airquality/point-sourceeijpsei.html). Information characterizing the process equipment, the control devices, and the emissions points is also required. Data submittedto theTCEQ are reviewed for quality assurance purposes and then stored in the State ofTexas Air Reporting System (STARS) database. The 2011 base year point source EI datawere extracted from STARS onJune 28, 2013. The extracted data contain ozone season daily and annual NOx andVOC emissions from each site in the Houston-Galveston-Brazoria (HGB) and Dallas-FortWorth (DFW) 2008 eight-hour ozone nonattainment areas that submitted a 2011 EIQ, including revisions reviewed, approved, and entered on orbefore the extract date. The point source inventory data will be extracted again in the spring of 2014 for the adoption ofthe EI State Implementation Plan (SIP) revision. Site level 2011 NOx and VOC emissions datawill be summarized and provided in an appendix for adoption. This second extract will account for revisions submitted on or before March 31, 2014 that havebeen reviewed, approved, and entered into STARS. Further information, including 2011 unit-level NOx andVOC emissions data, is available upon request.

2-1A summary ofthe 2011 point source EI data for the HGB and DFW 2008 eight-hour ozone nonattainment areas is presented in Table 2-1: 

### HGB 2011 

### NOx and VOCEmissions for Point Sources (tonsperday and tonsperyear), andTable 2-2: 

### DFW2011 

### NOx and VOCEmissions for PointSources (tonsperday and tonsperyear).

2.2.2 HGB Point Source EI Table 2-1: HGB 2011NOx andVOC Emissions for Point Sources (tons per day and tons peryear) "**~ O~one**  Season " -**O;z~;:me** Season**~unty** WeekdayNQx AnnoalNOx**W4;?ek~ayVOC** AnnuaiVOC (tpy) (tpy) •(tpd) _c (tpd} Brazoria 18.37 6,863.08 11.34 3,825.03 Chambers 7.76 2,290.55 5.64 1,975.19 Fort Bend 19.84 5,583.10 1.60 508.70 Galveston 13.17 3,595.94 15.43 3,625.09

Harris 47.33 16,062.18 56.77 19,017.06 Liberty 0.29 108.28 3.10 893.98 Montgomery 1.21 361.75 1.49 513.35 Waller 0.21 77.06 0.16 53.13 Total 108.18 34,941.94 95.53 30,411.53

2.2.3 DFW Point Source EI Table 2-2: DFW 2011 NOx andVOC Emissions for Point Sources (tons per day and tons peryear) 

## ·9i91le Season Annual NOx Ozone Season AnnuaJ VOC Cpt,ipty**W~ekdayNOx** (tpy) WeekdayVOC (tpy) (tpd) {tpd) Collin 0.66 173.98 0.80 234.73 Dallas 2.97 811.83 4.92 1,586.86 Denton 1.31 479.95 2.92 812.87

Ellis 12.15 4,122.43 5.12 1,681.72 Johnson 6.12 2,093.01 3.48 1,120.60 Kaufman 3.51 1,058.26 0.61 168.27

Parker 1.17 409.56 2.23 638.63 Rockwall 0.01 3.30 0.07 16.88 Tarrant 3.44 1,145.01 7.47 2,266.33

Wise 8.61 2,581.53 2.14 644.99 Total 39.95 12,878.86 29.76 9,171.88

2.3 AREA SOURCES Stationary source emissions data from sites andprocesses that do not meet the reporting requirements for point sources are classified as area sources. Area sources are small-scale industrial, commercial, and residential sources that generate emissions. Emissions are

2-2calculated and recorded onthe county-level. Area sources are divided according to emissions mechanism: hydrocarbon evaporative emissions or fuel combustion emissions. Examples of evaporative emissions sources include: printing operations, industrial coatings, degreasing solvents, house paints, gasoline service station undergroundtankfilling, andvehicle refueling operations. Examples offuel combustion emissions sources include: stationary source fossil fuel combustion, outdoor refuse burning, and structural fires. With some exceptions, area source emissions are calculatedbymultiplying an established emissions factor (emissions perunit of activity) bythe appropriate activity or activity surrogate responsible for generating emissions. Population is one ofthe more commonlyused activity surrogates for area sources. Other activity data include the amount ofgasoline sold in an area, employmentbyindustrytype, and crude oil and natural gas production. 2.3.1 Area Source EI Development The 2011 area source EI was developed per theAERR reporting requirements. The 2011 EI was developed using a combination ofmethodologies and data: EPA-generated Els, TCEQcontractedprojects, TCEQ staffprojects, and categories grown from the 2008 EI using factors derived from study data compiled by Eastern Research Group's (ERG) Economy and Consumer CreditAnalytics website (http://www.economy.comjdefault.asp) andAnnual Energy Outlook (AEO). The EPA developed Els for states to use for many source categories as part ofthe NEI. The states access these individual inventories through the EPA's NEI website (ftp://ftp.epa.gov /Emislnventory / 2011nei/doc/). These source categories includebut are not limitedto industrial coatings; degreasing; residential, commercial/institutional, andindustrial fuel use; commercial cooking; aviation fuel use; and consumer products. For some source categories, theTCEQ developed state-specific emissions estimatesby acquiring current state specific activity data and applying appropriate emissions factors. These source categories includebut are not limitedto: storage tanks, structural fires, dry cleaners, automobile fires, and oil and gas. In particular, significant resources were expended to improve the oil and gas area source inventoryproduction categories for the 2011 inventory. The improvements included the development andrefinement ofa state-specific oil and gas area source emissions calculator. This oil and gas area source emissions calculator uses county-level production and local equipment activity data with local emissions requirements to estimate emissions from individual production categories including compressors engines, condensate and oil storage tanks, loading operations, heaters, and dehydrators. The documentation for the development ofthe oil and gas emissions calculator canbefound inAppendixA: 

### Characterization of Oil and Gas Production Equipment andDevelop a Methodology to Estimate Statewide Emissions. A significant improvement made to the oil and gas calculator for the 2011 inventory was the development of refined emission factors for VOC emissions from condensate storage tanks. The documentation for the refined emission factors can also be found inAppendix B: 

### Condensate Tank Oil and Gas Activities. 2.3.2 HGB Area Source EI County-level totals from the 2011 area source EI for the HGB area are presented in Table 2-3: 

### HGB 2011 

### NOx and VOCEmissions forArea Sources (tonsper day and tonsperyear).

2-3Table 2-3: HGB 2011 NOx andVOC Emissions forArea Sources (tons per day and tons peryear)**Ozone~asog** Annual NOx Ozone Season AnmtaiVOC County**WeekdC:~y** NOx (tpy) WeekdayVOC (tpy) (tpd) (tpd) Brazoria 1.65 656.00 32.41 11,413.00 Chambers 0.30 111.23 7.98 2,852.06 Fort Bend 1.51 706.02 25.16 8,396.40 Galveston 0.79 372.09 16.94 5,655.31

Harris 13.90 5,520.95 181.38 61,051.67 Liberty 0.78 302.91 24.32 8,728.19 Montgomery 1.98 826.20 22.96 7,795.19 Waller 0.34 121.91 4.08 1,413.66 Total 21.25 8,617.31 315.23 107,305.48

2.3.3 DFWArea Source EI County-level totals from the 2011 area source EI for the DFW area are presentedin Table 2-4: 

### DFW2011 

### NOx and VOCEmissionsforArea Sources (tonsper day and tonsperyear). Table 2-4: DFW 2011 NOx andVOC Emissions for Area Sources (tons per day and tons peryear) Ozone Sea$qn Annual NOx ozoneSeq$()!1 AnnuaiVOC County**WeekdayNp~** (tpy) WeekdayVoc (tpy} (tpd} (tpd} • Collin 2.41 1,039.42 24.21 7,752.33 Dallas 11.71 4,148.81 84.45 26,686.03 Denton 2.95 1,226.28 35.09 11,845.20

Ellis 0.69 243.05 7.05 2,247.32 Johnson 1.94 712.82 18.39 6,403.31 Kaufman 0.42 153.96 5.34 1,714.06

Parker 0.93 350.13 12.95 4,458.74 Rockwall 0.16 77.18 3.01 965.74 Tarrant 10.63 3,840.88 75.38 24,706.06

Wise 13.27 4,846.50 29.41 10,535.28 Total 45.10 16,639.03 295.28 97,314.07

2.4 NON-ROAD MOBILE SOURCES Non-road vehicles do not normally operate on roads or highways and are often referred to as off-road or off-highway vehicles. The non-road source category is composed ofa diverse collection ofequipment, many ofwhich are poweredby diesel engines. Non-road emissions sources include, but are not limited to: agricultural equipment, construction and mining equipment, lawn and garden equipment, aircraft and airport equipment, locomotives, drilling rigs and commercial marine vessels (CJ\!IV). For the 2011 EI, emissions inventories for non-road

2-4sources were developed as subcategories: NONROAD model categories; airports; CMVs; drilling rigs; and locomotives. The sections below describe the emissions calculation methods used for the non-road mobile source subcategories. 2.4.1 Non-road EI Development ATexas-specific version ofthe EPA's latest NONROAD 2008a model, called theTexas NONROAD (TexN) model, was used to calculate emissions from all non-road mobile source equipment and recreational vehicles, with the exception ofairports, locomotives, CMVs, and drilling rigs. The TexN model allows TCEQ staffto replace the EPA NONROAD model's default data with more specific local survey data per EPA recommendations. Several equipment survey studies havebeen conducted which focused onvarious equipment categories operating in different areas in Texas. The resulting survey data are used as inputs to theTexN model to more accurately estimate non-road emissions for the state ofTexas. The 2011 non-road category EI development usedthe same methodology found in the report

### Development of 2008

### Annualand Ozone Season Daily Emissions Inventories andActivityData forNon-roadSources within the Texas NONROAD Model (TexN). A copy ofthe ERG report and associated inputs and meteorological data are provided inAppendix C: 

### Development of 2008

### Annualand Ozone Season Daily Emissions Inventories andActivityData forNon-road Sources within the Texas NONROAD Model (TexN). The 2011 airport EI contains both annual and ozone season weekday emissions for airport sources related to aircraft operations. These emission sources include aircraft engines, auxiliary power units, and ground support equipment. The United States FederalAviation Administration's Emissions and Dispersion Modeling System (EDMS) was usedto calculate airport source emissions. To estimate the 2011 emissions from the airport sources, a survey collected updated information on aircraft activity, fleet mix, and other EDMS model input parameters. Model input data was compiled and reviewed, and any identified data gaps were filled using the most closely related data available. Documentation ofmethods and procedures used in developing HGB area 2011 airport EI canbe found inAppendix D: 

### Development of StatewideAnnualEmissions Inventory andActivityData forAirports. Documentation of methodology and procedures usedto develop the DFW airport Eis can be found in Appendix E: 

### Development of AnnualandEmissions Inventories andActivityData forAirports in the 12- 

### County Dallas-Fort WorthArea. The 2011 CMV inventory was developed based on multiple recent studies and datasets. 2011 activity data were compiled using local port data and the United States Department of Transportation MaritimeAdministration. The EPA's updated 2011 emissions factors were used to account for vessel turnover and compliance with marine vessel air quality regulations. The emissions factors were applied to the 2011 activity values to calculate 2011 emissions. The emissions were spatially allocated to Geographic Information System (GIS) shape-files. Documentation ofmethodologies andprocedures used in developing the CMV Eis can be found inAppendix F: 

### Development of 2011 

### Statewide Toxics andActualAnnualand Ozone Season Weekday Emissions Inventories for CommercialMarine Vessels. The 2011 EI for the drilling rig diesel engines were developed as part ofa statewide EI improvement study. Well activity data were obtained through the acquisition ofthe "Drilling Permit Master andTrailer" database from the Railroad Commission ofTexas (RRC) and through a survey ofoil and gas exploration andproduction companies, which was used to develop improved drilling rig emissions characterization profiles. Documentation ofmethods and procedures used in developing the drilling rig diesel engine Eis can be found inAppendix G:

2-5

### Development ofTexasStatewide Drilling RigsEmissions Inventories for the Years 1990, 1993, 1996, 

### and 1999 

### through 2040. The 2011 Texas locomotive EI includes Class I, II, and IIIlocomotive activity and emissions by rail segment for all counties within Texas. Locomotive line haul andyard activity data were compiled from companies operating inTexas to create a county-level Class I line haul inventory. Data developed by Eastern Regional Technical Advisory Committee in collaboration with the Federal RailroadAdministration, theAmerican Short Line and Regional Railroad Association (ASLRRA), and members ofthe Class II and III railroad communities used 2008 activity and emissions profiles for Class II and Class III railroads. To calculate annual gallons offuel usedby railroads, data compiledbyASLRRA from the Class II and III railroads, including total industry fuel use in 2008 for locomotives and total Class II/III route miles, were used. Based onthe United States Energy InformationAdministration's latest AEO, 2008 fuel usage values were grown to estimate 2011 emissions. Documentation ofmethods and procedures used in developing the locomotive Eis can be found inAppendix H: 2011 

### Texas Railroad Emission Inventory Report. 2.4.2 HGB Non-road Source EI County-level2011 non-road category source EI totals for the eight-county HGB 2008 eight-hour ozone nonattainment area are presented in Table 2-5: 

### HGB 2011 

### NOx and VOCEmissions for Non-road Categories (tonsper day and tonsperyear). Table 2-5: HGB 2011 NOx andVOC Emissions for Non-road Categories (tons per day and tons peryear)**~~** . Ozone Season Anl'}qi;\t NOx Ozone Season AnnuaiVOC County WeekdayNOx WeekdayVOC (tpd) 

### (tpy) (tpd) (tpy) Brazoria 9.01 3,192.74 3.37 1,308.12 Chambers 1.16 428.75 1.05 534.64 Fort Bend 6.59 2,261.29 2.53 872.09 Galveston 14.31 5,233.81 4.06 2,092.63

Harris 80.84 27,576.66 33.45 11,715.87 Liberty 3.63 1,302.90 0.71 260.25 Montgomery 4.77 1,672.49 4.31 1,876.18 Waller 0.98 351.98 0.43 162.99 Total 121.29 42,020.62 49.91 18,822.77 2.4.3 DFWNon-road Source El County-level2011 non-road category source EI totals for the ten-county DFW 2008 eight-hour ozone nonattainment area are presented in Table 2-6: 

### DFW2011 

### NOx and VOCEmissions for Non-road Categories (tonsper day and tonsperyear).

2-6Table 2-6: DFW 2011 NOx andVOC Emissions for Non-road Categories (tons per day andtons peryear)

.. Ozone Season**AnnuaiN~** '**,(>t~me** Season Annual VOC C9u.ntv WeekdayNOx**(~.!?** ) ·.**w~el<day**

## voc (tpy) (tpd) 

## .Y (tpd) : .... Collin 8.41 2,499.55 6.00 1,823.13 Dallas 30.92 9,627.17 21.73 6,569.67 Denton 10.84 3,676.79 4.83 1,531.68

Ellis 3.8 1,150.11 1.59 481.20 Johnson 7.14 2,353.82 1.12 344.63 Kaufman 3.33 959.17 1.08 315.02

Parker 3.35 1,017.00 1.17 355.84 Rockwall 0.95 284.14 1.22 416.69 Tarrant 41.02 13,951.32 14.82 4,681.54

Wise 6.13 2,020.44 1.21 395.27 Total 115.89 37,539.51 54.77 16,914.67 2.5 ON-ROADMOBILESOURCES On-road mobile emission sources consist ofautomobiles, trucks, motorcycles, and othermotor vehicles traveling on public roadways. On-road mobile source emissions are usually categorized as either combustion-related emissions or evaporative hydrocarbon emissions. Combustionrelated emissions are estimatedfor vehicle engine exhaust. Evaporative hydrocarbon emissions are estimated for the fuel tank and other evaporative leak sources onthe vehicle. To calculate emissions, both the rate ofemissions per unit ofactivity (emissions factors) and the number of units ofactivity must be determined. The emissions factors for on-road mobile sources are determined using models developed and approved bythe EPA. The models allow for input of local conditions andvehicle characteristics. The activity information corresponding to the emissions factors is obtained using local travel demand models, the outputfrom the highway performance monitoring system, and speed models. 2.5.1 On-roadMobile Source EI Development The 2011 on-road mobile source inventory was developed using the latest available data, current emissions factors and models, and the most current planning assumptions. Some changes in the inventories canbe expected when a SIP is revised ifthere have been changes in any ofthe underlying tools or data used inthe inventory development. On-road mobile source category Eis presented in this proposal used emissions factors developed from the EPA's Motor Vehicle Emissions Simulator (MOVES) model and also used methods consistent with both the EPA SIP inventory development guidance and with the requirements oftransportation conformity. In March 2010, the EPA replaced the MOBILE6.2 model with MOVES as the official emissions factor model for developing on-road mobile source category Eis. Although MOVES represents a new approach to assessing on-road emissions, the sources are the same, and the opportunityto use local inputs for meteorological conditions, control programs, and fleet characteristics remains. The primary approach to developing an on-road inventory is the same with either MOVES or MOBILE6.2. With both models, emission rates are produced for subsets ofthe onroad fleet, andthe emission rates are multipliedbythe activity level ofeach vehicle type or source use type.

2-7During the development phase ofthe 2011 AERR inventories, EPA released multiple versions of the MOVES model. EPA prefers that states use the latest version ofMOVES that is available. Per EPA guidance, ifstates have completed significant work on an inventory for periodic reporting or for a SIP when a new version ofMOVES is released, such work can be completed and submittedto EPA using the previous version ofthe model. EPA released MOVES2010a in August of2010 and MOVES2010b in April 2012. EPA originally released MOVES2010b inApril 2012 to allow MOVES users tobenefit from several improvements to general model performance relative to MOVES2010a. The difference inthe models is related solely to model performance and does not affect the final emissions estimates. In October 2012 a database update to MOVES2010b was released, which corrected an errorthat affects emissions estimates for years after 2020, however this version was not used for the 2011 AERR inventories due to schedule constraints. The 2011 AERR emissions estimates for all pollutants, precursors ortaxies are not affected whether MOVES2010a or MOVES2010b (April2012) is used. The inventories for reporting under theAERR for which significant work hadbeen completedbyApril 2012 were developed using MOVES2010a. The AERR inventories developed afterApril 2012 used MOVES2010b (April2012). TheAERR inventory development schedule for HGB required the use of MOVES2010a. The AERR inventory development schedule for DFW required the use of MOVES2o10b (April2012). The MOVES model may be run using default information, orthe default information maybe modified to simulatethe driving behavior, meteorological conditions, andvehicle characteristics specific to a particular area. Because modifications to the inputs significantly influence the emissions factors calculated bythe MOVES model, input parameters reflecting local conditions were used instead ofrelying on national default values for the development ofthe 2011 on-road inventory. The localized inputs used for the DFW and HGB on-road mobile source 2011 EI development include vehicle speeds for each roadway link, temperature, humidity, vehicle age distributions for each vehicle type, percentage ofmiles traveled for each vehicle type, type of inspection and maintenance (I/M) program (excluding Wise County), fuel control programs, and gasoline vapor pressure controls. To estimate on-road mobile source emissions, emissions rates calculated bythe MOVES model mustbe multiplied bythe level ofvehicle activity. On-road mobile source emissions factors are expressed in units ofgrams per mile; therefore, the activity information that is required to complete the inventory calculation is vehicle miles traveled (VMT) in units ofmiles per day. The level ofvehicle travel activity is developed using a travel demand model (TDM) run bytheTexas Department ofTransportation orbythe local metropolitan planning organizations. The TDMs are validated against a large number ofground counts, i.e., traffic passing over counters placed invarious locations throughout a county or area. For SIP and reporting inventories, VMT estimates are calibrated against outputs from the federal highway performance monitoring system, a model built from a different set oftraffic counters. In addition to the number ofmiles traveled on each roadway link, the speed on each roadway type or segment is also needed to complete an on-roadEI. Roadway speeds, required inputs for the MOVES model, are calculatedbyusing the activityvolumes from theTDM and a postprocessor speed model. A summary ofthe annual and daily DFW and HGB 2011 on-road mobile source NOx andVOC emissions levels is presented in Sections 2.5.2: HGB On-roadMobile Source EIand 2.5.3: DFW On-roadMobile Source EI. The inventorydevelopment methods, MOVES inputs, and the results are documented in Appendix I: Development of 2011 On-roadMobile SourceActual

2-8

### AnnualandSummer Weekday Emissions Inventories forAll Texas Counties (Exceptfor 12 

### Counties in the Dallas-Fort WorthArea), and Winter Weekday Emissions Inventories for El Paso: Houston-Galveston-BrazoriaArea andAppendix J: 

### Development of 2011 

### On-road Mobile SourceActualAnnualandSummerSeason Weekday Emissions Inventories for 12 

### Counties in the Dallas-Fort Worth Metropolitan StatisticalArea-Amendment. 2.5.2 HGB On-roadMobile Source EI The 2011 HGB 2008 eight-hour ozone nonattainment area EI for on-road mobile sources was developed using emissions factors calculated using the MOVES2o10a version ofthe MOVES model. All control strategies implementedby 2011 were included in the inputto the EI development for the 2011 on-road mobile source base year EI. Those controls include the effects ofthe federal motorvehicle control program (FMVCP), reformulated gasoline (RFG), the HGB vehicle I/M program, andtheTexas Low Emission Diesel (TxLED) program. TheVMT was developed using the latest activity estimates from the HGB TDM 2011 network. The activity levels used to calculate the EI reflect the 2011 roadway network with 2011 VMT and speeds. A summary ofthe EI is presentedinTable 2-7: 

### HGB 2011 

### NOx and VOCEmissions for On-roadMobile Sources (tonsper day and tonsperyear). Complete documentation ofthe development ofthe EI and details on MOVES model inputs are provided inAppendix I. Table 2-7: HGB 2011 NOx andVOC Emissions for On-roadMobile Sources (tons per day andtons peryear)**O~one** Season Annual NOx (),tone Season Annual VOC County "Weekday NOx (tpy) WeekdayVOC (tpy) (tpd} (tpd) Brazoria 8.44 3,155.45 4.20 1A36.68 Chambers 6.84 2,501.74 1.07 357.56 Fort Bend 12.54 4,720.44 6.20 2,143.22 Galveston 7.37 2,746.59 3.86 1,319.75

Harris 137.01 50,782.06 58.18 19,955.62 Liberty 4.92 1,772.54 1.66 547.55 Montgomery 15.22 5,727.18 6.30 2,161.07 Waller 3.87 1A70.91 1.15 391.48 Total 196.21 72,876.91 82.62 28,312.93 2.5.3 DFW On-roadMobile Source EI The 2011 DFW 2008 eight-hour ozone nonattainment area EI for on-road mobile sources was developed using emissions factors calculated using the MOVES2010b version ofthe MOVES model. All control strategies implementedby 2011 were included in the input to the EI development for the 2011 on-road mobile source baseyear EI. Those controls include the effects ofthe FMVCP; RFG, the DFW vehicle I/M program (excludingWise County), andtheTxLED program. TheVMT was developed using the latest activity estimates from the DFW TDM 2011 network. The activity levels usedto calculate the EI reflect the 2011 roadway network with 2011 VMT and speeds. A summary ofthe EI is presentedin Table 2-8: 

### DFW2011 

### NOx and VOCEmissions for On-roadMobile Sources (tonsper day and tonsperyear). Complete documentation ofthe development ofthe EI and details on MOVES model inputs are provided inAppendix J.

2-9Table 2-8: DFW 2011 NOx andVOC Emissions for On-roadMobile Sources (tons per day and tons peryear)

-**-O~one** Season Annual NOx Ozone Season AnnuaiV()C County**W~kdayNOx** WeekdayVOQ

. (tpd} (tpy) (tpd) (tpy) Collin 22.76 7,827.63 10.28 3,050.34 Dallas 89.86 31,244.48 37.98 11,301.26 Denton 20.99 7,349.39 8.68 2,582.00

Ellis 11.39 4,195.26 3.31 1,003.77 Johnson 8.81 3,197.03 3.21 972.89 Kaufman 9.40 3,323.77 2.33 799.21

Parker 8.68 3,238.67 2.43 738.60 Rockwall 3.29 1,181.82 1.22 360.17 Tarrant 57.48 20,088.88 27.12 8,039.88

Wise 6.21 2,270.95 1.80 556.29 Total 238.87 83,917.88 98.36 29,404.41 2.6 BIOGENIC SOURCES Biogenic sources includeVOC emissions from crops, lawn grass, and trees as well as a small amount ofNOx emissions from soils. Plants are sources ofVOC such as isoprene, monoterpene, and alpha-pinene. Biogenic emissions are estimatedbythe EPA using the EPA's Biogenic Emissions Inventory tool. 2.7 EMISSIONS SUMMARY The 2011 NOx andVOC emissions in the HGB and DFW 2008 eight-hour ozone nonattainment areas for each source category are summarized in Table 2-9: 

### Summary of HGB 2011 

### NOx and VOCEmissions (tonsper day and tonsperyear) andTable 2-10: 

### Summary of DFW2011 

### NOx and VOCEmissions (tonsper day and tonsperyear). Table 2-9: SummaryofHGB 2011 NOxandVOC Emissions (tons per day andtons peryear)

···-····· . -**~ -~.-**  .. Qzqne Season Annual NOx**O~one** Season AnnuaiVOC**(at~gary** WeekdayNOx WeekdayVOC (!pd) (tpy) (tpd) (tpy) Point 108.18 34,941.94 95.53 30,411.53 Area 21.26 8,617.31 315.24 107,305.47 Non-road Mobile 121.29 42,020.62 49.91 18,822.77 On-road Mobile 196.21 72,876.91 82.63 28,312.93 Total 446.94 158,456.78 543.31 184,852.70

2-10Table 2-10: Summary ofDFW 2011 NOxandVOC Emissions (tons per day andtons peryear) Ozone Season**AnnuaiN~** Ozone Season AnnualVOC Category Weekdi\y l\IOx WeekdayVOC (tpd} (tpy) (tpd) (tpy) Point 39.95 12,878.86 29.76 9,171.88 Area 45.10 16,637.69 295.27 97,303.79 Non-road Mobile 115.88 37,539.49 54.77 16,914.68 On-road Mobile 238.88 83,917.88 98.36 29,404.41 Total 439.81 150,973.92 478.16 152,794.76

2-11

### AppendicesAvailable Upon Request Nina Castillo SIP Project Manager nina.castillo@tceq.texas.gov 512.239-4415

# TESTIMONYReference Number W-1

W-2 W-3

W-4 INDEX OF WRITTEN TESTIMONY

Submitted by Cyrus Reed and Neil Carman, Lone Star Chapter ofthe Sierra Club; Brandt Mannchen, Houston Regional Group of the Sierra Club (similar to 0-1); Molly Rooke, Dallas Group ofthe Sierra Club (similar to 0-10) David E. Cozad (similar to 0-3) Faith Chatham, DFW Regional Concerned Citizens (similar to 0-2) Harriet Irby (similar to 0-4)

### January24, 2014 

### Ms. Nina Castillo MC206 State Implementation Plan Team Office of

### Air Texas Commission on Environmental Quality P.O. Box 13087 Austin, Texas 78711-3087 Dear

### Ms. Castillo, 

# W-1

Enclosed are the joint comments of the Houston Regional Group of the Sierra dub (Sierra Club), the Dallas Group and the Lone Star Chapter of the Sierra dub regarding the Texas Commission on Environmental Quality's (TCEQ) proposal to revise the Emissions Inventory (EI) for the Houston-Galveston-Brazoria Nonattainment area and the Dallas-Fort Worth Nonattainment areas for the State Implementation Plan (SIP) under the 2008 8-Hour Ozone National Ambient 

### Air Quality Standard as required by the Federal dean 

### Air Act Amendments (FCAAA). The Lone Star Chapter has some 20,000 members throughout Texas concerned with air quality among other issues. The majority of our members reside in non-attainment areas 

### like Houston and Dallas, as well as areas considered near nonattainment such as Austin and San Antonio. We would first note that while we recognize that TCEQ should and must update their Emissions Inventory by mid-2014, to meet the regulatory requirements under the 2008 standards and it is reasonable to base the EI on 2011, anticipated changes at the EPA may lead to a new ozone standard this year, which could significantly expand the required EI reporting, monitoring, planning and implementation of SIP controls. We would note that we also believe the classifications for Dallas-Fort Worth and Houston-Galveston-Brazoria are not correct -moderate and marginal respectively-- and these non-attainment areas should have been classified differently. Furthermore, we would note that the Beaumont-Port Arthur, Tyler-Longview and San Antonio metropolitan areas have all violated the existing 75 PPB standard and should also be candidates for non-attainment under the existing standard. We would also point out that the decision to only expand the Dallas-Fort Worth NonAttainment Area from nine counties to ten (with the addition ofWise Countf? was one with which Sierra dub disagreed, as we believed there were at least three other counties which could have and should have been added to the non-attainment area. Thus, we believe TCEQ should consider a 13 or 14-countynonattainment area.

1

### Finally, we would continue to note that while the Emissions Inventory being discussed is limited to listing the emissions from point, area, non-mobile and mobile sources within the two designated non-attainment areas, there is irrefutable evidence that emissions from large power plants, refineries, and other major dean 

### Air Act point sources outside of the nonattainment areas influence emissions in these two areas. Thus, we would support the development of a SIP for all of East Texas that would address NOx and VOC emissions from major point sources such as power plants, including the development of an emissions inventory. This has been done in the past in Texas some 10 years ago to help lower emissions from certain facilities. In particular, Dallas Fort-Worth is impacted by the emissions from several large coal-burning power plants to the east and southeast and these emissions should be inventoried, and appropriate controls should be developed as part of the SIP. \X!hile we recognize that these issues

- which counties should be considered part of the nonattainment areas, the classification of their ozone "problem", whether additional airsheds should have been classified as non-attainment, and the need for a SIP to cover those point sources contributing to the ozone problem in Dallas-Fort Worth- are generally outside the bounds ofthis proposed change to the SIP, we wanted to state them up front. In terms of the proposed revisions, the major concern that the Sierra dub has about this proposed change to the EI is that what is proposed is not accurate enough. The SIP control strategies that 

### will follow are based and entirelydependent upon an accurate EI. In ourview the EI does not provide a basis that can provide the assurance that when control strategies are implemented based upon the EI that attainment of the eight-hour ozone NAAQS 

### will be achieved. This is of particular concern with the EI related to area sources. \X!hile point sources required to report annually to TCEQ are relatively straight-forward, area sources -including those sources related to oil and gas facilities which do not meet the criteria for reporting to the PDS

- are much more difficult to quantify. \X!hile we recognize the significant work done in recent years byTCEQ and bycontractors hired byTCEQ to better assess emissions from these sources, we are concerned that the 2011 base year is inaccurate, particularlygiven the widespread development of natural gas and oil (and associated truck traffic) which occurred as a result of hydraulic fracturing development throughout Texas. Our concern is not onlythat emissions from these area sources are being undervalued in the present EI, but that because they are undervalued, the real emissions reductions occurring and likely to occur as a result of new regulations like the EPA's NSPS for newer storage tanks 

### will not be appropriatelyrecognized as a valid control strategy. Our concern about the failure of this EI and ultimatelythe SIP to achieve ozone attainment is based upon the history of TCEQ and its predecessors to create an EI that reflects ozone precursor air emission reality. From the early 1970s until today, an over 40 year span of time, the TCEQ has inaccurately calculated the EI, implemented inadequate control strategies, and proclaimed that the SIP would attain the ozone standard. Unfortunately, while significant improvements have occurred and air quality has improved generally, Texas has not achieved ozone attainment and the EI has continuouslybeen shown to be inaccurate.

2

### TCEQ on a number of occasions has stated that it is concerned about "over-controlling emissions" and therefore requiring air pollution control that is not needed and is a waste of money. Forthe record, the Sierra Club states the fact that TCEQ has never over-controlled because the ozone standard has never been attained. Even recently this same trend has remained. For instance, in the Federal Register, Volume 78, No. 174, page 55039, EPAApproval and Promulgation of Implementation Plans; Texas; Attainment Demonstration for the Houston-Galveston-Brazoria 1997 8-Hour Ozone Nonattainment Area, the U.S. Environmental Protection Agency (EPA) stated: "As 

### a result, TCEQ created an 'imputed' inventory (approximately 5.8 times the reported levels for these HRVOC species) in its 1-hour ozone attainment SIP. TCEQ also instituted rules to better regulate the industrial point sources that emit these compounds with "HRVOC rules" in a 2004 SIP modification approved byEPA 

### (71 FR 52656, September 6, 2006). The more recent 2005/6 field study confirmed that these measures resulted in lower levels of these pollutants (approximately 42% lower on average than 2000 levels) but the HRVOC levels were still under reported with ambient measurements indicating that actual emissions were an average of 2-3 times reported levels." Again, as we begin this latest SIP process to meet the 2008 8-hour ozone standard

- which again we believe 

### will be lowered this year - getting the EI as accurate as possible is paramount. What follows are specific comments on Chapter 2 of the SIP and several of the related appendices. Chapter 2: Emissions Inventory 

### Point Sources Sierra Club supports the use of the STARS database for point sources within the nonattainment areas, and looks forward to the refining of the numbers once more accurate data is available at the end of the first quarter of 2014. An 

### initial look confirms that the numbers in Table 2-1 and Table 2-2 appear to be accurate. We would note that one potentially difficult issue are the oil and gas processing facilities which can meet reporting requirements one year, and perhaps not in another year. TCEQ 

### will need to keep tabs on individual sources as it projects emissions in future years. We would again note that major point sources outside of the non-attainment areas impact ozone levels within both the DFW and HGB non-attainment areas and we reiterate our support for a separate SIP to reduce emissions from these sources. One additional issue we wanted to raise in these and other tables within Chapter 2 is the failure to clarify the definition of Ozone Season. Thus, the TCEQ fails to state what the ozone season is for the Houston-Galveston-Brazoria and DFW Ozone Non-attainment Area. TCEQ fails to state howthe NOx and VOC emissions were calculated for Tables 2-1 through Tables 2-10. The Sierra Club is thus unable to duplicate the values calculated by TCEQ for NOX and VOC emissions for weekday totals. The public must have this information so that it can review, comment on, and understand all the potential impacts of the proposal.

3

### If the Sierra dub assumes that the ozone season for the Houston-Galveston-Brazoria Ozone Non-attainment Area is from April 1 

### through November 30 

### of each year, eight months, then the total number of days during the ozone season is 244. 

### If you multiple the tons per dayweekdayNOx during ozone season of 108.18 

### times 244 

### days you get 26,395.92 

### tons peryear and not the 39,941.94 

### tons peryear that is found in Table 2-1.



### Area Sources We are most concerned about the potential accuracy of the numbers in the area sources. \Xlhile point sources have an existing database that is checked and refined for accuracy, and the mobile source and non-mobile source database have at least developed through the years more accurate numbers with significant EPA guidance, area sources are by their nature subject to change, economics and source categories. We recognize is it a difficult issue, but also believe that a significant amount of NOx but particularly VOC emissions

- roughly two-thirds in both DFW and HGB according to Table 2-9 

### and Table 2-10- 

### are caused by area sources. Therefore, obtaining an accurate count of 2011 

### emissions from these sources, and then requiring appropriate controls to assure lower emissions in the future is paramount. \Xlhile we have some specific comments on some of the appendices that explains the methodology for estimating some of the emissions from area sources, our overall concern is that it is impossible from the information to determine exactly how the total area sources were derived. Thus, on page 2-3, 

### TCEQ states that it obtained data from the EPA NEI inventories for a number of category sources, but then obtained its own data related to storage tanks, structural fires, drycleaners, automobiles fires and oil and gas. We are supportive of TCEQ's attempt to develop specific numbers and methodologies for oil and gas area sources, and of the refining and development of specific numbers for VOC emissions from condensate storage tanks. That being said, as our comments 

### will show, we think it is very difficult for the public to determine howthe numbers in Table 2-3 

### and Table 2-4 

### are derived. In essence, the public is being asked to accept that methodologies discussed in Appendix 

### A, B and G among others for oil and gas facilities 

### will result in the numbers in those tables, combined with numbers from an EPA-run database. Instead, we would suggest a more refined table that breaks out emissions bycategorywith a note on how those numbers were derived. Thus, condensate tanks might refer to Appendix B, while other oil and gas numbers might refer to the Barnet Shale Special Inventory. Without this kind of detailed break-out, it is impossible to understand for example, whether the 24,706 

### tons of annual VOC attributed to Tarrant Countyare reflective of the total? VOC emissions in 2011 

### ornot. Part of our confusion actually results from the appendices. Thus, Appendix A Characterization of Oil and Gas Production Equipment- has a date of December 11, 2013, 

### but is actually composed of a work order completed on November 24, 2010, 

### which by 

### its nature could not include emissions from 2011. 

### In addition, separate appendices on Condensate Tanks (Appendix B) and drilling rigs (Appendix G) would appear to supersede some ofthis information, but it is not clearlystated.

4

### Thus, as an example, during the Barnett Shale Special Inventory conducted by TCEQ, TCEQ was able to derive county-level emission numbers from the facilities which responded to the survey. Thus, as an example, according to the Barnett Shale Survey, in Wise County, sources emitted some 5,601 tons of VOCs in 2009, of which 4,296 came from Condensate Tanks. However, this is data from 2009 based upon a survey, and the TCEQ has done significant work since then on emissions from condensate tanks (Appendix B). Appendix B thnen includes some information on county-level production weighted emission factors for each county in Texas from Condensate Tanks. But there is no way to know how much of the 10,535 tons of VOC listed in Table 2-4 for Wise County is from condensate tanks. A true Emissions Inventory should be easyto determine both the amount and source of anyemissions, and howthat numberwas derived. This is particularly true of both condensate tanks

- which because of new EPA NSPS regulations

- 

### will be better controlled in the future, and compressor engines, which are also being better controlled due to new engine standards. Getting the base of 2011 correct, before new regulations should lower emissions from both existing and new engines and tanks, is important to assure TCEQ sets appropriate regulations to control emissions in nonattainment areas. In particular it is unclear whether emissions from compressor engines are being based on stack testing at maximum operating rate or stack CEMS of NOx, or are based on an average emission rate pertype of compressor engines, as discussed in Appendix 

### A Moreover, it is unclear how TCEQ

### will update some of these numbers going forward. 

### As an example, one of our specific comments is we believe that emissions from pneumatic devices our undercounted, based on recent studies nationwide showing significant emissions from pneumatic devices. However, we are aware that TCEQ is currently conducting a statewide pneumatic device survey, which could lead to changes in emissions from these devices.

2) Page 2-8, 2.5.1 On-road Mobile Source EI Development, TCEQ states "In October 2012 a database update to MOVES2010b was released, which corrected an error that affects emissions estimates for years after 2020, however this version was not used for the 2011 AERR inventories due to schedule constraints." The Sierra Club does not approve of this choice by TCEQ. Over a year ago TCEQ got an improved model for mobile sources that would correct "emissions estimates for years after 2020" and chose not to use the newest model. This means that mobile source EI 

### will be less accurate for future years. The Sierra Club would like more information about why TCEQ is choosing not to use this more accurate database and would express its initial opposition. Appendix A, Characterization of Oil and Gas Production Equipment and Develop a Methodology to Estimate Statewide Emissions Appendix A provides important information on the methodology for arriving at emissions for the oil and gas sector that is not large enough to report directlyto STARS. However, we would note that this appendix is actually a series of studies which culminated in 2010, and are based principally on emissions in 2008 and 2009. Therefore we are concerned and confused as to whether this methodologyis fully relevant for a 2011 EI.

5

### 1) Page iv, Executive Summary, development of a 2008 base year EI is inadequate as a basis for a 2011 EI. This means that instead of having actual air quality data that is 3 years old we have air quality data that is 6 years old and probably even older than that since much of the estimates in the EI come from studies that were conducted in 2007-2009 and which data in those studies that were earlier than those dates. The 2008 EI is obsolete and does not reflect the magnitude of air pollution sources and activities that occurtoday. Thus, on page iv, the Executive Summary states "with over 90,000 gas wells and 150,000 oil wells in Texas, the cumulative magnitude of these emissions may be significant." According to recent data from the RRC, however, there were over 22,480 permits for oil and gas wells issued in 2011 and 22,479 in 2012. Thus as of November 2013, there were 304,900 active wells in Texas, as well as 108,452 inactive wells. \'Vhat is needed to ensure that the 2011 EI is accurate is emissions data from 2011 and not estimates that are based upon old calculations and analyses. We fully recognize that some data has been updated through separate analysis, such as that related to Condensate Tanks in Appendix B. But it is very unclear how the final numbers presented in Chapter Two of the SIP have been derived. Thus, the Sierra dub assumes that emission factors presented in Appendix A are used with more recent 2011 date from the Railroad Commission of Texas and TCEQ to arrive at new 2011 numbers, but because the 2011 Oil and Gas Emissions Inventory is not available on the website underthis project it is unclear. However, it is very confusing. Thus Table E-2 presents county-level data on oil and gas emissions from 2008 that indicates some 24,000 tons per year of VOCs in Wise County is caused by oil and gas facilities, yet the Area source table of the 2011 Emissions Inventory onlylists 10,535 tons of VOC. 

### Ifthis giant reduction is related to new motor and condensate tank rules, our understanding is that these new rules would not have impacted emissions in 2011. In particular, this old data does not address the recession and its effects on the 2008 EI and the likelihood that this either produces a lower EI than what reality gives us today or a higher one based upon old models of growth in air emissions. Further, since 2008 literally 10,000s of oil/gas wells have been drilled all over Texas. Even ifthese wells were not drilled in the Houston-Galveston-Brazoria or Dallas-Fort Worth ozone non-attainment area they create an increased background of NOx and VOC emissions that are transported across Texas, ournon-attainment areas, and into other states and then circulate back into Texas and ournonattainment areas. The same inadequate EI exists for offshore oil and gas air emissions because the studythat serves as the base line for this category of air pollution was conducted in 2010, using data earlier than 2010 and not conducted with 2011 data. 

### On page vi, TCEQ states "More accurate emissions estimates would require a comprehensive survey of upstream oil and gas site operators to obtain information such as

6county-level gas composition data, quantification of the use of control devices, updated equipment profiles (such as the number and size of heater treaters used on a typical well pad), and updated equipment characteristics and counts." Thus, the EI is lacking in what is needed to be accurate and therefore 

### will be lacking in modeling and control strategy accuracy when those tasks are accomplished. The people of Texas deserve betterbecause their lungs, livelihoods, and futures are on the line. 2) Pages 1-1 and 1-2, Table 1-1 Upstream Oil and Gas Production Source Types, TCEQ should state whether there are any flares used at well sites and if so why these emission sources are not listed. 3) Page 4-1, the proper name of the organization is Houston Advanced Research Center and not Houston Advanced Research Council. 4) Page 4-1, TCEQ is using data that is more than six years old for engine surveys for natural gas compressors and production facilities. Tens of thousands of more oiVgas wells have been drilled since that time and engines mayalso have changed during that time. 

### If TCEQ is able to take more recent data on compressor engines in these non-attainment areas, and use a formula such as that developed in 4-2, where older wells require compression, then TCEQ should make this clear. Thus, Table 4-1 should be updated to showwells completed in 2011

- the year of the supposed emissions inventory- versus those completed more than a year before. 5) Page 4-2, all the shale zones which are subject to highly intensive hydraulic fracturing oiVgas drilling and production should be listed and their air emissions estimated in this EI including Barnett Shale, Barnett-Woodford Shale, Permian Basin Shale, Eagle Ford Shale, Pearsall Shale, Palo Duro Shale, Haynesville-Bossier Shale, and any other similar highly intensive drilled and produced areas. This is important for NOx and VOC background levels and transport in and out of ozone non-attainment areas. 6) Page 4-3, TCEQ reports that 20% of the engine population is not known with regard to specifics about the type of engine used. TCEQ must not assume from two different studies what this 20% of the engine population is. This is a large percent of the engine population and TCEQ must find out the specifics about it so that a more accurate EI can be done. 

### 7) Page 4-4. We would note that TCEQ removed 61engines from the population and does not use them for air emission estimation purposes. "While removing some of these- such as those no longer operational or relying on electricityfor power-- is legitimate, TCEQ should make more of an effort to find out the specific characeristics about those engines for which it lacked adequate data to see if they still exist, if they are not electric and are at oiVgas wells and should estimate air emissions from real data instead of ignoring these engines. In addition, TCEQ should define what "minor gap-filling" is and state clearly how this alters estimates for air emissions. In addition, since these two studies have been conducted, some 15,000 to 20,000 oil and gas wells per year have been drilled, most of which are producing, and manypipelines have either been constructed or are under construction like the Keystone XL pipeline through Texas and the Enterprise pipeline that ends in Brazoria County. Again,

7

### it Is unclear to us how these additional engines have been taken into account in the 2011 Emissions Inventory. 8) Page 

### 4-5, TCEQ never states how much manufacturer's air emissions data vary and therefore how much it alters that data byaveraging across all performance data for a specific engine. This exclusion must be clearly stated for the public. 9) Pages 

### 4-7 and 

### 4-10 and Table 

### 4-3, TCEQ states that it applies a "90% reduction to the emission factors for CO and VOC for certain engineers using non-selective catalytic reduction." TCEQ should not assume such a high control efficiency especially since use over time and whether maintenance of adequately applied can result in reduced efficiencies. 

### Itwould be more conservative and better for the EI to assume an 85% control efficiencyto take these factors into account. 10) Page 

### 4-10, TCEQ states that a 100 Hp engine would burn an equal amount of fuel as two 50 Hp engines. Is this the case or an assumption? TCEQ should verifywhat is said and



### . . notJUSt accept assumptions. 11) Page 

### 4-16, TCEQ states that year old oil wells need an artificial lift engine. Since 2008 10,000s of oil!gas wells have been drilled. So there should be 1,000s of additional lift engines in operation now. Does the 2011 EI reflect these additional emissions from additional lift engines? 12) Page 

### 4-17, TCEQ states that a conservative estimate of the number of electrically operated artificial lift engines is 70%. This is not a conservative estimate. A conservative estimate would be 50%. Seventypercent is the median estimate and is not conservative. 13) Page 

### 4-18, TCEQ assumes there are no pump-jack engines that were manufactured after July 1, 2008. The EI is for three years after this date and the current date is 5 years after this date. This assumption is not valid and must be changed. 14) Page 

### 4-19, TCEQ must survey operators to verify that pump-jacks in Texas are only operating roughly half the year. 

### It is not appropriate to make assumptions when TCEQ can determine without great effort whether the assumption is correct or not. Thus, we would be supportive of conducting an actual surveyof pumpjacks as suggested byERG. 15) Page 

### 4-22, TCEQ admits that emission estimate may be lower than actual emissions at area-source dehydrators. 

### Ifthis is so then TCEQ should investigate this and correct it iftrue for the EI now. Page 4-27. We assume the information for the Oll and Condensate Storage Tanks have been superseded by new Appendix B but if the estimates and numbers generated in this section no longer are being used, than it should be clearlystated. 16) Page 

### 4-31, TCEQ states that splash loading may occur for loading and unloading operations. The Sierra Club was under the impression that no one uses splash loading anymore. 

### If splash loading is used, an outdated operational technique that can easier be corrected, then TCEQ should outlaw its use.

8

### 17) Page 

### 4-36, TCEQ refers to "green completion or add-on control technologies" but never defines what this term means and what technologies specifically are considered green. This must be done. This is important because the new EPA NSPS is requiring green completions for new gas wells beginning this year, and should be listed as a control device for the SIP. In terms of the amount of gas vented during completion, we believe that more recent data available from the RRC would indicate an increase

- particularly in South Texas

- in the amount of gas being vented during completion. Interestingly, the Eagle Ford is not even listed on 4-36 again indicating the 2008 EI is no longer appropriate for use on oil and gas sources. Page 4-37). We would note that RRC does have information about the amount of vented gas during well completions as theyrequire permits to flare orvent gas. We would also note that making assumptions about how many completed wells in a year are oil versus gas is not necessary because TCEQ can look at the information for completed wells during 2011 without having to "guess" what percentage are oil versus gas wells. Page 4-41

- Well Blowdowns. To their credit, TRRC does keep records of any reported blowdowns. TCEQ should use actual data of blowdowns in 2011 and include them to the extent theywere within non-attainment areas and then use the formulas to arrive at countylevel numbers. Page 4-43. Pneumatic Devices. "While we do not doubt the use of an emission estimation approach, we would note that several recent studies have indicated that emissions from pneumatic devices are higher than previously estimated. In addition, our understanding is that TCEQ is engaged in a pneumatic device survey. Information from new studies and the surveys should be incorporated into the 2011 EI. Page 4-49. Fugitives at Gas Wells. We would note that Eagle Ford has not been included in the CENRAP studies on which fugitives are based. "While this does not impact the DFWor HGB NAAs, it is of concern for total emissions reported in state databases.

18) Page 

### 4-53, it is vety troubling that TCEQ states "Total active wells by county for the full2008 year are not readily available from the TRCwebsite." 

### Ifthis is so then TCEQ must contact the Railroad Commission and request the data that is not on the website. This indicates that even the 2008 EI, much less the 2011 EI, is inaccurate with regard to air emissions. 

### Ifthe TCEQ does not have a Memorandum of Understanding (MOU) with the TRC in order to help the TCEQ obtain more accurate total active well data by county and other TRC data that the TCEQ depends on, the TCEQ should work with the TRC to develop such an MOUorbe sure than an existing MOUis updated for the TCEQ and TRC to 

### efficientlycooperate on making the TRC data available to TCEQ.

5-1. Results. We would note that according to the detailed tables and analysis, compressor engines account for some 70% of NOx from oil and gas sources, while storage tanks

9

### account for over 70 percent of VOC emissions. This again points out the importance of getting emissions from these two particular sources. While Appendix B indicates a more recent look at emissions from condensate tanks, we continue to be concerned by the outdated numbers for compressor engines, and again, suggest that a fresh look is needed to look at pneumatic devices. In any case, we would note that the numbers for VOCs and NOX for counties in the DFWareas are higher in Table 

### 5-2 than those reported in Chapter 2 of the EI. We are unclear whether this indicates that part of these totals were actually reported bypoint sources (larger processing units) or whether TCEQ actuallyprojected that oil and gas emissions DECREASED between 2008 

### and 2014. 

### Page 7-1. 

### The ERG report makes four recommendation on how to improve their report by obtaining more information on: Well completions and well blowdowns; Pneumatic Devices; Fugitive Emissions; and Heaters and boilers. We agree and would note that a report which admits theylack sufficient information in these categories to arrive at accurate emissions totals for area sources indicates the 2011 

### EI is not as accurate as it should be. We suggest incorporating further efforts to better assess these erruss1ons sources. 19) Page A-3, Appendix A- Task 2 Memorandum, April26, 2010, the TCEQ fails to list flares. Flares may be used at oil/gas well production sites and should be investigated. Several oil/gas production sites have been observed with one or more flares operating continuously. 20) 

### Page A-10, TCEQ states that "flaring or other "green completion methods". Flaring is not a green completion method because it generates additional VOC and other air pollutants due to low burning efficiencies that TCEQ is well aware of. There is no indication in this paragraph that TCEQ requires any comparison with stack tests to determine if destruction efficiency is what it is purported to be. Any emission factors that are used based upon high destruction efficiency of flares are incorrect and should not be used. Indeed several significantly smoking flares have been observed at oil and gas production sites. 21) 

### Page A-11, and repeated manytimes throughout this memo the phrase "The CENRAP data can also be used as a QA checkto ensure that results from the survey area reasonable." TCEQ never states why the CENRAP data is so good that it 

### will be used as a QA check The public must have this information so that it can review, comment on, and understand all the potential air emissions in the EI. 

### 22) Page A-11, and repeated many times throughout this memo the phrase "ERG 

### will attempt to collect all other data items by conducting a survey of oil and gas producers" or "attempt to obtain estimates", etc. An "attempt" is not good enough. 

### If TCEQ hires ERG then the contractor must agree to do more than "attempt". Otherwise public money is wasted. 

### If the data cannot be collected then the public must know why this data was not collected and howit can be collected and then the data must be collected.

10

### 23) Page A-12, TCEQ states "Because gas is directly vented from the blowdown event, blowdowns can be a source of VOC emissions." This is true but carbon dioxide and methane may also be air pollutants emitted. TCEQ should report these greenhouse gas air pollutants as part ofthis study. 25) Page A-33, TCEQ states that "control of waste VOCvia flaring would control VOCby a minimum of 98%." TCEQ and EPA have both conducted recent studies that document flares often operate at much lower destruction efficiencies. TCEQ should not allow a 98% destruction efficiencyto be used. A lot more unburned VOC is emitted from flares than has been recognized in the past. We know better now and should use that knowledge for this 

### EI. Appendix B. 

### Condensate Tank and Oil 

### Gas Activities We applaud TCEQ for including this separate study on emissions. 

### As stated in Appendix 

### A, TCEQ and its contractors believe that tanks represent 70% of VOC emissions from oil and gas activities throughout Texas. While new regulations being implemented should significantly lower emissions on tanks built after 2011, many of the tanks implemented before and still operating have significant emissions and should be reflected in the 2011 EI, particularlyin the Dallas-Fort Worth NAAcounties like Wise, Parker and Tarrant. Page 2-2. We agree that it is important to distinguish between oil and condensate tanks since oil tanks have relatively low emissions and are less volatile. That being said, Appendix B appears to onlymeasure emissions from condensate tanks and we are unclear as to whether information from oil tanks from this study is included in the emission factors developed for each county. Thus, the studybasically removed anydata for sites that has an API gravity less than 40. While this may be a good cut-off to separate true condensate tanks from those that are not, this does not mean those less dense liquids do not have emissions that should be considered. The Appendix should clarifyhowthese emissions were determined. Page 2-4. Appendix B points out how many factors

- API gravity, separator pressure, controls

- determine emissions and makes the case that individual emissions for each sources Is impractical and that a regional emissions approach is the preferred methodology. While we are not necessarily opposed to such an approach, TCEQ maywant to consider use of individual source data where available, and use of a regional emissions factor where it is not. Page 2-5- 2-12. It is instructive howwidelyvaried emission factors are derived from different measurement techniques and methodologies. Thus, as Table 205 indicates, a single tanksuch as the Waggoner Crystelle- could range from 3.8lbs/bblto 31.5lbs/bbl depending on the test or measurement technique used. Interestingly, the emissions factor being used for Wise CountybyTCEQ appears to be in the mid-range. Page 2-20. Attempting to assess how many of the tanks installed in or before 2011 actually employed flares, combustors or vapor recovery units to control emissions is difficult. While the more recent survey indicate most production is being controlled, the older 2010 study

11indicated most is not. Page 2-36 through Page 2-40 shows that ERG and TCEQ are being conservative in terms of how they are taking into account these controls. We are supportive of this approach since we believe much of the controls are resulting from the new PRB and NSPS regulations, all of which went into effect after 2011. The EI should assume lower controls on storage tanks. Hopefully, more representative surveys 

### will show the amount of storage tanks that are being controlled for future Eis and hopefully it will confirm that significant control of emissions is occurring. Page 4-1. We support the ERG recommendation that future surveys on oil and gas producers be handled through mandatory requirements, and that a consistent definition of condensate based on API gravity be developed. Further, we would like emissions factors to be developed both for condensate and oil tanks separatelyand reported in the EI. Appendix F, Development of 2011 Statewide Toxics and Actual Annual and Ozone SeasonWeekday Emissions Inventories for Commercial Marine Vessels 1) Pages 1-1 and 2-1, Appendix 

### F, Development of 2011 Statewide Toxics and Actual Annual and Ozone Season Weekday Emissions Inventories for Commercial Marine Vessels, refer to EI for locomotives. But there is no information about locomotives in this appendix. 2) Page 1-2, Appendix 

### F, the TCEQ states that the Houston-Galveston, Texas Gty, and Freeport is a "Hotspot of activity''. The Sierra Club agrees and therefore this area should be a "hotspot of emission reductions" in the upcoming and future SIPs. 3) Page 2-1, Appendix 

### F, the TCEQ states that 2011 EI for commercial marine vessels (CMVs) was conducted in August 31, 2010. The EI is for 2011. TCEQ should explain how 2010 orearlier data reflect 2011 air emissions. 

### 4) Pages 2-1, 2-2, 2-4, and 2-5, Appendix 

### F, TCEQ states "it was not possible to use the raw data to accuratelyestimate operating hours and 

### links that data up to vessel characteristics needed to estimate emissions within the project schedule." This is troubling. TCEQ must have the most recent EI, 2011, as possible. Here TCEQ states that it was able to conduct such an EI for CMVs. TCEQ should state plainly how it 

### will correct this problem and update the 2011 EI. 5) Pages 2-2 and 2-3, Appendix 

### F, TCEQ states "only EPA defined SCG can be used. For marine vessels, the acceptable codes are limited to the following

. . . Note that actual operations may vary'. Does this result in any missing vessels or vessel activities? TCEQ should state how changes were made to ensure that all vessels and vessel activities were accounted for in the EI. 6) Page 2-4, Appendix F, TCEQ states that "The methodologies used to estimate emissions for this inventory project comply with the latest EPA guidance on estimating emissions from marine vessels.". TCEQ should state what are the weaknesses are of the EPA methodologies and how these weaknesses can be adjusted or fixed so that a more accurate EI is produced. TCEQ should say what it 

### will do in the future to ensure that a betterEI is produced for CMVs.

12

### 7) Page 2-5, Appendix F, 

### TCEQ states "slight differences in activityfrom month to month for 2011 

### for different vessel types, in aggregate vessels traffic was consistent throughout the year."' TCEQ should state what "slight" means and what "consistent" means with regard to these differences in activity. 8) 

### Page 3-1, Appendix F, 

### the TCEQ never states how accurate the 2007 

### Port of Houston EI is. The 2007 

### EI is the basis for the 2011 

### EI but there is no analysis about its accuracy. The Sierra Club is concerned that the 2007 

### EI may be inaccurate and thus the 2011 

### EI 

### will be inaccurate. There is no way for the public to determine this because this concern is not addressed byTCEQ with this study. 9) Pages 3-1 and 3-2, Appendix

### F, TCEQ states "Unfortunatelythe port inventories were not developed to represent activities in 2011. 

### In order for data from the 2007 

### port inventory to be used in this 2011 

### inventory, ERG obtained historical MARAD vessel call data

... ERG used the linear projection of Houston and Galveston traffic to account for the increased traffic to 20 11." 

### This method of using linear projection, where it is simply assumed that the growth occurred in a linear fashion over a period of time, is not a good assumption to make especially since the recession occurred at least from 2007 

### to 2010 

### and even today shows that growth is less in certain places than it was before 2007. 

### Tables 3-1 and 3-2 

### document that in certain ports the port calls are less in 2010 

### (not 2011 

### as is needed for a 2011 

### EI) than they were in 2007. 

### It is not clear how "2007 

### Houston port activity data were adjusted using the above data" when such a significant downturn in shipping occurred. 10) 

### Pages 3-3 and 3-6, Appendix F, 

### TCEQ states that "in the upper reaches of the ship channel loads may be as low as 6 Percent and that towboat operations may be a high as 65 percent." 

### It is not clear how an accurate estimate can be made when such large swings in load 

### (59%) occur. TCEQ should fully reveal how a reasonable load figure was calculated. 

### It is not evident how accurate TCEQs statement "Kilowatt hours were adjusted for a load factor of 80 

### percent for underwayoperations and 20 

### percent for dockside load" is. 11) 

### Page 3.7, Appendix F, 

### TCEQ states "ERG assumed that Navy vessel activities in Texas state waters were relatively small, since the last Navybase located in Texas was closed around 2006 

### and most military vessel exercises occur in Federal waters." There is no indication that this assumption was verified with the Navy. This assumption should be verified. 12) 

### Page 3-7, Appendix F, 

### TCEQ states "These boats tend to be used at coastal rescue stations, so actual hours of operations maybe relatively small and their impact on coastal air quality 

### will be limited." This assumption about Coast Guard operations must be verified. No assumptions when theycan be easilyverified. 13) Page 3-7, Appendix F, 

### the TCEQ should state where "San Padre Island" is. There is a South Padre Island but the Sierra Club is not aware of a "San Padre Island" in southern Texas.

1314) Page 3-10, Appendix F, because air pollution can travel hundreds of miles (transport) federal waters as well as state waters for Coast Guard and other ship activities should also be part ofthe EI and modeled for the SIP. 15) Page 3-16, Appendix F, TCEQ states "ERG used the dredging start and completion date to estimate the total hours of operations for the dredging equipment

. . . ERG assumed that dredging engines operate 90 percent of the time, to account for vessel positioning, minor maintenance, and refueling activities

. . . (for this project ERG used a value of 9,600 horsepower (7,161 k\XI) based on data provided by dredging services that implemented similar dredging activities)". TCEQ should require that these assumptions are verified. There is not reason not to contact dredge companies and get more accurate information ratherthan relying upon assumptions. 16) Page 3-17, Appendix 

### F, TCEQ states "arrived at site onJanuary 1, 2011 and departed on January 11, 2007". This statement does not make sense and is wrong. TCEQ must correct this statement. 17) Page 3-19, Appendix F, there is no indication that TCEQ used the age of the dredge engine to determine the air emissions of the dredge. TCEQ should use the age of the engine to determine what the engine's air emissions are. Appendix G. Development ofTexas Statewide Drilling Rig Emissions 

### It is instructive that TCEQ lacks basic information on emissions from onland drigging rigs, in part because TRRC is in charge of the drilling and well completion process and TCEQ

- other than nuisance- does not generally regulate emissions from this initial drilling process. Obtaining this data from RRC in 2009 and for the present study significantly improved estimates of emissions from these important sources. Texas todayremains the state with the most rigs. While we are generally supportive of the approach taken in this appendix, we would note the assumptions about reductions in emissions in the 2009-2010 due to new engine and fuel standards maybe overlyoptimistic. We would also note on 1-5, the report notes that "the contribution of hydraulic fracturing operations to drilling activity emissions remains unknown at this time." We have a big concern with using these drilling emission numbers if it is not taking into account fully the impacts of hydraulic fracturing. The report notes that the long depths and horizontally "may result in substantial NOx emissions due to the veryhigh horsepower requirements." Thus, the study shows that in the leading countyfor NOx emissions

- Tarrant

- the amount of NOx emissions being reduced from 3,500 NOx in 2008 to less than 1,000 Tons by2011. We are not convinced this large a reduction occurred in Tarrant and similar counties. 

### As the report makes clear, projections

- including 2011

- are based upon EIA projections which are inaccurate. Thus, as page 5-1 states "significant sources of uncertainty remains." The report makes clear that the fracturing processes occurring after the initial drilling

- including the potential for refracturing

-- merit their own study. We agree with this recommendation and therefore conclude that the emissions from drilling contained in Appendix G do not accuratelyreflect all oil and gas emissions associated with drilling.

14

### There is an assumption in the report

- see Figure 4-6

- 

### that the number of thousand of feet of drilling 

### will stay static from 2010 to 2040, 

### when the reality is that 2011 

### and 2012 

### saw increased activitydue to the expansion in the Eagle Ford and Permian Basins. The Sierra dub appreciates this opportunityto comment. Thankyou. Sincerely,

Cyrus Reed Conservation Director Lone Star Chapter, Sierra Club 1202 

### San Antonio Austin, Texas 78701 

### Cyrus.reed@sierraclub.org Neil Carman 

### Air Quality Specialist Lone Star Chapter, Sierra Club Brandt :Mannchen Chair, 

### Air QualityCommittee Houston Regional Group ofthe Sierra Club 5431 

### Carew Houston, Texas 77096 713-664-5962 

### brandtshnfbt@juno.com MollyRooke Clean 

### Air Conservation Chair Dallas Group, Sierra Club Dallas, Texas 214-369-6667



### 15

# W-2

P.O. Box 171443, Arlington, TX 76003-1443 817 909-2360 cozadforcongress@gmai!.com 

### Statement to TCEQ- Arlington Air Check Public Hearing- January 16, 2014 I am David E. Cozad. I have lived in Arlington, Texas for over 30 years. I am the Democratic candidate who will be on the ballot in November for the U.S. Congressional seat currently held by Joe Barton. I am addressing you as a private citizen, a husband, a father and as a grandfather. Creating a reliable inventory of emissions, and creating guidelines and rules which allow you to enforce the Clean Air Act, is not a simple task. Your job is not easy but it is emphatically important. Without air that is healthy to breathe, the contributions of individuals in the classroom, in the workplace, in civic, and in family life is impaired. That which is emphatically important is rarely easy. Through the division of authority and responsibility, TCEQ, with the EPA, is charged with enforcing the Clean Air Act in Texas. The DFW Region, and other areas ofthis state, have been out of attainment for a very long time. It does not take scientific instruments to know that the air quality frequently experienced by citizens in this region is not healthy. I am a pre-asthmatic, and to drive or ride in an automobile in this area for more than a very short distance, requires that I utilize an air mask. It is rather starling for people to observe me in this !I use it because it enables me to function out-of-doors. I remember when using this mask was not necessary. The air quality has changed here in Arlington. Despite closing some ofthe cement kilns and getting old automobiles off of our roadways, we are still not in attainment for the Clean Air Act. We all still have a lot of hard work to do. It is important that the inventory of emissions from natural and industrial sources in each area be accurate, kept up-to-date, and used before more permits are granted to enterprises which will contribute to poor air quality. Jobs are important. Identification and enforcement to ensure that enterprises utilize best practices is an important key to ensuring that we continue to thriveeconomically. We must be pro-active in ensuring that the air is healthy enough for people to work and study and contribute to the vitality of our communities. On the business and political side, we must partner to create clean industries, next generation enterprises which will feed our families, pay more than just a living wage, provide career paths in industries which promote clean air and water instead of impairing them. It is your job, as a partner with the Federal Environmental Protection Agency, to establish a reliable baseline for emissions-- the nitrogen oxides and volatile organic compounds which create ground-level ozone pollution

. It is your task to create a comprehensive inventory of area sources and those from outside the region and to utilize it in granting new permits. You must apply it in your plan to reduce ozone. It is yourjob to evaluate all sources of air pollution- natural and man-made, and establish scientific baselines for their cumulative impact on the people, animals, vegetation and air and water which is vital to the present and future economic and civic growth in every region in Texas. Air does not stay within boundaries. It moves outside the fence of those who profit from enterprises and impacts the health ofthose who are least able to lose time from work or school or to afford the medical care. We must work together to create new, clean industries to replace those which are detrimental to the health of the region. This will require leadership and partnering with local, regional, state and national agencies, elected officials and the business community. We must create a path to the future for this state and for every citizen in this state. To do that, it is imperative that your Agency gets this inventory right. We are depending on you to do your part to keep the people in this region able to do our part in transitioning dirtyjobs to clean next generation solutions.

# W-3

January 16, 2014 I am Faith Chatham of Arlington, TX and I am the spokesperson for DFW Regional Concerned Citizens. Thank you for hearing me. For half a decade we have been urging the Texas Commission on Environmental Quality, The U.S. Environmental Protection Agency and our NCTCOG regional planners to compile a comprehensive, accurate inventory of emissions and to apply sound science in evaluate the CUMULATIVE IMPACT of emissions per regions. It is imperative that such an inventory be accurate, regularly updated, and available to planners, local officials and citizens. It is imperative that the cumulative impact of emissions per region include emissions from outside the non-attainment area- because air pollution cannot be fenced into a pad site or a cement kiln or a power plant! It is also imperative that emissions from the non-attainment area which blow to other regions be considered. One region cannot be allowed to contribute to the demise oftheir neighbors Without an accurate inventory of area sources such as oil and gas drilling, diesel generators and engines, dry cleaners and industrial emissions such as General Motors and other important economic enterprises in the region, determining what new enterprises can safely be added in a region is precarious at best. We must have jobs and we must be healthy enough to work, study, play and serve in our communities. We know this is complex. We are not asking for a simple chart which can be compiled without research and diligence. However, our lives and the lives of our neighbors and children depend upon the TCEQ and regional partners getting it right. It is essential that it considers the area sources and the emissions that blow through the regions and that it be evaluated for different weather conditions and traffic patterns. It must accurate and it must be used in granting future permits. We have asked for an inventory of the allowable emissions part per thousand from enterprises already permitted in the region. It may be out there but I have yet to see it. We know that the permits allow more emissions than are actually healthy for the residents ofthe DFW Region. We have been out of attainment for the 8 hour ozone standard for a very long time. It does not take sophisticated equipment to show that the current level of emissions in this region has an adverse impact on the health of many of the residents. I cannot stay outside more than a few minutes most days without respiratory problems from the combination of natural and man-made emissions. I am not alone. We urge you to diligently work on this inventory and to get it right. Partner with the EPA and do not let political pressure from the Governor's office deter you from getting this right. I challenge you to earnour trust. Earn our respect by creating a comprehensive inventory, keeping it updated and available, utilize it before granting future permits. Will this be popular? Probably not with everyone. Will you be accused of overreaching your authority? Probably by those who want to profit from enterprises which contribute to non-attainment. Will you be doing yourjob? Absolutely. Will you be over reaching your authority? No. It is your job to know what is in the air in every region in Texas and to enforce the Clean Air Act. We have to work together to get this right. It is more than a pay check and it is more than who occupies the Governor's Mansion or contributes to a political campaign. Without air life ceases. Without life, there is no industry, no political appointments or advancement in a career. Thank you.INDEX OF ORAL TESTIMONY



### January 14, 2014, 2:00p.m. 

### -Houston-GalvestonArea Council

Reference Number 0-1



### Reference Number 

### 0-2

0-3 0-4 

# o-s 0-6 0-7 0-8 0-9

0-10



### 0-11 Submittedby Brandt Mannchen, Houston Sierra Club (similar to W-1)



### January 16, 2014, 2:00p.m. -Arlington CityHall



### Submittedby 

### Faith Chatham, DFW regional concerned citizens (similar to W-3) David E. 

### Cozad (similar to W-2) 

### Harriet Irby (similar to W-4) Julia Burgen Jim Schermbeck, Downwinders at Risk Gregory Perry Kim Feil Rita Beving Molly Rooke, Houston regional group, Lone Star Chapter andthe Dallas Group ofthe Sierra Club (similar to W-1) 

### Lorraine Levine1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 TEXAS COMMISSION ON ENVIRONMENTAL QUALITY PROPOSED REVISIONS TO THE STATE IMPLEMENTATION PLAN PUBLIC HEARING JANUARY 14, 2014

23 The meeting convened at 2:01 p.m. at the Houston-Galveston 24 Area Council, 3555 Timmons Lane, Houston, Texas, Nina Castillo 25 presiding.2 1 A P P E A R A N C E S 2 3 Nina Castillo, Air Quality Division 4 Walker Williamson, Air Quality Division 5 Lindley Anderson, Air Quality Division 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 253 1 2 P R 0 C E E D I N G S MS. CASTILLO: Good afternoon. I'd like to 3 welcome everyone to the public hearing being held by the Texas 4 Comission on Environmental Quality, or TCEQ. My name is Nina 5 Castillo with the Air Quality Division. With me is Walker 6 Williamson and Lindley Anderson, also with the Air Quality 7 division. 8 We are here this afternoon to receive oral and 9 written comments on a proposed Emissions Inventory, EI, State 10 Implementation Program, or SIP Revision, for the 2008 11 Eight-Hour Ozone National Ambient Air Quality Standard, or 12 NAAQS. Copies of the proposed SIP revision are available on 13 registration table for you to refer to while you're here. 14 If you have not already signed in, please do so 15 now. If you intend to present oral comments, please make sure 16 to indicate that on the sign-up sheet. Also, available on the 17 registration table are copies of the public hearing notice that 18 contain information about how to submit written comments on 19 this proposal. We will continue to accept written comments on 20 this proposal until January 27, 2014. 21 This hearing is structured strictly to receive 22 for

-- to receive oral and written comments for this proposal. 23 Open discussion during the hearing is not allowed; however, if 24 anyone has any additional questions regarding the proposal, 25 there will be additional opportunity after the hearing to talk4 1 to staff. 2 We will now begin receiving comments in the 3 order in which you registered. When I call your name, please 4 come up to the podium, state your name, and who you represent 5 and begin your comments. 6 Right now, we have Brandt Mannchen. 7 MR. MANNCHEN: My name is Brandt Mannchen, 8 B-R-A-N-D-T, M-A-N-N-C-H-E-N. I'm here representing the 9 Houston regional group of the Sierra Club. We, along with the 10 Dallas regional group of the Lone Star Chapter, will be 11 submitting comments before the January 27th deadline. Today, I 12 want to present some preliminary comments, and I want to thank 13 Nina, Lindley, and Walker for being here and taking these 14 comments. 15 The Sierra Club has several comments regarding 16 the Emissions Inventory. Our concern about the Emissions 17 Inventory is that what you do here today sets the floor for 18 what happens afterwards with the State Implementation Plan and 19 control strategies. So if we don't get this right, then the 20 control strategies aren't going to be sufficient, and we won't 21 have a chance of reaching attainment for the ozone standard. 22 The concern we have is that for 40-some-odd 23 years, the TCEQ and its predecessors have been doing 24 inventories. And in many cases, they have been very deficient. 25 They have underestimated and not overestimated emissions,5 1 whether they be nitrogen oxygen emissions or volatile organic 2 compound emission. 3 I'd like to read from an EPA document that came 4 out in the Federal Register recently that sort of sets this 5 sort of concern in place: 6 "As a result, TCEQ created an imputed inventory 7 approximately 5.8 times the reported levels for these HRVOC 8 species in its one-hour ozone attainment SIP. TCEQ also has 9 instituted rules to better regulate the industrial point 10 sources that emit these compounds with HRVOC rules in a 2004 11 SIP modification approved by EPA. 12 The more recent 2005, '6 field study confirmed 13 that these measures resulted in lower levels of these 14 pollutants approximately 40 percent"

-- "42 percent lower on 15 average than 2000 levels, but the HRVOC levels are still 16 underreported with ambient measurements indicating that actual 17 emissions were an average of 2 to 3 times the reported levels." 18 We're concerned that this is going to happen 19 again with this Emissions Inventory. We'd like to specifically 20 refer to certain parts of this mission's inventory and also the 21 appendices about why we have this concern. 22 In "Appendix A, Characterization of Oil and Gas 23 Equipment," there's a date of December 11, 2013, but it's 24 actually composed of work ordered

-- work ordered completed on 25 November 24, 2010, which by its nature couldn't include6 1 emissions from 2011. You know, real emissions, looking at 2 sources that were established or documented in 2011. In other 3 words, we're using estimates. This is a grave danger. We 4 should look at data through 2011 and not use data previous to 5 that. This appendix also, if you look at some of the studies, 6 they go back to 2005 and use data pre-2005 in some of their 7 estimates with regards to emissions and also types of equipment 8 and numbers of equipment and we're very concerned. We could be 9 underestimating greatly the total numbers and types of 10 equipment, especially area sources that could emit VOCs or 11 nitrogen oxides. 12 We also want to note that, for instance, for the 13 public to accurately read the documents and understand them, we 14 often have found that we can't understand how TCEQ got from one 15 point to another. An example is, how much of the 10,535-tons 16 of VOC listed in Table 2-4 for Wise County is from condensate 17 tanks. We're not told that. We need to break these down into 18 categories, and then show people, for these different 19 categories how much in the way of emissions for ozone 20 precursors that we're getting. 21 We're also not told with regard to compressor 22 engines whether the emissions stated are based on stack testing 23 and maximum operating or stack continuous emissions monitors or 24 based on average emission rate from type of compressor engines. 25 Obviously, when you base it on a stack test, when you're7 1 actually doing something, that is a more accurate figure than 2 using any sort of emissions factors. And we would urge TCEQ 3 it's really important-- to update your commission's factors by 4 actually having some real stack tests of compressors or some of 5 those other sources from different categories. If you don't 6 have that, then you don't know what's really happening in real 7 life. Also, it's really important to test these sources the 8 way they're actually operated, and the way they're actually 9 maintained because those two things can change, for instance, 10 the percent of efficiency for a control device greatly. 11 We're also concerned that TCEQ had the 12 opportunity a year ago to use an improved model from mobile 13 sources that would correct emission estimates for the years 14 after 2020 and chose not to do this. We don't think that's a 15 wise decision. We need to use the most up-to-date emissions 16 inventory, models, and tools so we get the very, very best 17 estimates. 18 We're also very concerned about area sources 19 that are not exactly in the Houston/Galveston or the 20 Dallas/Fort Worth non-attainment areas, but could provide a 21 background or a transport level of ozone into those areas or 22 ozone precursors. A good example would be that, as of 23 November 2013, there were 304,900 active wells in the State of 24 Texas, and that there were permits issued in 2011 for 22,480 25 oil and gas wells in 2011 and 2012 between 2,479 oil and gas8 1 wells. That category of area sources is changing really 2 rapidly, and it seems very obvious that the background level 3 for ozone precursors and perhaps even ozone is going to 4 increase and that's going to be transported around Texas 5 between non-attainment areas and also maybe even out of the 6 state and affect other places outside of the state. So it's a 7 great concern that this particular Emissions Inventory is not 8 able to account for those facts and is, in fact, obsolete by 9 the time you calculate everything. 10 When TCEQ talks about a 90-percent reduction to 11 the emission factors for carbon monoxide and volatile organic 12 compounds for certain engines using nonselective catalytic 13 reduction, we're concerned that assuming a 90-percent 14 efficiency may, in fact, not be a conservative way to look at 15 the emissions that are emitted from these devices these 16 control devices on these particular categories of pollution. 17 And it's like we mentioned before

-- the way they're operated, 18 their age, and their maintenance levels can affect the percent 19 efficiency of these devices and so it's we would rather you 20 use a figure like 85 percent instead of 90 and be a little 21 conservative; therefore, estimating a low grade in the 22 emissions because in the past we have never overcontrolled for 23 volatile organic compounds or nitrogen oxide. We've never 24 reached attainment. We've always been chasing that. A few 25 years ago TCEQ stood here in this room and said they could shut9 1 down the entire Houston Ship Channel and not reach attainment, 2 and then a year or two later the person who said that talked to 3 me and said, "You know, those NOx controls, they really worked. 4 I had no idea that we would be making such progress." So it's 5 really important that we be conservative because we've never 6 overcontrolled before. We've always underestimated emissions. 7 It's also important when looking at flares, 8 which are called in here green completion methods. I think the 9 term is flares-and-green-completion method, which are not 10 defined anywhere. So the public doesn't know what you're 11 talking about. It's really important when you mention a word 12 or a phrase that wouldn't be something the public would be 13 knowledgeable about, that you explain that. 14 But using 98 percent minimum controls for 15 flaring for VOCs? TCEQ and the EPA in recent years have done 16 reports that show this just simply isn't the case. And in many 17 cases, flares are operating at efficiencies very low 18 80 percent, 60 percent. You should not assume these 19 efficiencies for flares because we found out in the field that 20 they don't operate at those efficiencies. When does one 21 problem oversteaming as another problem? There's no real 22 problems that TCEQ has done the studies as well as the EPA 23 recently to show those things. So I'm not sure why TCEQ is 24 putting the same 98 percent in here when it's been shown by 25 TCEQ to be inaccurate.10 1 It's also of concern when talking about 2 condensate tanks for oil and gas activities. There's such a 3 wide range of emissions that could occur from this source 4 category. On Table 205, it indicates a single tank, such as 5 the Wegner/Crystal could range from 3.8 pounds per barrel to 6 31.5 pounds per barrel depending on the test or measurement 7 used. That's a tremendous range, and trying to take that and 8 come up with an emission's factor is extremely difficulty. And 9 there's a problem here in even coming up with a emission's 10 factor when you have such a huge range between what an oil 11 condensate tank could emit. So somehow TCEQ needs to get a 12 much better handle on that. And I know you want to do some 13 additional studies, and we support you in doing those studies; 14 but it seems to us a lot of that studying should have been done 15 before and should be incorporated in the EI right now. 16 Regarding ships, in that particular appendix, 17 which is "F", twice it mentions locomotives and then says 18 nothing else about locomotives. So I don't understand. If 19 you're going to estimate emissions from locomotives also, then, 20 do it; but why did you mention locomotives in F, but not do any 21 estimations about them? Also it says that for commercial 22 marine vessels, the study that was done for those was conducted 23 August 31, 2010. The IE is for 2011. And, again, we're not 24 waiting until the end of 2011 to make some estimates about what 25 2011 did. We're estimating in 2010. We don't think that's a11 1 smart way to do things. 2 Also, under F, says, "Unfortunately, the port 3 inventories were not developed to represent activities in 4 2011." So what was done was this method of using linear 5 projection where it simply assumed that growth occurred in a 6 linear fashion over a period of time from our standpoint it's 7 not a good assumption to make, especially since the recession 8 occurred, at least from 2007 to 2010 and even today shows that 9 growth is less in certain places today, than it was 10 before 2007. 11 Your own tables documents this in Tables 3-1 and 12 3-2 that currently some ports are emitting less today than they 13 were several years ago because of the recession. So it's of 14 concern to us you're using a estimation technique using linear 15 projections when you're tables don't document that that's 16 what's happening. 17 Also, Appendix F, page 3-3 to 3-6, talks about 18 in the upper reaches of the Ship Channel, "Loads may be as low 19 as six percent and that towboat operations may be as high as 20 65 percent. It's not clear how an accurate estimate can be 21 made when you have such large swings in the load

-- 59 percent 22 difference between those two figures. That needs to be 23 explained. Also on page 3-17, obviously, this is a typo: 24 "States arrived at site on January 1, 2011, and departed on 25 January 11, 2007." Something is wrong there.12 1 We're also concerned because a lot of the of 2 well drilling today is hydraulic fracturing, and from our 3 understanding, because of the long depths and horizontal 4 directions, there may be increased NOx emissions due to those 5 as opposed to just drilling straight down or even doing a slant 6 drill. So we're concerned that that type of difference in 7 operation be taken into effect as far as calculating the VOC or 8 NOx emissions from any of the wells that deal with fracking. 9 And we have other comments, but that's all we 10 have right now. And like I said, we will submit written 11 comments to you. Thank you. 12 MS. CASTILLO: All right. Thank you. 13 Is there anyone else that would like to present 14 comments at this time? 15 (No audience response.) 16 All right. Once again, the commission will 17 continue to accept written comments on its proposal till 18 January 27, 2014. All comments should reference the EI SIP 19 Provision Eight-Hour Ozone Standard and the Project Number, 20 2013-016-SIP-NR. Copies of the proposed SIP revision and 21 appendices can be obtained at the Commission's website. Please 22 feel free to pick up any of the handouts

-- that lists the web 23 addresses from the registration table. The handout also 24 includes instructions on how to register to receive e-mail 25 updates on issues related to SIP development.13 1 We appreciate your comments, and we thank you 2 for coming. If there's no further comments, this hearing is 3 now closed. All right. Thank you. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Proceedings concluded at 2:22p.m.)14 1 2 3 4 5 TEXAS COMMISSION ON ENVIRONMENTAL QUALITY. PROPOSED REVISIONS TO THE STATE IMPLEMENTATION PLAN PUBLIC HEARING JANUARY 14, 2014

6 I, Abigail Guerra, Certified Shorthand Reporter in 7 and for the State of Texas, certify that the above and 8 foregoing contains a true and correct transcription of all 9 portions of evidence and other proceedings requested in writing 10 to be included in the record in the above-referenced matter, 11 all of which was reported by me. 12 I further certify that this transcript of the record 13 of proceedings truly and correctly reflects the exhibits, if 14 any, offered by the parties. 15 I further certify that I am neither related to, nor 16 employed by any parties to the action in which this testimony 17 is taken, nor do I have a financial interest in the action. 18 19 20 21 22 23 24 25 Certified to by me on this day of January, 2014.

ABIGAIL GUERRA, Texas CSR 9059 Expiration Date: 12/31/15 INTEGRITY LEGAL SUPPORT SOLUTIONS Firm Registration No. 528 3100 West Slaughter Lane, Suite 101 Austin, Texas 78748 512-320-8690

### - 1 - 

# Texas Commission on Environmental 

# Quality Public Hearing Registration Date: January 14, 2014 

### Time: 2:00p.m. 

### Rule Project No.: 2013-016-SIP-NR 

### ShortTitle: EI SIP Revision for the 2008 Eight-Hour Ozone Standardfor the HGB and DFW Areas 

### Location: Houston-GalvestonArea Council, 3555 Timmons, Suite 120, Houston, Texas 77027 

### Concerning: Emissions Inventory (EI) State Implementation Plan (SIP) Revision for the 2008 Eight-Hour Ozone National AmbientAir Quality Standard (NAAQS) for the Houston-Galveston-Brazoria (HGB) and Dallas-Fort Worth (DFW) Areas Name Representing Presenting Oral Testimony? (Please Print) (Circle One) 

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# Texas Commission on Environmental 

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### Time: 2:oop.m. 

### Rule ProjectNo.: 2013-016-SIP-NR 

### ShortTitle: EI SIP Revision for the 2008 Eight-Hour Ozone Standardfor the HGB and DFW Areas 

### Location: Houston-Galveston Area Council, 3555 Timmons, Suite 120, Houston, Texas 77027 

### Concerning: Emissions Inventory (EI) State Implementation Plan (SIP) Revision for the 2008 Eight-Hour Ozone National Ambient Air Quality Standard (NAAQS) for the Houston-Galveston-Brazoria (HGB) and Dallas-FortWorth (DFW) Areas Name Representing Presenting Oral Testimony? (Please Print) (Circle One) 

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'--·TRANSCRIPT OF PROCEEDINGS BEFORE THE TEXAS COMMISSION ON ENVIRONMENTAL QUALITY ARLINGTON, TEXAS

************************************* PUBLIC HEARING JANUARY 16, 2014 *************************************

BE IT REMEMBERED that the above-entitled matter

came on for hearing on the 16th day of January, 2014,

at Council Chambers, Arlington City Hall Building, 101 W. Abram Street, Arlington, Texas, and the following proceedings were transcribed by Alicia A. Roberson, Certified Shorthand Reporter in and for the State of Texas.

### TCEQ

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1 

### I N D E X 2 

### PAGE 3 PROCEEDINGS JANUARY 16, 2014 3 

### 4 COMMENTS OFFERED BY: 5 

### MS. FAITH CHATHAM

......................... 4 6 

### MR. DAVID E. COZAD........................ 8 7 

### MS. HARRIET IRBY

.......................... 12 8 

### MS. JULIA BORGEN.

. . . . . . . . . . . . . . . . . . . . . . . . . 14 9 

### MR. JIM SCHERMBECK

........................ 17 10 MR. GREGORY PERRY

......................... 25 11 MS. KIM FEIL

.............................. 26 12 MS. RITA BEVING.

. . . . . . . . . . . . . . . . . . . . . . . . . . 32 13 MS. MOLLY ROOKE

........................... 37 14 MS

. LORRAINE LEVINE. . . . . . . . . . . . . . . . . . . . . . . 4 5 15 16 PROCEEDINGS CONCLUDED............................. 46 17 REPORTER'S CERTIFICATE............................ 47 18 19 20 21 22 23 24 25 Integrity Legal Support Solutions www.integrity-texas.corn 2

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1 

### P R 0 C E E D I N G S 2 MS. CASTILLO: Good afternoon. I would 3 like to welcome

-- welcome everyone to the public 4 hearing being conducted by the Texas Commission on 5 Environmental Quality or TCEQ. 

### 6 My name is Nina Castillo. I'm with the 7 Air Quality Division. With me here is Walker 8 Williamson and Melanie Rousseau, also with the 9 Air Quality Division. 10 We are here this afternoon to receive 11 oral and written comments on the Proposed Emissions 12 Inventory State Implementation Plan, or SIP revision, 13 for the 2008 Eight-Hour Ozone National Ambient Air 14 Quality Standard, or NAAQS. 15 Copies of the proposed SIP revision are 16 available on the registration table for you to refer to 17 while you're --while you're here. 18 If you have not already done so, please 19 sign in at the registration table and

-- and indicate 20 whether you prefer to speak. If you intend to present 21 oral comments, make sure you indicate on the sign-in 22 sheet. 23 Also available on -- at the registration 24 table are copies of the public hearing notice that 25 contain information on how to submit written comments Integrity Legal Support Solutions www.integrity-texas.com 3

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1 on this proposal. We will continue to accept written 2 comments on this proposal until January 27, 2014. 3 This hearing is structured strictly for 4 the receipt of oral and written comments on this 5 proposal. 6 Open discussion during the hearing is 7 not allowed; however, if anyone has any additional 8 questions regarding the proposal, there will be an 9 opportunity after the hearing to talk with staff. 10 We will now begin receiving comments in 11 the order in which you registered. When I call your 12 name, please come up to the podium and state your name, 13 who you represent, and begin your comments. 14 First up, we have Faith Chatham. 15 MS. CHATHAM: Good afternoon. I'm 16 Faith Chatham, and I am representing DFW regional 17 concerned citizens. Thank you for hearing me. 18 For half a decade, we have been urging 19 the Texas Commission on Environmental Quality, the 20 U.S. Environmental Protection Agency, and our North 21 Central Texas Council of Government regional planners 22 to compile a comprehensive, accurate inventory of 23 emissions and to apply science in evaluating the 24 cumulative impact of emissions per region. 25 It is imperative that such an inventory Integrity Legal Support Solutions www.integrity-texas.com 4

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1 be accurate, regularly updated, and available to 2 planners, local officials, and citizens. It is 3 

### imperative that the cumulative impact of emissions 4 per region include emissions from outside the 5 nonattainment area, because air pollution cannot be 6 fenced into a pad site or a cement kiln or a power 7 plant. 8 It is also imperative that emissions 9 from the nonattainment areas, which blow to other 10 regions, be considered. One region cannot be allowed 11 to contribute to the demise of your neighbors. 12 Without an accurate inventory area 13 area sources, such as oil and gas drilling, diesel 14 generators and engines, dry cleaning and industrial 15 emissions, such as General Motors and other important 16 economic enterprises in the region, determining what 17 new enterprises can safely be added in a region is 18 precarious, at best. 19 We must have jobs, and we must be 20 healthy enough to work, study, play, and serve in our 21 communities. We know this is complex. 22 We are not asking for a simple chart 23 which can be compiled without research and diligence. 24 However, our lives and the lives of our neighbors and 25 children depend upon the TCEQ and regional partners Integrity Legal Support Solutions www.integrity-texas.com 5



### of

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1 getting it right. 2 It is essential that it consider the 3 area sources and the emissions that blow through the 4 region and that it be evaluated for different weather 5 conditions and traffic patterns. It must be accurate, 6 and it must be used in granting future permits. 7 We have asked for an inventory of the 8 allowable emissions, part per thousand, from 9 enterprises already permitted in the region. It may be 10 out there, but I have yet to see it. 11 We know that the permits allow more 12 emissions than are actually healthy for the residents 13 of the D FW region

. 14 It does not take sophisticated equipment 15 to show that the current level of emissions in this 16 region has an adverse impact on the health of many of 17 the residents. 18 I cannot stay outside for more than a 19 few minutes most days without respiratory problems from 20 the combination of natural and man-made emissions. I 21 am not alone. 22 We urge you to diligently work on this 23 inventory and to get it right. Partner with the EPA 24 and do not let political pressure from the governor's 25 office deter you from getting this right. Integrity Legal Support Solutions www.integrity-texas.com 6

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1 

### I challenge you to earn our trust. Earn 2 our respect by creating a comprehensive inventory, 3 keeping it updated and available, utilizing it before 4 granting future permits. 5 Will this be popular? Probably not with 6 everyone. 7 Will you be accused of overreaching your 8 authority? Probably by those who want to profit from 9 

### enterprises which contribute to nonattainment. 10 Will you be doing your job? Absolutely. 11 Will you be overreaching your authority? 12 No. 13 It is your job to know what is in the 14 air in every region in Texas and to enforce the 15 Clean Air Act. 16 We have to work together to get this 17 right. It is more than a paycheck, and it is more than 18 who occupies the governor's mansion or contributes to a 19 political campaign. 20 Without air, life ceases. Without life, 21 there is no industry, no political appointments, no 22 advancement in career. 23 Thank you very much. 24 MS. CASTILLO: Okay. Next up, we have 25 David E. Cozad. Integrity Legal Support Solutions www.integrity-texas.com 7

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1 

### MR. COZAD: I'm David E. Cozad, and 2 I've lived in Arlington, Texas for over 30 years. I 3 am the democratic candidate who will be on the ballot 4 in November for the U.S Congressional seat currently 5 held by Joe Barton. That's the --basically, 6 Arlington, Ellis, and Navarro County. 7 The reason why this is of special 8 importance is some of the worst pollution is coming out 9 of my district that I would be congressman for. 10 I'm addressing you as a private citizen, 11 husband and father, and a grandfather. Creating 12 reliable inventory of emissions and creating guidelines 13 and rules which allow you to enforce the Clean Air Act 14 is not a simple task. Your job is not easy, but it is 15 emphatically important. 16 Without air that is healthy to breathe, 17 then contributions of individuals in the classroom, in 18 the workplace and civic, and in all family life is 19 impaired. I can testify to that from my own personal 20 experience. 21 That which is emphatically important is 22 rarely easy. Through the division of authority and 23 responsibility, TCEQ, with the EPA, is charged with 24 enforcing the Clean Air Act in Texas. 25 The DFW region and the other areas of Integrity Legal Support Solutions www.integrity-texas.com 8

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1 the state have been out of attainment for a very long 2 time, just about how long I've lived here. It does not 3 take scientific instruments to know that the air 4 quality frequently experienced by citizens in this 5 region is not healthy. 6 

### I am a preasthmatic, and to drive or 7 ride in an automobile in this area for more than a 8 short distance requires I utilize an air mask, 9 primarily this one. It has to be this quality or 10 better, primarily for the microparticulates and VOCs, 11 volatile organic compounds. 12 It is rather startling for people to 13 observe me in this. In fact, I do not wear it through 14 crossing guard sections at schools because the crossing 15 guards get a little upset when they see this. 16 Sometimes the police get upset, too. I use it because 17 it enables me to function outdoors. 18 I remember when using this mask was not 19 necessary. The air quality has changed here in 20 Arlington. Despite closing some of the cement kilns 21 and getting rid of old automobiles off our highways, we 22 are still not in attainment for the Clean Air Act. We 23 still

-- all still have a lot of hard work to do. 24 It is important that the inventory of 25 emissions from natural and industrial sources in each Integrity Legal Support Solutions www.integrity-texas.com 9

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1 area be accurate, kept up to date, and used before more 2 permits are granted to enterprises which will 3 contribute to the poor air quality. 4 Jobs are important. Identification and 5 enforcement to ensure that enterprises utilize best 6 practices is an important key to ensuring that we 7 continue to thrive economically. 8 We must be proactive in ensuring that 9 air is healthy enough for people to work and study and 10 contribute to the vitality of our communities. 11 On the business and political side, we 12 must partner to create clean industries, 13 next-generation enterprises which will feed our 14 families, pay more than just a living wage, provide a 15 career path in industries which promote clean air and 16 water instead of impairing them. 17 It is your job, as partner with the 18 federal Environmental Protection Agency, to establish a 19 reliable baseline for emissions, the nitrogen oxides, 20 the volatile organic compounds which create 21 ground-level ozone pollution. And it's not just in the 22 summertime, in winter, too. 23 It is your task to create a 24 comprehensive inventory of area sources and those from 25 outside the region and to utilize it in granting new Integrity Legal Support Solutions www.integrity-texas.com 10

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1 permits. You must apply it in your place

-- in your 2 plan to reduce ozone. 3 It is your job to evaluate all sources 4 of air pollution, natural and man-made, and establish 5 scientific baselines with their cumulative impact on 6 people, animals, vegetation, and air and water, which 7 is vital to the present and future economic and civic 8 growth in every region in Texas. 9 Air does not stay within boundaries. It 10 moves outside the fence of those who profit, from 11 industries and enterprises, that impact the health of 12 those who are least able to lose time from work or 13 school or to afford the medical care. 14 We must work together to create new, 15 clean industries to replace those which are detrimental 16 to the health of the region. This will require 17 leadership and partnering with local, regional, state, 18 and national agencies, elected officials, and the 19 business community. 20 We must create a path to the future for 21 the state and for every citizen in the state. To do 22 that, it is imperative that your agency gets this 23 inventory right. 24 We are depending on you to do your part 25 to keep the people in this region able to do our part Integrity Legal Support Solutions www.integrity-texas.com 11

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1 in transit

-- transitioning dirty jobs for clean 2 next-generation solutions. 3 Thank you. 4 

### MS. CASTILLO: Okay. Next up, we have 5 Harriet Inley. 6 

### MS. IRBY: Irby. 7 

### Good afternoon. My name is Harriet 8 Irby. I live at 9 As a citizen and I guess I should say 10 victim of environmentally caused lung disease, I am 11 here because I am convinced the TCEQ does not protect 12 either the environment or public health. 13 There are poisons in our north Texas air 14 that are killing and disabling both children and 15 adults. North Texas air is polluted, dirty, and out of 16 compliance with federal standards, has been for a long 17 time. Governor Perry and his appointees and his 18 capless cronies fight to keep it that way. 19 

### The TCEQ, for political necessity, has 20 to serve Rick Perry's agenda. To Texas bureaucracies, 21 though, no ozone is bad, and we know this as the public 22 because we have ozone alert days. 23 Solution, lock up the runners, bad ozone 24 day; you get to stay inside, go to jail. Yank our 25 children from their playgrounds and sports fields. Integrity Legal Support Solutions www.integrity-texas.com 12

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1 Problem solved with ozone. Attainment isn't necessary. 2 

### But the problem isn't solved. Asthma is 3 rapidly increasing in north Texas. The statistics are 4 available from the UTA College of Nursing. And so is 5 COPD. The number and amount of ozone (inaudible), NOx, 6 VOCs is also increasing and is getting higher. So 7 ozone cooks up better in the broiling Texas summer. 8 As citizens, I personally feel we don't 9 get much from your agency. When we call and complain, 10 nobody ever settles anything. When we ask for 11 statistics, it could take a year to get a report, but 12 everybody there, apparently, thinks federal air quality 13 standards are nothing but a joke. 14 Personally, I am tired of picking up 15 Albuterol ampules in my rental properties. I am tired 16 of tenants too sick with bronchitis or asthma or COPD 17 to be able to work and pay rent. 18 40 years ago, asthma was rare here. Now 19 it is expected that children will have an asthmatic 20 period in their lives. Three of my six grandchildren 21 have it, and one is already dead. 22 Other U.S. cities have far cleaner air 23 than DFW. San Francisco certainly does, but then 24 California has higher air quality standards than the 25 EPA itself. Integrity Legal Support Solutions www.integrity-texas.com 13

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1 

### A word about proposed standards. Use 2 current information. You can do it. You have the 3 equipment. Publish it so the public knows about it. 4 This hearing, for example, was not well-publicized, and 5 the volunteer at City Hall didn't know what TCEQ was 6 and thought it started at 1:00. 7 So things need to be better coordinated. 8 You now how to do it. You're bright and intelligent, 9 and you know how to do an inventory. Please, for the 10 sake of future generations, if not for us. 11 MS. CASTILLO: Up next, Julia Burgen. 12 MS. BORGEN: Thank you very much for 13 this opportunity. Just a bit of personal stuff that I 14 was thinking about as I was listening to other people. 15 I have three children. Two of them have 16 elected to move with their families to other states. 17 They do not live here. 18 The one who did stay in the Metroplex, 19 the general Metroplex, her oldest daughter, my 20 granddaughter, and her family, they moved east, 21 southeast actually. 22 And, you know, when I start hearing 23 these kind of things, I think they probably made the 24 wisest choice, because I can't understand why there is 25 still this drive to bring more residents to the Integrity Legal Support Solutions www.integrity-texas.com 14

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1 Metroplex, why-- why there's all this seeking of new 2 businesses and new entities and all this when we are 3 not in compliance. 4 I thought there were portions of the 5 Clean Air Act that dealt with the issue of, you can't 6 bring more people in until you clean up what you've 7 got. I guess that got lost along the way somewhere. 8 

### I have been a 40-year member of the 9 Sierra Club. I became an environmental activist in the 10 '70s, and I have never lost it, because I know it is 11 right. 12 I want to hold up the document which 13 you-all have received from the Sierra Club, dated 14 January '14, today, with respect to the SIP plan and 15 its contents, which I have read and which I adhere to 16 and which I ask you to pay attention to and address and 17 see that these things are done. I don't need to lit

-- 18 a litany of them right here, but those are the things 19 which I also would ask of you. 20 Personally, I never smoked, so I 21 can't

-- you can't

-- nobody can blame me there for my 22 health issues. I do have asthma. 23 I do have two different inhalers, and 24 the company that I buy them from and gets the money 25 from them is in California. It's not a Texas company. Integrity Legal Support Solutions www.integrity-texas.com 15

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1 So I'm not

-- you're not benefiting from my drug bill 2 even. 3 The State is not benefiting from my drug 4 bill, except maybe the local

-- well, no, I do it all 5 over the Internet. I don't even go -- have a local 6 pharmacy that's benefiting. 7 I have taken extremely good care of my 8 health because I knew I had to, but there are many 9 people who have not been as fortunate as myself in 10 managing and handling their asthma and also in being 11 able to afford, through insurance

-- private insurance, 12 doctors and assistance in my 79 years of life. 13 I 

## am 79. I will be 80 ln April. I'd 14 like to keep on living, so I keep on working at all of 15 these things. I would like to have Texas in compliance 16 before I die. It would be very, very nice

-- 17 (Applause) 18 MS. BURGEN:

-- it would be a gift to 19 those here and to those to come, but we've never been 20 in compliance. 21 There is a definite need to consider 22 wind-blown sources and all of this stuff that's coming 23 from other areas. The area sources need to be 24 expanded, the calculating the wind-blown stuff, and 25 you just need to get the inventory correct. Integrity Legal Support Solutions www.integrity-texas.com 16

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1 I know it's all I really need to say. 2 It all needs to be updated and accurate, and I 3 encourage you to use this as a guideline for what you 4 need to do. 5 Thank you very much. 6 (Applause) 7 

### MS. CASTILLO: Up next, Jim Schermbeck. 8 

### MR. SCHERMBECK: Hi, my name is 9 Jim Schermbeck. I'm with Down

-- Downwinders at Risk, 10 with the group that had to convince your agency that 11 the cement plants in Midlothian were affecting air 12 quality in Dallas/Fort Worth around 1994, '95. 13 This inventory is an example of the 14 agency making the same mistake

-- the same willful 15 mistake in regards to oil and gas increase, both in the 16 Barnett Shale and in other oil and gas plays affecting 17 the DFW airshed. 18 The lack of an accurate inventory for 19 these sources doomed the last SIP and will doom this 20 SIP in exactly the same way, but I fear that is TCEQ's 21 intent. 22 On its face, the failure of the last 23 SIP, the 2011 SIP, the spectacular failure in which the 24 agency predicted that we would have historically low 25 levels of ozone by now, all because people would buy Integrity Legal Support Solutions www.integrity-texas.com 17

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1 new cars that were so much cleaner than the older ones, 2 during the worst economic recession in 80 or so years, 3 that was TCEQ' s thinking. It's that same thinking 4 that's leading us into this next SIP with, again, I 5 fear, the same results. 6 It's not only just ignoring this 7 mistake; it's actually institutionalizing it. In doing 8 so, the agency is writing the obituary of the 2015 SIP 9 before it's even created. 10 Your own data shows that since 2006 all 11 other source categories of pollution in this area -- 12 this nonattainment area have declined, save one, oil 13 and gas. 14 If you look at the last inventory that 15 was done, the VOCs coming from the oil and gas industry 16 were larger than all the VOCs generated by all the 17 vehicles on all the roads in all of those nine or ten 18 counties. 19 During the same time, the design value 20 for ozone for the area has gone up, since the last SIP, 21 since at least the last 2006/2007 SIP. 22 So that you have the confluence of 23 events where every other source has gone down in the 24 last six or seven years, the design value has gone up, 25 and there's one culprit, the oil and gas emissions that Integrity Legal Support Solutions www.integrity-texas.com 18

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1 have gone up along the way as well, since 2006, the 2 whole development of the Barnett Shale. 3 We should be making more air quality 4 progress in this area. The cement plants have 5 decreased their emissions. The coal plants have 6 decreased their emissions. We do have cleaner cars. 7 Every other source category has gone down except oil 8 and gas. 9 It's oil and gas that's keeping 10 Dallas/Fort Worth in nonattainment, not only from 11 sources within the ten counties

-- now ten counties, 12 but sources to the southeast and east of us, in 13 Freestone and Limestone Counties. 14 The same counties that had the worst 15 coal plants now have the most oil and gas compressor 16 systems as well, and that is all directly upwind of 17 Dallas/Fort Worth. 18 It follows that familiar path of wind 19 patterns that hits the Gulf Coast, goes through Houston 20 and through the coal patch and up to DFW. Well, now 21 the coal patch is also the gas patch. And that is not 22 reflected in this inventory at all. 23 It's interesting, back in, gosh, 24 2002/2003, for that SIP, the State was allowed to get 25 away with it because of the phenomenon called Integrity Legal Support Solutions www.integrity-texas.com 19

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1 "manufactured winds," in which the State and EPA 2 literally conspired to a create a fictional scenario 3 where the city of Houston contributed two to three 4 parts per billion to the ozone problem here, and, thus, 5 we were out of a jam because it was all Houston's 6 fault. 7 It's interesting how elastic these 8 things are, that that thing can happen in 2003, and yet 9 here in 2014, they're keeping out real world data that 10 actually does have an impact on DFW air quality. 11 You're accepting the fictional results 12 of the manufactured wind scenario, but not accepting 13 the results of what's actually on the ground affecting 14 air quality in DFW. 15 (Applause) 16 There's no breakdown of emissions by 17 facility in this inventory. How much do you air 18 do compressors pollute in the state of Texas or even in 19 the Dallas/Forth Worth nonattainment area or in the 20 Haynesville Shale, which is to the southeast of us? We 21 do not know. 22 We don't know how much condensate tanks 23 release. We don't know what pipelines release. We 24 don't know what flaring is, even though there are 25 studies now out there that show that flaring Integrity Legal Support Solutions www.integrity-texas.com 20

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1 contributes to ozone concentrations downwind. It's 2 actually not a pollution control device. 3 Two-thirds of the VOCs you say come 4 in this area at least, from DFW, come from area 5 sources, but you don't say how much of that is from oil 6 and gas. You hide oil and gas emissions within this 7 category. 8 I mean, you don't have to be a rocket 9 scientist to figure out what the agency is doing. It's 10 not a very good job of hiding it, but that's what's 11 going on. 12 The current estimates are flawed. If 13 you look at Appendix A information, for instance, you 14 have information that goes back

-- way back to 2008, 15 2009, 2007. 16 This is a very, very old database for 17 oil and gas to be assuming things now in 2014, 18 especially with all the development to the southeast of 19 us, which isn't even counted. 20 It's based on industry surveys that are 21 voluntary. It's not based on real world capturing of 22 emissions or even stack testing, for that matter. 23 Compressor station emissions. We have 24 many, many, many more compressor stations in 2014 than 25 we do

-- did in 2007, '8 or '9 or '10, or even last Integrity Legal Support Solutions www.integrity-texas.com 21

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1 year. 2 How are those compressor station 3**emiss~ons** 

### being counted in this inventory, either in 4 the nonattainment area or outside of that nonattainment 5 area, in airsheds that affect that nonattainment area? 6 Are they based on stack testing; are 7 they based on continuous emission monitors; or are they 8 just based on industry assumptions about those 9 emissions? 10 You can't get all the right numbers, 11 even about the number of wells that are in the state. 12 According to TCEQ, in this inventory, there are about 13 240,000 gas wells in the state of Texas --gas and oil. 14 I'm sorry. 15 According to the Railroad Commission, 16 there are a whole 55,000 or 60,000 more oil and gas 17 wells than that. The State can't even agree on how 18 many sources of pollution there are, much less what's 19 coming out of them. 20 If you look at Wise County and the VOC 21 count you did there, in 2008, there were 24,000 tons a 22 year of VOCs coming out of the oil and gas industry in 23 Wise County, now in the nonattainment area. As of 24 2011, according to TCEQ, there's a third of that. 25 I really

-- as a property owner in Integrity Legal Support Solutions www.integrity-texas.com 22

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1 Wise County, I really doubt that VOCs have dropped by 2 two-thirds from 2008 to 2011. In fact, I'm pretty sure 3 they've increased with the development of compressors 4 and everything else, the infrastructure out there in 5 Wise County and around it. 6 I would imagine that there's more VOCs, 7 but the State doesn't really explain how it got to that 8 lower number. I doubt that there was a real drop. 9 You talk about flaring as if it was a 10 pollution control measure, as this is something that 11 should be encouraged. When, in fact, we know from 12 studies that are out there, as I said, that it actually 13 can increase ozone levels from five to ten parts per 14 billion a mile or more downwind. That's from a HARC 15 study just in

-- I'm sorry-- 2012 now. 16 You look at the engine types, and you 17 admit that 20 percent of the engines used in the oil 18 and gas industry don't have an inspection. You have no 19 idea what kind of emissions are coming out of it. 20 That's almost a quarter of all engines, and air 21 pollution is a mystery. 22 You talk about the need that as older 23 wells age, they will need lift engines, and yet those 24 are not reflected in this inventory, because when this 25 inventory was taken in 2008, 2009, these wells were all Integrity Legal Support Solutions www.integrity-texas.com 23

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1 new. 2 It doesn't consider the impact of aging 3 wells and the need for those new lift engines and 4 whether or not they're electrified. You assumed 5 70 percent electrification. 6 

### In my experience, that's

-- that's a 7 severe overestimate. And there's no data to confirm 8 that 70 percent estimate on your part. There's no 9 study. There's nothing. 10 If you look at blowdowns and 11 compressors, blowdowns can actually

-- they're the 12 fugitive emissions of compressors. They can actually 13 account for more emissions than what comes out of the 14 stack, and that can happen many, many, many times a 15 year, more than once a day. 16 You keep track of these blowdowns, and 17 yet those emissions are not reflected in the compressor 18 emissions here in this inventory. Those can double or 19 triple the annual emissions from a compressor, and yet 20 they are not in here, from either the Barnett Shale or 21 the shale that's upwind of us. It's also affecting our 22 air quality. 23 You need more recent data to

-- to look 24 at the explosion of new wells both in this area over 25 the last six or seven years as well as the areas upwind Integrity Legal Support Solutions www.integrity-texas.com 24

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1 of us. You need more comprehensive data about 2 compressors, whether they're being tested at all, what 3 kind of data surrounds them, fugitive emissions, 4 geographically where are the worst emissions coming 5 from. 6 You need the information to be logically 7 organized. You don't really want to have to revert to 8 fifth grade level hiding techniques and statistics, you 9 know, within one another. Tease the oil and gas 10 information out. Let it be known about exactly where 11 these emissions are coming from. 12 But mostly you need a state agency 13 that's interested in reducing air pollution, and I 14 really don't think we have that. Thanks. 15 (Applause) 16 MS. CASTILLO: I guess Gregory Perks. 17 There's a question mark on Gregory. 18 MR. PERRY: There's always a question 19 mark. 20 MS. CASTILLO: Is it Gregory Perks? 21 MR. PERRY: Perry. 22 MS. CASTILLO: Perry. 23 MR. PERRY: No relation. 24 I'm not going to read you a whole riot 25 act about the things that are wrong. I know there are Integrity Legal Support Solutions www.integrity-texas.com 25

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1 a lot of things wrong, and I know that you do, too. 2 You're the victims. If, as you read on my statement, I 3 get elected, I need to talk to you. If not, I wish you 4 well. 5 

### MS. CASTILLO: Kim Feil, did you want 6 to make a statement? 7 

### MS. FEIL: Yeah. 8 

### Kim Feil (indiscernible) here. I looked 9 at the North Central Texas Council of Government's 10 ozone report, and I averaged the 2012 and 2013 readings 11 for us, and over the 75 parts per billion, we had 34 12 days a year, and over the 84 parts per billion, we 13 averaged 11 days a year. 14 And that's

-- that's 45 days out of the 15 year, and we -- our summers are getting longer and 16 hotter, and we even had an ozone day back in September 17 of 2013, so we're not excepting this to get any better. 18 In reviewing the North Central Texas 19 Council of Government's Phase 1 Barnett Shale On-Road 20 Emissions Inventory-- and that's already two years 21 old

-- one statistic stood out, and that is something 22 we should have the oil and gas industry to control and 23 that they can control, and it's truck idling. 24 I mean, that just seems like a 25 no-brainer, but unless there's a law that makes them do Integrity Legal Support Solutions www.integrity-texas.com 26

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1 it, they're not going to do it. And in 2012, 2 78 percent of the emissions that had been reported were 3 related to idling. 4 The report further stated that from the 5 onset of north Texas drilling, which was in 2006, the 6 daily miles that were driven from oil and gas 7 infrastructure, from road miles, on-road miles, were 8 about 61,000 miles a day, but that doubled by the time 9 2012 rolled around, almost doubled. 10 And those findings for the on-site 11 Barnett shale parallel that, that they almost doubled 12 in a six-year period, yet the COG North Central 13 Texas Council of Government's report tries to 14 extrapolate into the future to say that from 2012 to 15 2018, in another six years, it's all going to stay 16 about the same. I disagree. 17 Those emissions are not going to 18 stabilize 2012 levels, because they're assuming that 19 the boom in the Barnett Shale has piqued. It has not. 20 Even the Chesapeake in Arlington is about 80 percent of 21 our drilling, and they're looking for shale. That 22 stuff blows this way, okay? 23 But when the price of natural gas comes 24 back up, they'll be back here. And, believe me, in 25 Arlington, they only drilled a couple of wells at a lot Integrity Legal Support Solutions www.integrity-texas.com 27

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1 of these sites. They can put 20 wells on these sites. 2 And then when they want to start stacking wells, what's 3 going to happen then? 4 Now, I've been chasing preproduction 5 drilling emission numbers for a while now. That would 6 be the drilling, the fracking, the flowback, because 7 TCEQ did the Phase 1 and Phase 2 emissions inventory, 8 and it was postproduction equipment, just the storage 9 tanks at (indiscernible). And it's real frustrating to 10 not have the whole piece of the pie. 11 Well, North Central Texas Council of 12 Governments pretty much had that information for me 13 this morning, and I really wanted to go through a lot 14 more of it before I fully spoke to you, but, basically, 15 by 2012, we're looking at about postproduction and 16 preproduction, including truck idling, to be 200,000 17 pounds per day. 18 Now, they're assuming the productions 19 aren't going to change, and they're assuming these 20 leaseholds aren't going to be built out, and they don't 21 figure out the other emissions related to oil and gas. 22 That would be like building pipelines. 23 In Frisco, December the 18th, last 24 month, Atmos flared, for two to three hours, a natural 25 gas line for the construction of a 20-inch gas Integrity Legal Support Solutions www.integrity-texas.com 28

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1 transmission line. That wasn't built into the COG's 2 report. 3 

### And what about those releases? We've 4 had drill sites in people's backyards going off, and 5 there's all kinds of releases. And those aren't built 6 into the models. 7 But, mostly, this ozone standard needs 8 to be so strict because we've got to save ourselves 9 from the Co2, the global warming. 10 And looking at COG's report, they were 11 saying that the on-site Barnett Shale productions from 12 truck idling, too, would be

-- went from 2006

-- ln 13 2006, from 87,000 pounds a day to almost 200,000 pounds 14 a day. 15 So this doesn't include the losses when 16 you transport the waste from the storage tanks to the 17 injection wells. You do get losses in transportation 18 and injection. 19 And as for

-- when we look at what is 20 called well completion, there seems to be a 21 pacification. People think that they have a 22 (indiscernible) pollution, that they don't really have 23 to worry about flowback, but flowback in its initial 24 stages is called topflow, and it is allowed to vent in 25 these open hatch flowback tanks, these 18-inch wide Integrity Legal Support Solutions www.integrity-texas.com 29

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1 hatches, and it is directly venting into the 2 atmosphere. 3 And if they could control those initial 4 flowback emissions with the right equipment and that 5 is called the ventless pressurized flowback tanks 6 that would be one component of the preproduction 7 emissions we can control. 8 And when we talk about blowdowns and we 9 think we have electric compressors at these drill sites 10 and that, you know, there's zero emissions, that's 11 incorrect, because any time we lose power, they have to 12 blow down everything in the pipes. 13 And what they try to do is blow them 14 down to the 200 pounds of pressure that goes into 15 the storage tanks, and they indirectly go through a few 16 patches there. So we still don't have a handle on how 17 not to vent. And we can't just shut these vents 18 completely sealed because they're under pressure. 19 What we don't know is how many of these 20 old wells leak, how many of the new wells leak. Last 21 year, we issued 465 drilling permits. How many of the 22 new future wells are going to be leaking? 23 And those 465 drilling permits, that was 24 for Wise, Parker, Tarrant, and Denton County. That's 25 not for the whole state. That's not for the Ford shale Integrity Legal Support Solutions www.integrity-texas.com 30

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1 that blows towards us. 2 The most important thing I want to 3 present to you today is what is happening in Azle, 4 Texas. Over the last couple of months, we've had at 5 least 30 earthquakes. 6 What we don't understand is how much 7 ozone is being released on every earthquake, how much 8 ozone is being released during every frac. 9 The Journal of Applied Physics' letters 10 back in late 2011 came out with information that the 11 University of Virginia reported on. 12 It seems that they were using ozone as a 13 way to look at impending earthquakes. When the ozone 14 is detected, they expect an earthquake. It's an early 15 indicator system. 16 Rocks breaking under pressure, like in 17 fracking, releases ozone, and it seems that the ozone 18 is higher with the type of rocks in a geological 19 stratus that has high silica content. 20 Well, we understand here ln north 21 central Texas there's a lot of drilling, there's a lot 22 of fracking, there's a lot of silica, and now there's a 23 lot of earthquakes. Thank you. 24 25 Beving. MS. CASTILLO: Next we have Rita

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1 

### MS. BEVING: Beving. Let me do this 2 first. 3 

### Good afternoon. My name is Rita Beving. 4 I'm here representing

-- a public citizen who has had a 5 position on the North Texas Clean Air Steering 6 Committee as a voting member for this region's air 7 SIP

-- air plan for numerous SIPs, all which have 8 failed this region getting to --to attainment. 9 And, you know, normally, as many of the 10 TCEQ staff would tell you, there would be 125 to 200 11 people in this room. 12 But I will tell you the citizens in this 13 region are so discouraged at the failed SIPs, the 14 earthquakes, like you have in Azle, and the continuing 15 pollution problems that this region faces, especially 16 with escalating oil and gas. 17 So today I'm here to comment on the 18 proposal to the TCEQ's revisions to the emissions 19 inventory under the 2008 Ozone

-- Eight-Hour Ozone 20 Standard. 21 As the EPA is considering even more 22 stringent standards, to levels of 65 to 74 PPB, the 23 current proposal is just woefully inadequate. 24 From the early '70s until today, the 25 TCEQ has inadequately calculated the emissions Integrity Legal Support Solutions www.integrity-texas.com 32

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1 inventory, implemented inadequate control strategies, 2 and proclaimed that the SIP

-- the next upcoming SIP, 3 as for this region, would attain the ozone standard. 4 I have now been a voting member or an 5 alternate of the North Texas Clean Air Steering 6 Committee for probably four or five SIPs by this point. 7 In the past, TCEQ, at many of our 8 meetings, have expressed concern about overcontrolling 9 point sources of pollution. Obviously, that has proved 10 to be faulty reasoning, as our area hasn't reached 11 attainment for air quality in decades. 12 So to reach attainment, we need the most 13 accurate emissions inventory possible. The DFW area 14 needs to come into attainment. 15 And right now, I'm just going to give 16 you some general comments that are also probably going 17 to be reflected in the letter that Molly Rooke is going 18 to give you from the Sierra Club, because I'm also on 19 that board. 20 The emissions inventory proposal does 21 not clarify the definition even of what the length of 22 the ozone season is. Is it 144 days? Is it 120? What 23 is it? That makes a difference in the calculation of 24 what you're doing with this proposal. 25 It fails to state how NOx and VOC Integrity Legal Support Solutions www.integrity-texas.com 33

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1 emissions were calculated for some of its tables; 2 namely, Table 2-1 through Table 2-10. So it cannot be 3 verified. 4 The accuracy of the 2011 database is 5 key, as a significant amount of NOx and two-thirds of 6 the VOCs in the DFW and Houston area are caused by area 7 sources. 8 Though the methodology in this document 9 is explained, the information is inadequate to 10 determine or verify that this is even right concerning 11 area sources. 12 In short, we can't trust the EI for 2011 13 for area sources, so data must be presented on the 14 contribution of area sources correctly. 15 And the appendices of this document, as 16 Jim said, are confusing and impossible to tell where 17 the area of resource where the area sources come 18 from by category. 19 In relation to the significant amount of 20 emissions the Dallas/Fort Worth area gets from coal, we 21 need a separate SIP to be devised for the East Texas 22 area, considering the large coal-fired power plants 23 that contribute to the DFW nonattainment area. 24 These would be the counties that have 25 Brown, Monticello, and Martin Lake that have been Integrity Legal Support Solutions www.integrity-texas.com 34

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1 grandfathered in, once again, for decades on new 2 pollution controls. Though there has been some 3 improvement, we are still getting significant emissions 4 from east Texas. 5 If the TCEQ can get the DFW area credits 6 for what Alcoa has done, then we can devise a SIP for 7 East Texas. 8 Also, we need to consider that besides 9 Wise County, more counties should be added to the 10 nonattainment area, where coal or gas and drilling 11 activities occur, because we -- not only is DFW in 12 nonattainment, but we have other regions of the state, 13 such as San Antonio and Tyler, teetering on the edge of 14 nonattainment. 15 And then we are deeply troubled in the 16 DFW region about the report's claim that NOx emissions 17 in Tarrant County were reduced from 3,500 to less than 18 1,000 tons between 2008 and 2011. 19 We are not convinced, not public citizen 20 nor Sierra Club, that these numbers are accurate. And 21 we are also especially concerned about the types of 22 facilities and oil and gas operations that were 23 excluded from the calculations of the emissions 24 inventory. 25 There is concern that the information Integrity Legal Support Solutions www.integrity-texas.com 35

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1 used for the 2011 emissions inventory is inaccurate and 2 undervalued, as the widespread development of oil and 3 gas has continued. Using a 2008 base year is 4 obsolete and inadequate for developing a 2011 emissions 5 inventory. 6 It means that you're using data that's 7 six years old, not three years old, to determine your 8 next SIP. The TCEQ, in its executive summary of the 9 proposal, notes 90,000 gas wells and 150,000 oil wells 10 in Texas. 11 As of 2013, there are 304,900 active 12 wells and 108,452 inactive wells. So the difference 13 here is exponential, and it's exponentially inadequate 14 to even begin to address local air quality problems. 15 This information void demands that 2011 16 data, not 2008, be used for an accurate emissions 17 inventory. 18 In regards to oil and gas sources, TCEQ 19 should state whether there are any flares used at well 20 sites and include those emission sources in the 21 proposal. 22 They're

-- TCEQ is using engine data 23 more than six years old for natural gas compressors and 24 production facilities, while tens of thousands of wells 25 have been drilled since that time. Integrity Legal Support Solutions www.integrity-texas.com 36

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1 

### I'm going to end that in ln relation 2 to oil and gas, because I know Molly is going to pick 3 up with more about the types of mechanics that are used 4 in oil and gas drilling that aren't in this inventory. 5 In conclusion, the numbers are not there 6 to make this emissions inventory accurate enough to use 7 for any future SIP, especially with the rapid oil and 8 gas operations in DFW, in

-- in the Eagle Ford, and in 9 other regions recently being discovered and being 10 drilled. 11 Knowingly submitting this proposal 12 without critical oil and gas data and, moreover, 13 outdated and incomplete information is a proposal for 14 failure for all those areas of the state that need to 15 attain clean air standards. Thank you. 16 17 18 that right? 19 20 21 22 23 Rooke. 24 25 conservation (Applause) MS. CASTILLO: Molly Rooke. Did I say

MS. ROOKE: Rooke. MS. CASTILLO: Pardon? MS. ROOKE: Rooke. MS. CASTILLO: Rooke. Okay. Molly

MS. ROOKE: I'm Molly Rooke. I'm cochair of the Dallas Sierra Club, Integrity Legal Support Solutions www.integrity-texas.com and 37

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1 I'm here to present the comments for the Houston 2 regional group of the Sierra Club, the Dallas group, 3 and the Lone Star Chapter of the Sierra Club regarding 4 the Texas Commission on Environmental Quality's 5 proposal to revise the emissions inventory for the 6 for those areas. 7 The Lone Star Chapter has some 20,000 8 members throughout Texas concerned with air quality, 9 among other issues. The majority of our members reside 10 in nonattainment areas, like Houston and Dallas, as 11 well as areas considered near nonattainment, such as 12 Austin and San Antonio. 13 We would first note that while we 14 recognize that TCEQ should and must update their 15 emissions inventory by mid-2014 to meet the regulatory 16 requirements under the

-- under the 2008 standards and 17 that it's reasonable to base the EI on 2011, 18 anticipated changes at the EPA may lead to a new ozone 19 standard this year, which could significantly expand 20 the required EI reporting, monitoring, planning, and 21 implementation of SIP controls. 22 We would note that we also believe the 23 classifications for Dallas/Fort Worth and Houston, 24 Galveston and Brazoria are not correct, moderate and 25 marginal respectively, and these nonattainment areas Integrity Legal Support Solutions www.integrity-texas.com 38

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1 should have been classified differently. 2 Furthermore, we would note that the 3 Beaumont, Port Arthur, Tyler, Longview, and San Antonio 4 metropolitan areas have all violated the existing 7

-- 5 75 part per billion standard and should also be 6 candidates for nonattainment under the existing 7 standard. 8 We also point out that the decision to 9 only expand the Dallas/Fort Worth nonattainment area 10 from n{ne counties to ten, with the addition of 11 Wise County, was one which the Sierra Club disagreed, 12 as we believe there were at least three other counties 13 which could have and should have been added to the 14 nonattainment area. 15 Finally, we would continue to note that 16 while the emissions inventory being discussed is 17 limited to listing the emissions from point area, 18 nonmobile and mobile sources within the two designated 19 nonattainment areas, there is irrefutable evidence that 20 emissions from large power plants, refineries, and 21 other major Clean Air Act point sources outside of the 22 nonattainment areas influence emissions in these two 23 areas. 24 Thus, we would support the development 25 of a SIP for all of East Texas that would address NOx Integrity Legal Support Solutions www.integrity-texas.com 39

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1 and VOC emissions from major point sources such as 2 power plants, including the development of an emissions 3 inventory. 4 In particular, Dallas/Fort Worth is 5 impacted by the emissions from several large coal 6 burning power plants to the east and southeast, and 7 these emissions should be inventoried, and appropriate 8 controls should be developed as part of the SIP. 9 In terms of the proposed revisions, a 10 major concern that the Sierra Club has about this 11 proposed change to the EI is that what is proposed is 12 not accurate enough. The SIP control strategies that 13 will follow are based and entirely dependent upon an 14 accurate EI. 15 In our view, the EI does not provide a 16 basis that can provide the assurance that when control 17 strategies are implemented, based on the EI, that 18 attainment of the eight-hour ozone will be achieved. 19 This is of particular concern when the EI

-- with the 20 EI relative to area sources. 21 While point sources require

-- are 22 required to report annually to the TCEQ, are relatively 23 straight forward, area sources including those sources 24 related to oil and gas facilities, which do not meet 25 the criteria for reporting to the PDS, are much more Integrity Legal Support Solutions www.integrity-texas.com 40

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1 difficult to quantify. 2 While we recognize the significant work 3 done in recent years by TCEQ and by contractors hired 4 by TCEQ to better access emissions from these sources, 5 we are concerned that the 2011 base year is inaccurate, 6 particularly given the wide spread development of 7 natural gas and oil and associated truck traffic, which 8 occurred as a result of hydraulic fracturing 9 development throughout Texas. 10 Our concern is not only that emissions 11 from these area sources are being undervalued at 

### -- in 12 the present IE, but that because they're undervalued, 13 the real emissions reductions occurring and likely to 14 occur as a result of new regulations, like the E 15 EPA's NSPS for newer storage tanks, will not be 16 appropriately recognized as a valid control strategy. 17 And I just want to go further and give a 18 little bit more, as Rita was saying, about the oil and 19 gas considerations for emissions inventory proposal. 20 The proposal needs to include all the 21 shale zones subject to £racking, with its production 22 listed and air emissions estimated. This is important 23 for NOx and VOC background levels and its transport 24 into nonattainment areas. 25 The TCEQ assumes that 20 percent of the Integrity Legal Support Solutions www.integrity-texas.com 41

### TCEQ

- Rule Project No. 2013-016-SIP-NR

- 1/16/2014

1 engine numbers is not known and, therefore, it cannot 2 make assumptions on this data. TCEQ refers to green 3 completion or add-on control technologies, but never 4 defines that in relation to oil and gas or what is 5 considered green. This should be done in this proposal 6 as a control device to this eight-year plan. 7 TCEQ makes an assumption about the 8 amount of how many oil versus gas wells are completed 9 in a year. We do not understand why the TCEQ doesn't 10 get this information from the Railroad Commission to 11 calculate the amount of vented gas or flares due to 12 permitting. 13 The NERC

-- yeah

-- ERG environmental 14 contractor makes good recommendations that these source 15 numbers be included to make this emissions inventory 16 more accurate: One, well completions and blowdowns; 17 two, pneumatic devices; three, fugitive emissions; 18 four, heaters and boilers. 19 The TCEQ needs to get information from 20 the Railroad Commission regarding emissions from 21 on-land drilling rigs and emissions from the drilling 22 process. 23 The 2009 information is available from 24 the Railroad Commission, and this would improve the 25 accuracy of the emissions inventory. Texas has more Integrity Legal Support Solutions www.integrity-texas.com 42

### TCEQ

- Rule Project No. 2013-016-SIP-NR

- 1/16/2014

1 active drilling rigs than any state in the nation, and 2 this should be taken into consideration. 3 The report notes that the contribution 4 of hydraulic fracturing operations to drilling 5 emissions

-- drilling activity emissions is unknown. 6 All the emissions from drilling to 7 completion need to be assessed with the most updated 8 and accurate information to develop the SIP for DFW, 9 Houston, and the sake of other regions teetering on 10 nonattainment. 11 I just want to reiterate that

-- that 12 there is a -- a big concern that information for the 13 2000

-- used for the 2011 emissions inventory is 14 inaccurate and undervalued, as the widespread 15 development of oil and gas has

-- has continued. 16 And using a 2008 base year is obsolete 17 and inadequate for developing a 2011 emissions 18 inventory, because you're using using air data 19 that's at least six years old, not three years old. 20 And there's so much more, I'm sure, 21 you'll enjoy reading. It's a 14-page letter from the 22 Sierra Club, and I present that to you. Thank you. 23 Oh, by the way, I have asthma myself, 24 and so I really care deeply about this personally. 2 5 Thank you. Integrity Legal Support Solutions www.integrity-texas.com 43

### TCEQ

- Rule Project No. 2013-016-SIP-NR

- 1/16/2014

1 

### MS. CASTILLO: Thank you. Is there 2 anyone else that would like to present their comments 3 at this time? 4 (No response) 5 

### MS. CASTILLO: We're going to wait just 6 a moment to see if there's anyone else joining us. 7 

### MS. CHATHAM: I would like to make a 8 comment. My friend

-- 9 

### MS. CASTILLO: Would you like to come 10 up to make a -- or 11 MS. CHATHAM: I think I can be heard 12 from here. 13 My friend on the front row, with her 14 oxygen bottle, has never smoked a cigarette in her 15 life. She is a victim of environmental COPD. 16 And if you think that she

-- what you 17 see today-- this is one of the most highly committed, 18 constructive women we have in this city, and her 19 limitations have escalated after the oil patch came 20 into Arlington and the compression station opened past 21 her house. 22 Literally, the failure of this agency 23 and others to enforce the Clean Air Act is murdering my 24 friend. That's how important your job is. 25 MS. CASTILLO: Anyone else that would Integrity Legal Support Solutions www.integrity-texas.com 44

### TCEQ

- Rule Project No. 2013-016-SIP-NR

- 1/16/2014

1 like to present any comments at this time? 2 (Conversation ln audience) 3 

### MS. CASTILLO: If you want to present 4 comment, you're welcome to. 5 

### MS. LEVINE: Okay. Should I use the 6 mic? 7 

### MS. CASTILLO: Yes. Yes, come up and 8 present

-- I don't have your name, so if you could 9 state your full name and who you're affiliated with, 10 please. 11 MS. LEVINE: I'm Lorraine Levine. I 

### 12 live in Arlington, and I just favor strong protection 13 for keeping our air clean. Thank you. 14 UNIDENTIFIED SPEAKER: That was worth 15 the drive, wasn't it? 16 MS. CASTILLO: Thank you. Is there 17 anyone else that would like to present comments at 18 this time? 19 (No response) 20 MS. CASTILLO: Okay. And, once again, 21 the Commission will continue to accept written 22 comments on this proposal until January 27, 2014. 23 All comments should reference the EI SIP 24 revision for the 2008 Eight-Hour Ozone Standard and 25 Project Number 2013-016-SIP-NR. Copies of the proposed Integrity Legal Support Solutions www.integrity-texas.com 45

### TCEQ

- Rule Project No. 2013-016-SIP-NR

- 1/16/2014

1 SIP revision and appendices can be obtained on the 2 commissioner's Web site. 3 Please feel free to pick up the handout 4 that's --with the list of Web addresses from the 5 registration table. The handout also includes 6 instructions on how to register to receive e-mail 7 

### updates on issues related to development of the SIP. 

### 8 We appreciate your comments, and we 9 thank you for coming. If there

-- if there are no 10 further comments, this hearing is now closed. 11 you. 12 (Hearing concluded) 13 14 15 16 17 18 19 20 21 22 23 24 25 Integrity Legal Support Solutions www.integrity-texas.com Thank 46

### TCEQ

- Rule Project No. 2013-016-SIP-NR

- 1/16/2014

1 C E R T I F I C A T E 2 STATE OF TEXAS 3 COUNTY OF TARRANT 4 

### I, Alicia Roberson, a Certified Shorthand 5 Reporter in and for the State of Texas, do hereby 6 certify that the above-mentioned matter occurred as 7 hereinbefore set out. 8 I FURTHER CERTIFY THAT the proceedings of 9 such were reported by me or under my supervision, 10 later reduced to typewritten form under my supervision 11 and control and that the foregoing pages are a full, 12 true and correct transcription, to the best of my 13 hearing ability. 14 15 16 17 18 19 20 21 22 23 24 25 hand and IN WITNESS WHEREOF, I have hereunto set my seal this 31st day of January, 2014.

Alicia Roberson, CSR Texas CSR 5855 Expiration: 12/31/15 Firm Registration No. 528 INTEGRITY LEGAL SUPPORT SOLUTIONS 3100 Slaughter Lane, Suite A-101 Austin, Texas 78748 512.320.8690

Integrity Legal Support Solutions www.integrity-texas.com 47

# Texas Commission 

# on Environmental Quality Public Hearing Registration

Rule ProjectNo.: 2013-016-SIP-NR Date: January 16,2014 

### Time: 2:00p.m.



### ShortTitle: EI SIP Revision for the 2008 Eight-Hour Ozone Standardfor the HGB and DFW Areas 

### Location: Arlington City Hall, 101 W. Abram Street, Arlington, Texas 76010 

### - 1 -

Concerning: Emissions Inventory 

### (EI) State Implementation Plan (SIP) Revision for the 2008 Eight-Hour Ozone National Ambient Air Quality Standard (NAAQS) for the Houston-Galveston-Brazoria (HGB) and Dallas-FortWorth (DFW) Areas Name (Please Print) Representing



### J

--

### -~ 

# f·.f? ( 

# . . ( Presenting Oral Testimony? (Circle One)

## ~No

# ~No 

# /l C:VNo

# ~' 

# 0DNo

### - 2- 

# Texas Commission 

# on Environmental Quality Public Hearing Registration Date: January 16,2014 

### Time: 2:00p.m. 

### Rule Project No.: 

### 2013-016-SIP-NR ShortTitle: 

### EI SIP Revision for the 2008 Eight-Hour Ozone Standard for the HGB and DFW

### Areas Location: 

### Arlington City Hall, 101 W. Abram Street, Arlington, Texas 76010 Concerning: 

### Emissions Inventory (EI) State Implementation Plan (SIP) Revision for the 2008 Eight-Hour Ozone National Ambient Air Quality Standard (NAAQS) for the Houston-Galveston-Brazoria (HGB) and Dallas-FortWorth (DFW) Areas Name Representing Presenting Oral Testimony? (Please Print) (Circle One)

-- 

# hrn' [ '' 

# Rnok :s; <.f' /'I/ /A 

# L_liA_ 0**~No** 

# {**~l:~<9** 4AaLc6' iJC-r-/"_ocn

.**Yes~** <;,._.)

# (3~ ;( t)VuOfi-N--- X**@L~{V ~** **d~r**

## e(**o~.___&r.l-/J-4** ' d Yes 

### No

Yes 

### No

Yes 

### No

Yes 

### No

Yes 

### No

# EVALUATION

# 0 Texas Commission on Environmental Quality Interoffice Memorandum To: Commissioners 

### Date: June 13, 2014 

### Thru: Bridget C. Bohac, Chief Clerk Richard A. 

### Hyde, P.E., Executive Director 

### From: 

# c:f Steve Hagle, P.E., Deputy Director 

# y**~Office** 

### ofAir 

### Docket No.: 2013-1682-SIP 

### Subject: Commission Approval for Adoption ofthe Emissions Inventory (EI) State Implementation Plan (SIP) Revision for the 2008 Eight-Hour Ozone National Ambient Air Quality Standard (NAAQS) for the HoustonGalveston-Brazoria (HGB) and Dallas-Fort Worth (DFW) Areas Non-rule Project No. 2013-016-SIP-NR 

### Background andreason(s) for the SIP revision: The Federal Clean Air Act (FCAA) requires states to submit EI information for all relevant sources for each area designated nonattainment for a NAAQS. On March 12, 2008, the United States Environmental Protection Agency (EPA) lowered the eight-hour ozone NAAQS from o.o8 parts per million (ppm) to 0.075 ppm. Under the 0.075 ppm (75 parts perbillion) standard, the EPA designated the HGB area, which includes Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties, nonattainment with a marginal classification and the DFW area, which includes Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, Tarrant, and Wise Counties, nonattainment with a moderate classification, effective July 20, 2012. According to FCAA, §172(c)(3) and §182(a)(1), states are required to submit "a comprehensive, accurate, current inventory ofactual emissions from all sources," within two years ofthe effective date ofnonattainment designations for the ozone NAAQS. Through the EPA's 

### Implementation of the 2008

### NAAQSfor Ozone: State Implementation Plan Requirements; ProposedRule (proposed 2008 ozone standard SIP requirements rule), the EPA interprets these FCAA requirements to be due within two years ofthe July 20, 2012 effective date ofdesignations for the 2008 eight-hour ozone NAAQS, which wouldbe July 20, 2014 (78 FR 34178). 

### Scope ofthe SIP revision: A.) Summaryofwhatthe SIP revision will do: This SIP revision satisfies the FCAA, §172 and §182 EI requirements for the HGB and DFW nonattainment areas under the 2008 eight-hour ozone NAAQS. As 

### reinforced bythe proposed 2008 ozone standard SIP requirements rule, the ozone nonattainment area base year EI submission is due no later than July 20, 2014 and then every three years thereafter (2017, 2020, etc.). The EPA's proposed 2008 ozone standard SIP requirements rule recommends states use 2011 as the base year to fulfill the EI requirements. The year 2011 is also a year for a required EI submission under the existingAir Emissions Reporting

### Commissioners Page2 June 13, 2014 Re: Docket No. 2013-1682-SIP Requirements (AERR) Rule. The 2011 AERR EI has been developed for manypollutants including ozone precursors, volatile organic compounds (VOC) and nitrogen oxides (NOx), from point, area, on-road mobile, and non-road mobile emissions source categories. B.) Scope required

### byfederal regulations or state statutes: The FCAA requires that Eisbeprepared for nonattainment areas generally, andprovides for specific requirements that apply in ozone nonattainment areas. Because ozone is photochemicallyproduced in the atmosphere whenVOC mix with NOx in the presence of sunlight, theTexas Commission on Environmental Quality (TCEQ) must compile information onthe important sources ofthese precursor pollutants. The EI identifies the source types present in an area, the amount ofeach pollutant emitted, andthe types of processes and control devices employed at each plant or source category. The Eis provide datafor a variety ofair qualityplanning tasks including establishingbaseline emission levels, calculating federally required emission reduction targets, emission inputs into air quality simulation models, andtracking emissions over time. The total inventory of emissions ofVOC andNOx for an area is summarizedfrom the estimates developed for four general categories ofemissions sources: point, area, on-road mobile, and non-road mobile. In accordance with the EPA's AERR, the National Emissions Inventory (NEI) is a comprehensive and detailed estimate ofair emissions ofboth criteria andhazardous air pollutantsfrom all air emissions. As 

### directedbythe AERR, the NEI includes statewide coverage, including specific emissions data for the eight-hour ozone nonattainment areas inTexas. Annual and summer day emissions are reported on a three-year cycle for the AERR. C.) Additional staffrecommendationsthat are notrequired

### byfederal rule or state statute: None Statutory authority: The EI SIP revision is adoptedunderTexas Health and Safety Code, §382.002, Policy and Purpose; §382.011, General Powers and Duties; §382.012, StateAir Control Plan; and §382.014, Emission Inventory. The EI SIP revision is also adopted underthe commission's general authority underTexas Water Code, §5.102, General Powers and §5.105, General Policy. Effect onthe: A.) Regulated community: Therewill be no new effect onthe regulated community. Regulated entities are already required to submit EI informationto the TCEQ, which is used to develop EI data in accordance with federal requirements. 

# 0

### Commissioners Page3 June 13, 2014

• Re: Docket No. 2013-1682-SIP



### B.) Public: This SIP revision will have no new effect on the public. 

### C.) Agencyprograms: This SIP revision will have no new effect on agency programs. 

### Stakeholder meetings: No stakeholder meetings were held because there are no new rules proposed with this SIP reVIsiOn. 

### Public comment: The commission held publichearings on the proposed SIP revision in Houston onJanuary 14, 2014 and inArlington on January 16, 2014. Notice ofpublic hearing was published in the 

### Texas Register and the

### AustinAmerican-Statesman, Fort Worth Star-Telegram and 

### Houston Chronicle newspapers. Oral comments were received at the Houston hearing from the Houston Regional Group of the Sierra Club (Sierra Club). Oral comments were received at theArlington hearing from DFW Regional Concerned Citizens, Downwinders at Risk (Downwinders), the Lone Star Chapter ofSierra Club (Sierra Club), Public Citizen, and five citizens. The TCEQ received written comments from DFW Regional Concerned Citizens, the Sierra Club, andtwo citizens. A summary ofthe comments andthe TCEQ response is provided as part ofthis SIP revision in the Response to Comments. Generally, the comments concerned the development ofthe EI and questioned the accuracy ofthe EI data. The comments also focused on nonattainment designations and recommended that the EI SIP revision include the attainment areas that potentially may contribute to the air quality ofthe nonattainment areas. There were also numerous comments concerning adverse health effects from oil and gas emissions and recommendations that the TCEQ implement additional monitoring operations and regulations regarding the oil and gas industry. 

### Significant changes from proposal: As 

### discussed in the proposal, the point source inventory data would be revised andwere extracted again onApril1, 2014 in order to assure that the most up-to-date emissions were available for the adoption ofthis SIP revision. Site-level 2011 NOx andVOC emissions data were summarized and provided in a newAppendix K: 

### PointSource HGB andDFWSite LevelEmissions. This second extract accounts for revisions submitted on orbefore March 31, 2014 that have been reviewed, approved, and entered into the State ofTexas Air Reporting System (STARS).

### Commissioners Page4 June13,2014 Re: Docket No. 2013-1682-SIP

In response to comments received, the 2011 inventorywas improvedbyupdating the projected 2011 drilling activity data from the studyDevelopment Of Texas Statewide Drilling RigsEmission Inventories For The Years 1990,1993, 1996,And1999 Through 2040

### with actual 2011 drilling activity data obtainedfrom the Railroad Commission of Texas (RRC). The TCEQ recently reviewed the number ofactive oil and gas wells used to develop the 2011 inventory and made an adjustmentto the emissions estimatesbased on this review. Originally, theTCEQ used the total number ofactive oil and gas wells as ofthe end of2011 with the assumption that all ofthewells were active for the entire year. For the revised emissions estimates, wells completed in 2011 were assumed tobe active on average for halftheyear instead ofthe entire year. In addition, emissions estimates from gasoline bulkterminals and gas plants were revised based on the recently completedAugust 2013 ERG study, Emission Inventory of Bulk Gasoline Terminals andBulk Gasoline Plants. 

### Emissions estimates from oil and gas well heaters were revised based on theAugust 2013 ERG study, Upstream Oil and Gas Heaters andBoilers. 

### Based on these adjustments, the emissions in Table 2-3: HGB 2011 NOx and VOC Emissions forAreaSources 

### and Table 2-4: DFW2011 NOx and VOCEmissions forArea Sources 

### ofthe EI SIP revision havebeen updated. Forthe HGB area, the 2011 annual NOx emissions estimate for area sources decreased from 8,617.31 tons peryear (tpy) to 8,577.07 tpy, and the VOC emissions estimate decreased from 107,305-48 tpyto 104,943.91 tpy. For the DFW area, the 2011 annual NOx emissions estimatefor area sources decreased from 16,639.03 tpyto 15,175.20 tpy, and theVOC emissions estimate decreased from 97,314.07 tpyto 96,604.76 tpy. The drilling rig emissions estimates in Table 2-5: HGB 2011 NOx and VOCEmissions forNon-road Categories 

### and Table 2-6: DFW2011 NOx and VOC Emissions forNon-road Categories 

### ofthe EI SIP revision were updatedusing the 2011 drilling activity data obtainedfrom the RRC. Forthe HGB area, the annual NOx emissions estimate for the non-road category decreased from 42,020.62 tpyto 41,946.29 tpy, and the VOC emissions estimate decreased from 18,822.77tpyto 18,820.83 tpy. For the DFW area, the annual NOx emissions estimate for the non-road categoryincreased from 37,539.51 tpy to 39,272.29 tpy, andtheVOC emissions estimate increased from 16,914.67 tpyto 16,998·73 tpy. Potential controversial concerns andlegislativeinterest: None Doesthis SIPrevision affect any currentpolicies orrequire development of newpolicies? No 

### What are the consequencesifthis SIP revision does not go forward? Are there alternativesto SIPrevision? The commission could choose not to comply with requirements to develop and submit this EI SIP revision to the EPA. If

### the EI SIP revision is not submitted within two years ofthe July 20, 2012 effective date ofdesignations for the 2008 eight-hour ozone NAAQS

### Commissioners Pages June 13, 2014 

# 0 Re: Docket No. 2013-1682-SIP



# - deadline as specified in the FCAA, the FCAA requires the EPA to impose sanctions on the state and promulgate a federal implementation plan (FIP). Sanctions could include transportation funding restrictions, grant withholding, and increased emissions offsets requirements for new construction and major modification ofstationary sources inthe HGB and DFW ozone nonattainment areas. The EPA would be required to impose such sanctions and implement a FIP until a SIP revision is approved for the area. Additionally, failure to submit the required EI wouldjeopardize approval offuture nonattainment plans for the HGB and DFW ozone nonattainment areas, which mustbebased on approved Eis. The EPA's proposed 2008 ozone standard SIP requirements rule states that EI and reasonably available control technology SIP revisions are due byJuly 20, 

### 2014. Other major SIP elements, including the attainment demonstration, reasonable further progress, and reasonably available control measures are due one year later. Alternatively, states could submit all elements together 30 months after designations byJanuary 2015. However, the January 2015 deadline would not allow sufficient time to complete all SIP required elements. Keypoints in the adoption SIP revision schedule: AnticipatedAdoption Date: 

### July 2, 2014 EPA Due Date: 

### July 20, 2014 Agency contacts: 

### Brian Foster, SIP Project Manager, (512) 239-1930, Air Quality Division Terry Salem, StaffAttorney, (512) 239-0469, Environmental Law Division Attachments



### cc: ChiefClerk, 2 copies Executive Director's Office Marshall Coover Tucker Royall John Bentley Office ofGeneral Counsel Brian Foster

# • RESPONSE TO COMMENTS RECEIVED REGARDING THE EMISSIONS INVENTORY (EI) STATE IMPLEMENTATION PLAN (SIP) REVISION FORTHE 2008 EIGHT-HOUR OZONE NATIONALAMBIENTAIR QUALITY STANDARD (NAAQS) FORTHE HOUSTONGALVESTON-BRAZORIA (HGB) AND DALLAS-FORT WORTH (DFW) AREAS The Texas Commission on Environmental Quality (TCEQ or commission) offered public hearings for this SIP revision on January 14, 2014 at 2:00p.m. in Houston atthe Houston-Galveston Area Council ofGovernments and on January 16, 2014 at 2:00p.m. in Arlington at the Arlington City Hall Building. Oral comments were received atthe Houston hearingfrom the Houston Regional Group ofthe Sierra Club (Sierra Club). Oral comments were received at theArlington hearing from DFW Regional Concerned Citizens, Downwinders at Risk (Downwinders), the Lone Star Chapter ofSierra Club (Sierra Club), Public Citizen, and five citizens. The commentperiod opened December 13, 2013 and closed January 27, 2014. The TCEQ received written comments from DFW Regional Concerned Citizens, the Sierra Club, and two citizens. TABLE OF CONTENTS Table ofContents

...... "

................................................................................................................................ 1 General Comments

..................................................................................................................................... 1

Air Quality Concerns

.............................................................................................................................. 1 Air Permitting

......................................................................................................................................... 6 EI Accuracy

.............................................................................................................................................. 7 Health Effects

.......................................................................................................................................... 9 Upstream Oil and Gas Industry and EI Trends

................................................................................ 10 Point Sources

............................................................................................................................................ 13 Flares

...................................................................................................................................................... 14 Greenhouse Gases

................................................................................................................................ 15 Area Sources

.............................................................................................................................................. 15 Non-road Sources

..................................................................................................................................... 27 On-road Sources

....................................................................................................................................... 33 GENERAL COMMENTS Air Quality Concerns Downwinders commented that the TCEQ relies on people buying new cars during the worst economic recession toreduce ozone levels. Downwinders linkedthe inaccurate EI to causing negative effects to the results and eventual failure ofthe DFW 1997 Eight-Hour Ozone Attainment Demonstration (AD) SIP revision. Downwinders also commentedthatthe ozone design value has increased due to the Barnett Shale oil and gas growth.

Page 1 of 34Downwinders, Public Citizen, andthe Sierra Club commented that emissions from large sources outside the DFW nonattainment areas contribute to the area's nonattainment. Public Citizen recommendedthe state develop an EI SIP to include counties with large coal-fired power plants that contribute to the DFW air quality. DFW Regional Concerned Citizens statedthatthe cumulative emissions from areas outsidethe Dl<W 2008 eight-hour ozone nonattainment area, weather, andtraffic patterns should all be includedin this EI SIP revision, andthat emissions from one area should notbe allowed to influence the air quality ofanother area. Thepurpose ofthis EI SIP revision is to satisfythe Federal CleanAirAct (FCAA), §172 and §182 EI requirements for the HGB andDFWnonattainment areas under the 2008 eight-hour ozone NAAQS. Accordingto FCAA, §172(c)(3) and §182(a)(1),**state~** are requiredto submit a comprehensive, accurate, and current EI for nonattainment areas within two years ofthe effective date ofnonattainment designations for the ozone NAAQS. This SIP revision is intendedto meetthose requirements andis notintendedto demonstrate attainment ofthe 2008 ozone NAAQS. This SIP revision includes emissions from the 10-countyDFW andthe eight-countyHGB 2008 eight-hour ozone nonattainment areas only, as requiredby the FCAA and United States Environmental Protection Agency (EPA) guidance. TheTCEQ is currentlydeveloping an AD SIP revision for the DFW 2008 eight-hour ozone nonattainment area. Separate Eis havebeen developed for the 2006 base case modeling, and 2018 future case inventories for the 2018 future case attainment demonstration modeling. In developingtheAD SIP revision modeling emissions, theTCEQ is usingthe most currentEI data and growth assumptions for aU categories, including oil andgas. Comments applicable to the AD inventories, ozone modeling, and control strategies shouldbe made duringthe public comment periodfor theAD SIP revision. Comments concerning classification andAD results are outsidethe scope ofthis EI SIP revision. No changeswere made as a result of these comments. Sierra Club commentedthatthe classifications for DFW and HGB 2008 eight-hour ozone nonattainment areas are incorrect. Sierra Club also statedthatthe Beaumont-PortArthur, TylerLongview and SanAntonio metropolitan areas have all violated the existing 75 parts perbillion (ppb) standard and shouldbe designated nonattainment underthe 2008 eight-hour ozone standard. Public Citizen commentedthat counties with coal or gas and drilling activities should be addedto ozone nonattainment areas. Public Citizen, Sierra Club, and one individual suggested thatthe TCEQ shouldhave included EI data from ozone attainment areas inthis SIP revision. Sierra Club, DFW Regional Concerned Citizens, andtwo individuals commented thattheTCEQ has never over-controlledbecause areas have been out ofattainmentfor a long period oftime andthe ozone standard has neverbeen attained. Downwinders commented thattheTCEQ is not interestedin reducing air pollution for the public. One individual favored strong protection for keeping the air clean. Thepurpose ofthis SIP revision is to fulfill the FCAA, §172 and §182 EI requirements for the HGB andDFWnonattainment areas underthe 2008 eighthour ozone standard. The FCAArequires states to submit EI informationfor all relevant sources within each area designatedbythe EPA as nonattainmentfor a Page 2 of 34**~'** 

### I

# 0 NAAQS, so no EI data was includedfrom attainment areas. Similarly, no change was made to address attainment designation status as such an actionis outside the scope ofthis SIP revision. DFW Regional Concerned Citizens commented thatpolitical pressure should not deter the development ofa comprehensive inventorythatwill be used in granting future permits, and that the TCEQ will notbe overreaching their authorityby enforcing the FCAA. The purpose ofthis SIPrevision is to satisfythe FCAA, §172 and §182 EI requirements for the HGB andDFW 2008 eight-hour ozone nonattainment areas underthe 2008 eight-hour ozone NAAQS. TheTCEQ takes its duties to Texas citizens very seriously andbelieves thatthis SIP revision meets FCAA requirements and guidance includedin the EPA's

### Implementation of

### the 2008

### NAAQSfor Ozone: 

### StateImplementationPlan Requirements;ProposedRule {proposed 2008 ozone standard SIP requirements rule) to submit a comprehensive, accurate, and current EI for ozone nonattainment areas. Comments regardingthepermittingprocess are outsidethe scope ofthis EI SIPrevision. No changes were made as a result ofthese comments. One individual commented thatthat ozone concentrations over 75 ppb averaged 34 days a year from 2012 and 2013 and ozone concentrations over 84 ppb averaged n days a year from 2012 and 2013, which equals 45 days out oftheyear. The individual also commented that that summer air conditions are worsening, as evidenced by an ozone day that occurred in September 2013. Thepurpose ofthis SIP revision is to satisfythe FCAA, §172 and §182 EI requirements for the HGB andDFWnonattainment areas underthe 2008 eighthour ozone NAAQS. While these comments are outside the scope ofthis SIP revision, the TCEQ does not agree thatthe commenter's analysis is the appropriate wayto investigate or compare the airin an area to the standards setbythe EPA. For example, days when eight-hour average ozone is greaterthan or equal to 84ppb would also count as days above 75 ppb. In otherwords, days above 84ppb cannot be totaledwith days above 75 ppb because thatwould resultin the double counting ofdays. Trend analysis ofhigh ozone days is a more effective wayto assess whetherthe qualityofthe air in an areais improving or deteriorating over a longperiod oftime. High ozone dayyearlytrends inthe DFW area show that days with eight-hour ozone greaterthan 75 ppb decreasedby49%, from 2000 (63 days) to 2013 (32 days). Similarly, days with ozone greaterthan 84ppb decreasedby75%, from 2000 (36 days) to 2013 (9 days). Please note datafrom 2013 in this response and following responses is preliminaryand subjectto change. Additionally, another means to examine the air qualityis to considerhow an area's airpollution concentrations compareto the NAAQS. The currentNAAQS for 2008 eight-hour ozone is set at 75 ppb. The design value is usedto compare the airin an areato the NAAQS. For ozone, the design value is calculatedbytaking the threeyear average ofthe fourth-highest eight-hour ozone concentration at each monitor in the area. This calculationremoves theyear-to-yearvariabilityfrom factors such as meteorology andnumber ofmonitors andprovides an effective means for evaluating ozone trends. Although the 2013 design value in the DFW area is above Page 3 of34the NAAQS at 87ppb, ithas decreasedby 15%from 2000, when the design value was 102ppb. Furthermore, thepercentage ofmonitors with valid design values which measured above the NAAQS has decreasedby 20% from 2000through 2013. Also, the ozone forecast season in the DFW arearunsfrom Marchthrough October, andhigh ozone days occurringin September arenotuncommon, andtherefore are not indicative ofworsening ozonepollution. The ozoneforecast seasons do not necessarilycorrespondtothe "ozone seasons" definedfor regulatorypurposesby the EPA. No changeswere made as a result ofthese comments. The Sierra Club commentedthatwhile overall air quality hasimproved, Texas has not attained the ozone standard. One individual statedthatthe DFW area hadbeen designated as an ozone nonattainment areafor manyyears and has notyet attainedthe ozone standard. Public Citizen and one individual commentedthat ozone concentrations have been increasing inthe DFW ozone nonattainment area. The DFWareahas made considerableimprovement in air quality. For example, between 2000 and 2013, the 1997eight-hour ozone design valuehas trended downward 15 ppb from 102ppb to 87ppb. The number ofDFW eight-hour ozone exceedance days has also decreasedfrom 36 to ninefrom 2000 to 2013. TheTCEQ appreciates the acknowledgement ofimproving air quality, but disagrees thatTexas has failed to ever attainthe ozone standard. Despitethe challenges of growingpopulation, theTCEQ's air qualityplanning effortshave resultedin significant air qualityimprovements, including attainmentofthe ozone standardin several areas ofthe state. In 2008, the EPAissued a determinationthatthe DFW four-county one-hour ozonenonattainment areahad attainedthe one-hour NAAQS based onverified 2004through 2006 monitoringdata and supportedby 2007 through 2008 monitoring data. The EPAhas redesignatedthe Beaumont-PortArthur ozonenonattainment areato attainmentfor the 1997 eight-hour ozone standard, andthe areais currently monitoring attainment ofthe 2008 eight-hour ozone standard. The EPAhas redesignatedboth the El Paso County andVictoria Countyone-hour ozone nonattainment areasto attainmentfor both the 1997 and 2008 eight-hour ozone standards. El Paso Countyhas monitored attainment ofthe one-hour ozone standard since 1998, andthe EPAredesignatedVictoria Countyas attainmentof the one-hour ozone standard on May 8, 1995· The HGB areais currently monitoring attainment ofthe one-hour ozone standard. Overall 1997eight-hour ozone design values havebeentrending downward since 2000 for both the DFW andHGB ozone nonattainment areas, andthe statehas seen a 24% decrease in the three-year average ofthe statewide maximumfourth highest eight-hour ozone concentrationsfrom 2000 through 2013. No changes were made as a result ofthese comments. One individual expressed concern about poor air quality in the DFW nonattainment area. DFW Regional Concerned Citizens commentedthatthe TCEQ is not doing itsjob to protect clean air. Public Citizen commentedthat more stringent air quality standards than the EPA has set should Page 4 of34

# 0

..I be applied in orderto improve air quality. Two individuals expressed consideration ofmoving from the DFW area ifair quality does not improve. One individual expressed concern thattheTCEQ does not workin a timely mannerto protect publichealth andthe environment. DFW Regional Concerned Citizens and one individual commented thatthe TCEQ should do more to protectthe environment and not allow itselfto be influencedby politics. TheTCEQ strives to protectthe state's human andnatural resources consistent with sustainable economic development. Thepurpose ofthis SIP revision is to satisfythe FCAA, §172 and §182 EI requirements for the HGB and DFW nonattainment areas underthe 2008 eight-hour ozone NAAQS. The DFW areahas made considerable improvementin air quality. For example, between 2000 through 2013 the eight-hour ozone design value hastrended downward 15 ppb. The number ofdays in DFWwherethe daily eight-hour ozonepeak exceedanced 84ppb has also decreasedfrom 36 to nine overthe sameperiod. The percentage of monitors in the DFW 2008 eight-hour ozone nonattainment area measuring nonattainmenthas decreasedby 20% from 2000 through 2013. No changes were made in response to this comment. DFW Regional Concerned Citizens commented that the public hearing information for this SIP revision was not published adequately for the public's knowledge. Notice ofthepublic hearings for this SIP revision was providedin the same manner as all SIP revision notices, as requiredbystate andfederal law. The noticewas published in the 

### TexasRegister as well as the

### AustinAmerican-Statesman, the 

### Fort Worth Star-Telegram, andthe 

### Houston Chronicle newspapers. The EI SIP revision and appendices were also made available to the publicthrough theTCEQ's SIP Hot TopicsWeb page (http://www.tceq.texas.gov/airqualitv/sip/Hottop.html) andthe TCEQ'sAir Pollution from OzoneWeb page (http://www.tceq.texas.gov/airquality/sip/criteriapollutants/sip-ozone). All interestedpersons can subscribe to receive e-mailwhen new information is updated on SIP revision and SIP-related news items on the SIP HotTopicsWeb page. No changeswere madein response to this comment. One individual recommendedthe TCEQ workv-ith other government agencies, elected officials, andthe regulated communityto create new, clean industries. The TCEQ's authorityin SIP development is limitedto air qualitycontrol. Creating new clean industries isbeyondthe scope ofthis EI SIP revision. No changeswere made in response to this comment. One individual commented that identification and enforcement were needed to ensure companies follow best practices. The TCEQ agrees with this comment andvigorouslypursues compliancewith the applicable environmentalrequirements. The TCEQ also pursues enforcement against anyperson orbusiness that is in non-compliance and whose violations meetthe criteriafor referral to enforcement as laid out in the TCEQ's Enforcement Page 5 of 34Initiation Criteria.Allpenalties assessed are done so in accordance with theTCEQ's PenaltyPolicy. As indicatedpreviously, this EI SIP revision is solelyto address the EI requirements inthe FCAA. No changeswere made in response to this comment. The Sierra Club and Public Citizen commented that thatthe ozone season was not clearly defined. To clarifythe definition of"ozone season"for emissions inventorypurposes, the TCEQ has included additionalinformationin section 2.2.1 ofthe EI SIP. Point source ozone season emissionsarereportedbysites for individualunits in accordance with TCEQ

### EmissionsInventory Guidelines and cannotbe calculatedin aggregatefromthe annual emissions. In the

### EmissionsInventory Guidelines, the EmissionsAssessment Sectionuses the definition ofozone seasonfound in 40 CFR §51.50 as the 153 dayperiodrunningfrom May 1 through September 30. Please note the ozone forecast seasons referencedin earlierresponses to comments do notnecessarilycorrespondto the "ozone seasons" definedfor regulatorypurposesbythe EPA. Ozoneforecast seasons for different areas ofthe state canbe found at:_ https://www.tceq.texas.gov /airquality/monops/ozonefacts.html AirPermitting DFW Regional Concerned Citizens statedthatithadrequested permitted emissions on a part per thousandbasisfrom the TCEQ, buthad notreceived it. The TCEQ authorizes emissions on a mass basis, generallyinpoundsperhour andjor tons peryear (tpy). Typically, authorizations do not contain concentrationbasedlimits, such aspartsperthousand, so this informationwouldnotbe available. Site-specific airpermittinginformation canbeviewed online at https:/ fwebmail.tceq.state.tx.us/gwfwebpub orbycontactingtheAirPermits Division at airperm@tceq.texas.gov. Comments regardingpermits are outside the scope ofthis EI SIP revision. No changeswere made as a result ofthese comments. DFW Regional Concerned Citizens and one individual stated that current permits authorized emissions thathave had an adverse health impact on local citizens. DFW Regional Concerned

. Citizens and one individual further statedthatwhile the community musthavejobs, it also must

remain healthyto actively participate in communitylife. Comments regardingpermits are outside the scope ofthis EI SIPrevision, which is to document emissionswithin the HGB andDFW 2008 eight-hour ozone nonattainment areas. No changes were made as a result ofthese comments. DFW Regional Concerned Citizens and two individuals statedthatthe TCEQ could not adequately assess the impact ofpermitting new sources on DFW air qualitywithout an accurate EI ofall source categories. TheTCEQ agrees that an accurate EI is usefulfor air qualityplanningpurposes. TheTCEQ uses thebest availableinformation atthe time ofinventorydevelopment and continues toperformEI improvementresearch. The EI reflects two decades of Page 6 of 34

# 0 continuous improvement. TheTCEQ has performed state-of-the-science studies to identify and quantifypotentiallyunder-reported emissions sources. These studies result in refined emissions factors, activity data, or emissions determination methods that are incorporated directlyinto the development ofthe appropriate inventory source category. These efforts ensurethebestpossible inventoryis used for control strategy and SIP development. The use ofthe EI for permittingpurposes is outside ofthe scope ofthis EI SIP revision. However, the TCEQ provides the following informationto clarifyhow EI datais usedin permitting. When permitting expansions ofexisting major stationarysources (sites), baseline actual emissions (BAE) are establishedfor sites usinghistorical emissions data. The BAE is comparedto theprojected actual emissions afterthe expansion to determine the impact ofthe proposedproject(s). Point source EI data maynot always be available to establish BAE. Ifpoint source EI data are usedto establish BAE, these data shouldbe the most accurate data available for thattimeperiod since sites are requiredto usethebest available methodto determine emissions, such as continuous emissions monitoring data. Area (nonpoint) andmobile source inventorydata are not typicallyusedin the air permittingprocess, andthe FCAAdoes notrequirethe TCEQ to assess allinventory source categories to issue air permits. For certaintypes ofpermitting actions, an air quality analysis canbe performedthat demonstrates that authorizedemissions from a proposedmajor stationarysourcewill notcontribute to a violation ofthe NAAQS. Background ambient concentration data, which encompasses air emissions from all sources, maybe evaluated duringthis analysis. No changes were made in responseto this comment. EIAccuracy The Sierra Club supports the use ofindustry-reported data to develop the point source EI. TheTCEQ appreciates the support. DFW Regional Concerned Citizens and one individual statedthat the EI needed to be accurate, comprehensive, updated, and publicly available. The individual further statedthatthe TCEQ must work with the EPA to establish a reliable inventory. The Sierra Club and Public Citizen commentedthatthat the TCEQ has failed to develop an accurate inventory for 40 years. The Sierra Club and Public Citizen statedthe current inventoryis too inaccurate to be usedfor SIP development, especiallywhen considering widespread and escalating oil and gas production. Downwinders commentedthat the lack ofaccurate inventory for oil and gas sources prevents the DFW area from attaining the ozone standard. The Sierra Club cited the September 9, 2013 issue ofthe FederalRegister (78 FR 55037), which discussed the TCEQ under-estimating highly reactive volatile organic compound (HRVOC) emissions, and expressed concern that this inventory similarlyunderestimates emissions. Public Citizen statedthatthe TCEQ has implementedinadequate control measures in DFW to ensure the region attains the ozone standard. The Sierra Club commented that the success of

Page 7 of 34future control measures depends upon an accurate EI, and further statedthatinaccurate inventories willjeopardize future control measures and attainment ofthe ozone standard. The TCEQ develops the EIin accordance with EPAreporting requirements and works closelywiththe EPAto ensurethe inventoryis accurate, updated, and comprehensive. The EI reflects two decades ofcontinuous improvement. TheTCEQ has performed state-of-the-science studies to identify and quantifypotentiallyunder-reported emissions sources. These studiesresultin refined emissions factors, activitydata, or emissions determination methods that are incorporated directlyinto the development ofthe appropriateinventorysource category. As one example, a recent studyrefinedupstream oil and gas industry storage tank emissions factors for the state. Moreinformation on these studies canbefound at: http: 

### 1/www.tceq. texas.gov /airquality/airmod/proiect/pj.html. The TCEQ disagreesthattheinventoryis too inaccurate for future SIP and control strategydevelopment. Forthe point sourceEI, industrial sites subjectto the TCEQ's reporting requirements submit emissions datausingthebest available method, such as monitoring ormeasurement data. The TCEQ's reporting requirements for ozone nonattainment areas require sites that emit either 10 tpy of volatile organic compounds (VOC) emissions or 25 tpyofnitrogen oxides (NOx) emissions to submit an annualpoint source EI. Sincethese emissionsthresholds are eitherlowerthan or equivalentto major stationary sourcethresholds, the TCEQ ensures that a detailedinventoryofstationary sources in ozone nonattainment areas is collectedfor ozone photochemical modelingpurposes. As this SIP revision is not intendedto demonstrate attainment, commenting on control strategies is outside the scope ofthis SIPrevision. Area (nonpoint) and mobile source EI estimates are developedusingthebest available data and emissions determination methods or models available atthe time. For example, the area source oil and gas inventoryuses the current production data andwell statistics from the Railroad Commission ofTexas (RRC) to develop specific county-level estimates. As noted above, theTCEQ has invested significantresources in advancing area source inventory developmentmethods. The methods TCEQ uses to develop its area source oil andgas inventoryserve as a model for otheragencies. TheTCEQ disagrees with the statement concerningthe inaccuracyofthe EI due to widespread and escalatingoil and gasproduction. RRC data indicatethat Barnett Shale gas production declinedby approximately 8% from 2012 to 2013 and approximately 6% from 2011 to 2013. Drillingpermits in the Barnett Shale area have experiencedmore significant declines, decreasing approximately 20%from 2012 to 2013, and morethan 77% from 2008, thepeakyear ofissuedpermits. These trends indicate that Barnett Shale oil andgas production has mostlikelypeaked andis now declining. Similarly, RRCproduction datafor the HGB 2008 eight-hour ozone nonattainment areaindicate an overall decline in oil and gas production from 2003 to 2012 (decreases of 11% in oilproduction, 28% in casingheadgas production, 64% in Page8of34

- I• naturalgas production, and 63% in condensateproduction). RRCproduction data for 2013 arepreliminaryatthe drafting ofthis SIPrevision, but overall decreases from 2003 to 2013 are stillreflected, with the exception ofoil production; for which preliminarydata indicate a modest 3%increase from 2003 values. Major stationary (point) sources are the largest emitters ofHRVOC emissions. The TCEQ annuallyupdates andpublishes a regulatoryguidance document, 

### Emissions Inventory Guidelines, to ensure accurate determination ofemissions, including HRVOC emissions, reportedbypoint sources. For several HRVOC emissions sources inthe HGB 2008 eight-hour ozonenonattainment area, Chapter 115. SubchapterH, Divisions 1 through 3, requires monitoring ormeasurement of HRVOC emissions orprocess streams; these data are requiredto be usedto determine and report emissions for the point source EI. For other HRVOC emissions sources, ifmonitoring or measurement data are not available, emissions estimates arebasedupon the mostrecent available acceptedmethod, as notedin the September 9, 2013 issue 

### oftheFederalRegister (78 FR55040). Ifthesebest available emissions determination methods still result in a discrepancybetween the point source EI and ambient monitoring data, the difference willbereconciled usingthe methods such as that commendedbythe EPAin the September 9, 2013 issue ofthe

### FederalRegister (78 FR55040) andused bythe TCEQ in the 2010 HGB attainment demonstration SIP revision. The commission will also continue to workwith all interested stakeholders to improve emissions inventory estimation methods. In the HGB area, applicable sites in Harris County are requiredto participatein an annual HRVOCmarket-based cap andtrade program. Thepurpose ofthis SIPrevision is to establishthe baseline yearinventoryfor the 2008 eight-hour ozone standard, notto demonstrate attainment ofthat standard. The TCEQ uses the best available information atthetime ofinventory development and continues to perform EI improvementresearch. These efforts ensure thebest possible inventoryis usedfor control strategy and SIP development. No changes were made as a result ofthese comments. Health Effects Two individuals commented about the increased sensitivity ofsome members ofthe population to the effects ofozone. DFW Regional Concerned Citizens and one individual expressed concern for children who will develop asthma and other chronic illnesses and another individual commented about the cost ofasthma medication. DFW Regional Concerned Citizens and one individual commented about children notbeing able to enjoy outdoor activities because oftheir respiratory problems. DFW Regional Concerned Citizens and two individuals commentedthat an increase in ozone precursors is causing an increase in asthma and chronic obstructive pulmonary disease. The TCEQ appreciates the comments relatedto health effects ofozone and economicwelfare and is committedto working with area stakeholders to attain the 2008 eight-hour ozone standard, which is a health-based standard. The primary NAAQS are thosethatthe EPA determines are necessaryto protectpublichealth, Page 9 of34including sensitive members ofthepopulation such as children, the elderly, and those withpre-existing conditions. Breathingrelativelyhigh levels ofground-level ozone maycause acute respiratoryproblems like cough and respiratory**irritation~** andmayaggravatethe symptoms ofasthma. Health effects from ozone generally canresolve quickly once an individual is no longer exposedto high levels. The commenters express the concernthat concentrations ofozoneprecursors (and presumably ozone itself) haveincreased, leadingto an increase in asthma and chronicobstructivepulmonarydisease (COPD). Between 2000 and 2013, the 1997 eight-hour ozone designvalue in the DFW areahastrended downward 15 ppb. This reduction in ozone design value has coincidedwith significantreductions in ozone precursor emissions. Between 2005 and 2011 (the mostrecentperiodic emissions inventoryyear available), VOC emissions havebeen reduced 16% across aU source categories (approximately29,000 tons), andNOx emissions havebeen reduced 34% across all source categories (approximately79,000 tons). However, although levels ofboth precursors and ozone have decreased overtime, diagnosis ofasthma continuesto increase (see below). As a result, itis notclear thatthereis a definitelinkbetween ozonelevels and asthmadevelopment. Regarding COPD, the most recent analysisfrom EPAindicates thathospitalizations for respiratory diseases, including COPD, wouldnotbe significantlyaffectedby concentrations ofozone lowerthanthe current NAAQS. Itis importantto emphasize that althoughthe causes ofasthma are notfully understood, there are manyfactors thatinfluencethe development and exacerbation ofasthma. Accordingto theWorldHealth Organization, one ofthe strongestriskfactors for developing asthma is geneticpredisposition. In addition, indoor allergens (dustmites, pet dander, andpresence ofpests such as rodents or cockroaches) togetherwith outdoor allergens (pollen and mold), tobacco smoke, or othertriggers such as cold air, extreme emotions (anger orfear) andphysical exercise can allprovoke symptoms inthose with asthma. The Centers for Disease Control and Prevention estimatesthat asthmaprevalence has increased over recentyears. The reasonfor this increase is unknown, but some scientistshave suggested changes in exposureto microorganisms (hygiene hypothesis) orthe rise in sedentarylifestyle (affectinglunghealth) and obesity (whichresults in inflammation) maybetoblame. For additional information on asthma, please contact the Texas Department ofState Health Services at512-458-7111. No changes weremade as a result ofthese comments. Upstream Oil and Gas Industryand EI Trends One individual commentedthat ozone precursor emissions have been increasing in the DFW ozone nonattainment area. Downwinders statedthat all source categories have reduced air pollution in the DFW area except for the oil and gas industry. The TCEQ disagrees withthese comments. As detailedin the DFWReasonable Further Progress (RFP) SIP Revision for the 1997Eight-Hour Ozone Standard (2010-023-SIP-NR), the overall controlledNOx andVOC EI for the DFW area decreased 19% from 2002 to 2012. WhileVOC emissions didincrease 6% during this timeframe, NOx emissions significantlydeclinedby39% duringthis same Page 10 of 34 ,-,. I I• period. Significantreductions in ozone concentrationshave occurredin the DFW area. Like most ofthe U.S., the DFW area is NOx-limitedwith respect to ozone formation, which means that NOx emission reductions are far more effectivethanVOC emission reductions atlowering ozonelevels. This is particularlytruein areas such as DFW and most ofeastern Texas, which havehigh amounts ofnaturally occurring VOC from biogenic sources. Mostnotably, isoprene is emittedby oaktrees and is highlyreactive in the presence ofNOxfor forming ozone. EachVOC type has a maximumincremental reactivity (MIR) value, which is the highest amount ofozone that canbe formedperunit ofVOCifa sufficient quantity ofNOxis present andthefull reaction is allowedto go to completion (i.e., not haltedbyloss ofsunlight or absence ofNOx). Additionally, the hydroxyl radical (OH) is critical to ozone formation and eachVOCtype has a reaction rate constant (KoH), which is the rate atwhich the reaction occurs. Providedbelowis a table of theseVOC-specificvalues. Natural gas is composedprimarilyofmethane, with the bulk ofthe remainder made up ofethane, propane, andbutane. As shown inthetable, 1 gram ofmethane willyield 0.0144 grams ofozone, but 1 gram ofisoprene willyield 10.61grams of ozone, which is 738 times more ozone createdthan with methane. Furthermore, the reaction rate at which isoprenewill make ozone is over 15,000 times faster than thatfor methane. The MIR and KoH reaction rate values for ethane, propane, and butane also show how much more reactive isoprene and other compounds are at forming ozone. In a hypothetical environmentwithoutvegetation where no otherVOC existed besides methane, ethane, propane, andbutane, thenthese lowerreactive compounds couldhave an increasedrelative effect on ozone formation, but it wouldbe small. Research donebythe University ofCalifornia at Riverside inthis area canbe obtainedfrom the saprco7.xls spreadsheet available at http:/ /www.cert.ucr.edu/**~carter/SAPRC/.**

Page 11 of34Compound MIR KoH Reaction Rate Name (grams 0 3/VOC) Ratio to Methane (cm 3 molec- 1 s- 1 ) Indexed to Isoprene 1,3-Butadiene 12.61 877 6.59E-11 1.5 Propene (Propylene) 11.66 811 2.60E-11 3.8 Isoprene 10.61 738 9.96E-11 1 1-Butene 9.73 676 3.11E-11 3.2 Ethene (Ethylene) 9.00 626 8.15Ec12 12.2

Alpha-Pinene 4.51 313 5.18E-ll 1.9 Beta-Pinene 3.52 245 7.35E-11 1.4 lsopentane 1.45 101 3.60E-12 27.7 n-Pentane 1.31 91 3.84E-12 25.9 lsobutane 1.23 86 2.14E-12 46.6 n-Butane 1.15 80 2.38E-12 41.8 Benzene 0.72 50 1.22E-12 81.4 Propane 0.49 34 1.11E-12 89.4 Ethane 0.28 20 2.54E-13 392.3 Methane 0.0144 1 6.62E-15 15,056.50

The 6% increase in theVOC EI cannotbe attributed entirelyto upstream oil and gas emissions. As detailedinthe DFWRFP SIPrevision andtheDFWAD SIP Revision for the 1997Eight-Hour Ozone Standard (2010-022-SIP-NR), the area source categoryexcluding oil and gas emissions increased overallfrom 2002 (RFP) and 2006 (AD) to 2012. The area source inventoryincludes specific area source categories that are population-dependentandincreasewithpopulation increases. Examples includeresidentialfuel combustion, landfills, andvehicle refueling. The TCEQ has implementedrules to reduce emissionsfrom sourceslocated at upstream oil and gas sites. The EastTexas combustionrule, 30 Texas Administrative Code (TAC) Chapter 117, SubchapterE, Divisions 2 and4, limits NOx emissions from stationarygas-fired reciprocating engines. Upstream oil and gas storagetankemissions in DFW and other areas are controlledby30 TAC Chapter 115, SubchapterB, Division 1. Additionally, newpermitsbyrule or standardpermit applicationprocedures that require notification and a registration are applicable for all oil and gas projects in the Barnett Shale that start construction afterApril1, 2011. Therefore, itis incorrectto statethat all source categories have reduced emissions exceptthe oil and gas category. No changeswere made inresponse to these comments. Downwinders statedthat oil and gas industryVOC emissions were largerthanVOC emissions generatedbymobile sources in the DFW nonattainment area.

Page 12 of 34• The TCEQ disagrees with this comment. Basedupon the most current 2011 EI for the DFW 10-county 2008 eight-hour ozone nonattainment area, oil and gas sources emit approximately 16,928 tpy ofNOx emissions and 26,142 tpy ofVOC emissions, whereas mobile source emissions total more than seven times the amount ofNOx emissions, 123,190 tpy, and nearlytwice the amount ofVOC emissions, 46,403 tpy. No changes were made inresponseto this comment. Downwinders stated that oil and gas emissions were hidden and not easily calculated from the data in this EI SIP revision. The TCEQ reports EI datato the EPAin accordance with the requirements ofthe AirEmissions Reporting Rule (AERR) (40 Code ofFederal Regulations (CFR) Part 51, SubpartA). TheAERR specificallyrequires states to reportpoint, area (nonpoint), and mobile source emissions and/or activity data at specifiedtime intervals. Different portions ofthe oil and gas industry are reportedin these three source categories. The point source EI typically contains gasprocessingplants and some upstream oil and gas sites in nonattainment areas, whereas the area source inventory contains the majorityofupstream oil and gas sites in the state, andthe mobile source inventoryincludes drillingrigs. More detailedinformation about sources and emissions rates includedin each categoryis available upon request from the TCEQ EmissionsAssessment Section. No changes were made in response to this comment. POINT SOURCES The Sierra Club stated that the TCEQ needs to track oil and gas sites that meet point source EI reporting requirements one year but not subsequentyears to avoid inaccurate point source emissions projections. The TCEQ does trackwhich sites reportto the point source EI on an annualbasis. Upstream oil and gas emissionsthat are notreported in the point source EI are accountedfor in the area source EI. Bothpoint and area source emissions projections account for industry activity and/or emissions trends. Therefore, the cumulativepoint source and area source emissions projections for the upstream oil and gas industry are accurate estimates despitethefluctuation inthe population ofupstream oil andgas sitesthat reportto thepoint source EI. No changeswere made in response to this comment. Downwinders asked ifblowdown emissions from compressor engines are in the inventory. Point source annual emissions include emissionsfrom blowdown activities in accordance with the TCEQ's

### EmissionsInventory Guidelines document. One individual commented that hydraulic fracturing produces earthquakes which could potentially generate ozone. Commentsrelatedto hydraulicfracturing causing earthquakes are beyond the scope ofthis SIP revision. However, the TCEQ is aware ofa relativelyrecent study from the University ofVirginiathat indicates thatin laboratory settings, Page 13 of 34earthquakes maydirectlygenerate ozone. Furtherresearch is requiredto determine whetherthis phenomenon actually occurs, i.e., canbe observed and measured, andthe extentto whichthis phenomenon contributes to increases in ground-level ozone. Criteriapollutant (orprecursor) emissions from earthquakes wouldbe classified asbiogenic emissions. The federal AERRno longerrequires statesto develop and submitbiogenic Eis, so these emissions wouldbe outsidethe scope ofthis EI SIP revision. Flares. Based on a 2012 HoustonAdvanced Research Center (HARC) study, Downwinders commented thatflares generate ozone and are not control devices. The Sierra Club commented thatflares do not control emissions atthe presumed 98% destruction andremoval efficiency (DRE) and questionedwhy the EI continuedto assume 98% DRE. The HARC studyreferredto inthe comment (Eduardo P. Olaguer, 

### The Potential Near-Source Ozone

### Impacts of Upstream Oil

### and GasIndustry Emissions, Journal oftheAir andWaste ManagementAssociation, August 2012) concludedthatflares could significantlycontribute to ozone formation. However, theTCEQ does not believe thatthe assumptions made in this studyreflect actual conditions or impacts. The modeledflare, described as receiving natural gas inthe abstract, was modeled as receiving a significant amount ofpropylene (an HRVOCthat can increase ozoneproduction efficiency). No evidence or citationwas presentedto substantiatethe addition ofpropylene to the modeledflare's input stream at a natural gas facility. Basedon TCEQ analyses, the majority ofVOC emissions at upstream oil and natural gas facilities are flash gas emissions, which occurwhen oil or condensednatural gas hydrocarbon liquids are reducedto atmospheric pressure after extraction. Flash gas emissions have been sampledfrom storage tanks located atnatural gas and oil wells at approximately70 sites statewide. None ofthe lab analysesfor these sites reported detectable quantities ofHRVOCs, such as propylene. Similarly, the EPA SPECIATE software's emissions profile for oil and gasproduction activities does not contain these compounds (EPA, 2012). The author's addition ofpropyleneto an oil and gas serviceflare appears highly unrealistic, even for an emissions event. Thepaper does not attribute themodeled ozoneproductionfrom theseflare emissions to the addition ofpropyleneinthe results and/or conclusions. The TCEQ disagrees thatflares are not control devices. Flares arefirst and foremost safetydevices. Flares protect industrial sites andthe adjacent communitiesbysafelyburningwaste gas. Flareshelp to reduce the amount of pollutionreleasedinto the environmentbyburning and destroyingwaste gas instead ofallowingitto vent directlyto the atmosphere. The EPA sets New Source Performance Standards (NSPS) and National Emission Standardsfor HazardousAir Pollutants (NESHAP) for sources. The EPAhas specificallydeterminedthatflares operatingin accordance with the specifications found inthe NSPS (40 CFR 60.18) andthe NESHAPS (40 CFR 63.11) destroyVOC or volatile hazardous airpollutants (HAP) with a destruction efficiencyof98% or Page 14 of34greater (reference:

### Basis andPurposeDocument onSpecifications ForHydrogenFueledFlares, EmissionStandardsDivision, U.S. EnvironmentalProtection Agency, Office of AirRadiation, Office of Air QualityPlanning Standards, Research Triangle Park,North Carolina 27711,p.1,March 1998; available at: http://www.tceq.state.tx.us

### Iassets/public/implementation/air/rules/Flare/Resour ce s.pdf). The TCEQ's 2010 Flare Study, conductedin conjunction withthe University of Texas atAustin, indicatedthat dual-serviceflares (flares inboth emergency and routine service) can achieve 98% or greater DRE, even duringlow flow conditions. However, providingtoo much steam or air assistto theflare can potentially decreaseflare DRE. To ensure thatthe TCEQ's studyresults were readily available to both the regulated community andpublic, the TCEQ partneredwiththe University ofTexas atAustin to create supplementalflare operations training (available free ofcharge at: sfot.ceer.utexas.edu). The primaryobjective ofthis trainingis to enhance operators' understanding ofindustrialflare operations andto providepractical information aboutvariables affectingflare performance. One ofthe major goals ofthe training is to increase operators' understanding of efficientflare operations, whichwill leadto maximizingflare DRE at or above 98% when using existingon-site resources. No changes were made inresponseto these comments. Greenhouse Gases One individual statedthatthe ozone standard mustbe strictto protect the environment from global warming and carbon dioxide (C02) emissions. The FCAA requires the EPAto set NAAQS for widespreadpollutants that are harmful to public health andthe environment, one ofwhich is ozone. The EPAhas notpromulgated a NAAQS for anygreenhouse gas, including C02, andthe reduction ofgreenhouse gas emissions is outsidethe scope ofthis EI SIP revision. No changes were made in response to this comment. AREA SOURCES The Sierra Club notedthattheTCEQ was unable to procure a full year of 2008 active wells for each county and should have a Memorandum ofUnderstanding (MOU) with the RRC to obtain this data. The TCEQ appreciates the needto share databetween agencies and does have an MOU with the RRC to share data. Although Eastern Research Group (ERG) was not able to obtain the total number ofactive wells bycountyfor 2008 for the report 

### Characterization of Oil and GasProduction

### EquipmentandDevelop a Methodology to Estimate Statewide Emissions due to timing ofthe data availability, theTCEQ did obtain this information from the RRC andwas able to adjustthe El appropriately. The TCEQ receives oil and gas data which is usedto estimate emissions from many oil and gas sources. For counts ofactive wells, the Page 15 of34TCEQ typicallyuses well countinformation from thefollowing RRCWeb page (http:/ fwww.rrc.state.tx.usjdatafwellsfwellcountjindex.php) because it offers regularlyupdated datafor active wells bycounty. No changes were made in response to this comment. The Sierra Club and Public Citizen noted thathaving an accurate area source inventoryis of paramount importance andthe 2011 inventory is inaccurate and undervalued given the widespread development ofnatural gas and oil through hydraulic fracturing development throughoutTexas. Public Citizen also commentedthat the methodologyfor area sources for the 2011 EI was inadequate. The Sierra Club also noted that as a result ofan inadequate 2011 inventory, the emission control strategies like the EPA's NSPS for new storagetanks will notbe recognized as a valid control strategy. TheTCEQ agrees with the Sierra Club on the importance ofthe area source EI. The area source inventoryis developedin accordance with an EPA-approvedquality assuranceprojectplan and in accordance with the requirements of40 CFRPart 51, SubpartA, AERR. TheTCEQ expends significantresources to develop an accurate area source inventory. To this end, for the oil and gas sector, improvements made bythe TCEQ includethe development andrefinement ofa state-specific oil and gas emissions calculator. This oil andgas area source emissions calculatoruses countylevelproduction andlocal equipment activity data with local emissions requirements to estimate emissions from individualproduction categories including compressor engines, condensate and oil storagetanks, loading operations, heaters, and dehydrators. A significantimprovement made to the oil and gas emissions calculatorfor the 2011 inventoryisthe development ofrefined emission factors forVOC emissions from condensate storage tanks. The TCEQ disagreesthatthe inventoryistoo inaccuratefor future SIP and control strategydevelopment. Area (nonpoint) andmobile source EI estimates are developedusingthebest available data and emissions determination methods or models available atthetime. For example, the area source oil and gas inventory uses the currentproduction data andwell statisticsfrom the RRC to develop specific county-level estimates. As noted above, theTCEQ has invested significant resources in advancing area source inventorydevelopmentmethods. The methods TCEQ uses to develop its area source oil and gas inventory serves as a modelfor other agencies. As this SIP revision is notintendedto demonstrate attainment, commenting on control strategies is outsidethe scope ofthis EI SIP. No changes weremade inresponseto these comments. Public Citizen statedthat in 2013 there were 304,900 active oil and gas wells inTexas, while the EI SIP revision uses 90,000 gas wells and 150,000 oil wells (or a total of 240,000 wells). Public Citizen indicatedthat the large difference in the number ofoil and gas wells is exponential and is inadequate tobegin to address local air quality problems. Downwinders indicated thatthe number ofwells used in the 2011 EI was not correct, andthat the TCEQ used about 240,000 oil and gas wells, while the RRC had 55,000 or 6o,ooo more oil and gas wells. The Sierra Club also notedthatthe numerous oil and gas wells drilled since 2008 were not included inAppendixA: Characterization of Oil and Gas Production Equipment and Develop aMethodology to Estimate StatewideEmissions. Page 16 of 34The 2011 oil and gas emissions estimates containedinthis SIP revision were developedusingthenumber ofoil and gas wells in 2011. Itwould notbe appropriate to use the number ofoil and gas wells in 2013 to develop the 2011 EI. In addition, it appears thatthe 304,900 active wells referencedbythe two groups include all active wells, including service wells, injection/disposal wells, and storagewells. The TCEQ onlyusedthe number ofactive oil and gas wells to develop the oil and gas EI. The 2011 area source EI was developedusing a total of261,476 oil and gas wells. Information taken on February 14, 2014 from the RRCindicates thatfor 2011, there were 263,402 oil andgas wells. This slight increaseis a difference ofless than 1%. The difference is dueto the RRC updatingthe well counts since the development of the EI. The RRC oilwell information is available at: http://www.rrc.state.tx.us/data/production/oilwellcounts.php andthe gas well information is available at http://www.rrc.state.tx.us/data/production/gaswellcounts.php. The Sierra Club is correctthatthe report does not accountfor drilling since 2008. However, the TCEQ obtained 2011 oil and gas well counts from the RRC andused these counts to develop oil and gas emissions estimates for 2011 including drilling emissions estimates. TheTCEQ recentlyreviewedthe number ofactive oil and gas wells usedto develop the 2011 inventory, andmade an adjustmentto the emissions estimatesbasedon this review. Originally, theTCEQ usedthe total number ofactive oil and gas wells as ofthe end of2011 with the assumption that all ofthe wells were activefor the entireyear. Forthe revised emissions estimates, wells completedin 2011 were assumedtobe active on averagefor halfthe year instead ofthe entire year. In addition, emissions estimatesfrom gasoline bulkterminals and gas plants were revisedbased on a recentlycompletedAugust 2013 Eastern Research Group (ERG) study, 

### EmissionInventory of Bulk Gasoline Terminals andBulk GasolinePlants; emission estimates from oil andgas well heaters were revisedbased on theAugust 2013 ERG study, 

### Upstream Oil and GasHeaters andBoilers; and emissions estimates from compressor engines inthe DFW 2008 eight-hour ozone nonattainment countieswere revisedbased on data obtainedfrom the Barnett Shale Special Inventory Based on these adjustments, the emissions in Table 2-3: 

### HGB 2011

### NOx and VOC Emissions forAreaSources andTable 2-4: 

### DFW2011 

### NOx and VOCEmissions for AreaSources ofthe EI SIPrevision have been updated. Forthe HGB area, the 2011 annualNOx emissions estimate for area sources decreasedfrom 8,617.31 tpyto 8,577.06 tpy, andtheVOC emissions estimate decreasedfrom 107,305.48 tpyto 104,944.04tpy. Forthe DFW area, the 2011 annual NOx emissions estimate for area sources decreasedfrom 16,639.03 tpyto 15,734.52 tpy, andtheVOC emissions estimate decreasedfrom 97,314.07tpyto 96,299.78 tpy. The Sierra Club questionedthe accuracy ofthe 2008 EI and the 2011 EI since the report stated, "Total active wells by countyfor the full 2008 year are not readily available from the RRC ."

Page 17 of 34Although ERGwas not able to obtain thetotal number ofactive wells bycountyfor 2008for the report 

### Characterization of Oiland GasProductionEquipmentand Develop a Methodology to

### Estimate StatewideEmissions due to timing ofthe data availability, theTCEQ did obtaintheinformationfrom the RRC andwas able to adjusttheEI appropriately. The 2008 EI is developedusingthetotal number of active wellsbycountyfor the full 2008 year. The 2011 EI is developedusingthe total number ofactive wells bycountyfor the full 2011 year. No changes were made in response to this comment. One individual statedthatthe assumption thattheboom inthe Barnett Shale has peaked is not accurate, andthus, the emissions are not going to stabilize at 2012 levels. The commenterfurther statedthat as the price ofnatural gas increases there will be more drilling activity in the DFW area. The oil and gas EI is basedprimarily on the actual number ofoil and gas wells and the amount ofTexas oil andgasproduction in 2011. These data are obtainedfrom the RRC. Data on changes in future activitywillbe availablefor usebythe TCEQ to developfuture inventories andto validatepastinventory accuracy. The TCEQ uses the most current data available atthetime ofSIP development. No changes were made inresponse to this comment. The Sierra Club requestedthat the appendices document the area source emissions by category. Downwinders statedthatthe TCEQ does notbreak down emissions from the oil and gas exploration andproduction from the area source portion ofthe EI. The Sierra Club and Downwinders statedthatthere was no way to know how much ofthe 10,535 tons ofVOC listed in Table 2-4for Wise County was from condensate storage tanks. The Sierra Club further stated that one shouldbe able to determine the amount and source ofanyemissions in the EI. TheTCEQ agreesthatthe 2011 emissions associated with oil and gas exploration andproduction are not detailedwithinthe narrative ofthe 2011 EI SIPrevision. The appendices containinformation onmethods usedto develop certain oil and gas categories containedwithinthe 2011 EIbutdo not contain 2011 emissions. The 2011 EI SIP revisionfocuses on aU 2011 ozoneprecursor emission estimates for the DFW and HGB nonattainment areas; notjustoil and gasproduction and exploration emissions. As a result, ozoneprecursors are summarizedbycounty and emissions sector (e.g., point source). Emission estimates ofozone precursors from oil and gas exploration andproduction sources are includedwithin the reportedtons of emissions suppliedin the 2011 EI SIPrevision. Area source oil andgas emissions bysource classification code are available by accessingthe EItitled "2011Area SourceV3" withintheTexasAir Emissions Repositorylocated at http://texaer.tceq.state.tx.us/texaer/index.cfm. Queryingthe 2011 datafor Wise County onthis website shows that 4,031 tons ofthe 10,455tons ofVOCforWise Countywere assignedto condensate storagetanks. No changeswere made in responseto these comments. The Sierra Club and Downwinders commentedthatthe source ofthe compressor engine emissions factors is unclear. Point source emission rates for compressor engines are based on the best available data, including stacktest data, atthe unit level in accordance with the TCEQ's Page 18 of34

# 0 EmissionsInventory Guidelines document. Area source compressor engine emissions estimates for the HGB 200S eight-hour ozone nonattainment counties are based on average emissions rates pertype ofcompressor engine as detailed in the ERG reportfound inAppendixA: 

### Characterization of Oil and GasProduction EquipmentandDevelop a Methodology toEstimate StatewideEmissions. Area source compressor engine emissions estimates for the DFW 200S eight-hour ozone nonattainment counties includingWise County are based on updated engine profile distributions and emissionfactors obtainedfrom the Barnett Shale Phase II Special Inventory. Compressor engine data obtainedfrom the Barnett Shale Phase II Special Inventoryand 2011 point source EI compressor engine emissions datawere usedto validate the dataused in the ERGreport. As a result ofthis analysis, the TCEQ concludes the emission factors developedin the ERG report are thebest available for developingthe 2011 EI SIP revisionfor the HGB area. The Barnett Shale Phase II Special Inventory datawas usedto updatethe engineprofile distributions and emission factors for the DFW 200S eight-hour ozone nonattainment counties. The Sierra Club and Public Citizen commented that the compressor engine emissions in the 2011 EI were not accurate because six-year-old compressor engine data was used to develop the emissions factors. The Sierra Club added that specifics aboutthe type ofengine for 20% ofthe compressor engine population inthe ERG report Characterization of Oil and Gas Production EquipmentandDevelop aMethodology were not known andthatthis negatively impactedthe accuracy ofthe EI. The Sierra Club, Downwinders, and one individual addedthat new compressor engines installed since the ERG report was completed were not being included properly in the 2011 EI. The Sierra Club noted that removing 61 compressor engines from the population ofengines used to develop the emissions factors in the ERG report could also affect the accuracy ofthe EI. One individual urged the TCEQ to update the compressor engine emissions factors using stack test data. This individual further indicated thatthe sources shouldbe tested the way they are actually operated and maintained in orderto correctly accountfor control device efficiencies. Downwinders statedthatthe ERG report to Estimate Statewide Emissions is based on voluntary industrysurveys and not on real world emissions or stacktesting. Compressor engine data obtainedfrom the Barnett Shale Phase II Special Inventory and 2011 point source EI were usedto validate the data usedin the ERG report. As a result ofthis analysis, the TCEQ concludes the emission factors developedin the ERG report are thebest available for developingthe 2011 EI SIP revisionfor the HGB area. The BarnettShale Phase II Special Inventory datawas usedto update the engineprofile distributions and emission factors for the DFW 200S eight-hour ozone nonattainment counties. The ERGreport states, "ERG combined datafrom the two 2007TCEQ engine surveys with the HARC survey data and determinedthe distribution orfraction of compression loadbyengine typefor the most reported engines (comprising So% of the population) for each ofthe three categories used in the HARC report." ERG did knowthe types ofengines for the entire compressor engine data referencedin the report, but usedthe specific compressor engine make andmodel numbers for the top So% ofthe engines reported. Thiswas done to make the number ofspecific Page 19 of 34compressor engine make and model numbers listedin Tables 4-3:

### EmissionFactor Data for TexasAttainment Areas, 4-4: 

### EmissionFactorData for Dallas NonattainmentAreas, and 4-5: 

### EmissionFactorDataforHoustonNonattainment Areas more manageable. Becausethe compressor engine emissions estimates are based on natural gasproduction, as theproduction increases, the number of compressor enginesrequiredincreases and are accountedfor inthe EI. While 61 compressor engineswere removed (57 dueto missing engine characteristicinformation), a population of2,880 compressor engineswas usedto develop the emissions factors. The removal of61 compressor engines amounts to only 2% ofthe total compressor engines. This fraction is not statistically significant andwouldnothave significantlyaffected emission estimates.Where available and applicable, the ERGreport 

### Characterization of Oiland GasProductionEquipment andDevelop a Methodology toEstimate StatewideEmissions used databased on stacktesting. When stacktest data are usedto develop the emissions estimate, the TCEQ requires thatthe stacktest data reflect current operations andprocesses including any control equipment. No changeswere madeinresponseto these comments. The Sierra Club and one individual statedthatthe TCEQ should not apply a 90% reduction to the carbon monoxide andVOC emission factors for compressor engines equipped with non-selective catalytic reduction. They statedthatinstead an 85% reduction should have been applied to be more conservative. While the TCEQ appreciates the comment, the 90% reduction is an accepted industry standardfrom theEPA'sAP-42, 

### Compilation of AirPollutantEmission Factors, Section 3.2, andis applicablefor determining area source compressor engine emissions. No changes were made in response to these comments. The Sierra Club asked whether the 2011 EI included the additional artificial lift engines from the oil wells drilled between 2008 and 2011. Artificiallift engine emissions estimates in the 2011 EI arebased onthenumber of active oilwells in 2011. Statewide, 5,263 additional oilwells were usedto develop the 201.1 EI as comparedto the 2008 EI. The 2011 El does include the emissions estimates from the additional artificial lift engines located atthese additional5,263 oilwells. No changes were made in responseto this comment. The Sierra Club indicatedthattheTCEQ's assumption that 70% ofartificial lift engines are electrically operatedwas not conservative and instead assuming so% ofartificial lift engines are electrically operated would be conservative. Downwinders indicated that assuming that 70% of artificial lift engines are electrified is a severe overestimation, andthatthere are no data or studies to confirmthe 70% estimate. The ERGreport states thatbetween 50% and 90% ofartificial lift engines are electricallyoperated. This information camefrom four companiesthat specialize in artificiallift engines. TheTCEQ usedthe mean ofthis range, 70%, as an estimate for the percentage ofartificial lift engines electricallyoperated. No changeswere made inresponseto these comments. Page 20 of34• The Sierra Club questioned whether the assumption made in the ERG report about no artificial lift engines being manufactured after July 1, 2008 would bevalid for the 2011 EI. The 2011 EI uses updated artificial lift engine emissionfactors taken from a 2011 CentralStatesAir ResourceAgencies (CenSARA) study, andthe EPA's Oil and Gas Emissions Estimation Tool thatis currentlyunder development. These updated factors take into account artificial lift engines manufactured after July 1, 2008. No changes were made in response to this comment. Downwinders indicated that the number ofartificial lift engines in the 2011 EI did notreflect the number ofnew artificial lift engines in use since the ERG report was completed in November 2010. The artificiallift engine emissions estimates in the 2011 EI were developed using the number ofoilwells in 2011 and does includethe number ofnewwells and artificiallift engines atthose wells since the reportwas completed. No changes were made in response to this comment. The Sierra Club statedthat they support theTCEQ conducting additional work and surveys that were recommended in the ERG report for pump-jacks and dehydrators. The TCEQ appreciates the Sierra Club's support. The Sierra Club assumed thatthe information for oil and condensate storage tanks contained in the ERG report inAppendixAhave been supersededbythe newer ERG report in Appendix B: Condensate Tank Oil and GasActivities. For the 2011 EI, condensate storage tankemissions estimates were calculatedusing the updatedfactors from the ERGreportlocatedinAppendix B: 

### Condensate Tank Oiland GasActivities. Oil storage tank emissions estimates are calculated using the factors containedin the original ERGreport containedinAppendixA: 

### Characterization of Oil and GasProductionEquipmentandDevelop a Methodology, becausethe 

### Condensate Tank Oil and GasActivities report did not research oil storage tanks. No changes were made inresponse to this comment. The Sierra Club questioned whether any companies use splash loading for loading and unloading operations, and ifany do, thatthe TCEQ should outlaw its use. The 2011 EI emissions estimates from loading and unloading operations are estimated usingthe dedicatedvaporbalance service emissionfactors from AP-42, 

### Compilation of AirPollutantEmission Factors, Section 5.2. The factors are the same for both submergedloading and splashloading. Regardless ofwhether companies use splash loading or submergedloading, the emissions in the 2011 EI wouldremain unchanged. Rulemakingregardingthe use ofsplash loading is outsidethe scope ofthe EI SIP revision. No changes were made inresponse to this comment. The Sierra Club indicated that information from studies and surveys done afterthe ERG report was developed shouldbe incorporated into the 2011 EI for pneumatic devices. The Sierra Club Page 21 of 34also stated itwas unclear how emissions from some sources wouldbe updated in the future; in particular, that emissions from pneumatic devices were undercounted. The TCEQ continues to workto improvethe EI, but due to the SIPrevision process timing requirements for publichearing and comment, cannot always include recentlyavailable data. Improvementsto emission estimates are subsequently incorporatedintofuture Eis. The datain the report represents thebest datathat was available whenthe 2011 inventorywas developed. Forthe 2011 EI, pneumatic device emissions estimates arebased on updated emissionfactors and activity data (includingthe average number ofpneumatic devices perwell) developedfrom two surveys conductedbythe TCEQ. Thefirst surveywas conductedin 2011 andfocused onthe 23-countyBarnett Shale area. The second surveywas conductedin 2012 and focused onthe remainder ofthe state. In addition, revisedbleedrate information from the EPA's Oil and Gas Emission EstimationToolwas usedinthe development ofthe emission factors usedfor the 2011 inventory. No changes were made in response to these comments. The Sierra Club indicatedthatthe RRC has information aboutthe amount ofgas vented during well completions, andthatthis data shouldbe used inthe 2011 EI. The Sierra Club addedthatthe TCEQ should obtain and use actual blowdown datafrom the RRC in 2011 for the 2011 EI. The Sierra Club addedthatitwas not necessaryfor the TCEQ to estimate the number ofwell completions that are oil wells versus gas wells, becausethat information is available from the RRC. While the RRC does have information aboutthe amount ofgasvented afterwells are putinto production, it does nothave information aboutthe amount ofgas vented duringwell completions. Therefore, the 2011 EI was developedusingthe methodologyfrom the ERGreport. As notedinthe ERGreport, the majority ofwell completions (64% 

### in 2008) are designated as "oil/gas wells"bythe RRC andnot separatelyas onlyoilwells orgas wells. Therefore,because the emissions factors differ, theTCEQ estimatedhow manyofthese "oil/gas well completions"were oilwells andhowmanywere gas wells toprovide a more accurateinventoryusingthe methodindicatedinthe ERG report. No changes were made inresponse to these comments. The Sierra Club was concernedthatthe Eagle Ford Shale was not included in the Central RegionalAir PlanningAssociation (CENRAP) studies on which equipment leakfugitive emissions are based. While the Eagle FordShalewas not separatelydetailedin the CENRAP studies referencedinthe ERGreport, the Eagle FordShaleis part oftheWestern Gulf Basin. TheWestern GulfBasinwas includedinthe CENRAP studies, so equipment leakfugitive emissionsfrom the Eagle Ford Shale were accountedfor in the 2011 EI. No changeswere made inresponse to this comment. Public Citizen questioned ifthe TCEQ should state whetherthere are anyflares used at oil and gas well sites, and those emission sources should be included the SIP revision.

Page 22 of34

# • The 2011 EI does include flare emissions estimates from oil and gas sites inthe point source EI andflare emissions from oil and gas wellhead sites in the area source EI. No changes were made in response to this comment. The Sierra Club, Downwinders, Public Citizen and one individual notedthatAppendix A contains a 2010 reportbased on emissions primarily from 2008 and 2009, and questioned whetherthis report was relevant to the 2011 EI. The Sierra Club, Public Citizen, and one individual also commentedthatthe 2011 EI should bebased on actual 2011 emissions data and not estimates based on old calculations. The Sierra Club, Public Citizen and one individual further questioned whethertheincreased development ofoil and gas sources since 2008 was reflected in the 2011 EI. One individual commented that the total numbers and types ofequipment could be underestimated since parts ofthe ERG report arebased on studies that go backto 2005 andused pre-2005 data. While the report containedinAppendixA was usedto develop the 2008 EI and contained somepre-2005 data, the calculation methodologies and emissions factors containedin the report still remain validfor developing emissions estimates for many sourcetypes. To develop the 2011 EI, the emissionfactors from the reportwere combinedwith 2011 activity datato estimate 2011 emissions. Oil and gas activity datafrom 2008 was not usedto develop the 2011 EI, andthe 2011 oil andgas area source EI was not grown orprojectedfrom the 2008 EI. The 2011 EI for these categories was based on actual oil and gas activity occurringin Texas in 2011. No changes were made inresponseto these comments.

- The Sierra Club questioned why the NOx andVOC emissions for the DFW 2008 eight-hour ozone nonattainment counties listed in Table 5-2: 

### State-wide Emissions Inventory for 2008 

### by County ofthe ERG report were lower than those reported in Chapter 2, 

### Emissions Inventories, of the EI SIP revision. Table 5-2 ofthe ERGreport lists 2008 area source oil and gas emissions, whilethe emissions reportedin Chapter 2 ofthe EI SIP revision are 2011 total area source emissions. NOx emission estimates for 2011 are lower than the 2008 estimates primarily due to the effect of30 TAC Section 117 NOx rules thatrequire NOx controls on many ofthe compressor engines in the DFW nonattainment counties. The compliance date for these rules was after 2008 andbefore 2011. VOC emissions estimates for 2011 are lowerthan the 2008 estimatesprimarilydue to the updated condensate storage tank emission factors developedinthe 2012 ERG study 

### Condensate Tank Oil and GasActivities. No changes were made in response to this comment. Public Citizen questioned the Tarrant County NOx emissions reductions from 3,500 tons in 2008 to less than 1,000 tons in 2011. The decrease in NOx emissions estimates is due almost entirelyto the implementation of30 TAC Chapter 117 emission specifications for compressor engines duringthat period. These extensive specifications required controls on compressor engines largerthan 50 horsepower (hp) in size in Tarrant County, and resultedin a significant decrease in emissions. These requirements went into effect afterthe 2008 EI was developed, andthe compliance deadlinesto meet these Page 23 of 34emissions**spe~ifications** were requiredbeforeJanuary 1, 2011. No changes were made inresponse to this comment. The Sierra Club and one individual questionedthe area sourceVOC emissions inWise County since Table E-2: State-wide EmissionsInventory for 2008 by County inAppendix Alists 24,000 tons ofVOCfrom oil and gas sources in 2008, while the 2011 EI indicates 10,535 tons ofVOC from all area sources. The TCEQ updatedthe emissions factors for several oil and gas sources for the 2011 EI. Inparticular, updated condensate storagetankemissions factors were developedin the 2012 ERG study 

### Condensate Tank Oil and GasActivities. Pneumatic device emissions factors wererevised and activity datawere developed from 2011 and 2012 TCEQ surveys. As a result ofthese improved emissions factors, the oil andgas emissions estimates for the 2011 EIwere significantlylowerthan the emissions estimates for the 2008 EI. No changeswere made in response to these comments. The Sierra Club suggested several revisions to the ERG report included inAppendix A, such as: 1) Indicatingwhetherthere are anyflares used atwell sites on pages 1-1 and 1-2 and Table 1-1: Upstream Oil and Gas Production Source Types; 2) Correcting the name ofthe HARC onpage 4- 1; 3) Updating Table 4-1: Fraction ofWells >1 Year Old to include wells completed in 2011; 4) Listing all ofthe shale zones which are subject to hydraulic fracturing along with their emissions estimates on page 4-2; 5) Defining "minor gap-filing" and explaining howthis alters estimates for air emissions on page 4-4; 6) Statinghowmuch manufacturer's datavary andhow much it alters that databy averaging across all performance data for a specific engine on page 4-5; and 7) Verifying that a 100 hp engineburns an equal amount offuel as two 

### so hp engines on page 4-10. While the TCEQ appreciates the comments, the report included inAppendixA is from a project completedin 2010. Changing a third-partyfinal report after acceptance is not a routinepractice. Therequested changes willbenotedforfuture workefforts, however, no updates willbe madeto the existingreport atthis time, sincethe changeswouldnot impactthe 2011 emissions listedinthe EI SIP. The Sierra Club indicatedthatthe term "green completion method" neededto be defined. The Sierra Club further statedthat sincethe new EPA NSPS requires green completions for new gas wells beginningthis year, it shouldbe listed as a control device for the EI SIP revision. The purpose ofthe EI SIP revision is to submit a comprehensive, accurate, current EIfor nonattainment areas andis notintendedto identifycontrol strategies or demonstrate attainment ofthe 2008 ozone NAAQS. Comments applicableto control strategies shouldbe made duringthepublic commentperiodfor theAD SIP revision. No changes were made a result ofthese comments. The TCEQ agreesthatthe term "green completion method" shouldhavebeen defined. Changing a third-partyfinal report after acceptance is not a routine practice. The requested changes will be notedfor future work efforts andno updateswillbe made to the existingreport atthis time, sincethe changes would not impact the 2011 emissions listed inthe EI SIP.

Page 24 of34

# 0 The Sierra Club agreed with the ERG report recommendations ofincorporating further efforts to better assess emissions from well completions andwell blowdowns, pneumatic devices, fugitive emissions, andheaters andboilers. The TCEQ thanks the Sierra Club for the comment. The Sierra Club indicated thatflares used at oil and gas well production sites shouldbe investigated and questioned whether the TCEQ requires companies to use stacktests to determine ifflare destruction efficiencies are whatthey are purportedtobe. To obtain the most complete EI possible, effortis prioritizedfor surveyworkfor the categories that are expectedto have the most significantimpact onthe EI and on anymodeling or control strategywork. Flare activity at well production sites will be consideredin this prioritization. Atthis time, the TCEQ is unaware ofany practical wayto perform a conventional stacktest on a flare. The 2011 EI is developedwith the assumption thatflares operate with a 98%VOC destruction efficiency as listedin the EPA'sAP-42, 

### Compilation of AirPollutantEmission Factors. No changeswere made in response to this comment. The Sierra Club questioned what made the CENRAP data accurate enoughthat ERG could make a comparison ofthe emissions developed inthe report to the CENRAP emissions as a quality assurance check. Atthe time the ERG studywas done, the CENRAP data includedbasin-specific factors developedfrom surveydatafor Texas. ERG concludedthat comparing emissions developed in their reportto the CENRAP data was appropriate. The TCEQ agrees with this approachbecause atthetime ofthe report, the CENRAP studycontainedthe most recent and relevantinformation available. No changes were made in response to this comment. The Sierra Club notedthatin Appendix Aofthe ERG report, ERG repeats many times throughout the memorandum associated with the work plan for this report thatitwill attempt to obtain data. The Sierra Club noted that an attemptwas not good enough, and thatERG must do more thanjust attemptto obtain data, otherwise public money is wasted. The TCEQ appreciates the comment, but notes that ERGwrote this memorandum before theprojectwas completed. This memo detailedhowtheWork Order effort wouldbe performedfor this project. The main report details what data ERGwas able to obtain and whetherthere were anyproblemswith obtainingthe data. Itis also importantto notethat a contractoris paid accordingto the elements ofthe contract that are completed, andthe level ofeffort expended. Ifa contractoris unableto complete anyportions ofa contract, then the amountpaidto the contractoris adjusted accordingly. No changes were made inresponseto these comments. The Sierra Club indicated that C02 and methane greenhouse gas emissions should be reported from well blowdown events. Estimating greenhousegas emissions is outside the scope ofthe EI SIP revision. No changes were made as a result ofthese comments. Page 25 of 34Oneindividual stated thatblowdown emissions can account for more compressor engine emissions than what comes out ofthe stack, and questioned why these emissions are not included inthe EI. Point source annual emissions include emissionsfrom blowdown activities in accordance withTCEQ's

### EmissionsInventory Guidelines document. Information on compressor engineblowdown emissions was not available to accurately estimate these emissions for the 2011 area source EI. This categoryhas been identified as a potential areafor further researchfor upcomingfiscal years. No changeswere madein responseto this comment. The Sierra Club questionedwhetherinformation from oil tanks was included in the emission factors developed bythe ERG report Condensate Tank Oil and GasActivitiesincluded in Appendix B. The Sierra Club further questioned how emissions from oil tanks were determined. The ERG studyfocused onlyon condensate storage tanks and did notinclude oil storage tank data. Forthe 2011 EI, oil storage tankemissions estimates were developedusingthe factors containedin the ERGreport 

### Characterization of Oil and GasProductionEquipmentandDevelop a Methodology toEstimate StatewideEmissions containedinAppendixA. Thesefactors were basedon stack test data. No changeswere made inresponsetothese comments. The Sierra Club and one individual notedthatthere was a wide range ofemission factors for condensate storage tanks, and mentionedtheWaggoner Crystelle tankfrom Table 2-5: Condensate TankEmissionFactors from the TCEQ 2010 Study from Appendix Binparticular. The individual further stated thatit is difficult to derive an average emission factor when there is such a wide range offactors. The Sierra Club added thatwhere individual source data were available, condensate tank emissions should bebased on those data andtheregional emissions factors should onlybe used where individual source data were not available. The Sierra Club also requested that emissions factors be developed for condensate and oil tanks separately andtheir emissions estimates be reported separately inthe EI. TheTCEQ agreesthat estimating condensatetankemissions is a complexissue. The TCEQ does have separate emissions factors for condensate storage tanks and oil storage tanks. These emissions are reported separatelyin the EI. Theupdated condensatetankemissionfactors developedin this ERGreport and usedfor the 2011 area source EI arebasedon numerous datapoints from a variety ofcondensate storagetanks with a range ofemission factors. Theseupdatedfactors wereusedbecause they are animprovement overtheprevious factors due to the larger data set, production-weighting ofthefactors, andweightingthefactors based on the emissions estimation method, withtest dataweightedmoreheavily than othermethods. The regional emission factors contained inthis ERG report wereusedto develop area source emissions atthe county-levelbecause individual source datafor everyindividual sourcewere not available. No changes were made inresponse tothese comments. The Sierra Club was supportive ofERG and the TCEQ being conservative with the control efficiencies developed bythis study, since theybelieve controls requiredbythe newpermitby rule and NSPS regulations thatwent into effect after 2011. Page 26 of 34

.. IThe TCEQ thanks the Sierra Club for their support. The Sierra Club supported ERG's recommendation thatfuture surveys on oil and gas producers be handled through mandatoryrequirements. The TCEQ appreciates the suggestion andwill consider mandatorysurvey participation as neededfor future research. The Sierra Club requestedthat a consistent definition ofcondensate based onAmerican Petroleum Institute (API) gravitybe developed. For EI purposes, condensate is defined as a liquidhydrocarbon with anAPI gravity greaterthan 40° at 6o°F (and a specific gravityless than 0.8251). The EI defines condensate inthis manner due to the definition ofblackoilfound in the Oil and Natural Gas Production and Natural Gas Transmission and Storage NESHAP, 40 CFRPart 63, Subpart HH. NON-ROAD SOURCES The Sierra Club indicated that emissions reductions from new engine andfuel standards for drilling rigs for 2009 and 2010 inAppendix G: Development of Texas StatewideDrilling Rigs Emissions Inventories for the Years 1990, 1993, 1996, and 1999 through 2040 maybe overly optimistic. Without stating specific reasons whythe Sierra Club believes the reductions maybe overly optimistic, the TCEQ is unable to specifically address the comment. The drillingrig emission factors inthe ERG reportDevelopment of Texas Statewide DrillingRigsEmissionsInventoriesfor the Years 1990,1993,1996, and1999 through2040 were developedusing EPA's NONROAD2oo8a model. TheTCEQ also notes thatthe drilling rig emissions estimates in 2009 and 2010 werelowerthan 2008 due in largepartto the decreased drilling activity duringthose years andnot solelydueto engine andfuel standards. No changes were made in response to this comment. The Sierra Club questioned ifthe drilling emission numbers included the impacts ofhydraulic fracturing. The Sierra Club also indicated thatthe differences in operations from wells that are hydraulically fractured and/or drilled horizontallyversus wells drilled vertically shouldbe taken into account. The Sierra Club further notedthatthe hydraulic fracturing processes merittheir own study. Hydraulicfracturing pump engine emissions are includedin the 2011 EI separately from the drilling rig emissions as an area source and are based on the EPA's Oil and Gas Emissions Estimation Tool. The EPA developedthese emissions usingthe actual number ofhorizontal spuds drilledin eachTexas countyin 2011 combined with activity data and emissionfactors taken from a 2012 CenSARA study. The differences in drilling rig operations (verticalversus horizontal) aretakeninto accountin the 2011 EI. The ERG reportDevelopment of Texas StatewideDrilling RigsEmissionsInventories for the Years 1990, 1993, 1996, and1999 through2040 developedthree different drillingrigprofiles: rigs usedfor vertical wells lessthan Page 27 of 34or equal to 7,000 feet, rigs usedfor verticalwells greaterthan 7000 feet, andrigs usedfor horizontal/directionalwells. Activity datawere developedfor each ofthe three rigprofiles andincludedthenumber ofenginesbyrigtype, engine age, engine horse-power size, engine operationaltime, and averageloadpercentage. Forthe 2011 EI, emissions estimatesfor each ofthe three rigprofiles are calculated separatelyandthen summed andreported as total drillingrig emissions. The TCEQ agrees thathydraulicfracturingprocesses are complex andwill continue to research EI improvements for all source categories, not justoil andgas, as funding allows. No changes were madeinresponse to these comments. The Sierra Club questioned ifthe large reduction in NOx emissions from drilling rigs inTarrant County and similar counties between 2008 and 2011 actually occurred. Thelarge decrease 

### in NOx emissions estimates is dueprimarilyto two factors. First, NOx reductions occurredwiththe introduction oftheTier 3 andTier4 diesel emission standards. TheTier 3 standards were fully implementedbythe endof 2008, andtheTier4 standardsbeganphasing-in startingin 2008 (with a tentative final implementation date of2015). Second, there is a reduced amount ofdrilling activityin 2011 as comparedto 2008. InTarrant Countyfor example, therewere 454 gaswells completed

### in 2011 comparedto 665 gas wells completedin 2008. No changes were made inresponseto this comment. The Sierra Club questioned the assumption inthe reportthatthe number ofthousands offeet of drilling will stay static from 2010 to 2040 when 2011 and 2012 saw increased activity due to the expansion ofthe Eagle Ford Shale and Permian Basins. Based onhistorical drilling activity, there was a significant decrease in drilling activity during 2009 and 2010 state-wide. Future drillingactivitywasthen projectedusingUnited States EnergyInformationAdministrationprojections ofoil andgas productionwhichwas thebestinformation available atthetime ofthe project development. Afterthe initial EI SIPrevision proposal, the TCEQ completed a review of2011 drilling activity datato determine ifthe drilling activity dataprojectedinthe ERG report

### Developmentof Texas StatewideDrillingRigsEmissionsInventories for the Years 1990,1993, 1996, 

### and 1999 

### through2040 alignedwiththe actual2011 drilling activity data. Based onthis review ofthe data, theTCEQ has updatedthe drillingrig emissions estimates in Table 2-5: 

### HGB 2011

### NOx and VOCEmissions for Non-road Categories andTable 2-6:

### DFW2011 

### NOx and VOCEmissions forNonroad Categories ofthis EI SIPrevision usingthe 2011 drilling activity data obtained from the RRC. Forthe HGB area, the annualNOx emissions estimatefor the nonroad categorydecreasedfrom 42,020.62 tpyto 41,946.29 tpy, andtheVOC emissions estimate decreasedfrom 18,822.77tpyto 18,820.83 tpy. Forthe DFW area, the annual NOx emissions estimate for the non-roadcategoryincreasedfrom 37,539.51 tpyto 39,272.29tpy, andtheVOC emissions estimateincreasedfrom 16,914.67tpyto 16,998.73 tpy. The Sierra Club indicatedthat 2009 drilling information is available from the RRC, andthis would improve the accuracy ofthe 2011 EI. Page 28 of 34

# 0 The ERGreport

### Development of Texas StatewideDrillingRigsEmissions Inventoriesfor the Years 1990,1993,1996, and1999 through2040 used 2009. drilling data thatwere obtainedfrom the RRC. The TCEQ used 2011 drilling activity data obtainedfrom the RRC to develop the 2011 EI. No changes were made in response to this comment.

... ..I The Sierra Club indicated that all the emissions from drilling to completion needto be assessed and included in the EI. The 2011 EI does include emissions estimates for drilling rigs, mud degassing, well completions, wellblowdowns, andhydraulicfracturing engines alongwith many other oil and gas related source types. The TCEQ included emissions from all oil and gas activities for which adequate informationwas available at thetimethe EI was developed. No changeswere made in response to this comment. The Sierra Club statedthathorizontal hydraulic fracturing andhorizontal drilling could result in increased NOx andVOC emissions as compared to the more conventional vertical or slant drilling. The TCEQ acknowledges thatthere maybe differences in the amount ofemissions from drillinghorizontalwells as comparedto verticalwells which also includes factors such as the depth ofdrillinginvolved. The TCEQ contractedwith ERGto perform a study on drillingrigs and examinehydraulicfracturing in Texas shale plays. In the ERGreport

### Developmentof Texas StatewideDrillingRigsEmissions Inventories for the Years 1990, 1993, 1996, and1999 through2040, different emissions profiles for horizontal drilling andvertical drilling rigs were identified. Each profile had specific, associated emissions, andhorizontal drilling emissions were larger. In addition, extensive research was conductedusing data from the RRCpermitrecords database to improvewell activity data and a surveywas employedto obtain detailed drilling rig engine data. The results ofthis reportwere incorporatedinto the 2011 EI. The TCEQ usedthehydraulicfracturing default emissions from the EPA's Oil and Gas Emissions Estimation Tool for the 2011 EI. TheTCEQ may consider additional research on this topic in the future. No changes were made inresponseto this comment. The Sierra Club and one individual commented thatAppendix F: Development of 2011 Statewide Taxies andActualAnnualand Ozone Season Weekday EmissionsInventories for Commercial Marine Vessels refers to the EI for locomotives although there is no information about locomotives in the appendix. The locomotive and commercial marine vessel (CMV) EI was developedunder a single project. The contractor, ERG, providedtwo separate reports: one reportfor CVM emissions, which is containedin Appendix F; and one reportfor locomotive emissions, which is found inAppendix H: 

### 2011 TexasRailroadEmissions InventoryReport. No changes were made inresponse to these comments. The Sierra Club supportedthe TCEQ's description ofthe Houston-Galveston, Texas City, and Freeport areas as a "hotspot ofactivity" and suggested that this area should be a "hotspot of emission reductions" in the upcoming andfuture SIP revisions. Page 29 of 34TheHGB area is currentlyclassified as marginal nonattainmentfor the 2008 eighthour ozone standard, andno attainment demonstration or control strategy analysis is requiredforthe areabased on this classificationfrom the EPA. Any potentialfuture control strategieswouldbebasedonphotochemical modeling results and othertechnical analyses usedto determine controls that wouldbethe most effective to attainthe standard atthattime. No changes were made in response to this comment. The Sierra Club and one individual notedthatAppendix F states the 2011 

### Statewide Taxies and ActualAnnualand Ozone Season Weekday EmissionsInventory for CommercialMarine Vessels studywas conducted onAugust 31, 2010 andrequested clarification on this statement. The 2011 

### Statewide Toxics andActualAnnualand Ozone

### Season Weekday EmissionsInventory for CommercialMarine Vessels studywas completed on August 17, 2012 for TeEQ under a contractwith ERG. This reportwas developed based on a variety ofrecent studies and activity datafrom prioryears projectedto 2011. One ofthe studies usedbyERGto supportthe EI developmentwas 

### ImplementPort of Houston's CurrentInventory andHarmonize theRemaining 8- County_ShippingInventory, which was completedbyEnviron International on August 31, 2010. The Sierra Club noted thattheAutomatic Identification System (AIS) data, compiledby contractorERG to quantifytraffic patterns in the GulfofMexico, was notusedto estimate emissionsfor the 2011 CMV EI due to projecttime constraints. The Sierra Club requested an explanation for howthis issue will be corrected with revisions applied to the 2011 CMV EI. As noted onpage 3-6 inAppendixF, "to match individualvesselsto their characteristicsis a verytime consumingprocess andtheprojectbudget and schedule limitedthe use ofAIS datato general spatial allocations ofvesseltraffic." Although theAIS datawas not directlyusedto develop individualvessel emissions due to projectbudget and schedule limitations, these datawere usedfor comparisonpurposes to verifygeneral spatial allocations ofvesseltraffic. The TeEQ notes that El improvementresearch andrelated efforts are ongoing andthe AIS data cited above maybe usedin thefuture for further inventoryrefinement and development. No changes were made in response to these comments. The Sierra Club notedthe TCEQ's use ofEPA-defined Source Classification Codes (SCC) as a means to attribute calculated emissions tothevarious marinevessel types and questioned ifthis resulted in anymissing vessels orvessel activity. These sees areused to accommodate EPAreporting and estimation requirements for grouping ofeMVsunder specific sees and does not resultin anymissing vessels orvessel activities. Formoreinformation referto Table 2-1: 

### Example SCC Assignments by Vessel Types inAppendixF. No changeswere made in response to this comment. The Sierra Club requestedthat the TCEQ further evaluate the EPA's latest guidance for estimating emissions from marine vessels for weaknesses and provide suggestions on how these methodologies canbe correctedfor improved accuracy. Page 30 of 34**I~**

# 0 The TCEQ continues to evaluate the best methodologies for estimating emissions from CMVs. However, evaluation ofthe EPA's methodologies for future inventory workis outside the scope ofthis SIP revision. No changes were made as a result of these comments. The Sierra Club requested clarification on the use ofthe terms "slight" and "consistent" as used in the ERG reportDevelopmentof 2011 Statewide Toxics andActualAnnual and Ozone Season Weekday Emissions Inventories for CommercialMarine Vessels listed in Appendix F to describe monthlyvariation in different marine vessel activityfor 2011. The.analysis was performed onlyto determineifthere were any significant differences in monthlyvariation to warrant additional resources inkeepingthe inventory disaggregated at a monthlylevel. Datausedto assess monthlyvariance were derivedfrom theAIS data, which shows actuallocations ofindividualvessels operating in Texas statewaters atmonthly and annual level maps (these data can be providedupon request). Based on theseAIS data maps ofvessel traffic, there is verylittle difference in marine vessel activityfrom month to month. No changes were made inresponse to this comment. The Sierra Club questioned the accuracy ofthe 2007 Port ofHouston EI which was used as part ofthebasis for the development ofthe 2011 EI for CMV. The 2007 Port ofHouston EI is well documented andrepresents a highly detailed inventorybased on actual operational data ofvessels andland-basedequipment characteristics and activities to the extent such informationwas available. Local activityparameters are usedto extend emission estimates to those portions not directlyinventoried. Actual operational data were obtainedfrom interviews with vessel operators, crew, pilots, andthe United States Coast Guard's (USCG) vessel traffic system, which tracks oceangoing commercial marine vessels from points of origin and destination. No changeswere madein response to this comment. The Sierra Club and one individual questioned the TCEQ's use oflinearprojection to growthe data from the 2007 Port ofHouston inventory for the 2011 CMV EI. Specifically, the Sierra Club noted that using this linear growth did not account for impacts due to the economic recession period of 2007to 2010 andrequested clarification on howthe 2007Port ofHouston inventory activity data were adjusted to 2011 activity levels. The TCEQ continues to workto improve the EI. The datafrom the 2007 Port of Houston inventoryrepresents the best data available when the 2011 inventorywas developed. CMV activity datafrom 2011 was not available for inclusion in the inventorywithin thetimeframe requiredto complete submittal ofthe inventoryto the EPAbyDecember 31, 2012. Therefore, activity data from prioryears was developed andprojectedfor 2011. No changes were made in response to these comments. The Sierra Club and one individual questioned the assumptions andvalidity ofthe load factors used in the EI development ofvessels in port. Quantifying operatingloads while a vessel is in portis one ofthe most challenging aspects ofport EI projects, as notedin the EPA's April2009 guidance, 

### Current Page 31 of 34

### Methodologies inPreparingMobile Source Port-RelatedEmissionInventories. The loadfactor methodologyusedis approvedbythe EPA andrepresents an approximate estimate for overall activityreflectingtypical engineloads during normal equipment operation. No changeswere made inresponse to these comments. The Sierra Club requested verification on ERG's assumptions that navy vessel activities in Texas state waterswere minimal since no active naval bases were located in Texas after 2006 and that most militaryvessel exercises occur in federal waters. Because ofhomeland securityissues, obtainingtimelyinformation 

### on military vessel activitywasnotpossible in theprojecttimeframe. Therefore, ERGmade assumptionsbased onthe data available atthetimefor the development ofthe 2011 EI. Sincetherewere no active navalbases in Texas after 2006, the assumption that navyvessel activitywas minimal is reasonable. No changeswere made in response to this comment. The Sierra Club requested that a statementinAppendix F, indicating that certain Coast Guard craft tend to be used at coastal rescue stations where hours ofoperation maybe relatively small with minimal impact on coastal air quality, beverified. TheTCEQ notes thatthis statementinthe reportis specificto newfleet (65-foot specialpurpose craft, SPC-LE 33) thatthe USCGindicatedithadtaken delivery of (as of2011) when providing datato ERG. The reportnotes that "ERGwas not able to get anyindicationfrom theUSCG onhowmany ofthesevessels were sentto Texas USCG stations. Theseboats tendto be used at coastalrescue stations, so actual hours ofoperation maybe relatively small andtheirimpact on coastal air qualitywillbelimited."ERGused available datato makethese assumptions andthe TCEQ hadno datato indicate otherwise. No changeswere madeinresponse to this comment. The Sierra Club notedthatAppendix F contains an errorwhich incorrectly refers to "San Padre Island." The TCEQ agrees thatthe wording referringto "SanPadre Island"is incorrect and shouldindicate "South Padre Island" inAppendixF. Changing a third-partyfinal report after acceptance is not a routine practice. The requested changes willbe notedforfutureworkefforts, however, no updates willbe madeto the existing report atthis time, sincethe changeswouldnotimpactthe 2011 emissions listedin the EI SIP. The Sierra Club suggested that marine vessel activityin federal waterways shouldbe included in the EI and modeled for the SIP. The EI inthis SIP revision includes an estimate ofthe emissions from marine vessels in state waters. Emissions estimates andmodelingfor the federal waters are outside the scope ofthis SIPrevision. No changes were made inresponseto this comment.

Page 32 of34• The Sierra Club commentedthat there was no indication that the TCEQ used the age ofdredge engines to determine the air emissions. The Sierra Club requested that assumptions related to dredging activity databeverified by contacting dredge companies to obtain more accurate information. The equation usedin calculating dredging emissions does not require a directinput ofthe age ofthe engine. However, dredge engine emissions were estimatedusing applicable EPAemissions factors thattakefleet age into account. Dredging assumptions werebased onthe

### DieselInventory of Marine Vessels Phase II- FinalReportdevelopedpreviouslyfor the TCEQ (see the list ofreferences includedinAppendix F). The TCEQ recognizes thatthe EI improvementprocess is on-going andwilltakethis suggestion under considerationfor future EI developmentresearch. No changes were made in response to these comments. The Sierra Club and one individual noted thatAppendix F indicates an errorinthe departure date listed on Page 3-17 in the calculation example. The TCEQ agrees that the indicated date of"January 11, 2007" is incorrect and Appendix F shouldindicate "January 11, 2011." Changing a third-partyfinal report after acceptance is not a routine practice. The requested changes willbe notedfor future workefforts, however, no updates willbe made to the existingreport atthis time, since the changes wouldnotimpact the 2011 emissions listedin the EI SIP. ON-ROAD SOURCES One individual commentedthatthe emissions results for trucks transporting waste waterfrom oil production wells, as represented in the reportDevelopment of Oil and Gas Mobile Source Inventory in the BarnettShale in the 12-County Dallas-Fort WorthArea, FinalReport,August 2012, North Central Texas Council of Governments, are a concern because most ofthe emissions produced bythe trucks are due to long-term idling that could easilybe mitigated ifcontrols were implemented and enforced. The TCEQ appreciates the commenter's interestin reducing emissions due to longterm truckidling; however, as discussedpreviously, this SIP revision is not intendedto demonstrate attainment ofthe 2008 eight-hour ozone standard or include additional control strategy analysis. Comments regarding control strategies in the DFW area shouldbe made duringthe public commentperiodfor the DFW AD SIPrevision, which is currently scheduledto beginin December 2014. This comment is beyondthe scope ofthis SIP revision. No changes were made as a result ofthis comment. One individual thought the 2018 extrapolated vehicle miles traveled (VMT) in the report Developmentof Oil and Gas Mobile Source Inventory in the BarnettShale in the 12-County Dallas-Fort WorthArea, FinalReport,August2012, North Central Texas Council of Governments for trucks transporting waste water from oil production wells during production phase was too low based upon VMT presented in the report for 2006 and 2012. TheVMTvalues for inventories that willbe usedin a SIP are developed using standardized methodologies approvedbythe EPA. TheVMT values usedin the EI Page 33 of 34SIP revision arebaseduponthe DFW andHGB travel demand models that are calibratedusing actual ground counts and are adjusted as neededtobe consistent withVMT estimates baseduponthe HighwayPerformanceMonitoring System (HPMS). The HPMS is anotherVMT estimation system thatis also calibratedto actual groundcounts. The DFW and HGB travel demandmodels are subjectedto extensivereviewprocesses in orderto be validatedfor use inVMT development of a SIP revision. TheVMTusedin this EI SIPrevision are documentedinAppendices I andJ. The emissions andVMTvalues documentedin the report

### Developmentof Oiland GasMobile Source

### Inventory in 

### theBarnettShale in 

### the 12-CountyDallas-Fort WorthAreawere developedusingthebest information that couldbe obtained usingthe available resources for the subjectvehicles, which is a very small subset ofthevehicles operatingthe DFWmetropolitanplanning area. As intended, the studyprovides preliminaryinformation concerningon-roadvehicles operating at oil and gas sites. The TCEQ is assessinghowto usethe activityinformation and assessingnext steps. However, becausethe on-roadSIP emissions inventories set motorvehicle emissionsbudgetsfor transportation conformity, the information is notyet comprehensive enoughto incorporate into the on-road SIP emissions inventoryprocess. No changeswere made in responseto this comment. One individual commented thatthe C02 emissions from trucks transporting waste waterfrom oil production wells, as represented in the reportDevelopmentof Oil andGasMobile Source Inventory in theBarnettShale in the 12-County Dallas-Fort WorthArea, FinalReport,August 2012, North Central Texas Council of Governments reaches a level of 200,000 pounds a day. The C02emissions are not a required elementfor this SIP revision. This SIP revision provides a basisfor theDFW and HGB nonattainment areas for the 2008 eight-hour ozone standard. Inventoryvalues for NOx andVOC areincludedinthe EI SIP revision as requiredbyFCAA, §182 andEPA's

### Implementation of the2008 NationalAmbient Air Quality Standard for Ozone: StateImplementationPlan Requirements. No changes were made in response to this comment. The Sierra Club and one individual commentedthattheTCEQ did not use the October 2012 MOVES database when developing the 2011 on-road mobile source EI. The October 2012 MOVES database corrected an error that only affects emissions 2020 andbeyond. Sierra Club stated thatfuture year inventories will be less accurate because theTCEQ did not usethe October 2012 database when developing the 2011 on-roadinventory. TheTCEQ is requiredto usethelatest available on-road emissions estimation model when developing Eis for SIP revisions. The October 2012 MotorVehicle Emission Simulator (MOVES) database was not available atthetimethe 2011 onroadEI was developed. However, the MOVES October 2012 database only affects emissions for analysisyears 2020 andbeyond. Therefore, use ofthe October 2012 database wouldhave no effect onthe 2011 Eis presentedinthe EI SIPrevision. No changes were made in responseto these comments.

Page 34 of 34



# -

# RECOMMENDATIONREVISIONS TO THE STATE OF TEXAS AIR QUALITY IMPLEMENTATION PLAN FORTHE CONTROL OF OZONE AIR POLLUTION

EMISSIONS INVENTORY FORTHE 2008 EIGHT-HOUR OZONE STANDARD NONATTAINMENTAREAS

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY P.O. BOX 13087 AUSTIN, TEXAS 78711-3087

EMISSIONS INVENTORY STATE IMPLEMENTATION PLAN REVISION FORTHE 2008 EIGHT-HOUR OZONE NATIONALAMBIENTAIR QUALITYSTANDARD FORTHE

HOUSTON-GALVESTON-BRAZORIAAND DALLAS-FORT WORTHAREAS

Project Number 2013-016-SIP-NR

Adoption July 2, 2014

### Thispage intentionally left blankEXECUTIVE SUMMARY The Federal Clean Air Act (FCAA) requires states to submit emissions inventory (EI) information for all relevant sources in areas that are designated nonattainmentfor the National Ambient Air Quality Standards (NAAQS). On March 12, 2008, the United States Environmental Protection Agency (EPA) lowered the eight-hour ozone NAAQS from o.o8 parts per million (ppm) to 0.075 ppm. Under the 0.075 ppm (75 parts perbillion) standard,the EPA designated the Houston-Galveston-Brazoria (HGB) area nonattainment with a marginal classification and the Dallas-Fort Worth (DFW) area nonattainment with a moderate classification, effective July 20, 2012. The eight-county HGB area includes Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, andWaller Counties. The ten-county DFW area includes Collin, Dallas, Denton, Ellis, .Johnson, Kaufman, Parker, Rockwall, Tarrant, andWise Counties. According to FCAA, §172(c)(3) and §182(a)(1), states are required to submit "a comprehensive, accurate, current inventory ofactual emissions from all sources," within two years ofthe effective date ofnonattainment designations for the ozone NAAQS. This revision to the state implementation plan will satisfy the FCAA EI submittal requirements for the HGB and DFW nonattainment areas under the 2008 eight-hour ozone standard. As reinforced bythe EPA's proposed 2008 ozone standard SIP requirements rule, the nonattainment area base year EI submission is due no later than 24 months from the July 20, 2012 effective date ofdesignations under the 2008 eight-hour ozone standard (July 20, 2014) andthen updated every threeyears thereafter (2017, 2020, etc.). The EPA specified that states use 2011 as a baseyear in the proposed 2008 ozone standard SIP requirements rule for the 2008 eight-hour ozone NAAQS. An EI submission is also required under the existing Air Emissions Reporting Requirements (AERR) Rule. The 2011 AERR EI has been developed for manypollutants including ozone precursors (volatile organic compounds and nitrogen oxides) from point, area, on-road mobile, non-road mobile, andbiogenic emissions source categories. This EI SIP revision is the baseline EI for the 2008 eight-hour ozone NAAQS and theAERR EI submittals every three years thereafter will satisfythe periodic EI requirements.

ES-1SECTIONV-A: LEGALAUTHORITY General TheTexas Commission on Environmental Quality (TCEQ) has the legal authorityto implement, maintain, and enforce the National AmbientAir Quality Standards (NAAQS) andto control the quality ofthe state's air, including maintaining adequate visibility. The first airpollution control act, known as the Clean Air Act ofTexas, was passedbytheTexas Legislature in 1965. In 1967, the CleanAir Act ofTexas was supersededby a more comprehensive statute, theTexas CleanAir Act (TCAA), found inArticle 4477-5, Vernon's Texas Civil Statutes. The legislature amended theTCAA in 1969, 1971, 1973, 1979, 1985, 1987, 1989, 1991, 1993, 1995, 1997, 1999, 2001, 2003, 2005, 2007, 2009, 2011, and 2013. In 1989, theTCAA was codified as Chapter 382 oftheTexas Health and Safety Code. Originally, theTCAA stated thattheTexas Air Control Board (TACB) is the state air pollution control agency andis theprincipal authorityinthe state onmatters relating to the quality ofair resources. In 1991, the legislature abolishedtheTACB effective September 1, 1993, andits powers, duties, responsibilities, andfunctions were transferredto theTexas Natural Resource Conservation Commission (TNRCC). With the creation oftheTNRCC, the authority over air quality is found inboththeTexas Water Code andtheTCAA. Specifically, the authority ofthe TNRCC is found in Chapters 5 and 7· Chapter 5, Subchapters A- F, H- J, and L, include the general provisions, organization, and general powers and duties oftheTNRCC, andthe responsibilities and authority ofthe executive director. Chapter 5 also authorizes theTNRCC to implement action when emergency conditions arise andto conduct hearings. Chapter 7 gives the TNRCC enforcement authority. In 2001, the 77th Texas Legislature continuedthe existence of theTNRCCuntil September 1, 2013, and changedthe name oftheTNRCC to theTCEQ. In 2009, the 81stTexas Legislature, during a special session, amended section 5.014 oftheTexas Water Code, changingthe expiration date oftheTCEQ to September 1, 2011, unless continued in existencebytheTexas SunsetAct. In 2011, the 82ndTexas Legislature continuedthe existence oftheTCEQ until 2023. The TCAA specifically authorizes theTCEQ to establish the level ofqualityto bemaintained in the state's air andto control the quality ofthe state's air bypreparing and developing a general, comprehensive plan. TheTCAA, SubchaptersA-D, also authorizetheTCEQ to collect informationto enablethe commissionto develop an inventory ofemissions; to conduct research andinvestigations; to enter property and examine records; to prescribe monitoring requirements; to institute enforcement proceedings; to enter into contracts and execute instruments; to formulate rules; to issue orders taking into consideration factors bearing upon health, welfare, social and economic factors, andpracticability and reasonableness; to conduct hearings; to establish air quality control regions; to encourage cooperation with citizens' groups and other agencies and political subdivisions ofthe state as well as with industries and the federal government; andto establish and operate a system ofpermits for construction or modification offacilities. Local government authorityis found in Subchapter E oftheTCAA. Local governments have the samepower as theTCEQ to enter propertyand make inspections. They also may make recommendations to the commission concerning any action oftheTCEQ that affects their territorialjurisdiction, maybring enforcement actions, and may execute cooperative agreements with theTCEQ or other local governments. In addition, a city ortown may enact and enforce ordinances for the control and abatement ofair pollution not inconsistentwith theprovisions of theTCAA and therules or orders ofthe commission.

iiSubchapters G and H oftheTCAA authorize theTCEQ to establish vehicle inspection and maintenance programs in certain areas ofthe state, consistent with the requirements ofthe Federal Clean Air Act; coordinate with federal, state, and local transportation planning agencies to develop and implement transportation programs and measures necessary to attain and maintain the NAAQS; establish gasoline volatility and low emission diesel standards; andfund and authorize participating counties to implement vehicle repair assistance, retrofit, and accelerated vehicle retirement programs. Applicable Law The following statutes and rules provide necessary authorityto adopt and implement the state implementation plan (SIP). The rules listedbelowhave previouslybeen submitted as part ofthe SIP. Statutes All sections ofeach subchapter are included, unless otherwise noted. Texas Health and Safety Code, Chapter 382 Texas Water Code Chapter 5: Texas Natural Resource Conservation Commission SubchapterA: General Provisions September1,2013 September 1, 2013 Subchapter B: Organization ofthe Texas Natural Resource Conservation Commission Subchapter C: Texas Natural Resource Conservation Commission Subchapter D: General Powers and Duties ofthe Commission Subchapter E: Administrative Provisions for Commission Subchapter F: Executive Director (except §§5.225, 5.226, 5.227, 5.2275,5.231, 5.232, and 5.236) Subchapter H: Delegation ofHearings Subchapter I: Judicial Review Subchapter J: Consolidated Permit Processing Subchapter L: Emergency and Temporary Orders (§§5.514, 5.5145, and 5.515 only) Subchapter M: Environmental Permitting Procedures (§5.558 only) Chapter7: Enforcement SubchapterA: General Provisions (§§7.001, 7.002, 7.0025, 7.004, and 7.005 only) Subchapter B: CorrectiveAction and Injunctive Relief (§7.032 only) Subchapter C: Administrative Penalties Subchapter D: Civil Penalties (except §7.109) Subchapter E: Criminal Offenses and Penalties: §§7.177, 7.179-7.183

Rules All ofthe following rules arefound in 30Texas Administrative Code, as ofthefollowing latest effective dates: Chapter 7: Memoranda ofUnderstanding, §§7.110 and.7.119 December 13, 1996 andMay 2, 2012 Chapter 19: Electronic Reporting Chapter 35: Subchapters A-C, K: Emergency andTemporary Orders and Permits; Temporary Suspension orAmendment ofPermit Conditions

iii November 11, 2010 July 20, 2006Chapter 39: Public Notice, §§39-402(a)(1)- (6), (8), and (10)- (12), 39-405(f)(3) and (g), (h)(1)(A)- (4), (6), (8)- (11), (i) and (j), 39.407, 39-409, 39-411(a), (e)(1)- (4)(A)(i) and (iii), (4)(B), (5)(A) and (B), and (6)- (10), (11)(A)(i) and (iii) and (iv), (11)(B)- (F), (13) and (15), and (f)(1)- (8), (g) and (h), 39-418(a), (b)(2)(A), (b)(3), and (c), 39-419(e), 39-420 (c)(1)(A)- (D)(i)(I) and (II), (D)(ii), (c)(2), (d)- (e), and (h), and 39.601- 39.605 June 24, 2010 Chapter 55: Requests for Reconsideration and Contested Case Hearings; Public Comment, §§55.150, 55.152(a)(1), (2), (5), and (6) and (b), 55.154(a), (b), (c)(l)- (3), and (5), and (d)- (g), and 55.156(a), (b), (c)(1), (e), and (g) June 24, 2010 Chapter 101: GeneralAir Quality Rules June 12, 2013 Chapter 106: Permitsby Rule, SubchapterA May 15, 2011 Chapter 111: Control ofAir Pollution from Visible Emissions and Particulate Matter February 6, 2014 Chapter 112: Control ofAir Pollution from Sulfur Compounds July 16, 1997 Chapter 113: Standards ofPerformance for HazardousAir Pollutants and for DesignatedFacilities and Pollutants May 14, 2009 Chapter 114: Control ofAir Pollutionfrom MotorVehicles March 6, 2014 Chapter 115: Control ofAir Pollution from Volatile Organic Compounds Chapter 116: Permits for New Construction or Modification Chapter 117: Control ofAir Pollutionfrom Nitrogen Compounds Chapter 118: Control ofAir Pollution Episodes Chapter 122: §122.122: Potential to Emit

iv November14,2013 August 16, 2012 May2, 2013 March 5, 2000 December 11, 2002SECTIONVI: CONTROL STRATEGY A. Introduction (No change) B. Ozone (Revised) 

### C. Particulate Matter (No change) D. Carbon Monoxide (No change) 

### E. Lead (No change) F. Oxides ofNitrogen (No change) G. Sulfur Dioxide (No change) H. Conformitywith the National AmbientAir Quality Standards (No change) I. Site Specific (No change) J. Mobile Sources Strategies (No change) K. Clean Air Interstate Rule (No change) L. Transport (No change) M. Regional Haze (No change)

vTABLE OF CONfENTS Executive Summary Section V-A: Legal Authority Section VI: Control Strategy Table ofContents List ofAcronyms List ofTables List ofAppendices Chapter 1: General 1.1 Background 1.2 Introduction 1.3 Health Effects 1.4 Public Hearing and Comment Information 1.5 Social andEconomic Considerations 1.6 Fiscal andManpower Resources Chapter 2: Emissions Inventories (EI) 2.1 Introduction 2.2 Point Sources 2.2.1 Point Source EI Development 2.2.2 HGB Point Source EI 2.2.3 DFW Point Source EI 2.3 Area Sources 2.3.1Area Source EI Development 2.3.2 HGB Area Source EI 2.3.3 DFWArea Source EI 2-4 Non-roadMobile Sources 2.4.1 Non-road EI Development 2-4.2 HGB Non-road Source EI 2-4.3 DFW Non-road Source EI 2.5 On-road Mobile Sources 2.5.1 On-road Mobile Source EI Development 2.5.2 HGB On-road Mobile Source EI 2.5.3 DFW On-road Mobile Source EI 2.6 Biogenic Sources 2.7 Emissions Summary

viLIST OFACRONYMS AEO Annual Energy Outlook AERR Air Emissions Reporting Requirements ASLRRA American Short Line and Regional Railroad Association CenSARA Central States Air Resources Agencies CMV commercial marinevessel DFW Dallas-Fort Worth EDMS EI EIQ EPA ERG FCAA FMVCP GIS HARC HGB HRVOC I/M MOU MOVES NAAQS NEI Emissions and Dispersion Modeling System emissions inventory emissions inventory questionnaire United States Environmental ProtectionAgency Eastern Research Group Federal Clean AirAct Federal Motor Vehicle Control Program Geographic Information Systems HoustonAdvanced Research Center Houston-Galveston-Brazoria highly reactive volatile organic compounds inspection and maintenance Memorandum ofUnderstanding Motor Vehicle Emissions Simulator National AmbientAir Quality Standard National Emissions Inventory NOx nitrogen oxides NESHAP National Emission Standards for HazardousAir Pollutants NSPS PEl ppm RFG RFP RRC SIP STARS TAC New Source Performance Standards periodic emissions inventory parts per million reformulated gasoline reasonable further progress Railroad Commission ofTexas stateimplementation plan State ofTexas Air Reporting System Texas Administrative Code

viiTACB TCAA TCEQ TDM TexN TNRCC tpd tpy TxLED VMT 

# voc Texas Air Control Board Texas Clean Air Act Texas Commission on Environmental Quality (commission) travel demand model Texas NONROAD Model Texas Natural Resource Conservation Commission tons per day tons peryear Texas Low Emission Diesel vehicle miles traveled volatile organic compounds

viiiLIST OFTABLES Table 2-1: HGB 2011 NOx andVOC Emissions for Point Sources (tons per day and tons peryear) Table 2-2: DFW 2011 NOx and VOC Emissions for Point Sources (tons per day and tons per year) Table 2-3: HGB 2011 NOx andVOC Emissions for Area Sources (tons per day andtons peryear) Table 2-4: DFW 2011 NOx andVOC Emissions for Area Sources (tons per day and tons peryear) Table 2-5: HGB 2011 NOx andVOC Emissions for Non-road Categories (tons per day and tons peryear) Table 2-6: DFW 2011 NOx andVOC Emissions for Non-road Categories (tons per day andtons peryear) Table 2-7: HGB 2011 NOx andVOC Emissions for On-road Mobile Sources (tons per day and tons peryear) Table 2-8: DFW 2011 NOx andVOC Emissions for On-road Mobile Sources (tons per day and tons peryear) Table 2-9: SummaryofHGB 2011 NOx andVOC Emissions (tons per day and tons peryear) Table 2-10: Summary ofDFW 2011 NOx andVOC Emissions (tons per day andtons peryear)

ixAppendix AppendixA Appendix B AppendixC

AppendixD AppendixE AppendixF AppendixG AppendixH Appendix I

AppendixJ

AppendixK LIST OFAPPENDICES Appendix Name Characterization ofOil and Gas Production Equipment and Develop a Methodologyto Estimate Statewide Emissions CondensateTank Oil and Gas Activities Development of2008Annual and Ozone Season Daily Emissions Inventories andActivity Data for Non-road Sources within the Texas NONROAD Model (TexN) Development ofStatewideAnnual Emissions Inventory andActivity Data for Airports Development ofAnnual Emissions Inventories andActivity Data for Airports inthe 12-County Dallas-FortWorthArea Development of2011 Statewide Toxics andActualAnnual and Ozone SeasonWeekdayEmissions Inventories for Commercial MarineVessels Development ofTexas Statewide Drilling Rigs Emissions Inventories for theYears 1990,1993, 1996, and 1999 through 2040 2011 Texas Railroad Emission Inventory Report Development of2011 On-road Mobile SourceActualAnnual and Summer Weekday Emissions Inventories for All Texas Cotmties (Except for 12 Counties inthe Dallas-FortWorthArea), andWinter WeekdayEmissions Inventories for El Paso: Houston-Galveston-BrazoriaArea Development of2011 On-road Mobile SourceActual Annual and Summer SeasonWeekday Emissions Inventories for 12 Counties inthe Dallas-Fort Worth Metropolitan StatisticalArea-Amendment Point Source HGB and DFW Site Level Emissions

X

### CHAPTER1: GENERAL 1.1BACKGROUND "The History ofthe Texas State Implementation Plan (SIP)," a comprehensive overview ofthe SIP revisions submittedto the United States Environmental Protection Agency (EPA) bythe State ofTexas, is available on the Introduction to the SIP Web page (http:/ jwww.tceq.texas.govjairqualityjsipjsipintro.html#History) ontheTexas Commission on Environmental Quality's (TCEQ) website (http:/ jwww.tceq.texas.gov). 

### 1.2 INTRODUCTION On March 12, 2008, the United States Environmental ProtectionAgency (EPA) lowered the eight-hour ozone standard from o.o8 parts per million (ppm) to 0.075 ppm. Under the 0.075 ppm (75 parts perbillion) standard, the EPA designated the Houston-Galveston-Brazoria (HGB) area nonattainment with a marginal classification and the Dallas-FortWorth (DFW) area nonattainment with a moderate classification, effective July 20, 2012. The eight-county HGB area includes Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties. Theten-county DFW area includes Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, Tarrant, and Wise Counties. This SIP revision satisfies the Federal Clean Air Act (FCAA), §172 and §182 emissions inventory (EI) requirements for the nonattainment areas under the 2008 eight-hour ozone National Ambient Air Quality Standard (NAAQS). Through the 

### Implementation of the 2008

### NAAQS for Ozone: StateImplementation Plan Requirements; ProposedRule (proposed 2008 ozone standard SIP requirements rule), the EPA interprets the FCAA requirements that states submit a comprehensive, accurate, current EI from all sources, as described in FCAA, §172(c)(3) and §182(a)(1) to be due within two years ofthe July 20, 2012 effective date ofdesignations for the 2008 eight-hour ozone NAAQS. The FCAA requires that Eis be preparedfor nonattainment areas generally, andprovides for specific requirements that apply in ozone nonattainment areas. Because ozone is photochemically produced in the atmosphere when volatile organic compounds (VOC) are mixed with nitrogen oxides (NOx) in thepresence ofsunlight, states are requiredto compile information on key sources ofthese precursor pollutants. The Eisprovide data for a variety ofair quality planning tasks including establishing baseline emission levels, calculating federally required emission reduction targets, emission inputs into air quality simulation models, and tracking emissions over time. The total EI ofVOC, NOx, and other pollutants for an area are summarized from the estimates developed for five general categories ofemissions sources: point, area, on-road mobile, non-road mobile, andbiogenic. TheEPA specified in the proposed 2008 ozone standard SIP requirements rule that states use 2011 as abaseyear for EI SIPs to address the EI requirements. The year 2011 is also a year for a required EI submission underthe existing Air Emissions Reporting Requirements (AERR) Rule. In accordance with the EPA's AERR, the National Emissions Inventory (NEI) is a comprehensive and detailed estimate ofair emissions ofboth criteria and hazardous air pollutants. As directedby the AERR, the NEI includes statewide coverage. Annual and summer day emissions are reported on a three-year cycle for theAERR. States can rely on these periodic AERR EI submittals to satisfy ongoing SIP EI submission requirements everythree years. The periodic EI SIP revision submission requirements fall on the same years as the AERR submittals.

1-11.3 HEALTH EFFECTS In 2008, the EPArevisedthe primaryozone standardto 0.075 ppm. To supportthe 2008 eighthour primary ozone standard,the EPAprovidedinformationthat suggestedthat health effects maypotentially occur at levels lower than the previous o.o8o ppm standard. Breathing relatively high levels ofground-level ozone can cause acute respiratoryproblems like cough and respiratory irritation and can aggravate the symptoms ofasthma. Repeated exposures to high levels ofozone canpotentiallymake people more susceptibleto respiratoryinfection andlung inflammation and canpotentially aggravate preexisting respiratory diseases, such asbronchitis and emphysema. Children are at a relativelyhigher riskfrom exposureto ozone when comparedto adults, since theybreathe more air perpound ofbodyweightthan adults andbecause children'srespiratory systems are still developing. Children also spend a considerable amount oftime outdoors during summer and duringthe start ofthe school year (August through October) when high ozone levels aretypically recorded. Adults most at riskfrom exposures to elevated ozone levels are people working or exercising outdoors and individuals with preexisting respiratory diseases. 1.4 PUBLIC HEARINGAND COMMENT INFORMATION The commission heldpublic hearings on this SIP revision onJanuary 14, 2014 at 2:00p.m. in Houston atthe Houston-GalvestonArea Council ofGovernments and onJanuary 16, 2014 at 2:00p.m. inArlington attheArlington City Hall Building. Notice ofthe publichearings for this SIP revision was publishedinthe 

### Texas Register andthe

### AustinAmerican-Statesman, the

### Fort Worth Star-Telegram, and

### Houston Chronicle newspapers. The public comment period opened on December 13, 2013 and closed onJanuary 27, 2014. Written comments were accepted via mail, fax, and through the eComments (http:/ jwwws.tceq.state.tx.usjrulesjecomments) system. Oral comments were received at the Houstonhearing from the Houston Regional Group ofthe Sierra Club (Sierra Club). Oral comments were received at theArlington hearing from DFWRegional Concerned Citizens, Downwinders at Risk (Downwinders), the Lone Star Chapter ofSierra Club (Sierra Club), Public Citizen, and five citizens. The TCEQ receivedwritten comments from DFW Regional Concerned Citizens, the Sierra Club, andtwo citizens. A summary ofthe comments andtheTCEQ response is provided as part ofthis SIPrevision in the Responseto Comments. An electronicversion ofthis SIP revision and appendices canbefound atthe TCEQ's Air Pollutionfrom OzoneWeb page (http:/ jwww.tceq.texas.govjairquality/sipjsipplans.html). 1.5 SOCIALAND ECONOMIC CONSIDERATIONS Because this SIP revision does not create new obligations for sources to report EI information, there are no changes thatwould have an impact on society or the economy. 1.6 FISCALAND MANPOWERRESOURCES TheTCEQ has determinedthat its fiscal andmanpower resources are adequate andwill notbe adversely affectedthrough the implementation ofthis plan.

1-2CHAPTER 2: EMISSIONS INVENTORIES (EI)

2.1 INTRODUCTION The Federal Clean Air Act (FCAA) requires that Els be preparedfor ozone nonattainment areas. Tropospheric, or ground-level, ozone is produced when ozone precursors, volatile organic compounds (VOC) and nitrogen oxides (NOx), undergo photochemical reactions in thepresence ofsunlight. TheTexas Commission on Environmental Quality (TCEQ) maintains a current EI for sources ofNOx andVOC that identifies the types ofemissions sources present in an area, the amount ofeach pollutant emitted, and the types ofprocesses and control devices employed at each facility or source category. The EI provides data for a variety ofair quality planning tasks, including establishingbaseline emissions levels, calculating federally required emission reduction targets, developing emissions inputs for air quality models, and tracking emissions reductions over time. The total inventory ofNOx andVOC emissions for an area is derived from estimates developed for five general categories ofemissions sources: point, area, non-road mobile, on-road mobile, andbiogenic. The federal Air Emissions Reporting Requirements (AERR) rule requires states to develop and submit periodic Eis to the United States Environmental ProtectionAgency (EPA) everythree years. The 2011 inventory was the first periodic emissions inventory (PEI) submitted under the AERR. In accordance with theAERR, the 2011 PEI was reportedto the EPA's National Emissions Inventory (NEI) as a comprehensive and detailed estimate ofair emissions, including ozone precursors (NOx and VOC). As directedbytheAERR, theTexas PEI includes annual emissions for the entire state and ozone season daily emissions for the 2008 eight-hour ozone nonattainment areas in Texas.

2.2 POINT SOURCES 2.2.1 Point Source EI Development Stationarypoint source emissions data are collected annuallyfrom sites that meet thereporting requirements of30Texas Administrative Code (TAC) §101.10. To collect the data, theTCEQ sends emissions inventory questionnaire (EIQ) courtesy notification letters to all sites identified as meeting the reporting requirements of30TAC §101.10. Companies are required to report emissions data, including ozone season (defined in TCEQ point source guidance 2013 Emissions Inventory Guidelines as May through September), andto provide samples ofcalculations used to determine reported emissions in accordance with detailed guidance. The guidance documents are available at theTCEQ Point Source Emissions InventoryWeb page (http:

## I lwww.tceq.texas.gov 

## I

airquality 

## I

point-source-eij psei.html). Information characterizing the process equipment, the control devices, andthe emissions points is also required. Data submittedto the TCEQ arereviewed for quality assurance purposes andthen stored in the State ofTexas Air Reporting System (STARS) database. The 2011 base year point source EI data were extracted from STARS onApril1, 2014. The extracted data contain ozone season daily and annual NOx and VOC emissions from each site in the Houston-Galveston-Brazoria (HGB) and Dallas-Fort Worth (DFW) 2008 eight-hour ozone nonattainment areas that submitted a 2011 EIQ, including revisions reviewed, approved, and entered on orbefore the extract date. Site level 2011 NOx and VOC emissions data are summarized and provided in Appendix K: PointSource HGB andDFWSite LevelEmissions. Further information, including 2011 unit-level NOx and VOC emissions data, is available upon request.

2-1A summary ofthe 2011 point source EI datafor the HGB and DFW 2008 eight-hour ozone nonattainment areas is presentedin Table 2-1: HGB 2011NOxand VOCEmissions for Point Sources (tonsperday and tonsperyear), andTable 2-2: DFW2011 NOx and VOCEmissions forPointSources (tonsperday and tonsperyear).

2.2.2 HGB Point Source EI Table 2-1: HGB 2011NOx andVOC Emissionsfor Point Sources (tons per day and tons peryear)

Brazoria 18.46 6,896.26 11.39 3,837.75 Chambers 7.93 2,344.79 5.66 1,970.04 Fort Bend 19.84 5,583.10 1.60 508.70 Galveston 13.18 3,602.04 15.40 3,613.96

Harris 47.32 16,076.28 55.78 18,801.24 Liberty 0.29 109.14 3.35 980.83 Montgomery 1.21 361.75 1.49 513.35 Waller 0.21 77.06 0.16 53.13 Total 108.44 35,050.42 94.83 30,279.00

2.2.3 DFWPoint Source EI Table 2-2: DFW 2011 NOx andVOC Emissions for Point Sources (tons per day and tonsperyear) -:--:=-r===-.,.,-.,...,.--c-=

Collin 0.66 173.98 0.80 234.73 Dallas 2.97 811.83 4.92 1,586.86 Denton 1.31 479.95 2.92 812.87

Ellis 12.15 4,122.43 5.12 1,681.72 Johnson 6.12 2,093.01 3.48 1,120.60 Kaufman 3.51 1,058.26 0.61 168.27

Parker 1.17 410.44 2.23 638.68 Rockwall 0.01 3.30 0.07 16.88 Tarrant 3.44 1,145.65 7.51 2,280.66

Wise 8.61 2,581.53 2.14 644.99 Total 39.95 12,880.38 29.80 9,186.26

2.3 AREASOURCES Stationary source emissions data from sites andprocesses that do notmeetthereporting requirements for point sources are classified as area sources. Area sources are small-scale industrial, commercial, andresidential sources that generate emissions. Emissions are

2-2calculated and recorded on the county-level. Area sources are divided according to emissions mechanism: hydrocarbon evaporative emissions orfuel combustion emissions. Examples of evaporative emissions sources include: printing operations, industrial coatings, degreasing solvents, house paints, gasoline service station underground tank filling, and vehicle refueling operations. Examples offuel combustion emissions sources include: stationary source fossil fuel combustion, outdoor refuse burning, and structural fires. With some exceptions, area source emissions are calculatedby multiplying an established emissions factor (emissions per unit of activity) bythe appropriate activity or activity surrogate responsible for generating emissions. Population is one ofthe more commonly used activity surrogates for area sources. Other activity data include the amount ofgasoline sold in an area, employment byindustrytype, and crude oil and natural gas production. 2.3.1 Area Source EI Development The 2011 area source EI was developed according to theAERR reporting requirements, using a combination ofmethodologies and data: EPA-generated Eis, TCEQ-contracted projects, TCEQ staffprojects, and categories grown from the 2008 EI using factors derived from study data compiled by Eastern Research Group's (ERG) Economy and Consumer Credit Analytics website (http:/ /vvww.economy.comjdefault.asp) andAnnual Energy Outlook (AEO). The EPA developed Eis for states to use for many source categories as part ofthe NEI. The states access these individual inventories through the EPA's NEI website (ftp:/ jftp.epa.gov/Emislnventoryj20lllleijdocj). These source categories include but are not limitedto industrial coatings; degreasing; residential, commercial/institutional, and industrial fuel use; commercial cooking; aviation fuel use; and consumer products. For some source categories, theTCEQ developed state-specific emissions estimates by acquiring current state specific activity data and applying appropriate emissions factors. These source categories includebut are not limited to: storage tanks, structural fires, dry cleaners, automobile fires, and oil and gas. In particular, significant resources were expended to improvethe oil and gas area source inventory production categories for 2011. The improvements included the development and refinement ofa state-specific oil and gas area source emissions calculator that uses county-level production and local equipment activity data with local emissions requirements to estimate emissions from individual production categories including compressors engines, condensate and oil storage tanks, loading operations, heaters, and dehydrators. The documentation for the development ofthe oil and gas emissions calculator can be found inAppendixA: 

### Characterization of Oil and Gas Production EquipmentandDevelop aMethodology to Estimate Statewide Emissions. A significant improvement made to the oil and gas calculator for the 2011 inventory was the development ofrefined emission factors for VOC emissions from condensate storage tanks. The documentation for the refined emission factors can also befound in Appendix B: 

### Condensate Tank Oil and GasActivities.

2.3.2 HGB Area Source EI County-level totals from the 2011 area source EI for the HGB area are presented in Table 2-3: 

### HGB 2011 

### NOx and VOCEmissionsforAreaSources (tonsper day and tonsperyear).

2-3Table 2-3: HGB 2011 NOx andVOC Emissions forArea Sources (tons per day and tons peryear)

Brazoria 1.63 648.43 32.35 11,390.72 Chambers 0.29 108.11 7.96 2,843.21 Fort Bend 1.49 698.96 25.14 8,390.74 Galveston 0.79 370.19 16.92 5,649.96

Harris 13.88 5,515.16 175.35 58,858.77 Liberty 0.76 295.27 24.21 8,688.68 Montgomery 1.97 821.76 22.73 7,712.93 Waller 0.33 119.18 4.07 1,409.03 Total 21.14 8,577.06 308.73 104,944.04 2.3.3 DFWArea Source EI County-leveltotals from the 2011 area source EI for the DFW area are presented inTable 2-4: DFW2011 NOx and VOCEmissions forAreaSources (tonsper day and tonsperyear). Table 2-4: DFW 2011 NOx andVOC Emissions for Area Sources (tons per day and tons peryear)

Collin 2.41 1,039.42 24.10 7,712.30 Dallas 11.70 4,144.41 84.25 26,613.80 Denton 2.26 975.32 34.54 11,644.710

Ellis 0.70 242.62 7.05 2,245.47 Johnson 2.06 758.48 17.98 6,253.20 Kaufman 0.42 152.32 5.35 1,716.17

Parker 0.67 253.47 12.85 4,422.75 Rockwall 0.16 77.18 3.01 965.71 Tarrant 10.12 3,656.01 74.18 24,270.94

Wise 12.14 4,435.29 29.18 10,454.74 Total 42.64 15,734.52 292.49 96,299.78

2.4 NON-ROAD MOBILE SOURCES Non-roadvehicles do not normally operate onroads orhighways and are often referredto as off-road or off-highway vehicles. The non-road source category is composed ofa diverse collection ofequipment, many ofwhich are poweredbydiesel engines. Non-road emissions sources include, but are notlimitedto: agricultural equipment, construction and mining equipment, lawn and garden equipment, aircraft and airport equipment, locomotives, drilling rigs and commercial marinevessels (CMV). For the 2011 EI, emissions inventories for non-road

2-4sources were developed as subcategories: NONROAD model categories; airports; CMVs; drilling rigs; and locomotives. The sections below describe the emissions calculation methods used for the non-road mobile source subcategories.

2.4.1 Non-road EI Development A Texas-specific version ofthe EPA's latest NONROAD 2008amodel, called theTexas NONROAD (TexN) model, was usedto calculate emissions from all non-road mobile source equipment and recreational vehicles, with the exception ofairports, locomotives, CMVs, and drilling rigs. The TexN model allows TCEQ staffto replace the EPA NONROAD model's default datawith more specific local survey data per EPA recommendations. Several equipment survey studies have been conductedwhich focused onvarious equipment categories operating in different areas in Texas. The resulting survey data are used as inputs to theTexN model to more accurately estimate non-road emissions for the state ofTexas. The 2011 non-road category EI development used the same methodology found inthe report

### Development of 2008

### Annualand Ozone Season Daily Emissions Inventories andActivityData forNon-Road Sources within the Texas NONROAD Model (TexN). A copy ofthe ERG report and associated inputs and meteorological data are provided inAppendix C: 

### Developmentof 2008

### Annualand Ozone Season Daily EmissionsInventories andActivityData forNon-Road Sources within the Texas NONROAD Model (TexN). The 2011 airport EI contains both annual and ozone season weekday emissions for airport sources related to aircraft operations. These emission sources include aircraft engines, auxiliary power units, and ground support equipment. The United States FederalAviation Administration's Emissions and Dispersion Modeling System (EDMS) was usedto calculate airport source emissions. To estimate the 2011 emissions from the airport sources, a survey collected updated information on aircraft activity, fleet mix, and other EDMS model input parameters. Model input data was compiled and reviewed, and any identified data gaps were filled using the most closely related data available. Documentation ofmethods andprocedures used in developing HGB area 2011 airport EI canbe found in Appendix D: 

### Development of StatewideAnnualEmissionsInventory andActivityDataforAirports. Documentation of methodology and procedures used to develop the DFW airport Eis can be found in Appendix E: 

### Development of AnnualandEmissions Inventories andActivityData forAirports in the 12- 

### County Dallas-Fort WorthArea. The 2011 CMV inventorywas developed based on multiple recent studies and datasets. The 2011 activity data were compiled using local port data andthe United States Department of Transportation MaritimeAdministration. The EPA's updated 2011 emissions factors were used to account for vessel turnover and compliance with marine vessel air quality regulations. The emissions factors were applied to the 2011 activity values to calculate 2011 emissions. The emissions were spatially allocated to Geographic Information Systems (GIS) shape-files. Documentation ofmethodologies andprocedures used in developing the CMV Eis can be found in Appendix F: 

### Developmentof 2011 

### Statewide Taxies andActualAnnual and Ozone Season Weekday Emissions Inventories for CommercialMarine Vessels. The 2011 EI for the drilling rig diesel engines was developed as part ofa statewide EI improvement study. Well activity data were obtainedthrough the acquisition ofthe "Drilling Permit Master and Trailer" database from the Railroad Commission ofTexas (RRC) and through a survey ofoil and gas exploration and production companies, which was usedto develop improved drilling rig emissions characterization profiles. Documentation ofmethods andprocedures used in developing the drilling rig diesel engine Eis can be found in Appendix G: 

### Development of Texas StatewideDrilling Rigs Emissions Inventories for the Years 1990, 1993,

2-51996, 

### and 1999 

### through 2040. An improvement made for the 2011 inventoryinvolved updating the projected 2011 drilling activity data from the studywith actual 2011 drilling activity data -obtainedfrom the RRC. The 2011 Texas locomotive EI includes Class I, II, and III locomotive activity and emissionsby rail segmentfor all counties withinTexas. Locomotive line haul andyard activity data were compiled from companies operating in Texas to create a county-level Class I line haul inventory. Data developedbythe Eastern Regional TechnicalAdvisory Committee in collaboration with the Federal RailroadAdministration, theAmerican Short Line and Regional Railroad Association (ASLRRA), and members ofthe Class II and III railroad communities used 2008 activity and emissions profiles for Class II and Class III railroads. To calculate annual gallons offuel usedby railroads, data compiledbyASLRRA from the Class II and III railroads, includingtotal industry fuel use in 2008 for locomotives andtotal Class II/III route miles, were used. Based onthe United States Energy InformationAdministration's latestAEO, 2008 fuel usagevalues were grown to estimate 2011 emissions. Documentation ofmethods and procedures used in developing thelocomotive Eis canbe found in Appendix H: 2011 

### Texas RailroadEmission InventoryReport. 2.4.2 HGB Non-Road Source EI County-level2011 non-road category source EI totals for the eight-county HGB 2008 eight-hour ozone nonattainment area are presented in Table 2-5: 

### HGB 2011 

### NOx and VOCEmissions for Non-Road Categories (tonsperday and tonsperyear). Table 2-5: HGB 2011NOx andVOC Emissionsfor Non-Road Categories (tonsper day andtonsperyear)

Brazoria 8.94 3,165.17 3.38 1,306.36 Chambers 1.10 409.09 1.04 533.25 Fort Bend 6.60 2,262.79 2.54 872.54 Galveston 14.32 5,235.62 4.07 2,093.54

Harris 80.85 27,575.79 33.44 11,715.84 Liberty 3.60 1,289.23 0.71 260.74 Montgomery 4.76 1,668.65 4.32 1,876.34 Waller 0.94 339.95 0.43 162.22 Total 121.11 41,946.29 49.93 18,820.83 2.4.3 DFWNon-RoadSourceEI County-level2011 non-road category source EI totals for theten-county DFW 2008 eight-hour ozone nonattainment area are presented inTable 2-6: 

### DFW2011

### NOx and VOCEmissions for Non-Road Categories (tonsper day and tonsperyear).

2-6Table 2-6: DFW 2011 NOx andVOC Emissionsfor Non-Road Categories (tonsper day and tons peryear)

Collin 8.41 2A99.54 6.00 1,823.14 Dallas 30.89 9,622.11 21.73 6,569.42 Denton 11.43 3,895.51 4.85 1,542.32

Ellis 3.76 1,138.51 1.59 480.65 Johnson 7.56 2,509.24 1.15 352.16 Kaufman 3.34 958.56 1.07 314.98

Parker 3.77 1,169.07 1.19 363.23 Rockwall 0.95 284.14 1.22 416.69 Tarrant 43.65 14,912.53 14.95 4,728.63

Wise 6.85 2,283.08 1.25 407.51 Total 120.61 39,272.29 55.00 16,998.73 2.5 ON-ROAD MOBILE SOURCES On-roadmobile emission sources consist ofautomobiles, trucks, motorcycles, and other motor vehicles traveling onpublic roadways. On-road mobile source emissions are usually categorized as either combustion-related emissions or evaporative hydrocarbon emissions. Combustionrelated emissions are estimated for vehicle engine exhaust. Evaporative hydrocarbon emissions are estimatedfor thefuel tank and other evaporative leak sources on the vehicle. To calculate emissions, both the rate ofemissions per unit ofactivity (emissions factors) and the number of units ofactivity mustbe determined. The emissions factors for on-road mobile sources are determined using models developed and approvedbythe EPA. The models allow for input of local conditions and vehicle characteristics. The activity information corresponding to the emissions factors is obtained using local travel demand models, the outputfrom the highway performance monitoring system, and speed models. 2.5.1 On-RoadMobile Source EI Development The 2011 on-road mobile source inventorywas developed using the latest available data, current emissions factors and models, andthe most current planning assumptions. Changes inthe inventories can be expected when a SIP is revised ifthere havebeen changes in any ofthe underlying tools or dataused in the inventory development. On-road mobile source category Eis presented in this SIPrevision used emissions factors developed from the EPA's Motor Vehicle Emissions Simulator (MOVES) model and methods consistent with both theEPA SIP inventory development guidance and with the requirements oftransportation conformity. In March 2010, the EPA replacedthe MOBILE6.2 model with MOVES as the official emissions factor model for developing on-roadmobile source category Eis. Although MOVES represents a new approach to assessing on-road emissions, the sources are the same, and the opportunityto use local inputs for meteorological conditions, control programs, andfleet characteristics remains. The primary approach to developing an on-road inventoryis the same with either MOVES or MOBILE6.2. With both models, emission rates are produced for subsets ofthe onroad fleet, and the emission rates are multiplied by the activity level ofeach vehicle type or source use type.

2-7During the development phase ofthe 2011 AERR inventories, the EPA released multiple versions oftheMOVES model. The EPA prefers that states use the latest version ofMOVES that is available. According to theEPA's guidance, ifstates have completed significant work on an inventoryfor periodic reporting orfor a SIP revision when a newversion ofMOVES is released, suchwork can be completed and submittedto EPA usingthepreviousversion ofthe model. The EPA released MOVES2010a inAugust of2010 andMOVES2010b inApril2012. The EPA originallyreleased MOVES201ob inApril 2012 to allow MOVES users tobenefit from several improvements to general model performancerelative to MOVES2010a. The difference inthe models is related solelyto model performance and does not affect the final emissions estimates. In October 2012, a database update to MOVES2010b was released, which corrected an errorthat affects emissions estimates for years after 2020; however, thisversion was not usedfor the 2011 AERRinventories due to schedule constraints. The 2011 AERR emissions estimates for all pollutants, precursors, or toxics were not affected by which version oftheMOVES model was used. The inventories for reporting under theAERRfor which significant workhadbeen completedbyApril 2012 were developed using MOVES2010a. TheAERRinventories developed after April2012 used MOVES201ob (April2012). TheAERR inventory development schedule for HGB requiredthe use ofMOVES2010a. TheAERR inventory development schedule for DFW allowed theuse ofMOVES2o10b (April2012). The MOVES model mayberun usi:rig default information, orthe default information maybe modifiedto simulatethe driving behavior, meteorological conditions, andvehicle characteristics specific to a particular area. Because modifications to theinputs significantly influencethe emissions factors calculatedbytheMOVES model, inputparameters reflecting local conditions were usedinstead ofrelying on national default values for the development ofthe 2011 on-road inventory. The localized inputs used for the DFW and HGB on-road mobile source 2011 EI development include vehicle speeds for each roadwaylink, temperature, humidity, vehicle age distributions for each vehicle type, percentage ofmiles traveled for eachvehicle type, type of inspection and maintenance (I/M) program, fuel control programs, and gasoline vaporpressure controls. To estimate on-road mobile source emissions, emissions rates calculatedbythe MOVES model mustbe multipliedbythe level ofvehicle activity. On-roadmobile source emissions factors are expressed in units ofgrams per mile; therefore, the activity informationthat is requiredto completethe inventory calculation is vehicle miles traveled (VMT) in units ofmiles per day. The level ofvehicle travel activity is developed using a travel demand model (TDM) runbytheTexas Department ofTransportation orbythe local metropolitan planning organizations. The TDMs are validated against a large number ofground counts, i.e., traffic passing over counters placed invarious locations throughout a countyor area. For SIP andreporting inventories, VMT estimates are calibrated against outputs from thefederal highway performance monitoring system, a model built from a different set oftraffic counters. In addition to the number ofmiles traveled on each roadwaylink, the speed on each roadway type or segment is also neededto complete an on-roadEI. Roadway speeds, required inputs for the MOVES model, are calculatedbyusing the activityvolumes from theTDM and a postprocessor speed model. A summary ofthe annual and daily DFW and HGB 2011 on-road mobile source NOx andVOC emissions levels is presented in Sections 2.5.2: HGB On-roadMobile SourceEIand 2.5.3: DFW On-roadMobile SourceEI. The inventory development methods, MOVES inputs, and the results are documented inAppendix I: Developmentof 2011 On-RoadMobile SourceActual Annual andSummer Weekday EmissionsInventories forAll Texas Counties (Exceptfor 12

2-8

### Counties in the Dallas-Fort WorthArea), and Winter Weekday Emissions Inventories for El Paso: Houston-Galveston-BrazoriaArea and AppendixJ: 

### Development of 2011 

### On-Road Mobile SourceActualAnnualandSummerSeason Weekday Emissions Inventories for 12 

### Counties in 

### the Dallas-Fort WorthMetropolitan StatisticalArea-Amendment. 2.5.2 HGB On-RoadMobile Source EI The 2011 HGB 2008 eight-hour ozone nonattainment area EI for on-road mobile sources was developed using emissions factors calculated using the MOVES2010a version ofthe MOVES model. All control strategies implementedby 2011 were included inthe input to the EI development for the 2011 on-road mobile sourcebaseyear EI. Those controls includethe effects ofthe federal motorvehicle control program (FMVCP), reformulated gasoline (RFG), the HGB vehicle I/M program, andthe Texas Low Emission Diesel (TxLED) program. TheVMT was developedusing the latest activity estimates from the HGB TDM 2011 network. The activity levels usedto calculate the EI reflect the 2011 roadway network with 2011 VMT and speeds. A summary ofthe EI is presentedin Table 2-7: 

### HGB 2011 

### NOx and VOCEmissions for On-roadMobile Sources (tonsperday and tonsperyear). Complete documentation ofthe development ofthe EI and details on MOVES model inputs are provided inAppendix I. Table 2-7: HGB 2011NOx andVOC Emissions for On-RoadMobile Sources (tons per dayandtons peryear)

Brazoria 8.44 3,155.45 4.20 1,436.68 Chambers 6.84 2,501.74 1.07 357.56 Fort Bend 12.54 4,720.44 6.20 2,143.22 Galveston 7.37 2,746.59 3.86 1,319.75

Harris 137.01 50,782.06 58.18 19,955.62 Liberty 4.92 1,772.54 1.66 547.55 Montgomery 15.22 5,727.18 6.30 2,161.07 Waller 3.87 1,470.91 1.15 391.48 Total 196.21 72,876.91 82.62 28,312.93 2.5.3 DFW On-RoadMobile Source EI The 2011 DFW 2008 eight-hour ozone nonattainment area EI for on-road mobile sources was developed using emissions factors calculated using the MOVES2010b version ofthe MOVES model. All control strategies implementedby 2011 were included in the input to the EI development for the 2011 on-road mobile source baseyear EI. Those controls include the effects ofthe FMVCP; RFG, the DFWvehicle I/M program, andthe TxLED program. TheVMT was developedusing the latest activity estimates from the DFWTDM 2011 network. The activity levels usedto calculate the EI reflect the 2011 roadway network with 2011 VMT and speeds. A summary ofthe EI is presented in Table 2-8: 

### DFW2011 

### NOx and VOCEmissions for On-RoadMobile Sources (tonsperday and tonsperyear). Complete documentation ofthe development ofthe EI and details on MOVES model inputs are provided inAppendix J.

2-9Table 2-8: DFW 2011 NOx andVOC Emissions for On-RoadMobile Sources (tons per day andtonsperyear)

Dallas 31,244.48 37.98 Denton 20.99 7,349.39 8.68 2,582.00

Ellis 11.39 4,195.26 3.31 1,003.77 Johnson 8.81 3,197.03 3.21 972.89 Kaufman 9.40 3,323.77 2.33 799.21

Parker 8.68 3,238.67 2.43 738.60 Rockwall 3.29 1,181.82 1.22 360.17 Tarrant 57.48 20,088.88 27.12 8,039.88

Wise 6.21 2,270.95 1.80 556.29 Total 238.87 83,917.88 98.36 29,404.41 2.6 BIOGENIC SOURCES Biogenic sources include VOC emissions from crops, lawn grass, andtrees as well as a small amount ofNOxemissions from soils. Plants are sources ofVOC emissions such as isoprene, monoterpene, and alpha-pinene. Biogenic emissions are estimatedbythe EPA using its biogenic emissions inventorytool. 2.7 EMISSIONS SUMMARY The 2011 NOx andVOC emissions in the HGB and DFW 2008 eight-hour ozone nonattainment areas for each source category are summarized in Table 2-9: 

### Summary ofHGB 2011 

### NOx and VOCEmissions (tonsper day and tonsperyear) andTable 2-10: 

### Summary of DFW2011 

### NOx and VOCEmissions (tonsperday and tonsperyear). Table 2-9: SummaryofHGB 2011 NOxandVOC Emissions (tons per day andtons peryear)

Point 108.44 35,050.42 94.83 30,279.00 Area 21.14 8,577.06 308.73 104,944.04 Non-Road Mobile 121.11 41,946.29 49.93 18,820.83 On-Road Mobile 196.21 72,876.91 82.62 28,312.93 Total 446.90 158,450.68 536.12 182,356.80

2-10Table 2-10: SummaryofDFW 2011 NOxandVOC Emissions (tons per day andtons peryear)

Point 39.95 12,880.38 29.80 9,186.26 Area 42.64 15,734.52 292.49 96,299.78 Non-Road Mobile 120.61 39,272.29 55.00 16,998.73 On-Road Mobile 238.87 83,917.88 98.36 29,404.41 Total 442.08 151,805.07 475.65 151,889.18

2-11

### AppendicesAvailable Upon Request Brian Foster SIP Project Manager brian.foster@tceq.texas.gov 512.239.1930

### TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

,_ -



### ORDERADOPTING REVISION TO THE STATE IMPLEMENTATION PLAN



### Docket No. 2013-1682-SIP Project No. 2013-016-SIP-NR 

### On July 2, 2014, the Texas Commission on Environmental Quality (Commission), during a public meeting, considered adoption ofa revision to the State Implementation Plan (SIP) for the 2008 Eight-Hour Ozone National Ambient Air Quality Standard (NAAQS) for the Houston-Galveston-Brazoria (HGB) and Dallas-FortWorth (DFW) Areas. The Commission adopted revisions to the SIP that include a baseline emission inventory (EI) for the 2008 Eight-Hour Ozone NAAQS for the HGB and DFW areas to satisfythe Federal Clean Air Act (FCAA), §172 and §182 EI requirements for the nonattainment areas. Under Tex. Health 

### &Safety Code Ann.§§ 382.011, 382.012, and 382.023 (Vernon 2011), the Commission has the authorityto control the quality ofthe state's air andto issue orders consistent with the policies and purposes ofthe Texas Clean Air Act, Chapter 382 ofthe Tex. Health &

### Safety Code. Notice ofthe proposed SIP revision was publishedfor comment in the December 27, 2013 issue ofthe Texas Register 

### (38 TexReg 9666). Pursuant to 40 Code ofFederal Regulations§ 51.102 and after proper notice, the Commission conducted a public hearings to consider the revision to the SIP. Proper notice included prominent advertisement in the areas affected at least 30 days priorto the dates of the hearings. Public hearings were heldin Houston on January 14, 2014 and in Arlington on January 16, 2014. The Commission circulated hearing notices ofits intended action to thepublic, including interestedpersons, the Regional Administrator ofthe EPA, and all applicable local air pollution control agencies. The public was invitedto submit data, views, and recommendations onthe proposed SIP revision, either orally or in\'VTiting, atthe hearings or during the comment period. Prior to the scheduledhearings, copies ofthe SIP revision were available for public inspection atthe Commission's central office and on the Commission's Web site. Data, views, andrecommendations ofinterested persons regarding the proposed SIP revision were submittedto the Commission during the comment period, andwere considered by the Commission as reflected in the analysis oftestimony incorporatedby reference to this Order. The Commission finds thatthe analysis oftestimony includes the names ofall interested groups or associations offering comment on the proposed SIP revision and their position concerning the same. IT IS THEREFORE ORDERED BY THE COMMISSION thatthe revision to the SIP incorporatedby reference to this Order is hereby adopted. The adopted re-vision to the SIP is incorporatedbyreference in this Order as ifsetforth atlength verbatim inthis Order.' / ; 

# , , ,,',IT lS FUitTHER ORDERED BY THE COMMISSION that onbehalfofthe Commission,**tlie,ci~aS~\nvnfsho~ld** 

### transmit a copy ofthis Order, together with the adoptedrevision to the SIP; to**U~e \~egi0ria1**  

### Administrator ofEPA as a proposed revision to the Texas SIP pursuantto the**Fed~rafClean'Air** 

### Act, codified at 42 

### U.S. Code Ann.§§ 7401- 7671q, 

### as amended.

-,, ,' ' 

### Ifany'portion ofthis Order is for any reason heldto be invalidby a court ofcompetent jurisdiction, the invalidity ofany portion shall not affect the validity ofthe remaining portions.

Date issued: 

# J 

# U l 10

# 2014 TEXAS COMMISSION ON ENVIRONMENTAL QUALITY