Bryan W. Shaw, Ph.D., P.E., Chainnan 

Toby Baker, Commissioner 

Zak Covar, Commissioner 

Richard A. Hyde, P.E., Executive Director 

·. 1:..: i"'UL > ,,.,r·::• ("'r(~ 

f• ' , ·~I •) C.. \.J, 

11, JUL. 18 Prl 6:03 

TEXAS COMMISSION ON ENVIRONMENTAL QUALI1Y 

Protecting Texas by Reducing and Preventing Pollution 

July 16, 2014 

Ron Curry 

Regional Administrator 

U.S. Environmental Protection Agency- 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-Fort Worth (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 satisfy the 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 of the public hearings, and the accompanying order. I look forward to your 

expeditious approval of this 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 of the Governor 

Mr. Richard A. Hyde, P.E., Executive Director, Texas Commission on Environmental 

Quality 

P.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 that the attached electronic file is included and that the electronic file 

is a true and correct copy of documents for a revision to the Texas State Implementation Plan, 

adopted on July 2, 2014, pursuant to 40 Code of Federal Regulations§ 51.104. I am the 

records administrator for the Air Quality Division of the Texas Commission on 

Environmental Quality (Commission). 

m(" 

0 DaVli:l ~.I\Qa~ rymer, Director 

Air Quality Division 

Texas Commission on Environmental Quality 
Texas 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-NR 
INTRODUCTION 

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 & PROPOSAL 
PUBLIC 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 Organization 
Federal 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 Agency 
Example 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 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 

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 prior to 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 of Public 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 of Federal Regulations Part 449, ich establishes technology-based effluent 

limitation guidelines and ne source performance standards to control 

discharges of pollutants fro airport de-icing operations. 

The commission will hold a ublic hearing on this 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 of registration. Open iscussion will not be permitted during the 

hearing: however, commiss on staff members 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 of Legal 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 of Public 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 of Texas Health and Safety Code, §382.017; Texas Government Code, Chapter 2001, Subchapter B; and 40 Code of Federal Regulations §51.1 02 of the 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 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 2:00p.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, I 0 I 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 permitted during the hearings; however, 

TCEQ staff members 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 of the 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 of Receipt of Ap 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 land38 TexReg 9666 December 27, 2013 Texas Register 
Bryan W. Shaw, Ph.D., Chairman 

Toby Baker, Commissioner 

Zak Covar, Executive Director 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

Protecting Texas by Reducing and Preventing Pollution 

NOTICE OF PUBLIC HEARINGS BY THE TEXAS 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) under the requirements 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 

concerning SIPs. 

The proposed SIP revision would 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 (NAAQS). 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. 

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 in Arlington 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 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 

permitted during the hearings; however, TCEQ staff members will be available to 

discuss the proposal 30 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:jjwwws.tceq.texas.govjrulesjecommentsj. 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 of the 

proposed rulemaking can be obtained from the TCEQ's Website at 

http:jjwww.tceq.texas.govjairqualityjsipjcriteria-pollutantsjsip-ozone. For further 

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 paper 
REVISIONS TO THE STATE OF TEXAS AIR QUALITY 

IMPLEMENTATION PLAN FOR THE CONTROL OF OZONE AIR 

POLLUTION 

EMISSIONS INVENTORY FOR THE 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 FOR THE 2008 EIGHT-HOUR OZONE 

NATIONAL AMBIENT AIR QUALITY STANDARD FOR THE 

HOUSTON-GALVESTON-BRAZORIAAND DALLAS-FORT 

WORTH AREAS 

Project Number 2013-016-SIP-NR 

Proposal 

December 11, 2013 
This page intentionally left blank 
EXECUTIVE 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 of the 

National Ambient Air Quality Standards (NAAQS) 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 per billion) 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, and Wise Counties. According to FCAA, §172(c)(3) and 

§182(a)(1), states are required to submit "a comprehensive, accurate, current inventory of actual 

emissions from all sources," within two years of the effective date of nonattainment 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 of the 

July 20, 2012 effective date of designations for the 2008 eight-hour ozone NAAQS (78 FR 

34178). 

This proposed revision to the state implementation plan would satisfy the FCAA, §§172 and 182 

requirements for the HGB and DFW nonattainment areas under the 2008 eight-hour ozone 

standard. As reinforced by the EPA's proposed 40 Code of Federal Regulations §51.1115, the 

nonattainment area base year EI submission is due no later than 24 months from the July 20, 

2012 effective date of designations under the 2008 eight-hour ozone standard (July 20, 2014) 

and then every three years thereafter (2017, 2020, etc.). The EPA specified that states use 2011 

as a base year in the proposed implementation 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 many pollutants including ozone 

precursors (volatile organic compounds and nitrogen oxides) from point, area, on-road mobile, 

non-road mobile, and biogenic emissions source categories. This EI SIP revision submittal is the 

baseline EI for the 2008 eight-hour ozone NAAQS and AERR EI submittals every three years 

thereafter will satisfy the periodic EI requirements. 

ES-1 
SECTION V-A: LEGAL AUTHORITY 

General 

The Texas Commission on Environmental Quality (TCEQ) has the legal authority to implement, 

maintain, and enforce the National Ambient Air Quality Standards (NAAQS) and to control the 

quality of the state's air, including maintaining adequate visibility. 

The first air pollution control act, known as the Clean Air Act of Texas, was passed by the Texas 

Legislature in 1965. In 1967, the Clean Air Act of Texas was superseded by a more 

comprehensive statute, the Texas Clean Air Act (TCAA), found in Article 4477-5, Vernon's Texas 

Civil Statutes. The legislature amended the TCAA in 1969, 1971, 1973, 1979, 1985, 1987, 1989, 

1991, 1993, 1995, 1997, 1999, 2001, 2003, 2005, 2007, 2009, 2011, and 2013. In 1989, the TCAA 

was codified as Chapter 382 of the Texas Health and Safety Code. 

Originally, the TCAA stated that the Texas Air Control Board (TACB) is the state air pollution 

control agency and is the principal authority in the state on matters relating to the quality of air 

resources. In 1991, the legislature abolished the TACB effective September 1, 1993, and its 

powers, duties, responsibilities, and functions were transferred to the Texas Natural Resource 

Conservation Commission (TNRCC). With the creation of the TNRCC, the authority over air 

quality is found in both the Texas Water Code and the TCAA. Specifically, the authority of the 

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 of the TNRCC, and the 

responsibilities and authority of the executive director. Chapter 5 also authorizes the TNRCC to 

implement action when emergency conditions arise and to conduct hearings. Chapter 7 gives the 

TNRCC enforcement authority. In 2001, the 77th Texas Legislature continued the existence of 

the TNRCC until September 1, 2013, and changed the name of the TNRCC to the TCEQ. In 

2009, the 81st Texas Legislature, during a special session, amended section 5.014 of the Texas 

Water Code, changing the expiration date of the TCEQ to September 1, 2011, unless continued in 

existence by the Texas Sunset Act. In 2011, the 82nd Texas Legislature continued the existence 

of the TCEQ until 2023. 

The TCAA specifically authorizes the TCEQ to establish the level of quality to be maintained in 

the state's air and to control the quality of the state's air by preparing and developing a general, 

comprehensive plan. The TCAA, Subchapters A- D, also authorize the TCEQ to collect 

information to enable the commission to develop an inventory of emissions; 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, and prttcticability and reasonableness; to conduct 

hearings; to establish air quality control regions; to encourage cooperation with citizens' groups 

and other agencies and political subdivisions of the state as well as with industries and the 

federal government; and to establish and operate a system of permits for construction or 

modification of facilities. 

Local government authority is found in Subchapter E of the 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 of the TCEQ that affects their 

territorial jurisdiction, may bring enforcement actions, and may execute cooperative agreements 

with the TCEQ or other local governments. In addition, a city or town may enact and enforce 

ordinances for the control and abatement of air pollution not inconsistent with the provisions of 

the TCAA and the rules or orders of the commission. 

ii 
Sub chapters G and H of the TCAA authorize the TCEQ to establish vehicle inspection and 

maintenance programs in certain areas of the state, consistent with the requirements of the 

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; and fund 

and authorize participating counties to implement vehicle repair assistance, retrofit, and 

accelerated vehicle retirement programs. 

Applicable Law 

The following statutes and rules provide necessary authority to adopt and implement the state 

implementation plan (SIP). The rules listed below have previously been submitted as part of the 

SIP. 

Statutes 

All sections of each subchapter are included, unless otherwise noted. 

TEXAS HEALTH & SAFETY CODE, Chapter 382 

TEXAS WATER CODE 

Chapter 5: Texas Natural Resource Conservation Commission 

Subchapter A: General Provisions 

September 1, 2013 

September 1, 2013 

Subchapter B: Organization of the Texas Natural Resource Conservation Commission 

Subchapter C: Texas Natural Resource Conservation Commission 

Subchapter D: General Powers and Duties of the 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 of Hearings 

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) 

Chapter 7: Enforcement 

Subchapter A: 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 of the following rules are found in 30 Texas Administrative Code, as of the following latest 

effective dates: 

Chapter 7: Memoranda of Understanding, §§7.110 and 7.119 

December 13,1996 and May 2, 2002 

Chapter 19: Electronic Reporting 

Chapter 35: Subchapters A-C, K: Emergency and Temporary Orders and 

Permits; Temporary Suspension or Amendment of Permit Conditions 

iii 

March 15, 2007 

July 20, 2006 
Chapter 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: Permits by Rule, Subchapter A May 15, 2011 

Chapter 111: Control of Air Pollution from Visible Emissions and Particulate 

Matter February 16, 2012 

Chapter 112: Control of Air Pollution from Sulfur Compounds July 16, 1997 

Chapter 113: Standards of Performance for Hazardous Air Pollutants and for 

Designated Facilities and Pollutants May 14, 2009 

Chapter 114: Control of Air Pollution from Motor Vehicles September 13, 2012 

Chapter 115: Control of Air Pollution from Volatile Organic Compounds December 29, 2011 

Chapter 116: Permits for New Construction or Modification August 16, 2012 

Chapter 117: Control of Air Pollution from Nitrogen Compounds May2, 2013 

Chapter 118: Control of Air 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 of Economic Incentives, Marketable Permits, and Emissions Trading June 3, 2001 

iv 
SECTION VI: 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 of Nitrogen (No change) 

G. Sulfur Dioxide (No change) 

H. Conformity with the National Ambient Air 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) 

v 
TABLE OF CONTENTS 

Executive Summary 

Section V-A: Legal Authority 

Section VI: Control Strategy 

Table of Contents 

List of Acronyms 

List of Tables 

List of Appendices 

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 

vi 
AEO 

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 OF ACRONYMS 

Annual Energy Outlook 

Air Emissions Reporting Requirements 

American Short Line and Regional Railroad Association 

Code of Federal Regulations 

commercial marine vessel 

Dallas-Fort Worth 

Emissions and Dispersion Modeling System 

emissions inventory 

emissions inventory questionnaire 

United States Environmental Protection Agency 

Federal Clean Air Act 

Federal Motor Vehicle Control Program 

Federal Register 

Geographic Information System 

Houston -Galveston-Brazoria 

inspection and maintenance 

Motor Vehicle Emissions Simulator 

National Ambient Air Quality Standard 

National Emissions Inventory 

nitrogen oxides 

periodic emissions inventory 

parts per billion 

parts per million 

Railroad Commission of Texas 

state implementation plan 

State of Texas Air Reporting System 

Texas Administrative Code 

Texas Clean Air Act 

Texas Commission on Environmental Quality (commission) 

travel demand model 

Texas NONROAD Model 

Texas Natural Resource Conservation Commission 

tons per day 

vii 
tpy 

TxLED 

VMT 

voc 

tons per year 

Texas Low Emission Diesel 

vehicle miles traveled 

volatile organic compounds 

viii 
LIST OF TABLES 

Table 1-1: Public Hearing Information 

Table 2-1: HGB 2011 NOx and VOC Emissions for Point Sources (tons per day and tons per year) 

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 and VOC Emissions for Area Sources (tons per day and tons per year) 

Table 2-4: DFW 2011 NOx and VOC Emissions for Area Sources (tons per day and tons per year) 

Table 2-5: HGB 2011 NOx and VOC Emissions for Non-road Categories (tons per day and tons 

per year) 

Table 2-6: DFW 2011 NOx and VOC Emissions for Non-road Categories (tons per day and tons 

per year) 

Table 2-7: HGB 2011 NOx and VOC Emissions for On-road Mobile Sources (tons per day and 

tons per year) 

Table 2-8: DFW 2011 NOx and VOC Emissions for On-road Mobile Sources (tons per day and 

tons per year) 

Table 2-9: Summary ofHGB 2011 NOxand VOC Emissions (tons per day and tons per year) 

Table 2-10: Summary ofDFW 2011 NOxand VOC Emissions (tons per day and tons per year) 

ix 
Appendix 

Appendix A 

Appendix B 

Appendix C 

Appendix D 

Appendix E 

Appendix F 

Appendix G 

AppendixH 

Appendix I 

AppendixJ 

LIST OF APPENDICES 

Appendix N arne 

Characterization of Oil and Gas Production Equipment and Develop a 

Methodology to Estimate Statewide Emissions 

Condensate Tank Oil and Gas Activities 

Development of 2008 Annual and Ozone Season Daily Emissions 

Inventories and Activity Data for Non-road Sources within the Texas 

NONROAD Model (TexN) 

Development of Statewide Annual Emissions Inventory and Activity Data 

for Airports 

Development of Annual Emissions Inventories and Activity Data for 

Airports in the 12-County Dallas-Fort Worth Area 

Development of 2011 Statewide Toxics and Actual Annual and Ozone 

Season Weekday Emissions Inventories for Commercial Marine Vessels 

Development of Texas Statewide Drilling Rigs Emissions Inventories for 

the Years 1990, 1993, 1996, and 1999 through 2040 

2011 Texas Railroad Emission Inventory Report 

Development of 2011 On-road Mobile Source Actual Annual and Summer 

Weekday Emissions Inventories for All Texas Counties (Except for 12 

Counties in the Dallas-Fort Worth Area), and Winter Weekday Emissions 

Inventories for El Paso: Houston-Galveston-Brazoria Area 

Development of 2011 On-road Mobile Source Actual Annual and Summer 

Season Weekday Emissions Inventories for 12 Counties in the Dallas-Fort 

Worth Metropolitan Statistical Area-Amendment 

X 
CHAPTER1: GENERAL 

1.1BACKGROUND 

"The History of the Texas State Implementation Plan (SIP)," a comprehensive overview of the 

SIP revisions submitted to the United States Environmental Protection Agency (EPA) by the 

State of Texas, is available on the 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 Protection Agency (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 per billion) 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, and Wise 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 Ambient Air 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 of the July 20, 2012 effective date of 

designations for the 2008 eight-hour ozone NAAQS. The FCAA requires that Eis be prepared for 

nonattainment areas generally, and provides for specific requirements that apply in ozone 

nonattainment areas. Because ozone is photochemically produced in the atmosphere when 

volatile organic compounds (VOC) emissions are mixed with nitrogen oxides (NOx) in the 

presence of sunlight, states are required to compile information on the important sources of 

these precursor pollutants. The Eis provide data for a variety of air 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 of emissions sources: point, area, on-road 

mobile, non-road mobile, and biogenic. 

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. The year 2011 

is also a year for a required EI submission under the 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 of air emissions of both criteria and 

hazardous air pollutants. As directed by the AERR, the NEI includes statewide coverage. Annual 

and summer day emissions are reported on a three-year cycle for the AERR. 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. 

1-1 
1.3 HEALTH EFFECTS 

In 2008, the EPA revised the primary ozone standard to 0.075 ppm. To support the 2008 eighthour primary ozone standard, the EPA provided information that suggested that health effects 

may potentially occur at levels lower than the previous o.o8o ppm standard. Breathing 

relatively high levels of ground-level ozone can cause acute respiratory problems like cough and 

respiratory irritation and can aggravate the symptoms of asthma. Repeated exposures to high 

levels of ozone 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 

they breathe more air per pound of body weight than adults and because children's respiratory 

systems are still developing. Children also spend a considerable amount of time outdoors during 

summer and during the start of the 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 HEARING AND COMMENT INFORMATION 

The commission will hold public hearings for this proposed SIP revision at the times and 

locations listed below. 

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 

The public comment period will open on December 13, 2013 and close on January 27, 2014. 

Notice of public hearings for this SIP revision will be published in the Texas Register and 

various newspapers. Written comments will be accepted via mail, fax, or through 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 may be submitted to Nina Castillo, MC 206, State 

Implementation Plan Team, Office of Air, Texas Commission on Environmental Quality, P.O. 

Box 13087, Austin, Texas 78711-3087 or faxed to (512) 239-6188. If you choose to submit 

electronic comments, they must be submitted through the eComments 

(http:/ jwww5.tceq.state.tx.usjrules/ecomments) system. File size restrictions may apply to 

comments being submitted via the eComments system. Comments must be received by January 

27,2014. 

An electronic version of this proposed SIP revision and appendices can be found at the TCEQ's 

SIP Hot Topics Web page (http:/ jwww.tceq.texas.govjairqualityjsip/Hottop.html). 

1-2 
1.5 SOCIAL AND 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 FISCAL AND MANPOWER RESOURCES 

The TCEQ has determined that its fiscal and manpower resources are adequate and will not be 

adversely affected through the implementation of this plan. 

1-3 
CHAPTER 2: EMISSIONS INVENTORIES (EI) 

2.1 INTRODUCTION 

The Federal Clean Air Act (FCAA) requires that Eis be prepared for ozone nonattainment areas. 

Tropospheric ozone is produced when ozone precursors, volatile organic compounds (VOC) and 

nitrogen oxides (NOx), undergo photochemical reactions in the presence of sunlight. The Texas 

Commission on Environmental Quality (TCEQ) maintains an EI of current information for 

sources of NOx and VOC that identifies the types of emissions sources present in an area, the 

amount of each pollutant emitted, and the types of processes and control devices employed at 

each plant or source category. The EI provides data for a variety of air quality planning tasks, 

including establishing baseline emissions levels, calculating federally required emission 

reduction targets, developing emissions inputs for air quality models, and tracking emissions 

reductions over time. The total inventory of NOx and VOC emissions for an area is derived from 

estimates developed for five general categories of emissions sources: point, area, non-road 

mobile, on-road mobile, and biogenic. 

The federal Air Emissions Reporting Requirements (AERR) rule requires states to develop and 

submit periodic Els to the United States Environmental Protection Agency (EPA) every three 

years. The 2011 inventory was the first periodic emissions inventory (PEl) submitted under the 

AERR. Per the AERR, the 2011 PEl was reported to the EPA's National Emissions Inventory 

(NEI) as a comprehensive and detailed estimate of air emissions, including ozone precursors 

(NOx and VOC). As directed by the AERR, 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 

Stationary point source emissions data are collected annually from sites that meet the reporting 

requirements of 30 Texas Administrative Code (TAC) §101.10. To collect the data, the TCEQ 

mails emissions inventory questionnaire (EIQ) courtesy notification letters to all sites identified 

as meeting the reporting requirements of 30 TAC §101.10. Companies are required to report 

emissions data and to provide samples of calculations used to determine reported emissions in 

accordance with detailed guidance. The guidance documents are available at the TCEQ Point 

Source Emissions Inventory Web 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 submitted to the TCEQ are reviewed for quality 

assurance purposes and then stored in the State of Texas Air Reporting System (STARS) 

database. 

The 2011 base year point source EI data were extracted from STARS on June 28, 2013. 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 or before the extract date. The point source inventory data will be extracted again in 

the spring of 2014 for the adoption of the EI State Implementation Plan (SIP) revision. Site level 

2011 NOx and VOC emissions data will be summarized and provided in an appendix for 

adoption. This second extract will account for revisions submitted on or before March 31, 2014 

that have been reviewed, approved, and entered into STARS. Further information, including 

2011 unit-level NOx and VOC emissions data, is available upon request. 

2-1 
A summary of the 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 VOC Emissions for Point 

Sources (tons per day and tons per year), and Table 2-2: DFW 2011 NOx and VOC Emissions 

for Point Sources (tons per day and tons per year). 

2.2.2 HGB Point Source EI 

Table 2-1: HGB 2011 NOx and VOC Emissions for Point Sources (tons per day and 

tons per year) " ~ 

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 and VOC Emissions for Point Sources (tons per day and 

tons per year) 

· 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 and processes 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 

2-2 
calculated and recorded on the 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 underground tank filling, and vehicle refueling 

operations. Examples of fuel combustion emissions sources include: stationary source fossil fuel 

combustion, outdoor refuse burning, and structural fires. With some exceptions, area source 

emissions are calculated by multiplying an established emissions factor (emissions per unit of 

activity) by the appropriate activity or activity surrogate responsible for generating emissions. 

Population is one of the more commonly used activity surrogates for area sources. Other activity 

data include the amount of gasoline sold in an area, employment by industry type, and crude oil 

and natural gas production. 

2.3.1 Area Source EI Development 

The 2011 area source EI was developed per the AERR reporting requirements. The 2011 EI was 

developed using a combination of methodologies and data: EPA-generated Els, TCEQcontracted projects, TCEQ staff projects, 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:/ /www.economy.comjdefault.asp) and Annual Energy Outlook 

(AEO). 

The EPA developed Els for states to use for many source categories as part of the NEI. The 

states access these individual inventories through the EPA's NEI website 

(ftp:/ /ftp.epa.gov /Emislnventory / 2011nei/ doc/). These source categories include but are not 

limited to industrial coatings; degreasing; residential, commercial/institutional, and industrial 

fuel use; commercial cooking; aviation fuel use; and consumer products. For some source 

categories, the TCEQ developed state-specific emissions estimates by acquiring current state 

specific activity data and applying appropriate emissions factors. These source categories 

include but are not limited to: 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 

inventory production categories for the 2011 inventory. The improvements included the 

development and refinement of a 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 of the oil and gas 

emissions calculator can be found in Appendix A: Characterization of Oil and Gas Production 

Equipment and Develop 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 in Appendix 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 VOC Emissions for Area Sources (tons per day and tons per year). 

2-3 
Table 2-3: HGB 2011 NOx and VOC Emissions for Area Sources (tons per day and 

tons per year) 

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 DFW Area Source EI 

County-level totals from the 2011 area source EI for the DFW area are presented in Table 2-4: 

DFW 2011 NOx and VOCEmissionsfor Area Sources (tons per day and tons per year). 

Table 2-4: DFW 2011 NOx and VOC Emissions for Area Sources (tons per day and 

tons per year) 

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 of a diverse 

collection of equipment, many of which are powered by 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 

2-4 
sources 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 of the EPA's latest NONROAD 2008a model, called the Texas 

NONROAD (TexN) model, was used to calculate emissions from all non-road mobile source 

equipment and recreational vehicles, with the exception of airports, locomotives, CMVs, and 

drilling rigs. The TexN model allows TCEQ staff to replace the EPA NONROAD model's default 

data with more specific local survey data per EPA recommendations. Several equipment survey 

studies have been conducted which focused on various equipment categories operating in 

different areas in Texas. The resulting survey data are used as inputs to the TexN model to more 

accurately estimate non-road emissions for the state of Texas. The 2011 non-road category EI 

development used the same methodology found in the report Development of 2008 Annual and 

Ozone Season Daily Emissions Inventories and Activity Data for Non-road Sources within the 

Texas NONROAD Model (TexN). A copy of the ERG report and associated inputs and 

meteorological data are provided in Appendix C: Development of 2008 Annual and Ozone 

Season Daily Emissions Inventories and Activity Data for Non-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 Federal Aviation 

Administration's Emissions and Dispersion Modeling System (EDMS) was used to 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 of methods and procedures 

used in developing HGB area 2011 airport EI can be found in Appendix D: Development of 

Statewide Annual Emissions Inventory and Activity Data for Airports. Documentation of 

methodology and procedures used to develop the DFW airport Eis can be found in Appendix E: 

Development of Annual and Emissions Inventories and Activity Data for Airports in the 12-

County Dallas-Fort Worth Area. 

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 Maritime Administration. 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 of methodologies and procedures used in developing the CMV Eis can be found 

in Appendix F: Development of 2011 Statewide Toxics and Actual Annual and Ozone Season 

Weekday Emissions Inventories for Commercial Marine Vessels. 

The 2011 EI for the drilling rig diesel engines were developed as part of a statewide EI 

improvement study. Well activity data were obtained through the acquisition ofthe "Drilling 

Permit Master and Trailer" database from the Railroad Commission of Texas (RRC) and 

through a survey of oil and gas exploration and production companies, which was used to 

develop improved drilling rig emissions characterization profiles. Documentation of methods 

and procedures used in developing the drilling rig diesel engine Eis can be found in Appendix G: 

2-5 
Development ofTexas Statewide Drilling Rigs Emissions Inventories for the Years 1990, 1993, 

1996, and 1999 through 2040. 

The 2011 Texas locomotive EI includes Class I, II, and III locomotive activity and emissions by 

rail segment for all counties within Texas. Locomotive line haul and yard activity data were 

compiled from companies operating in Texas to create a county-level Class I line haul inventory. 

Data developed by Eastern Regional Technical Advisory Committee in collaboration with the 

Federal Railroad Administration, the American 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 of fuel used by 

railroads, data compiled by ASLRRA 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 on the 

United States Energy Information Administration's latest AEO, 2008 fuel usage values were 

grown to estimate 2011 emissions. Documentation of methods and procedures used in 

developing the locomotive Eis can be found in Appendix 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 VOC Emissions for 

Non-road Categories (tons per day and tons per year). 

Table 2-5: HGB 2011 NOx and VOC Emissions for Non-road Categories (tons per 

day and tons per year) ~~ . 

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 DFW Non-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: DFW 2011 NOx and VOC Emissions for 

Non-road Categories (tons per day and tons per year). 

2-6 
Table 2-6: DFW 2011 NOx and VOC Emissions for Non-road Categories (tons per 

day and tons per year) .. 

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 of automobiles, trucks, motorcycles, and other motor 

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 estimated for vehicle engine exhaust. Evaporative hydrocarbon emissions 

are estimated for the fuel tank and other evaporative leak sources on the vehicle. To calculate 

emissions, both the rate of emissions per unit of activity (emissions factors) and the number of 

units of activity must be determined. The emissions factors for on-road mobile sources are 

determined using models developed and approved by the 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 output from the highway 

performance monitoring system, and speed models. 

2.5.1 On-road Mobile 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 can be expected when a SIP is revised if there have been changes in any of the 

underlying tools or data used in the 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 of transportation 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 opportunity to 

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 of the onroad fleet, and the emission rates are multiplied by the activity level of each vehicle type or 

source use type. 

2-7 
During the development phase of the 2011 AERR inventories, EPA released multiple versions of 

the MOVES model. EPA prefers that states use the latest version of MOVES that is available. Per 

EPA guidance, if states have completed significant work on an inventory for periodic reporting 

or for a SIP when a new version of MOVES is released, such work can be completed and 

submitted to EPA using the previous version of the model. EPA released MOVES2010a in 

August of 2010 and MOVES2010b in April 2012. EPA originally released MOVES2010b in April 

2012 to allow MOVES users to benefit from several improvements to general model 

performance relative to MOVES2010a. The difference in the 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 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 2011 AERR emissions estimates for all pollutants, precursors or taxies are not affected 

whether MOVES2010a or MOVES2010b (April2012) is used. The inventories for reporting 

under the AERR for which significant work had been completed by April 2012 were developed 

using MOVES2010a. The AERR inventories developed after April 2012 used MOVES2010b 

(April2012). The AERR 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, or the default information may be 

modified to simulate the driving behavior, meteorological conditions, and vehicle characteristics 

specific to a particular area. Because modifications to the inputs significantly influence the 

emissions factors calculated by the MOVES model, input parameters reflecting local conditions 

were used instead of relying on national default values for the development of the 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 of miles 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 by the MOVES model 

must be multiplied by the level of vehicle activity. On-road mobile source emissions factors are 

expressed in units of grams per mile; therefore, the activity information that is required to 

complete the inventory calculation is vehicle miles traveled (VMT) in units of miles per day. The 

level of vehicle travel activity is developed using a travel demand model (TDM) run by the Texas 

Department of Transportation or by the local metropolitan planning organizations. The TDMs 

are validated against a large number of ground counts, i.e., traffic passing over counters placed 

in various 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 of traffic counters. 

In addition to the number of miles traveled on each roadway link, the speed on each roadway 

type or segment is also needed to complete an on-road EI. Roadway speeds, required inputs for 

the MOVES model, are calculated by using the activity volumes from the TDM and a postprocessor speed model. 

A summary of the annual and daily DFW and HGB 2011 on-road mobile source NOx and VOC 

emissions levels is presented in Sections 2.5.2: HGB On-road Mobile Source EI and 2.5.3: DFW 

On-road Mobile Source EI. The inventory development methods, MOVES inputs, and the 

results are documented in Appendix I: Development of 2011 On-road Mobile Source Actual 

2-8 
Annual and Summer Weekday Emissions Inventories for All Texas Counties (Exceptfor 12 

Counties in the Dallas-Fort Worth Area), and Winter Weekday Emissions Inventories for El 

Paso: Houston-Galveston-Brazoria Area and Appendix J: Development of 2011 On-road 

Mobile Source Actual Annual and Summer Season Weekday Emissions Inventories for 12 

Counties in the Dallas-Fort Worth Metropolitan Statistical Area- Amendment. 

2.5.2 HGB On-road Mobile 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 of the MOVES 

model. All control strategies implemented by 2011 were included in the input to the EI 

development for the 2011 on-road mobile source base year EI. Those controls include the effects 

of the federal motor vehicle control program (FMVCP), reformulated gasoline (RFG), the HGB 

vehicle I/M program, and the Texas Low Emission Diesel (TxLED) program. 

The VMT 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 of the EI is presented in Table 2-7: HGB 2011 NOx and VOC Emissions for 

On-road Mobile Sources (tons per day and tons per year). Complete documentation of the 

development of the EI and details on MOVES model inputs are provided in Appendix I. 

Table 2-7: HGB 2011 NOx and VOC Emissions for On-road Mobile Sources (tons per 

day and tons per year) 

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-road Mobile 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 of the MOVES 

model. All control strategies implemented by 2011 were included in the input to the EI 

development for the 2011 on-road mobile source base year EI. Those controls include the effects 

of the FMVCP; RFG, the DFW vehicle I/M program (excluding Wise County), and the TxLED 

program. 

The VMT was developed using the latest activity estimates from the DFW TDM 2011 network. 

The activity levels used to calculate the EI reflect the 2011 roadway network with 2011 VMT and 

speeds. A summary of the EI is presented in Table 2-8: DFW 2011 NOx and VOC Emissions for 

On-road Mobile Sources (tons per day and tons per year). Complete documentation of the 

development of the EI and details on MOVES model inputs are provided in Appendix J. 

2-9 
Table 2-8: DFW 2011 NOx and VOC Emissions for On-road Mobile Sources (tons 

per day and tons per year) 

--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 include VOC emissions from crops, lawn grass, and trees as well as a small 

amount of NOx emissions from soils. Plants are sources ofVOC such as isoprene, monoterpene, 

and alpha-pinene. Biogenic emissions are estimated by the EPA using the EPA's Biogenic 

Emissions Inventory tool. 

2.7 EMISSIONS SUMMARY 

The 2011 NOx and VOC 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 

VOC Emissions (tons per day and tons per year) and Table 2-10: Summary of DFW 2011 NOx 

and VOC Emissions (tons per day and tons per year). 

Table 2-9: Summary of HGB 2011 NOx and VOC Emissions (tons per day and tons 

per year) ···-····· . - ~ -~.- .. 

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 

2-10 
Table 2-10: Summary ofDFW 2011 NOxand VOC Emissions (tons per day and tons 

per year) 

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 
Appendices Available Upon Request 

Nina Castillo 

SIP Project Manager 

nina.castillo@tceq.texas.gov 

512.239-4415 
TESTIMONY 
Reference Number 

W-1 

W-2 

W-3 

W-4 

INDEX OF WRITTEN TESTIMONY 

Submitted by 

Cyrus Reed and Neil Carman, Lone Star 

Chapter of the Sierra Club; 

Brandt Mannchen, Houston Regional Group of 

the Sierra Club (similar to 0-1); 

Molly Rooke, Dallas Group of the 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 of Wise 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-county nonattainment 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 of this 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 entirely dependent upon an accurate EI. In our view 

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 by TCEQ and by contractors hired by TCEQ to better assess emissions 

from these sources, we are concerned that the 2011 base year is inaccurate, particularly given 

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 only that 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 

appropriately recognized as a valid control strategy. 

Our concern about the failure of this EI and ultimately the 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 continuously been 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. For the 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. 17 4, page 55039, EPA Approval 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 by EPA (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 how the 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 day weekday NOx during ozone season of 108.18 times 244 days you get 26,395.92 

tons per year and not the 39,941.94 tons per year 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, dry cleaners, 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 how the 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 by category with 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 County are reflective of the total? VOC 

emissions in 2011 or not. 

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 of this information, but it is not clearly stated. 

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 easy to determine both the amount and source 

of any emissions, and how that number was 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 per type 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 directly to 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 methodology is 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 occur today. 

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 under this 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 

only lists 10,535 tons of VOC. If this 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 if these 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, our non-attainment areas, and into other states and then circulate back into Texas and 

our nonattainment areas. 

The same inadequate EI exists for offshore oil and gas air emissions because the study that 

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 

6 
county-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 better because 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 oiV gas wells 

have been drilled since that time and engines may also 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 

show wells 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 

oiV gas 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 electricity for 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 oiV gas 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 many pipelines 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 by averaging 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. 

It would be more conservative and better for the EI to assume an 85% control efficiency to 

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 verify what is said and . . not JUSt 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%. Seventy percent 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 survey of pump jacks as suggested by ERG. 

15) Page 4-22, TCEQ admits that emission estimate may be lower than actual emissions at 

area-source dehydrators. If this is so then TCEQ should investigate this and correct it if true 

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 clearly stated. 

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 they require permits to flare or vent 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 they were 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 DFW or 

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 TRC website." If this 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. If the 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 MOU or be sure than an existing MOU is updated for the TCEQ and TRC 

to efficiently cooperate 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 DFW areas 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 by point sources (larger processing units) or whether TCEQ actually projected 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 they lack 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 many times throughout this memo the phrase "The CENRAP 

data can also be used as a QA check to 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 how it 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 of this study. 

25) Page A-33, TCEQ states that "control of waste VOC via flaring would control VOC by 

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 efficiency to 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, 

particularly in the Dallas-Fort Worth NAA counties 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 only measure 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 study basically removed any data 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 clarify how these 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 may want 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 how widely varied 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/bbl to 31.5lbs/bbl depending on 

the test or measurement technique used. Interestingly, the emissions factor being used for 

Wise County by TCEQ 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 

11 
indicated 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 separately and reported in the EI. 

Appendix F, Development of 2011 Statewide Toxics and Actual Annual and Ozone 

Season Weekday 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 or earlier 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 accurately estimate 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 

better EI is produced for CMVs. 

12 
7) Page 2-5, Appendix F, TCEQ states "slight differences in activity from 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 "Unfortunately the 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 underway operations 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 Navy base 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 may be relatively small and their impact on coastal air 

quality will be limited." This assumption about Coast Guard operations must be verified. 

No assumptions when they can be easily verified. 

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. 

13 
14) 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 of the 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 

rather than relying upon assumptions. 

16) Page 3-17, Appendix F, TCEQ states "arrived at site on January 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 of Texas 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 today remains 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 may be overly optimistic. 

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 very high horsepower requirements." 

Thus, the study shows that in the leading county for NOx emissions - Tarrant - the amount 

of NOx emissions being reduced from 3,500 NOx in 2008 to less than 1,000 Tons by 2011. 

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 accurately reflect 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 activity due to the expansion in the Eagle Ford and Permian Basins. 

The Sierra dub appreciates this opportunity to comment. Thank you. 

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 Quality Committee 

Houston Regional Group of the Sierra Club 

5431 Carew 

Houston, Texas 77096 

713-664-5962 

brandtshnfbt@juno.com 

Molly Rooke 

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 of this 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 of the 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 thrive 
economically. 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 your job 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 of those 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 dirty jobs 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 of their 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 of the 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 earn 
our 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 your job? 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-Galveston Area 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 

Submitted by 

Brandt Mannchen, Houston Sierra Club 

(similar to W-1) 

January 16, 2014, 2:00p.m. -Arlington City Hall 

Submitted by 

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 and the Dallas Group 

of the Sierra Club (similar to W-1) 

Lorraine Levine 
1 

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. 
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1 A P P E A R A N C E S 

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3 Nina Castillo, Air Quality Division 

4 Walker Williamson, Air Quality Division 

5 Lindley Anderson, Air Quality Division 

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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 talk 
4 

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 include 
6 

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're 
7 

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 gas 
8 

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 shut 
9 

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 a 
11 

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. 

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(Proceedings concluded at 2:22p.m.) 
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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 

Short Title: EI SIP Revision for the 2008 Eight-Hour Ozone Standard for 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-Fort Worth (DFW) Areas 

Name Representing Presenting Oral Testimony? 

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Texas Commission on Environmental Quality 

Public Hearing Registration 

Date: January 14, 2014 

Time: 2:oop.m. 

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

Short Title: EI SIP Revision for the 2008 Eight-Hour Ozone Standard for 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-Fort Worth (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 - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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 

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Integrity Legal Support Solutions 

www.integrity-texas.corn 

2 
TCEQ - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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 
TCEQ - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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 

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4 
TCEQ - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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 
TCEQ - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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 
TCEQ - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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. 

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7 
TCEQ - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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 

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8 
TCEQ - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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 heal thy. 

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 
TCEQ - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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 

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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 

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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. 

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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 

2 0 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. 

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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 

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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. 

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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. 

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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 air shed. 

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 

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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 

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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 

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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 

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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 

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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 

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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 

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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 

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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 

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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 

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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 

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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 

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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 

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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 

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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 

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TCEQ - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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 

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TCEQ - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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 

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34 
TCEQ - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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 

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TCEQ - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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. 

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TCEQ - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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, 

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and 

37 
TCEQ - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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 

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TCEQ - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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 

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TCEQ - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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 

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TCEQ - Rule Project No. 2013-016-SIP-NR - 1/16/2014 

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 

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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 

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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. 

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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 

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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 

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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 

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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 

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47 
Texas Commission on Environmental Quality 

Public Hearing Registration 

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

Date: January 16,2014 

Time: 2:00p.m. 

Short Title: 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 

- 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-Fort Worth (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 

Short Title: 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-Fort Worth (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~ 

<;,._.) 

;( t)VuOfi-N--- X @L~{V ~ d~r e( o~.___&r.l-/J-4 (3~ ' 

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 of Air 

Docket No.: 2013-1682-SIP 

Subject: Commission Approval for Adoption of the 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 and reason(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 

per billion) 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 of actual emissions from all sources," within two years of the effective 

date of nonattainment designations for the ozone NAAQS. Through the EPA's 

Implementation of the 2008 NAAQSfor Ozone: State Implementation Plan 

Requirements; Proposed Rule (proposed 2008 ozone standard SIP requirements rule), the 

EPA interprets these FCAA requirements to be due within two years of the July 20, 2012 

effective date of designations for the 2008 eight-hour ozone NAAQS, which would be July 

20, 2014 (78 FR 34178). 

Scope of the SIP revision: 

A.) Summary of what the 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 by the 

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 existing Air Emissions Reporting 
Commissioners 

Page2 

June 13, 2014 

Re: Docket No. 2013-1682-SIP 

Requirements (AERR) Rule. The 2011 AERR EI has been developed for many pollutants 

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 by federal regulations or state statutes: 

The FCAA requires that Eis be prepared for nonattainment areas generally, and provides 

for specific requirements that apply in ozone nonattainment areas. Because ozone is 

photochemically produced in the atmosphere when VOC mix with NOx in the presence of 

sunlight, the Texas Commission on Environmental Quality (TCEQ) must compile 

information on the important sources of these precursor pollutants. The EI identifies the 

source types present in an area, the amount of each pollutant emitted, and the types of 

processes and control devices employed at each plant or source category. The Eis provide 

data for a variety of air 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 inventory of 

emissions ofVOC and NOx for an area is summarized from the estimates developed for 

four general categories of emissions 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 of air emissions of both criteria and hazardous air 

pollutants from all air emissions. As directed by the AERR, the NEI includes statewide 

coverage, including specific emissions data for the eight-hour ozone nonattainment areas 

in Texas. Annual and summer day emissions are reported on a three-year cycle for the 

AERR. 

C.) Additional staff recommendations that are not required by federal rule or 

state statute: 

None 

Statutory authority: 

The EI SIP revision is adopted under Texas Health and Safety Code, §382.002, Policy and 

Purpose; §382.011, General Powers and Duties; §382.012, State Air Control Plan; and 

§382.014, Emission Inventory. The EI SIP revision is also adopted under the commission's 

general authority under Texas Water Code, §5.102, General Powers and §5.105, General 

Policy. 

Effect on the: 

A.) Regulated community: 

There will be no new effect on the regulated community. Regulated entities are already 

required to submit EI information to 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.) Agency programs: 

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 public hearings on the proposed SIP revision in Houston on January 

14, 2014 and in Arlington on January 16, 2014. Notice of public hearing was published in 

the Texas Register and the Austin American-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 the Arlington hearing from 

DFW Regional Concerned Citizens, Downwinders at Risk (Downwinders), the Lone Star 

Chapter of Sierra Club (Sierra Club), Public Citizen, and five citizens. The TCEQ received 

written comments from DFW Regional Concerned Citizens, the Sierra Club, and two 

citizens. A summary of the comments and the TCEQ response is provided as part of this 

SIP revision in the Response to Comments. 

Generally, the comments concerned the development of the EI and questioned the 

accuracy of the 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 of the 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 and were 

extracted again on April1, 2014 in order to assure that the most up-to-date emissions were 

available for the adoption of this SIP revision. Site-level 2011 NOx and VOC emissions data 

were summarized and provided in a new Appendix K: Point Source HGB and DFW Site 

Level Emissions. This second extract accounts for revisions submitted on or before March 

31, 2014 that have been reviewed, approved, and entered into the State of Texas Air 

Reporting System (STARS). 
Commissioners 

Page4 

June13,2014 

Re: Docket No. 2013-1682-SIP 

In response to comments received, the 2011 inventory was improved by updating the 

projected 2011 drilling activity data from the study Development Of Texas Statewide 

Drilling Rigs Emission Inventories For The Years 1990,1993, 1996,And 1999 Through 

2040 with actual 2011 drilling activity data obtained from the Railroad Commission of 

Texas (RRC). The TCEQ recently reviewed the number of active oil and gas wells used to 

develop the 2011 inventory and made an adjustment to the emissions estimates based on 

this review. Originally, the TCEQ used the total number of active oil and gas wells as of the 

end of 2011 with the assumption that all ofthe wells were active for the entire year. For the 

revised emissions estimates, wells completed in 2011 were assumed to be active on average 

for half the year instead of the entire year. In addition, emissions estimates from gasoline 

bulk terminals and gas plants were revised based on the recently completed August 2013 

ERG study, Emission Inventory of Bulk Gasoline Terminals and Bulk Gasoline Plants. 

Emissions estimates from oil and gas well heaters were revised based on the August 2013 

ERG study, Upstream Oil and Gas Heaters and Boilers. 

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

Emissions for Area Sources and Table 2-4: DFW 2011 NOx and VOC Emissions for Area 

Sources of the EI SIP revision have been updated. For the HGB area, the 2011 annual NOx 

emissions estimate for area sources decreased from 8,617.31 tons per year (tpy) to 8,577.07 

tpy, and the VOC emissions estimate decreased from 107,305-48 tpy to 104,943.91 tpy. For 

the DFW area, the 2011 annual NOx emissions estimate for area sources decreased from 

16,639.03 tpy to 15,175.20 tpy, and the VOC emissions estimate decreased from 97,314.07 

tpy to 96,604.76 tpy. The drilling rig emissions estimates in Table 2-5: HGB 2011 NOx and 

VOC Emissions for Non-road Categories and Table 2-6: DFW 2011 NOx and VOC 

Emissions for Non-road Categories of the EI SIP revision were updated using the 2011 

drilling activity data obtained from the RRC. For the HGB area, the annual NOx emissions 

estimate for the non-road category decreased from 42,020.62 tpy to 41,946.29 tpy, and the 

VOC emissions estimate decreased from 18,822.77 tpy to 18,820.83 tpy. For the DFW area, 

the annual NOx emissions estimate for the non-road category increased from 37,539.51 tpy 

to 39,272.29 tpy, and the VOC emissions estimate increased from 16,914.67 tpy to 

16,998·73 tpy. 

Potential controversial concerns and legislative interest: 

None 

Does this SIP revision affect any current policies or require development of 

new policies? 

No 

What are the consequences if this SIP revision does not go forward? Are there 

alternatives to SIP revision? 

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 of the 

July 20, 2012 effective date of designations 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 of stationary sources in the 

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 would jeopardize approval of future nonattainment plans 

for the HGB and DFW ozone nonattainment areas, which must be based 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 by July 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 by January 2015. 

However, the January 2015 deadline would not allow sufficient time to complete all SIP 

required elements. 

Key points in the adoption SIP revision schedule: 

Anticipated Adoption 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, Staff Attorney, (512) 239-0469, Environmental Law Division 

Attachments 

cc: Chief Clerk, 2 copies 

Executive Director's Office 

Marshall Coover 

Tucker Royall 

John Bentley 

Office of General Counsel 

Brian Foster 
• RESPONSE TO COMMENTS RECEIVED REGARDING 

THE 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 

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 at the Houston-Galveston Area 

Council of Governments and on January 16, 2014 at 2:00p.m. in Arlington at the Arlington City 

Hall Building. Oral comments were received at the Houston hearing from the Houston Regional 

Group of the Sierra Club (Sierra Club). Oral comments were received at the Arlington hearing 

from DFW Regional Concerned Citizens, Downwinders at Risk (Downwinders), the Lone Star 

Chapter of Sierra Club (Sierra Club), Public Citizen, and five citizens. 

The comment period 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 of Contents ...... " ................................................................................................................................ 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 to reduce ozone levels. Downwinders linked the 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 commented that the ozone 

design value has increased due to the Barnett Shale oil and gas growth. 

Page 1 of 34 
Downwinders, Public Citizen, and the Sierra Club commented that emissions from large sources 

outside the DFW nonattainment areas contribute to the area's nonattainment. Public Citizen 

recommended the 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 stated that the 

cumulative emissions from areas outside the Dl<W 2008 eight-hour ozone nonattainment area, 

weather, and traffic patterns should all be included in this EI SIP revision, and that emissions 

from one area should not be allowed to influence the air quality of another area. 

The purpose of this EI SIP revision is to satisfy the Federal Clean Air Act (FCAA), 

§172 and §182 EI requirements for the HGB and DFW nonattainment areas under 

the 2008 eight-hour ozone NAAQS. According to FCAA, §172(c)(3) and §182(a)(1), 

state~ are required to submit a comprehensive, accurate, and current EI for 

nonattainment areas within two years of the effective date ofnonattainment 

designations for the ozone NAAQS. This SIP revision is intended to meet those 

requirements and is not intended to demonstrate attainment of the 2008 ozone 

NAAQS. This SIP revision includes emissions from the 10-county DFW and the 

eight-county HGB 2008 eight-hour ozone nonattainment areas only, as required by 

the FCAA and United States Environmental Protection Agency (EPA) guidance. 

The TCEQ is currently developing an AD SIP revision for the DFW 2008 eight-hour 

ozone nonattainment area. Separate Eis have been developed for the 2006 base 

case modeling, and 2018 future case inventories for the 2018 future case 

attainment demonstration modeling. In developing the AD SIP revision modeling 

emissions, the TCEQ is using the most current EI data and growth assumptions for 

aU categories, including oil and gas. Comments applicable to the AD inventories, 

ozone modeling, and control strategies should be made during the public comment 

period for the AD SIP revision. Comments concerning classification and AD results 

are outside the scope of this EI SIP revision. No changes were made as a result of 

these comments. 

Sierra Club commented that the classifications for DFW and HGB 2008 eight-hour ozone 

nonattainment areas are incorrect. Sierra Club also stated that the Beaumont-Port Arthur, TylerLongview and San Antonio metropolitan areas have all violated the existing 75 parts per billion 

(ppb) standard and should be designated nonattainment under the 2008 eight-hour ozone 

standard. Public Citizen commented that counties with coal or gas and drilling activities should 

be added to ozone nonattainment areas. 

Public Citizen, Sierra Club, and one individual suggested that the TCEQ should have included EI 

data from ozone attainment areas in this SIP revision. 

Sierra Club, DFW Regional Concerned Citizens, and two individuals commented that the TCEQ 

has never over-controlled because areas have been out of attainment for a long period of time 

and the ozone standard has never been attained. Downwinders commented that the TCEQ is not 

interested in reducing air pollution for the public. One individual favored strong protection for 

keeping the air clean. 

The purpose of this SIP revision is to fulfill the FCAA, §172 and §182 EI 

requirements for the HGB and DFW nonattainment areas under the 2008 eighthour ozone standard. The FCAA requires states to submit EI information for all 

relevant sources within each area designated by the EPA as nonattainment for a 

Page 2 of 34 ~' 

I 
0 NAAQS, so no EI data was included from attainment areas. Similarly, no change 

was made to address attainment designation status as such an action is outside the 

scope of this SIP revision. 

DFW Regional Concerned Citizens commented that political pressure should not deter the 

development of a comprehensive inventory that will be used in granting future permits, and that 

the TCEQ will not be overreaching their authority by enforcing the FCAA. 

The purpose of this SIP revision is to satisfy the FCAA, §172 and §182 EI 

requirements for the HGB and DFW 2008 eight-hour ozone nonattainment areas 

under the 2008 eight-hour ozone NAAQS. The TCEQ takes its duties to Texas 

citizens very seriously and believes that this SIP revision meets FCAA requirements 

and guidance included in the EPA's Implementation of the 2008 NAAQSfor Ozone: 

State Implementation Plan Requirements; Proposed Rule {proposed 2008 ozone 

standard SIP requirements rule) to submit a comprehensive, accurate, and current 

EI for ozone nonattainment areas. Comments regarding the permitting process are 

outside the scope of this EI SIP revision. No changes were made as a result of these 

comments. 

One individual commented that that 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 ofthe year. The individual also commented that that summer 

air conditions are worsening, as evidenced by an ozone day that occurred in September 2013. 

The purpose of this SIP revision is to satisfy the FCAA, §172 and §182 EI 

requirements for the HGB and DFW nonattainment areas under the 2008 eighthour ozone NAAQS. While these comments are outside the scope of this SIP 

revision, the TCEQ does not agree that the commenter's analysis is the appropriate 

way to investigate or compare the air in an area to the standards set by the EPA. For 

example, days when eight-hour average ozone is greater than or equal to 84 ppb 

would also count as days above 75 ppb. In other words, days above 84 ppb cannot 

be totaled with days above 75 ppb because that would result in the double counting 

of days. 

Trend analysis ofhigh ozone days is a more effective way to assess whether the 

quality of the air in an area is improving or deteriorating over a long period of time. 

High ozone day yearly trends in the DFW area show that days with eight-hour 

ozone greater than 75 ppb decreased by 49%, from 2000 (63 days) to 2013 (32 

days). Similarly, days with ozone greater than 84 ppb decreased by 75%, from 2000 

(36 days) to 2013 (9 days). Please note data from 2013 in this response and 

following responses is preliminary and subject to change. 

Additionally, another means to examine the air quality is to consider how an area's 

air pollution concentrations compare to the NAAQS. The current NAAQS for 2008 

eight-hour ozone is set at 75 ppb. The design value is used to compare the air in an 

area to the NAAQS. For ozone, the design value is calculated by taking the threeyear average of the fourth-highest eight-hour ozone concentration at each monitor 

in the area. This calculation removes the year-to-year variability from factors such 

as meteorology and number of monitors and provides an effective means for 

evaluating ozone trends. Although the 2013 design value in the DFW area is above 

Page 3 of34 
the NAAQS at 87 ppb, it has decreased by 15% from 2000, when the design value 

was 102 ppb. Furthermore, the percentage of monitors with valid design values 

which measured above the NAAQS has decreased by 20% from 2000 through 2013. 

Also, the ozone forecast season in the DFW area runs from March through October, 

and high ozone days occurring in September are not uncommon, and therefore are 

not indicative of worsening ozone pollution. The ozone forecast seasons do not 

necessarily correspond to the "ozone seasons" defined for regulatory purposes by 

the EPA. No changes were made as a result ofthese comments. 

The Sierra Club commented that while overall air quality has improved, Texas has not attained 

the ozone standard. One individual stated that the DFW area had been designated as an ozone 

nonattainment area for many years and has not yet attained the ozone standard. Public Citizen 

and one individual commented that ozone concentrations have been increasing in the DFW 

ozone nonattainment area. 

The DFW area has made considerable improvement in air quality. For example, 

between 2000 and 2013, the 1997 eight-hour ozone design value has trended 

downward 15 ppb from 102 ppb to 87 ppb. The number ofDFW eight-hour ozone 

exceedance days has also decreased from 36 to nine from 2000 to 2013. 

The TCEQ appreciates the acknowledgement of improving air quality, but disagrees 

that Texas has failed to ever attain the ozone standard. Despite the challenges of 

growing population, the TCEQ's air quality planning efforts have resulted in 

significant air quality improvements, including attainment of the ozone standard in 

several areas of the state. In 2008, the EPA issued a determination that the DFW 

four-county one-hour ozone nonattainment area had attained the one-hour NAAQS 

based on verified 2004 through 2006 monitoring data and supported by 2007 

through 2008 monitoring data. 

The EPA has redesignated the Beaumont-Port Arthur ozone nonattainment area to 

attainment for the 1997 eight-hour ozone standard, and the area is currently 

monitoring attainment of the 2008 eight-hour ozone standard. The EPA has 

redesignated both the El Paso County and Victoria County one-hour ozone 

nonattainment areas to attainment for both the 1997 and 2008 eight-hour ozone 

standards. El Paso County has monitored attainment of the one-hour ozone 

standard since 1998, and the EPA redesignated Victoria County as attainment of 

the one-hour ozone standard on May 8, 1995· The HGB area is currently 

monitoring attainment of the one-hour ozone standard. 

Overall 1997 eight-hour ozone design values have been trending downward since 

2000 for both the DFW and HGB ozone nonattainment areas, and the state has 

seen a 24% decrease in the three-year average of the statewide maximum fourth 

highest eight-hour ozone concentrations from 2000 through 2013. No changes 

were made as a result of these comments. 

One individual expressed concern about poor air quality in the DFW nonattainment area. DFW 

Regional Concerned Citizens commented that the TCEQ is not doing its job to protect clean air. 

Public Citizen commented that more stringent air quality standards than the EPA has set should 

Page 4 of34 
0 

.. I 

be applied in order to improve air quality. Two individuals expressed consideration of moving 

from the DFW area if air quality does not improve. 

One individual expressed concern that the TCEQ does not work in a timely manner to protect 

public health and the environment. DFW Regional Concerned Citizens and one individual 

commented that the TCEQ should do more to protect the environment and not allow itself to be 

influenced by politics. 

The TCEQ strives to protect the state's human and natural resources consistent 

with sustainable economic development. The purpose of this SIP revision is to 

satisfy the FCAA, §172 and §182 EI requirements for the HGB and DFW 

nonattainment areas under the 2008 eight-hour ozone NAAQS. The DFW area has 

made considerable improvement in air quality. For example, between 2000 

through 2013 the eight-hour ozone design value has trended downward 15 ppb. The 

number of days in DFW where the daily eight-hour ozone peak exceedanced 84 ppb 

has also decreased from 36 to nine over the same period. The percentage of 

monitors in the DFW 2008 eight-hour ozone nonattainment area measuring 

nonattainment has decreased by 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 of the public hearings for this SIP revision was provided in the same manner 

as all SIP revision notices, as required by state and federal law. The notice was 

published in the Texas Register as well as the Austin American-Statesman, the 

Fort Worth Star-Telegram, and the Houston Chronicle newspapers. 

The EI SIP revision and appendices were also made available to the public through 

the TCEQ's SIP Hot Topics Web page 

(http://www.tceq.texas.gov/airqualitv/sip/Hottop.html) and the TCEQ's Air 

Pollution from Ozone Web page (http://www.tceq.texas.gov/airquality/sip/criteriapollutants/sip-ozone). All interested persons can subscribe to receive e-mail when 

new information is updated on SIP revision and SIP-related news items on the SIP 

Hot Topics Web page. No changes were made in response to this comment. 

One individual recommended the TCEQ work v-ith other government agencies, elected officials, 

and the regulated community to create new, clean industries. 

The TCEQ's authority in SIP development is limited to air quality control. Creating 

new clean industries is beyond the scope of this EI SIP revision. No changes were 

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 and vigorously pursues compliance with the 

applicable environmental requirements. The TCEQ also pursues enforcement 

against any person or business that is in non-compliance and whose violations 

meet the criteria for referral to enforcement as laid out in the TCEQ's Enforcement 

Page 5 of 34 
Initiation Criteria. All penalties assessed are done so in accordance with the TCEQ's 

Penalty Policy. As indicated previously, this EI SIP revision is solely to address the 

EI requirements in the FCAA. No changes were made in response to this comment. 

The Sierra Club and Public Citizen commented that that the ozone season was not clearly 

defined. 

To clarify the definition of "ozone season" for emissions inventory purposes, the 

TCEQ has included additional information in section 2.2.1 of the EI SIP. Point 

source ozone season emissions are reported by sites for individual units in 

accordance with TCEQ Emissions Inventory Guidelines and cannot be calculated in 

aggregate from the annual emissions. In the Emissions Inventory Guidelines, the 

Emissions Assessment Section uses the definition of ozone season found in 40 CFR 

§51.50 as the 153 day period running from May 1 through September 30. 

Please note the ozone forecast seasons referenced in earlier responses to 

comments do not necessarily correspond to the "ozone seasons" defined for 

regulatory purposes by the EPA. Ozone forecast seasons for different areas of the 

state can be found at:_ 

https://www .tceq.texas.gov /airquality/monops/ ozonefacts.html 

Air Permitting 

DFW Regional Concerned Citizens stated that it had requested permitted emissions on a part per 

thousand basis from the TCEQ, but had not received it. 

The TCEQ authorizes emissions on a mass basis, generally in pounds per hour 

andjor tons per year (tpy). Typically, authorizations do not contain concentrationbased limits, such as parts per thousand, so this information would not be 

available. Site-specific air permitting information can be viewed online at 

https:/ fwebmail.tceq.state.tx.us/gwfwebpub or by contacting the Air Permits 

Division at airperm@tceq.texas.gov. Comments regarding permits are outside the 

scope of this EI SIP revision. No changes were made as a result of these comments. 

DFW Regional Concerned Citizens and one individual stated that current permits authorized 

emissions that have had an adverse health impact on local citizens. DFW Regional Concerned 

. Citizens and one individual further stated that while the community must have jobs, it also must 

remain healthy to actively participate in community life. 

Comments regarding permits are outside the scope ofthis EI SIP revision, which is 

to document emissions within the HGB and DFW 2008 eight-hour ozone 

nonattainment areas. No changes were made as a result of these comments. 

DFW Regional Concerned Citizens and two individuals stated that the TCEQ could not 

adequately assess the impact of permitting new sources on DFW air quality without an accurate 

EI of all source categories. 

The TCEQ agrees that an accurate EI is useful for air quality planning purposes. 

The TCEQ uses the best available information at the time ofinventory development 

and continues to perform EI improvement research. The EI reflects two decades of 

Page 6 of 34 
0 continuous improvement. The TCEQ has performed state-of-the-science studies to 

identify and quantify potentially under-reported emissions sources. These studies 

result in refined emissions factors, activity data, or emissions determination 

methods that are incorporated directly into the development of the appropriate 

inventory source category. These efforts ensure the best possible inventory is used 

for control strategy and SIP development. 

The use of the EI for permitting purposes is outside of the scope of this EI SIP 

revision. However, the TCEQ provides the following information to clarify how EI 

data is used in permitting. When permitting expansions of existing major 

stationary sources (sites), baseline actual emissions (BAE) are established for sites 

using historical emissions data. The BAE is compared to the projected actual 

emissions after the expansion to determine the impact of the proposed project(s). 

Point source EI data may not always be available to establish BAE. If point source 

EI data are used to establish BAE, these data should be the most accurate data 

available for that time period since sites are required to use the best available 

method to determine emissions, such as continuous emissions monitoring data. 

Area (nonpoint) and mobile source inventory data are not typically used in the air 

permitting process, and the FCAA does not require the TCEQ to assess all inventory 

source categories to issue air permits. For certain types of permitting actions, an 

air quality analysis can be performed that demonstrates that authorized emissions 

from a proposed major stationary source will not contribute to a violation of the 

NAAQS. Background ambient concentration data, which encompasses air 

emissions from all sources, may be evaluated during this analysis. No changes were 

made in response to this comment. 

EIAccuracy 

The Sierra Club supports the use of industry-reported data to develop the point source EI. 

The TCEQ appreciates the support. 

DFW Regional Concerned Citizens and one individual stated that the EI needed to be accurate, 

comprehensive, updated, and publicly available. The individual further stated that the TCEQ 

must work with the EPA to establish a reliable inventory. 

The Sierra Club and Public Citizen commented that that the TCEQ has failed to develop an 

accurate inventory for 40 years. The Sierra Club and Public Citizen stated the current inventory is 

too inaccurate to be used for SIP development, especially when considering widespread and 

escalating oil and gas production. Downwinders commented that the lack of accurate inventory 

for oil and gas sources prevents the DFW area from attaining the ozone standard. 

The Sierra Club cited the September 9, 2013 issue of the Federal Register (78 FR 55037), which 

discussed the TCEQ under-estimating highly reactive volatile organic compound (HRVOC) 

emissions, and expressed concern that this inventory similarly underestimates emissions. 

Public Citizen stated that the TCEQ has implemented inadequate control measures in DFW to 

ensure the region attains the ozone standard. The Sierra Club commented that the success of 

Page 7 of 34 
future control measures depends upon an accurate EI, and further stated that inaccurate 

inventories will jeopardize future control measures and attainment of the ozone standard. 

The TCEQ develops the EI in accordance with EPA reporting requirements and 

works closely with the EPA to ensure the inventory is accurate, updated, and 

comprehensive. 

The EI reflects two decades of continuous improvement. The TCEQ has performed 

state-of-the-science studies to identify and quantify potentially under-reported 

emissions sources. These studies result in refined emissions factors, activity data, 

or emissions determination methods that are incorporated directly into the 

development of the appropriate inventory source category. As one example, a 

recent study refined upstream oil and gas industry storage tank emissions factors 

for the state. More information on these studies can be found at: 

http: 1/www. tceq. texas .gov /airquality/airmod/proiect/pj .html. 

The TCEQ disagrees that the inventory is too inaccurate for future SIP and control 

strategy development. For the point source EI, industrial sites subject to the 

TCEQ's reporting requirements submit emissions data using the best available 

method, such as monitoring or measurement 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 tpy of nitrogen oxides (NOx) 

emissions to submit an annual point source EI. Since these emissions thresholds 

are either lower than or equivalent to major stationary source thresholds, the 

TCEQ ensures that a detailed inventory of stationary sources in ozone 

nonattainment areas is collected for ozone photochemical modeling purposes. As 

this SIP revision is not intended to demonstrate attainment, commenting on 

control strategies is outside the scope of this SIP revision. 

Area (nonpoint) and mobile source EI estimates are developed using the best 

available data and emissions determination methods or models available at the 

time. For example, the area source oil and gas inventory uses the current 

production data and well statistics from the Railroad Commission ofTexas (RRC) 

to develop specific county-level estimates. As noted above, the TCEQ has invested 

significant resources in advancing area source inventory development methods. 

The methods TCEQ uses to develop its area source oil and gas inventory serve as a 

model for other agencies. 

The TCEQ disagrees with the statement concerning the inaccuracy of the EI due to 

widespread and escalating oil and gas production. RRC data indicate that Barnett 

Shale gas production declined by approximately 8% from 2012 to 2013 and 

approximately 6% from 2011 to 2013. Drilling permits in the Barnett Shale area 

have experienced more significant declines, decreasing approximately 20% from 

2012 to 2013, and more than 77% from 2008, the peak year ofissued permits. These 

trends indicate that Barnett Shale oil and gas production has most likely peaked 

and is now declining. 

Similarly, RRC production data for the HGB 2008 eight-hour ozone nonattainment 

area indicate an overall decline in oil and gas production from 2003 to 2012 

(decreases of 11% in oil production, 28% in casinghead gas production, 64% in 

Page8of34 -

I 
• natural gas production, and 63% in condensate production). RRC production data 

for 2013 are preliminary at the drafting of this SIP revision, but overall decreases 

from 2003 to 2013 are still reflected, with the exception of oil production; for which 

preliminary data indicate a modest 3% increase from 2003 values. 

Major stationary (point) sources are the largest emitters of HRVOC emissions. The 

TCEQ annually updates and publishes a regulatory guidance document, Emissions 

Inventory Guidelines, to ensure accurate determination of emissions, including 

HRVOC emissions, reported by point sources. For several HRVOC emissions 

sources in the HGB 2008 eight-hour ozone nonattainment area, Chapter 115. 

Subchapter H, Divisions 1 through 3, requires monitoring or measurement of 

HRVOC emissions or process streams; these data are required to be used to 

determine and report emissions for the point source EI. For other HRVOC 

emissions sources, if monitoring or measurement data are not available, emissions 

estimates are based upon the most recent available accepted method, as noted in 

the September 9, 2013 issue oftheFederalRegister (78 FR55040). 

If these best available emissions determination methods still result in a 

discrepancy between the point source EI and ambient monitoring data, the 

difference will be reconciled using the methods such as that commended by the 

EPA in the September 9, 2013 issue of the Federal Register ( 78 FR 55040) and used 

by the TCEQ in the 2010 HGB attainment demonstration SIP revision. The 

commission will also continue to work with all interested stakeholders to improve 

emissions inventory estimation methods. 

In the HGB area, applicable sites in Harris County are required to participate in an 

annual HRVOC market-based cap and trade program. 

The purpose of this SIP revision is to establish the baseline year inventory for the 

2008 eight-hour ozone standard, not to demonstrate attainment of that standard. 

The TCEQ uses the best available information at the time of inventory development 

and continues to perform EI improvement research. These efforts ensure the best 

possible inventory is used for control strategy and SIP development. No changes 

were made as a result of these comments. 

Health Effects 

Two individuals commented about the increased sensitivity of some members of the population 

to the effects of ozone. 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 of asthma medication. DFW Regional Concerned Citizens and one 

individual commented about children not being able to enjoy outdoor activities because oftheir 

respiratory problems. DFW Regional Concerned Citizens and two individuals commented that an 

increase in ozone precursors is causing an increase in asthma and chronic obstructive pulmonary 

disease. 

The TCEQ appreciates the comments related to health effects of ozone and 

economic welfare and is committed to working with area stakeholders to attain the 

2008 eight-hour ozone standard, which is a health-based standard. The primary 

NAAQS are those that the EPA determines are necessary to protect public health, 

Page 9 of34 
including sensitive members ofthe population such as children, the elderly, and 

those with pre-existing conditions. Breathing relatively high levels of ground-level 

ozone may cause acute respiratory problems like cough and respiratory irritation~ 

and may aggravate the symptoms of asthma. Health effects from ozone generally 

can resolve quickly once an individual is no longer exposed to high levels. 

The commenters express the concern that concentrations of ozone precursors (and 

presumably ozone itself) have increased, leading to an increase in asthma and 

chronic obstructive pulmonary disease (COPD). Between 2000 and 2013, the 1997 

eight-hour ozone design value in the DFW area has trended downward 15 ppb. This 

reduction in ozone design value has coincided with significant reductions in ozone 

precursor emissions. Between 2005 and 2011 (the most recent periodic emissions 

inventory year available), VOC emissions have been reduced 16% across aU source 

categories (approximately 29,000 tons), and NOx emissions have been reduced 34% 

across all source categories (approximately 79,000 tons). 

However, although levels of both precursors and ozone have decreased over time, 

diagnosis of asthma continues to increase (see below). As a result, it is not clear 

that there is a definite link between ozone levels and asthma development. 

Regarding COPD, the most recent analysis from EPA indicates that hospitalizations 

for respiratory diseases, including COPD, would not be significantly affected by 

concentrations of ozone lower than the current NAAQS. 

It is important to emphasize that although the causes of asthma are not fully 

understood, there are many factors that influence the development and 

exacerbation of asthma. According to the World Health Organization, one of the 

strongest risk factors for developing asthma is genetic predisposition. In addition, 

indoor allergens (dust mites, pet dander, and presence ofpests such as rodents or 

cockroaches) together with outdoor allergens (pollen and mold), tobacco smoke, or 

other triggers such as cold air, extreme emotions (anger or fear) and physical 

exercise can all provoke symptoms in those with asthma. The Centers for Disease 

Control and Prevention estimates that asthma prevalence has increased over 

recent years. The reason for this increase is unknown, but some scientists have 

suggested changes in exposure to microorganisms (hygiene hypothesis) or the rise 

in sedentary lifestyle (affecting lung health) and obesity (which results in 

inflammation) may be to blame. For additional information on asthma, please 

contact the Texas Department of State Health Services at 512-458-7111. No changes 

were made as a result of these comments. 

Upstream Oil and Gas Industry and EI Trends 

One individual commented that ozone precursor emissions have been increasing in the DFW 

ozone nonattainment area. Downwinders stated that all source categories have reduced air 

pollution in the DFW area except for the oil and gas industry. 

The TCEQ disagrees with these comments. As detailed in the DFW Reasonable 

Further Progress (RFP) SIP Revision for the 1997 Eight-Hour Ozone Standard 

(2010-023-SIP-NR), the overall controlled NOx and VOC EI for the DFW area 

decreased 19% from 2002 to 2012. While VOC emissions did increase 6% during 

this timeframe, NOx emissions significantly declined by 39% during this same 

Page 10 of 34 ,-,. 

I I 
• period. Significant reductions in ozone concentrations have occurred in the DFW 

area. 

Like most of the U.S., the DFW area is NOx-limited with respect to ozone formation, 

which means that NOx emission reductions are far more effective than VOC 

emission reductions at lowering ozone levels. This is particularly true in areas such 

as DFW and most of eastern Texas, which have high amounts of naturally occurring 

VOC from biogenic sources. Most notably, isoprene is emitted by oak trees and is 

highly reactive in the presence ofNOx for forming ozone. 

Each VOC type has a maximum incremental reactivity (MIR) value, which is the 

highest amount of ozone that can be formed per unit ofVOC if a sufficient quantity 

ofNOx is present and the full reaction is allowed to go to completion (i.e., not 

halted by loss of sunlight or absence ofNOx). Additionally, the hydroxyl radical 

(OH) is critical to ozone formation and each VOC type has a reaction rate constant 

(KoH), which is the rate at which the reaction occurs. Provided below is a table of 

these VOC-specific values. 

Natural gas is composed primarily of methane, with the bulk of the remainder 

made up of ethane, propane, and butane. As shown in the table, 1 gram of methane 

will yield 0.0144 grams of ozone, but 1 gram of isoprene will yield 10.61 grams of 

ozone, which is 738 times more ozone created than with methane. Furthermore, 

the reaction rate at which isoprene will make ozone is over 15,000 times faster than 

that for 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 environment without vegetation where no other VOC existed 

besides methane, ethane, propane, and butane, then these lower reactive 

compounds could have an increased relative effect on ozone formation, but it 

would be small. Research done by the University of California at Riverside in this 

area can be obtained from the saprco7.xls spreadsheet available at 

http:/ /www.cert.ucr.edu/ ~carter/SAPRC/. 

Page 11 of34 
Compound MIR KoH Reaction Rate 

Name (grams 0 3/VOC) Ratio to Methane (cm3 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 the VOC EI cannot be attributed entirely to upstream oil and gas 

emissions. As detailed in the DFW RFP SIP revision and the DFW AD SIP Revision 

for the 1997 Eight-Hour Ozone Standard (2010-022-SIP-NR), the area source 

category excluding oil and gas emissions increased overall from 2002 (RFP) and 

2006 (AD) to 2012. The area source inventory includes specific area source 

categories that are population-dependent and increase with population increases. 

Examples include residential fuel combustion, landfills, and vehicle refueling. 

The TCEQ has implemented rules to reduce emissions from sources located at 

upstream oil and gas sites. The East Texas combustion rule, 30 Texas 

Administrative Code (TAC) Chapter 117, Subchapter E, Divisions 2 and 4, limits 

NOx emissions from stationary gas-fired reciprocating engines. Upstream oil and 

gas storage tank emissions in DFW and other areas are controlled by 30 TAC 

Chapter 115, Subchapter B, Division 1. 

Additionally, new permits by rule or standard permit application procedures that 

require notification and a registration are applicable for all oil and gas projects in 

the Barnett Shale that start construction after April1, 2011. Therefore, it is 

incorrect to state that all source categories have reduced emissions except the oil 

and gas category. No changes were made in response to these comments. 

Down winders stated that oil and gas industry VOC emissions were larger than VOC emissions 

generated by mobile sources in the DFW nonattainment area. 

Page 12 of 34 
• The TCEQ disagrees with this comment. Based upon 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 nearly twice the amount ofVOC emissions, 46,403 tpy. 

No changes were made in response to this comment. 

Down winders stated that oil and gas emissions were hidden and not easily calculated from the 

data in this EI SIP revision. 

The TCEQ reports EI data to the EPA in accordance with the requirements of the 

Air Emissions Reporting Rule (AERR) (40 Code of Federal Regulations (CFR) Part 

51, Subpart A). The AERR specifically requires states to report point, area 

(nonpoint), and mobile source emissions and/or activity data at specified time 

intervals. Different portions of the oil and gas industry are reported in these three 

source categories. The point source EI typically contains gas processing plants and 

some upstream oil and gas sites in nonattainment areas, whereas the area source 

inventory contains the majority of upstream oil and gas sites in the state, and the 

mobile source inventory includes drilling rigs. More detailed information about 

sources and emissions rates included in each category is available upon request 

from the TCEQ Emissions Assessment 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 subsequent years to avoid inaccurate point source 

emissions projections. 

The TCEQ does track which sites report to the point source EI on an annual basis. 

Upstream oil and gas emissions that are not reported in the point source EI are 

accounted for in the area source EI. 

Both point and area source emissions projections account for industry activity 

and/ or emissions trends. Therefore, the cumulative point source and area source 

emissions projections for the upstream oil and gas industry are accurate estimates 

despite the fluctuation in the population of upstream oil and gas sites that report to 

the point source EI. No changes were made in response to this comment. 

Downwinders asked ifblowdown emissions from compressor engines are in the inventory. 

Point source annual emissions include emissions from blowdown activities in 

accordance with the TCEQ's Emissions Inventory Guidelines document. 

One individual commented that hydraulic fracturing produces earthquakes which could 

potentially generate ozone. 

Comments related to hydraulic fracturing causing earthquakes are beyond the 

scope of this SIP revision. However, the TCEQ is aware of a relatively recent study 

from the University ofVirginia that indicates that in laboratory settings, 

Page 13 of 34 
earthquakes may directly generate ozone. Further research is required to 

determine whether this phenomenon actually occurs, i.e., can be observed and 

measured, and the extent to which this phenomenon contributes to increases in 

ground-level ozone. 

Criteria pollutant (or precursor) emissions from earthquakes would be classified 

as biogenic emissions. The federal AERR no longer requires states to develop and 

submit biogenic Eis, so these emissions would be outside the scope of this EI SIP 

revision. 

Flares. 

Based on a 2012 Houston Advanced Research Center (HARC) study, Down winders commented 

that flares generate ozone and are not control devices. The Sierra Club commented that flares do 

not control emissions at the presumed 98% destruction and removal efficiency (DRE) and 

questioned why the EI continued to assume 98% DRE. 

The HARC study referred to in the comment (Eduardo P. Olaguer, The Potential 

Near-Source Ozone Impacts of Upstream Oil and Gas Industry Emissions, Journal 

of the Air and Waste Management Association, August 2012) concluded that flares 

could significantly contribute to ozone formation. However, the TCEQ does not 

believe that the assumptions made in this study reflect actual conditions or 

impacts. The modeled flare, described as receiving natural gas in the abstract, was 

modeled as receiving a significant amount of propylene (an HRVOC that can 

increase ozone production efficiency). No evidence or citation was presented to 

substantiate the addition of propylene to the modeled flare's input stream at a 

natural gas facility. Based on TCEQ analyses, the majority ofVOC emissions at 

upstream oil and natural gas facilities are flash gas emissions, which occur when 

oil or condensed natural gas hydrocarbon liquids are reduced to atmospheric 

pressure after extraction. Flash gas emissions have been sampled from storage 

tanks located at natural gas and oil wells at approximately 70 sites statewide. None 

of the lab analyses for these sites reported detectable quantities of HRVOCs, such 

as propylene. Similarly, the EPA SPECIATE software's emissions profile for oil and 

gas production activities does not contain these compounds (EPA, 2012). The 

author's addition of propylene to an oil and gas service flare appears highly 

unrealistic, even for an emissions event. The paper does not attribute the modeled 

ozone production from these flare emissions to the addition of propylene in the 

results and/or conclusions. 

The TCEQ disagrees that flares are not control devices. Flares are first and 

foremost safety devices. Flares protect industrial sites and the adjacent 

communities by safely burning waste gas. Flares help to reduce the amount of 

pollution released into the environment by burning and destroying waste gas 

instead of allowing it to vent directly to the atmosphere. 

The EPA sets New Source Performance Standards (NSPS) and National Emission 

Standards for Hazardous Air Pollutants (NESHAP) for sources. The EPA has 

specifically determined that flares operating in accordance with the specifications 

found in the NSPS (40 CFR 60.18) and the NESHAPS (40 CFR 63.11) destroy VOC or 

volatile hazardous air pollutants (HAP) with a destruction efficiency of 98% or 

Page 14 of34 
greater (reference: Basis and Purpose Document on Specifications For HydrogenFueled Flares, Emission Standards Division, U.S. Environmental Protection 

Agency, Office of Air Radiation, Office of Air Quality Planning Standards, 

Research Triangle Park, North Carolina 27711, p.1, March 1998; available at: 

http://www. tceq.state. tx. us I assets /public/implementation/ air /rules /Flare/Resour 

ce s.pdf). 

The TCEQ's 2010 Flare Study, conducted in conjunction with the University of 

Texas at Austin, indicated that dual-service flares (flares in both emergency and 

routine service) can achieve 98% or greater DRE, even during low flow conditions. 

However, providing too much steam or air assist to the flare can potentially 

decrease flare DRE. 

To ensure that the TCEQ's study results were readily available to both the regulated 

community and public, the TCEQ partnered with the University of Texas at Austin 

to create supplemental flare operations training (available free of charge at: 

sfot.ceer.utexas.edu). The primary objective ofthis training is to enhance 

operators' understanding of industrial flare operations and to provide practical 

information about variables affecting flare performance. 

One of the major goals of the training is to increase operators' understanding of 

efficient flare operations, which will lead to maximizing flare DRE at or above 98% 

when using existing on-site resources. 

No changes were made in response to these comments. 

Greenhouse Gases 

One individual stated that the ozone standard must be strict to protect the environment from 

global warming and carbon dioxide (C02) emissions. 

The FCAA requires the EPA to set NAAQS for widespread pollutants that are 

harmful to public health and the environment, one of which is ozone. The EPA has 

not promulgated a NAAQS for any greenhouse gas, including C02, and the 

reduction of greenhouse gas emissions is outside the scope of this EI SIP revision. 

No changes were made in response to this comment. 

AREA SOURCES 

The Sierra Club noted that the TCEQ was unable to procure a full year of 2008 active wells for 

each county and should have a Memorandum of Understanding (MOU) with the RRC to obtain 

this data. 

The TCEQ appreciates the need to share data between 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 of active wells by county for 2008 for the report 

Characterization of Oil and Gas Production Equipment and Develop a 

Methodology to Estimate Statewide Emissions due to timing of the data 

availability, the TCEQ did obtain this information from the RRC and was able to 

adjust the El appropriately. The TCEQ receives oil and gas data which is used to 

estimate emissions from many oil and gas sources. For counts of active wells, the 

Page 15 of34 
TCEQ typically uses well count information from the following RRC Web page 

(http:/ fwww.rrc.state.tx.usjdatafwellsfwellcountjindex.php) because it offers 

regularly updated data for active wells by county. No changes were made in 

response to this comment. 

The Sierra Club and Public Citizen noted that having an accurate area source inventory is of 

paramount importance and the 2011 inventory is inaccurate and undervalued given the 

widespread development of natural gas and oil through hydraulic fracturing development 

throughout Texas. Public Citizen also commented that the methodology for area sources for the 

2011 EI was inadequate. The Sierra Club also noted that as a result of an inadequate 2011 

inventory, the emission control strategies like the EPA's NSPS for new storage tanks will not be 

recognized as a valid control strategy. 

The TCEQ agrees with the Sierra Club on the importance of the area source EI. The 

area source inventory is developed in accordance with an EPA-approved quality 

assurance project plan and in accordance with the requirements of 40 CFR Part 51, 

Subpart A, AERR. The TCEQ expends significant resources to develop an accurate 

area source inventory. To this end, for the oil and gas sector, improvements made 

by the TCEQ include the development and refinement of a state-specific oil and gas 

emissions calculator. This oil and gas area source emissions calculator uses countylevel production and local equipment activity data with local emissions 

requirements to estimate emissions from individual production categories 

including compressor engines, condensate and oil storage tanks, loading 

operations, heaters, and dehydrators. A significant improvement made to the oil 

and gas emissions calculator for the 2011 inventory is the development of refined 

emission factors for VOC emissions from condensate storage tanks. 

The TCEQ disagrees that the inventory is too inaccurate for future SIP and control 

strategy development. Area (nonpoint) and mobile source EI estimates are 

developed using the best available data and emissions determination methods or 

models available at the time. For example, the area source oil and gas inventory 

uses the current production data and well statistics from the RRC to develop 

specific county-level estimates. As noted above, the TCEQ has invested significant 

resources in advancing area source inventory development methods. The methods 

TCEQ uses to develop its area source oil and gas inventory serves as a model for 

other agencies. As this SIP revision is not intended to demonstrate attainment, 

commenting on control strategies is outside the scope of this EI SIP. No changes 

were made in response to these comments. 

Public Citizen stated that in 2013 there were 304,900 active oil and gas wells in Texas, while the 

EI SIP revision uses 90,000 gas wells and 150,000 oil wells (or a total of 240,000 wells). Public 

Citizen indicated that the large difference in the number of oil and gas wells is exponential and is 

inadequate to begin to address local air quality problems. 

Downwinders indicated that the number of wells used in the 2011 EI was not correct, and that 

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 noted that the numerous oil and gas wells drilled since 2008 

were not included in Appendix A: Characterization of Oil and Gas Production Equipment and 

Develop a Methodology to Estimate Statewide Emissions. 

Page 16 of 34 
The 2011 oil and gas emissions estimates contained in this SIP revision were 

developed using the number of oil and gas wells in 2011. It would not be 

appropriate to use the number of oil and gas wells in 2013 to develop the 2011 EI. In 

addition, it appears that the 304,900 active wells referenced by the two groups 

include all active wells, including service wells, injection/disposal wells, and 

storage wells. The TCEQ only used the number of active oil and gas wells to develop 

the oil and gas EI. 

The 2011 area source EI was developed using a total of 261,476 oil and gas wells. 

Information taken on February 14, 2014 from the RRC indicates that for 2011, there 

were 263,402 oil and gas wells. This slight increase is a difference ofless than 1%. 

The difference is due to the RRC updating the well counts since the development of 

the EI. The RRC oil well information is available at: 

http://www.rrc.state.tx.us/data/production/oilwellcounts.php and the gas well 

information is available at 

http://www.rrc.state.tx.us/data/production/gaswellcounts.php. 

The Sierra Club is correct that the report does not account for drilling since 2008. 

However, the TCEQ obtained 2011 oil and gas well counts from the RRC and used 

these counts to develop oil and gas emissions estimates for 2011 including drilling 

emissions estimates. 

The TCEQ recently reviewed the number of active oil and gas wells used to develop 

the 2011 inventory, and made an adjustment to the emissions estimates based on 

this review. Originally, the TCEQ used the total number of active oil and gas wells 

as of the end of 2011 with the assumption that all of the wells were active for the 

entire year. For the revised emissions estimates, wells completed in 2011 were 

assumed to be active on average for half the year instead of the entire year. In 

addition, emissions estimates from gasoline bulk terminals and gas plants were 

revised based on a recently completed August 2013 Eastern Research Group (ERG) 

study, Emission Inventory of Bulk Gasoline Terminals and Bulk Gasoline Plants; 

emission estimates from oil and gas well heaters were revised based on the August 

2013 ERG study, Upstream Oil and Gas Heaters and Boilers; and emissions 

estimates from compressor engines in the DFW 2008 eight-hour ozone 

nonattainment counties were revised based on data obtained from the Barnett 

Shale Special Inventory 

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

Emissions for Area Sources and Table 2-4: DFW 2011 NOx and VOC Emissions for 

Area Sources of the EI SIP revision have been updated. For the HGB area, the 2011 

annual NOx emissions estimate for area sources decreased from 8,617.31 tpy to 

8,577.06 tpy, and the VOC emissions estimate decreased from 107,305.48 tpyto 

104,944.04 tpy. For the DFW area, the 2011 annual NOx emissions estimate for 

area sources decreased from 16,639.03 tpy to 15,734.52 tpy, and the VOC emissions 

estimate decreased from 97,314.07 tpy to 96,299.78 tpy. 

The Sierra Club questioned the accuracy of the 2008 EI and the 2011 EI since the report stated, 

"Total active wells by county for the full 2008 year are not readily available from the RRC ." 

Page 17 of 34 
Although ERG was not able to obtain the total number of active wells by county for 

2008 for the report Characterization of Oil and Gas Production Equipment and 

Develop a Methodology to Estimate Statewide Emissions due to timing of the data 

availability, the TCEQ did obtain the information from the RRC and was able to 

adjust the EI appropriately. The 2008 EI is developed using the total number of 

active wells by county for the full 2008 year. The 2011 EI is developed using the 

total number of active wells by county for the full 2011 year. No changes were made 

in response to this comment. 

One individual stated that the assumption that the boom in the Barnett Shale has peaked is not 

accurate, and thus, the emissions are not going to stabilize at 2012 levels. The commenter further 

stated that as the price of natural gas increases there will be more drilling activity in the DFW 

area. 

The oil and gas EI is based primarily on the actual number of oil and gas wells and 

the amount of Texas oil and gas production in 2011. These data are obtained from 

the RRC. Data on changes in future activity will be available for use by the TCEQ to 

develop future inventories and to validate past inventory accuracy. The TCEQ uses 

the most current data available at the time of SIP development. No changes were 

made in response to this comment. 

The Sierra Club requested that the appendices document the area source emissions by category. 

Downwinders stated that the TCEQ does not break down emissions from the oil and gas 

exploration and production from the area source portion of the EI. The Sierra Club and 

Down winders stated that there was no way to know how much of the 10,535 tons ofVOC listed in 

Table 2-4 for Wise County was from condensate storage tanks. The Sierra Club further stated 

that one should be able to determine the amount and source of any emissions in the EI. 

The TCEQ agrees that the 2011 emissions associated with oil and gas exploration 

and production are not detailed within the narrative of the 2011 EI SIP revision. 

The appendices contain information on methods used to develop certain oil and gas 

categories contained within the 2011 EI but do not contain 2011 emissions. The 2011 

EI SIP revision focuses on aU 2011 ozone precursor emission estimates for the DFW 

and HGB nonattainment areas; not just oil and gas production and exploration 

emissions. As a result, ozone precursors are summarized by county and emissions 

sector (e.g., point source). Emission estimates of ozone precursors from oil and gas 

exploration and production sources are included within the reported tons of 

emissions supplied in the 2011 EI SIP revision. Area source oil and gas emissions 

by source classification code are available by accessing the EI titled "2011 Area 

Source V3" within the Texas Air Emissions Repository located at 

http://texaer.tceq.state.tx.us/texaer/index.cfm. Querying the 2011 data for Wise 

County on this website shows that 4,031 tons ofthe 10,455 tons ofVOC for Wise 

County were assigned to condensate storage tanks. No changes were made in 

response to these comments. 

The Sierra Club and Down winders commented that the source of the compressor engine 

emissions factors is unclear. 

Point source emission rates for compressor engines are based on the best available 

data, including stack test data, at the unit level in accordance with the TCEQ's 

Page 18 of34 
0 Emissions Inventory Guidelines document. Area source compressor engine 

emissions estimates for the HGB 200S eight-hour ozone nonattainment counties 

are based on average emissions rates per type of compressor engine as detailed in 

the ERG report found in Appendix A: Characterization of Oil and Gas Production 

Equipment and Develop a Methodology to Estimate Statewide Emissions. Area 

source compressor engine emissions estimates for the DFW 200S eight-hour ozone 

nonattainment counties including Wise County are based on updated engine 

profile distributions and emission factors obtained from the Barnett Shale Phase 

II Special Inventory. 

Compressor engine data obtained from the Barnett Shale Phase II Special 

Inventory and 2011 point source EI compressor engine emissions data were used to 

validate the data used in the ERG report. As a result of this analysis, the TCEQ 

concludes the emission factors developed in the ERG report are the best available 

for developing the 2011 EI SIP revision for the HGB area. The Barnett Shale Phase 

II Special Inventory data was used to update the engine profile 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 about the type of engine for 20% of the 

compressor engine population in the ERG report Characterization of Oil and Gas Production 

Equipment and Develop a Methodology were not known and that this negatively impacted the 

accuracy of the EI. The Sierra Club, Down winders, and one individual added that 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 of engines used to develop the emissions factors in the ERG report could also affect 

the accuracy of the EI. 

One individual urged the TCEQ to update the compressor engine emissions factors using stack 

test data. This individual further indicated that the sources should be tested the way they are 

actually operated and maintained in order to correctly account for control device efficiencies. 

Downwinders stated that the ERG report to Estimate Statewide Emissions is based on voluntary 

industry surveys and not on real world emissions or stack testing. 

Compressor engine data obtained from the Barnett Shale Phase II Special 

Inventory and 2011 point source EI were used to validate the data used in the ERG 

report. As a result of this analysis, the TCEQ concludes the emission factors 

developed in the ERG report are the best available for developing the 2011 EI SIP 

revision for the HGB area. The Barnett Shale Phase II Special Inventory data was 

used to update the engine profile distributions and emission factors for the DFW 

200S eight-hour ozone nonattainment counties. 

The ERG report states, "ERG combined data from the two 2007 TCEQ engine 

surveys with the HARC survey data and determined the distribution or fraction of 

compression load by engine type for the most reported engines (comprising So% of 

the population) for each of the three categories used in the HARC report." ERG did 

know the types of engines for the entire compressor engine data referenced in the 

report, but used the specific compressor engine make and model numbers for the 

top So% of the engines reported. This was done to make the number of specific 

Page 19 of 34 
compressor engine make and model numbers listed in Tables 4-3: Emission Factor 

Data for Texas Attainment Areas, 4-4: Emission Factor Data for Dallas 

NonattainmentAreas, and 4-5: Emission Factor Datafor HoustonNonattainment 

Areas more manageable. Because the compressor engine emissions estimates are 

based on natural gas production, as the production increases, the number of 

compressor engines required increases and are accounted for in the EI. 

While 61 compressor engines were removed (57 due to missing engine 

characteristic information), a population of 2,880 compressor engines was used to 

develop the emissions factors. The removal of 61 compressor engines amounts to 

only 2% of the total compressor engines. This fraction is not statistically significant 

and would not have significantly affected emission estimates. Where available and 

applicable, the ERG report Characterization of Oil and Gas Production Equipment 

and Develop a Methodology to Estimate Statewide Emissions used data based on 

stack testing. When stack test data are used to develop the emissions estimate, the 

TCEQ requires that the stack test data reflect current operations and processes 

including any control equipment. No changes were made in response to these 

comments. 

The Sierra Club and one individual stated that the TCEQ should not apply a 90% reduction to the 

carbon monoxide and VOC emission factors for compressor engines equipped with non-selective 

catalytic reduction. They stated that instead an 85% reduction should have been applied to be 

more conservative. 

While the TCEQ appreciates the comment, the 90% reduction is an accepted 

industry standard from the EPA's AP-42, Compilation of Air Pollutant Emission 

Factors, Section 3.2, and is applicable for 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. 

Artificial lift engine emissions estimates in the 2011 EI are based on the number of 

active oil wells in 2011. Statewide, 5,263 additional oil wells were used to develop 

the 201.1 EI as compared to the 2008 EI. The 2011 El does include the emissions 

estimates from the additional artificial lift engines located at these additional5,263 

oil wells. No changes were made in response to this comment. 

The Sierra Club indicated that the TCEQ's assumption that 70% of artificial lift engines are 

electrically operated was not conservative and instead assuming so% of artificial lift engines are 

electrically operated would be conservative. Downwinders indicated that assuming that 70% of 

artificial lift engines are electrified is a severe overestimation, and that there are no data or 

studies to confirm the 70% estimate. 

The ERG report states that between 50% and 90% of artificial lift engines are 

electrically operated. This information came from four companies that specialize in 

artificial lift engines. The TCEQ used the mean of this range, 70%, as an estimate 

for the percentage of artificial lift engines electrically operated. No changes were 

made in response to 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 be valid for the 2011 EI. 

The 2011 EI uses updated artificial lift engine emission factors taken from a 2011 

Central States Air Resource Agencies ( CenSARA) study, and the EPA's Oil and Gas 

Emissions Estimation Tool that is currently under development. These updated 

factors take into account artificial lift engines manufactured after July 1, 2008. No 

changes were made in response to this comment. 

Down winders indicated that the number of artificial lift engines in the 2011 EI did not reflect the 

number of new artificial lift engines in use since the ERG report was completed in November 

2010. 

The artificial lift engine emissions estimates in the 2011 EI were developed using 

the number of oil wells in 2011 and does include the number of new wells and 

artificial lift engines at those wells since the report was completed. No changes 

were made in response to this comment. 

The Sierra Club stated that they support the TCEQ 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 that the information for oil and condensate storage tanks contained in 

the ERG report in Appendix A have been superseded by the newer ERG report in Appendix B: 

Condensate Tank Oil and Gas Activities. 

For the 2011 EI, condensate storage tank emissions estimates were calculated using 

the updated factors from the ERG report located in Appendix B: Condensate Tank 

Oil and Gas Activities. Oil storage tank emissions estimates are calculated using 

the factors contained in the original ERG report contained in Appendix A: 

Characterization of Oil and Gas Production Equipment and Develop a 

Methodology, because the Condensate Tank Oil and Gas Activities report did not 

research oil storage tanks. No changes were made in response to this comment. 

The Sierra Club questioned whether any companies use splash loading for loading and unloading 

operations, and if any do, that the TCEQ should outlaw its use. 

The 2011 EI emissions estimates from loading and unloading operations are 

estimated using the dedicated vapor balance service emission factors from AP-42, 

Compilation of Air Pollutant Emission Factors, Section 5.2. The factors are the 

same for both submerged loading and splash loading. Regardless of whether 

companies use splash loading or submerged loading, the emissions in the 2011 EI 

would remain unchanged. Rulemaking regarding the use of splash loading is 

outside the scope of the EI SIP revision. No changes were made in response to this 

comment. 

The Sierra Club indicated that information from studies and surveys done after the ERG report 

was developed should be incorporated into the 2011 EI for pneumatic devices. The Sierra Club 

Page 21 of 34 
also stated it was unclear how emissions from some sources would be updated in the future; in 

particular, that emissions from pneumatic devices were undercounted. 

The TCEQ continues to work to improve the EI, but due to the SIP revision process 

timing requirements for public hearing and comment, cannot always include 

recently available data. Improvements to emission estimates are subsequently 

incorporated into future Eis. The data in the report represents the best data that 

was available when the 2011 inventory was developed. For the 2011 EI, pneumatic 

device emissions estimates are based on updated emission factors and activity data 

(including the average number of pneumatic devices per well) developed from two 

surveys conducted by the TCEQ. The first survey was conducted in 2011 and focused 

on the 23-county Barnett Shale area. The second survey was conducted in 2012 and 

focused on the remainder of the state. In addition, revised bleed rate information 

from the EPA's Oil and Gas Emission Estimation Tool was used in the development 

of the emission factors used for the 2011 inventory. No changes were made in 

response to these comments. 

The Sierra Club indicated that the RRC has information about the amount of gas vented during 

well completions, and that this data should be used in the 2011 EI. The Sierra Club added that the 

TCEQ should obtain and use actual blowdown data from the RRC in 2011 for the 2011 EI. The 

Sierra Club added that it was not necessary for the TCEQ to estimate the number of well 

completions that are oil wells versus gas wells, because that information is available from the 

RRC. 

While the RRC does have information about the amount of gas vented after wells 

are put into production, it does not have information about the amount of gas 

vented during well completions. Therefore, the 2011 EI was developed using the 

methodology from the ERG report. 

As noted in the ERG report, the majority of well completions (64% in 2008) are 

designated as "oil/gas wells" by the RRC and not separately as only oil wells or gas 

wells. Therefore, because the emissions factors differ, the TCEQ estimated how 

many of these "oil/ gas well completions" were oil wells and how many were gas 

wells to provide a more accurate inventory using the method indicated in the ERG 

report. No changes were made in response to these comments. 

The Sierra Club was concerned that the Eagle Ford Shale was not included in the Central 

Regional Air Planning Association (CENRAP) studies on which equipment leak fugitive 

emissions are based. 

While the Eagle Ford Shale was not separately detailed in the CENRAP studies 

referenced in the ERG report, the Eagle Ford Shale is part of the Western Gulf 

Basin. The Western Gulf Basin was included in the CENRAP studies, so equipment 

leak fugitive emissions from the Eagle Ford Shale were accounted for in the 2011 

EI. No changes were made in response to this comment. 

Public Citizen questioned if the TCEQ should state whether there are any flares 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 in the 

point source EI and flare emissions from oil and gas wellhead sites in the area 

source EI. No changes were made in response to this comment. 

The Sierra Club, Down winders, Public Citizen and one individual noted that Appendix A contains 

a 2010 report based on emissions primarily from 2008 and 2009, and questioned whether this 

report was relevant to the 2011 EI. The Sierra Club, Public Citizen, and one individual also 

commented that the 2011 EI should be based on actual 2011 emissions data and not estimates 

based on old calculations. The Sierra Club, Public Citizen and one individual further questioned 

whether the increased development of oil and gas sources since 2008 was reflected in the 2011 

EI. One individual commented that the total numbers and types of equipment could be 

underestimated since parts of the ERG report are based on studies that go back to 2005 and used 

pre-2005 data. 

While the report contained in Appendix A was used to develop the 2008 EI and 

contained some pre-2005 data, the calculation methodologies and emissions 

factors contained in the report still remain valid for developing emissions 

estimates for many source types. To develop the 2011 EI, the emission factors from 

the report were combined with 2011 activity data to estimate 2011 emissions. Oil 

and gas activity data from 2008 was not used to develop the 2011 EI, and the 2011 

oil and gas area source EI was not grown or projected from the 2008 EI. The 2011 

EI for these categories was based on actual oil and gas activity occurring in Texas in 

2011. No changes were made in response to these comments. -

The Sierra Club questioned why the NOx and VOC emissions for the DFW 2008 eight-hour ozone 

nonattainment counties listed in Table 5-2: State-wide Emissions Inventory for 2008 by 

County of the ERG report were lower than those reported in Chapter 2, Emissions Inventories, of 

the EI SIP revision. 

Table 5-2 of the ERG report lists 2008 area source oil and gas emissions, while the 

emissions reported in Chapter 2 of the 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 of 30 TAC Section 117 NOx rules that require NOx 

controls on many of the compressor engines in the DFW nonattainment counties. 

The compliance date for these rules was after 2008 and before 2011. VOC emissions 

estimates for 2011 are lower than the 2008 estimates primarily due to the updated 

condensate storage tank emission factors developed in the 2012 ERG study 

Condensate Tank Oil and Gas Activities. 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 entirely to the 

implementation of 30 TAC Chapter 117 emission specifications for compressor 

engines during that period. These extensive specifications required controls on 

compressor engines larger than 50 horsepower (hp) in size in Tarrant County, and 

resulted in a significant decrease in emissions. These requirements went into effect 

after the 2008 EI was developed, and the compliance deadlines to meet these 

Page 23 of 34 
emissions spe~ifications were required before January 1, 2011. No changes were 

made in response to this comment. 

The Sierra Club and one individual questioned the area source VOC emissions in Wise County 

since Table E-2: State-wide Emissions Inventory for 2008 by County in Appendix A lists 24,000 

tons ofVOC from oil and gas sources in 2008, while the 2011 EI indicates 10,535 tons ofVOC 

from all area sources. 

The TCEQ updated the emissions factors for several oil and gas sources for the 2011 

EI. In particular, updated condensate storage tank emissions factors were 

developed in the 2012 ERG study Condensate Tank Oil and Gas Activities. 

Pneumatic device emissions factors were revised and activity data were developed 

from 2011 and 2012 TCEQ surveys. As a result of these improved emissions factors, 

the oil and gas emissions estimates for the 2011 EI were significantly lower than the 

emissions estimates for the 2008 EI. No changes were made in response to these 

comments. 

The Sierra Club suggested several revisions to the ERG report included in Appendix A, such as: 1) 

Indicating whether there are any flares used at well sites on pages 1-1 and 1-2 and Table 1-1: 

Upstream Oil and Gas Production Source Types; 2) Correcting the name of the HARC on page 4-

1; 3) Updating Table 4-1: Fraction of Wells >1 Year Old to include wells completed in 2011; 4) 

Listing all of the shale zones which are subject to hydraulic fracturing along with their emissions 

estimates on page 4-2; 5) Defining "minor gap-filing" and explaining how this alters estimates for 

air emissions on page 4-4; 6) Stating how much manufacturer's data vary and how much it alters 

that data by averaging across all performance data for a specific engine on page 4-5; and 7) 

Verifying that a 100 hp engine burns an equal amount offuel as two so hp engines on page 4-10. 

While the TCEQ appreciates the comments, the report included in Appendix A is 

from a project completed in 2010. Changing a third-party final report after 

acceptance is not a routine practice. The requested changes will be noted for future 

work efforts, however, no updates will be made to the existing report at this time, 

since the changes would not impact the 2011 emissions listed in the EI SIP. 

The Sierra Club indicated that the term "green completion method" needed to be defined. The 

Sierra Club further stated that since the new EPA NSPS requires green completions for new gas 

wells beginning this year, it should be listed as a control device for the EI SIP revision. 

The purpose of the EI SIP revision is to submit a comprehensive, accurate, current 

EI for nonattainment areas and is not intended to identify control strategies or 

demonstrate attainment of the 2008 ozone NAAQS. Comments applicable to 

control strategies should be made during the public comment period for the AD SIP 

revision. No changes were made a result of these comments. 

The TCEQ agrees that the term "green completion method" should have been 

defined. Changing a third-party final report after acceptance is not a routine 

practice. The requested changes will be noted for future work efforts and no 

updates will be made to the existing report at this time, since the changes would not 

impact the 2011 emissions listed in the EI SIP. 

Page 24 of34 
0 The Sierra Club agreed with the ERG report recommendations of incorporating further efforts to 

better assess emissions from well completions and well blowdowns, pneumatic devices, fugitive 

emissions, and heaters and boilers. 

The TCEQ thanks the Sierra Club for the comment. 

The Sierra Club indicated that flares used at oil and gas well production sites should be 

investigated and questioned whether the TCEQ requires companies to use stack tests to 

determine if flare destruction efficiencies are what they are purported to be. 

To obtain the most complete EI possible, effort is prioritized for survey work for 

the categories that are expected to have the most significant impact on the EI and 

on any modeling or control strategy work. Flare activity at well production sites will 

be considered in this prioritization. At this time, the TCEQ is unaware of any 

practical way to perform a conventional stack test on a flare. The 2011 EI is 

developed with the assumption that flares operate with a 98% VOC destruction 

efficiency as listed in the EPA's AP-42, Compilation of Air Pollutant Emission 

Factors. No changes were made in response to this comment. 

The Sierra Club questioned what made the CENRAP data accurate enough that ERG could make 

a comparison of the emissions developed in the report to the CENRAP emissions as a quality 

assurance check. 

At the time the ERG study was done, the CENRAP data included basin-specific 

factors developed from survey data for Texas. ERG concluded that comparing 

emissions developed in their report to the CENRAP data was appropriate. The 

TCEQ agrees with this approach because at the time of the report, the CENRAP 

study contained the most recent and relevant information available. No changes 

were made in response to this comment. 

The Sierra Club noted that in Appendix A of the ERG report, ERG repeats many times 

throughout the memorandum associated with the work plan for this report that it will attempt to 

obtain data. The Sierra Club noted that an attempt was not good enough, and that ERG must do 

more than just attempt to obtain data, otherwise public money is wasted. 

The TCEQ appreciates the comment, but notes that ERG wrote this memorandum 

before the project was completed. This memo detailed how the Work Order effort 

would be performed for this project. The main report details what data ERG was 

able to obtain and whether there were any problems with obtaining the data. It is 

also important to note that a contractor is paid according to the elements of the 

contract that are completed, and the level of effort expended. If a contractor is 

unable to complete any portions of a contract, then the amount paid to the 

contractor is adjusted accordingly. No changes were made in response to these 

comments. 

The Sierra Club indicated that C02 and methane greenhouse gas emissions should be reported 

from well blowdown events. 

Estimating greenhouse gas emissions is outside the scope of the EI SIP revision. No 

changes were made as a result of these comments. 

Page 25 of 34 
One individual stated that blowdown emissions can account for more compressor engine 

emissions than what comes out of the stack, and questioned why these emissions are not 

included in the EI. 

Point source annual emissions include emissions from blowdown activities in 

accordance with TCEQ's Emissions Inventory Guidelines document. Information 

on compressor engine blowdown emissions was not available to accurately 

estimate these emissions for the 2011 area source EI. This category has been 

identified as a potential area for further research for upcoming fiscal years. No 

changes were made in response to this comment. 

The Sierra Club questioned whether information from oil tanks was included in the emission 

factors developed by the ERG report Condensate Tank Oil and Gas Activities included in 

Appendix B. The Sierra Club further questioned how emissions from oil tanks were determined. 

The ERG study focused only on condensate storage tanks and did not include oil 

storage tank data. For the 2011 EI, oil storage tank emissions estimates were 

developed using the factors contained in the ERG report Characterization of Oil 

and Gas Production Equipment and Develop a Methodology to Estimate 

Statewide Emissions contained in Appendix A. These factors were based on stack 

test data. No changes were made in response to these comments. 

The Sierra Club and one individual noted that there was a wide range of emission factors for 

condensate storage tanks, and mentioned the Waggoner Crystelle tank from Table 2-5: 

Condensate Tank Emission Factors from the TCEQ 2010 Study from Appendix Bin particular. 

The individual further stated that it is difficult to derive an average emission factor when there is 

such a wide range of factors. The Sierra Club added that where individual source data were 

available, condensate tank emissions should be based on those data and the regional emissions 

factors should only be used where individual source data were not available. The Sierra Club also 

requested that emissions factors be developed for condensate and oil tanks separately and their 

emissions estimates be reported separately in the EI. 

The TCEQ agrees that estimating condensate tank emissions is a complex issue. The 

TCEQ does have separate emissions factors for condensate storage tanks and oil 

storage tanks. These emissions are reported separately in the EI. 

The updated condensate tank emission factors developed in this ERG report and 

used for the 2011 area source EI are based on numerous data points from a variety 

of condensate storage tanks with a range of emission factors. These updated factors 

were used because they are an improvement over the previous factors due to the 

larger data set, production-weighting of the factors, and weighting the factors 

based on the emissions estimation method, with test data weighted more heavily 

than other methods. The regional emission factors contained in this ERG report 

were used to develop area source emissions at the county-level because individual 

source data for every individual source were not available. No changes were made 

in response to these comments. 

The Sierra Club was supportive of ERG and the TCEQ being conservative with the control 

efficiencies developed by this study, since they believe controls required by the new permit by 

rule and NSPS regulations that went into effect after 2011. 

Page 26 of 34 .. 

I 
The TCEQ thanks the Sierra Club for their support. 

The Sierra Club supported ERG's recommendation that future surveys on oil and gas producers 

be handled through mandatory requirements. 

The TCEQ appreciates the suggestion and will consider mandatory survey 

participation as needed for future research. 

The Sierra Club requested that a consistent definition of condensate based on American 

Petroleum Institute (API) gravity be developed. 

For EI purposes, condensate is defined as a liquid hydrocarbon with an API gravity 

greater than 40° at 6o°F (and a specific gravity less than 0.8251). The EI defines 

condensate in this manner due to the definition of black oil found in the Oil and 

Natural Gas Production and Natural Gas Transmission and Storage NESHAP, 40 

CFR Part 63, Subpart HH. 

NON-ROAD SOURCES 

The Sierra Club indicated that emissions reductions from new engine and fuel standards for 

drilling rigs for 2009 and 2010 in Appendix G: Development of Texas Statewide Drilling Rigs 

Emissions Inventories for the Years 1990, 1993, 1996, and 1999 through 2040 may be overly 

optimistic. 

Without stating specific reasons why the Sierra Club believes the reductions may be 

overly optimistic, the TCEQ is unable to specifically address the comment. The 

drilling rig emission factors in the ERG report Development of Texas Statewide 

Drilling Rigs Emissions Inventoriesfor the Years 1990,1993,1996, and1999 

through 2040 were developed using EPA's NONROAD2oo8a model. The TCEQ also 

notes that the drilling rig emissions estimates in 2009 and 2010 were lower than 

2008 due in large part to the decreased drilling activity during those years and not 

solely due to engine and fuel standards. No changes were made in response to this 

comment. 

The Sierra Club questioned if the drilling emission numbers included the impacts of hydraulic 

fracturing. The Sierra Club also indicated that the differences in operations from wells that are 

hydraulically fractured and/ or drilled horizontally versus wells drilled vertically should be taken 

into account. The Sierra Club further noted that the hydraulic fracturing processes merit their 

own study. 

Hydraulic fracturing pump engine emissions are included in 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 developed these emissions using the 

actual number of horizontal spuds drilled in each Texas county in 2011 combined 

with activity data and emission factors taken from a 2012 CenSARA study. 

The differences in drilling rig operations (vertical versus horizontal) are taken into 

account in the 2011 EI. The ERG report Development of Texas Statewide Drilling 

Rigs Emissions Inventories for the Years 1990, 1993, 1996, and 1999 through 2040 

developed three different drilling rig profiles: rigs used for vertical wells less than 

Page 27 of 34 
or equal to 7,000 feet, rigs used for vertical wells greater than 7000 feet, and rigs 

used for horizontal/directional wells. Activity data were developed for each of the 

three rig profiles and included the number of engines by rig type, engine age, 

engine horse-power size, engine operational time, and average load percentage. 

For the 2011 EI, emissions estimates for each of the three rig profiles are calculated 

separately and then summed and reported as total drilling rig emissions. 

The TCEQ agrees that hydraulic fracturing processes are complex and will continue 

to research EI improvements for all source categories, not just oil and gas, as 

funding allows. No changes were made in response to these comments. 

The Sierra Club questioned if the large reduction in NOx emissions from drilling rigs in Tarrant 

County and similar counties between 2008 and 2011 actually occurred. 

The large decrease in NOx emissions estimates is due primarily to two factors. 

First, NOx reductions occurred with the introduction of the Tier 3 and Tier 4 diesel 

emission standards. The Tier 3 standards were fully implemented by the end of 

2008, and the Tier 4 standards began phasing-in starting in 2008 (with a tentative 

final implementation date of 2015). Second, there is a reduced amount of drilling 

activity in 2011 as compared to 2008. In Tarrant County for example, there were 

454 gas wells completed in 2011 compared to 665 gas wells completed in 2008. No 

changes were made in response to this comment. 

The Sierra Club questioned the assumption in the report that the number of thousands of feet of 

drilling will stay static from 2010 to 2040 when 2011 and 2012 saw increased activity due to the 

expansion of the Eagle Ford Shale and Permian Basins. 

Based on historical drilling activity, there was a significant decrease in drilling 

activity during 2009 and 2010 state-wide. Future drilling activity was then 

projected using United States Energy Information Administration projections of oil 

and gas production which was the best information available at the time of the 

project development. 

After the initial EI SIP revision proposal, the TCEQ completed a review of 2011 

drilling activity data to determine ifthe drilling activity data projected in the ERG 

report Development of Texas Statewide Drilling Rigs Emissions Inventories for 

the Years 1990,1993, 1996, and 1999 through 2040 aligned with the actual2011 

drilling activity data. Based on this review ofthe data, the TCEQ has updated the 

drilling rig emissions estimates in Table 2-5: HGB 2011 NOx and VOC Emissions for 

Non-road Categories and Table 2-6: DFW 2011 NOx and VOC Emissions for Nonroad Categories of this EI SIP revision using the 2011 drilling activity data obtained 

from the RRC. For the HGB area, the annual NOx emissions estimate for the nonroad category decreased from 42,020.62 tpy to 41,946.29 tpy, and the VOC 

emissions estimate decreased from 18,822.77 tpy to 18,820.83 tpy. For the DFW 

area, the annual NOx emissions estimate for the non-road category increased from 

37,539.51 tpy to 39,272.29 tpy, and the VOC emissions estimate increased from 

16,914.67 tpy to 16,998.73 tpy. 

The Sierra Club indicated that 2009 drilling information is available from the RRC, and this 

would improve the accuracy of the 2011 EI. 

Page 28 of 34 
0 The ERG report Development of Texas Statewide Drilling Rigs Emissions 

Inventoriesfor the Years 1990,1993,1996, and1999 through2040 used 2009. 

drilling data that were obtained from the RRC. The TCEQ used 2011 drilling activity 

data obtained from 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 need to be assessed 

and included in the EI. 

The 2011 EI does include emissions estimates for drilling rigs, mud degassing, well 

completions, well blowdowns, and hydraulic fracturing engines along with many 

other oil and gas related source types. The TCEQ included emissions from all oil 

and gas activities for which adequate information was available at the time the EI 

was developed. No changes were made in response to this comment. 

The Sierra Club stated that horizontal hydraulic fracturing and horizontal drilling could result in 

increased NOx and VOC emissions as compared to the more conventional vertical or slant 

drilling. 

The TCEQ acknowledges that there may be differences in the amount of emissions 

from drilling horizontal wells as compared to vertical wells which also includes 

factors such as the depth of drilling involved. The TCEQ contracted with ERG to 

perform a study on drilling rigs and examine hydraulic fracturing in Texas shale 

plays. In the ERG report Development of Texas Statewide Drilling Rigs Emissions 

Inventories for the Years 1990, 1993, 1996, and 1999 through 2040, different 

emissions profiles for horizontal drilling and vertical drilling rigs were identified. 

Each profile had specific, associated emissions, and horizontal drilling emissions 

were larger. In addition, extensive research was conducted using data from the 

RRC permit records database to improve well activity data and a survey was 

employed to obtain detailed drilling rig engine data. The results of this report were 

incorporated into the 2011 EI. The TCEQ used the hydraulic fracturing default 

emissions from the EPA's Oil and Gas Emissions Estimation Tool for the 2011 EI. 

The TCEQ may consider additional research on this topic in the future. No changes 

were made in response to this comment. 

The Sierra Club and one individual commented that Appendix F: Development of 2011 Statewide 

Taxies and Actual Annual and Ozone Season Weekday Emissions Inventories 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 developed under a 

single project. The contractor, ERG, provided two separate reports: one report for 

CVM emissions, which is contained in Appendix F; and one report for locomotive 

emissions, which is found in Appendix H: 2011 Texas Railroad Emissions 

Inventory Report. No changes were made in response to these comments. 

The Sierra Club supported the TCEQ's description of the Houston-Galveston, Texas City, and 

Freeport areas as a "hotspot of activity" and suggested that this area should be a "hotspot of 

emission reductions" in the upcoming and future SIP revisions. 

Page 29 of 34 
The HGB area is currently classified as marginal nonattainment for the 2008 eighthour ozone standard, and no attainment demonstration or control strategy 

analysis is required for the area based on this classification from the EPA. Any 

potential future control strategies would be based on photochemical modeling 

results and other technical analyses used to determine controls that would be the 

most effective to attain the standard at that time. No changes were made in 

response to this comment. 

The Sierra Club and one individual noted that Appendix F states the 2011 Statewide Taxies and 

Actual Annual and Ozone Season Weekday Emissions Inventory for Commercial Marine 

Vessels study was conducted on August 31, 2010 and requested clarification on this statement. 

The 2011 Statewide Toxics and Actual Annual and Ozone Season Weekday 

Emissions Inventory for Commercial Marine Vessels study was completed on 

August 17, 2012 for TeEQ under a contract with ERG. This report was developed 

based on a variety of recent studies and activity data from prior years projected to 

2011. One of the studies used by ERG to support the EI development was 

Implement Port of Houston's Current Inventory and Harmonize the Remaining 8-

County_ Shipping Inventory, which was completed by Environ International on 

August 31, 2010. 

The Sierra Club noted that the Automatic Identification System (AIS) data, compiled by 

contractor ERG to quantify traffic patterns in the Gulf of Mexico, was not used to estimate 

emissions for the 2011 CMV EI due to project time constraints. The Sierra Club requested an 

explanation for how this issue will be corrected with revisions applied to the 2011 CMV EI. 

As noted on page 3-6 in Appendix F, "to match individual vessels to their 

characteristics is a very time consuming process and the project budget and 

schedule limited the use of AIS data to general spatial allocations of vessel traffic." 

Although the AIS data was not directly used to develop individual vessel emissions 

due to project budget and schedule limitations, these data were used for 

comparison purposes to verify general spatial allocations of vessel traffic. The 

TeEQ notes that El improvement research and related efforts are ongoing and the 

AIS data cited above may be used in the future for further inventory refinement 

and development. No changes were made in response to these comments. 

The Sierra Club noted the TCEQ's use of EPA-defined Source Classification Codes (SCC) as a 

means to attribute calculated emissions to the various marine vessel types and questioned if this 

resulted in any missing vessels or vessel activity. 

These sees are used to accommodate EPA reporting and estimation requirements 

for grouping of eMVs under specific sees and does not result in any missing 

vessels or vessel activities. For more information refer to Table 2-1: Example SCC 

Assignments by Vessel Types in Appendix F. No changes were made in response to 

this comment. 

The Sierra Club requested that the TCEQ further evaluate the EPA's latest guidance for 

estimating emissions from marine vessels for weaknesses and provide suggestions on how these 

methodologies can be corrected for improved accuracy. 

Page 30 of 34 I~ 
0 The TCEQ continues to evaluate the best methodologies for estimating emissions 

from CMVs. However, evaluation of the EPA's methodologies for future inventory 

work is outside the scope of this SIP revision. No changes were made as a result of 

these comments. 

The Sierra Club requested clarification on the use of the terms "slight" and "consistent" as used in 

the ERG report Development of 2011 Statewide Toxics and Actual Annual and Ozone Season 

Weekday Emissions Inventories for Commercial Marine Vessels listed in Appendix F to describe 

monthly variation in different marine vessel activity for 2011. 

The.analysis was performed only to determine ifthere were any significant 

differences in monthly variation to warrant additional resources in keeping the 

inventory dis aggregated at a monthly level. Data used to assess monthly variance 

were derived from the AIS data, which shows actual locations of individual vessels 

operating in Texas state waters at monthly and annual level maps (these data can 

be provided upon request). Based on these AIS data maps of vessel traffic, there is 

very little difference in marine vessel activity from month to month. No changes 

were made in response to this comment. 

The Sierra Club questioned the accuracy of the 2007 Port of Houston EI which was used as part 

of the basis for the development of the 2011 EI for CMV. 

The 2007 Port of Houston EI is well documented and represents a highly detailed 

inventory based on actual operational data of vessels and land-based equipment 

characteristics and activities to the extent such information was available. Local 

activity parameters are used to extend emission estimates to those portions not 

directly inventoried. Actual operational data were obtained from interviews with 

vessel operators, crew, pilots, and the United States Coast Guard's (USCG) vessel 

traffic system, which tracks oceangoing commercial marine vessels from points of 

origin and destination. No changes were made in response to this comment. 

The Sierra Club and one individual questioned the TCEQ's use oflinear projection to grow the 

data from the 2007 Port of Houston 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 2007 to 2010 and requested clarification on how the 2007 Port of Houston inventory 

activity data were adjusted to 2011 activity levels. 

The TCEQ continues to work to improve the EI. The data from the 2007 Port of 

Houston inventory represents the best data available when the 2011 inventory was 

developed. CMV activity data from 2011 was not available for inclusion in the 

inventory within the time frame required to complete submittal of the inventory to 

the EPA by December 31, 2012. Therefore, activity data from prior years was 

developed and projected for 2011. No changes were made in response to these 

comments. 

The Sierra Club and one individual questioned the assumptions and validity of the load factors 

used in the EI development of vessels in port. 

Quantifying operating loads while a vessel is in port is one of the most challenging 

aspects ofport EI projects, as noted in the EPA's April2009 guidance, Current 

Page 31 of 34 
Methodologies in Preparing Mobile Source Port-Related Emission Inventories. 

The load factor methodology used is approved by the EPA and represents an 

approximate estimate for overall activity reflecting typical engine loads during 

normal equipment operation. No changes were made in response to these 

comments. 

The Sierra Club requested verification on ERG's assumptions that navy vessel activities in Texas 

state waters were minimal since no active naval bases were located in Texas after 2006 and that 

most military vessel exercises occur in federal waters. 

Because of homeland security issues, obtaining timely information on military 

vessel activity was not possible in the project timeframe. Therefore, ERG made 

assumptions based on the data available at the time for the development of the 2011 

EI. Since there were no active naval bases in Texas after 2006, the assumption that 

navy vessel activity was minimal is reasonable. No changes were made in response 

to this comment. 

The Sierra Club requested that a statement in Appendix F, indicating that certain Coast Guard 

craft tend to be used at coastal rescue stations where hours of operation may be relatively small 

with minimal impact on coastal air quality, be verified. 

The TCEQ notes that this statement in the report is specific to new fleet (65-foot 

special purpose craft, SPC-LE 33) that the USCG indicated it had taken delivery of 

(as of 2011) when providing data to ERG. The report notes that "ERG was not able 

to get any indication from the USCG on how many of these vessels were sent to 

Texas USCG stations. These boats tend to be used at coastal rescue stations, so 

actual hours of operation may be relatively small and their impact on coastal air 

quality will be limited." ERG used available data to make these assumptions and the 

TCEQ had no data to indicate otherwise. No changes were made in response to this 

comment. 

The Sierra Club noted that Appendix F contains an error which incorrectly refers to "San Padre 

Island." 

The TCEQ agrees that the wording referring to "San Padre Island" is incorrect and 

should indicate "South Padre Island" in Appendix F. Changing a third -party final 

report after acceptance is not a routine practice. The requested changes will be 

noted for future work efforts, however, no updates will be made to the existing 

report at this time, since the changes would not impact the 2011 emissions listed in 

the EI SIP. 

The Sierra Club suggested that marine vessel activity in federal water ways should be included in 

the EI and modeled for the SIP. 

The EI in this SIP revision includes an estimate of the emissions from marine 

vessels in state waters. Emissions estimates and modeling for the federal waters 

are outside the scope of this SIP revision. No changes were made in response to this 

comment. 

Page 32 of34 
• The Sierra Club commented that there was no indication that the TCEQ used the age of dredge 

engines to determine the air emissions. The Sierra Club requested that assumptions related to 

dredging activity data be verified by contacting dredge companies to obtain more accurate 

information. 

The equation used in calculating dredging emissions does not require a direct input 

of the age of the engine. However, dredge engine emissions were estimated using 

applicable EPA emissions factors that take fleet age into account. 

Dredging assumptions were based on the Diesel Inventory of Marine Vessels Phase 

II- Final Report developed previously for the TCEQ (see the list of references 

included in Appendix F). The TCEQ recognizes that the EI improvement process is 

on-going and will take this suggestion under consideration for future EI 

development research. No changes were made in response to these comments. 

The Sierra Club and one individual noted that Appendix F indicates an error in the 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 should indicate "January 11, 2011." Changing a third-party final report 

after acceptance is not a routine practice. The requested changes will be noted for 

future work efforts, however, no updates will be made to the existing report at this 

time, since the changes would not impact the 2011 emissions listed in the EI SIP. 

ON-ROAD SOURCES 

One individual commented that the emissions results for trucks transporting waste water from 

oil production wells, as represented in the report Development of Oil and Gas Mobile Source 

Inventory in the Barnett Shale in the 12-County Dallas-Fort Worth Area, Final Report, August 

2012, North Central Texas Council of Governments, are a concern because most of the emissions 

produced by the trucks are due to long-term idling that could easily be mitigated if controls were 

implemented and enforced. 

The TCEQ appreciates the commenter's interest in reducing emissions due to longterm truck idling; however, as discussed previously, this SIP revision is not 

intended to demonstrate attainment of the 2008 eight-hour ozone standard or 

include additional control strategy analysis. Comments regarding control strategies 

in the DFW area should be made during the public comment period for the DFW 

AD SIP revision, which is currently scheduled to begin in December 2014. This 

comment is beyond the scope of this SIP revision. No changes were made as a 

result of this comment. 

One individual thought the 2018 extrapolated vehicle miles traveled (VMT) in the report 

Development of Oil and Gas Mobile Source Inventory in the Barnett Shale in the 12-County 

Dallas-Fort Worth Area, Final Report, August 2012, 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. 

The VMT values for inventories that will be used in a SIP are developed using 

standardized methodologies approved by the EPA. The VMT values used in the EI 

Page 33 of 34 
SIP revision are based upon the DFW and HGB travel demand models that are 

calibrated using actual ground counts and are adjusted as needed to be consistent 

with VMT estimates based upon the Highway Performance Monitoring System 

(HPMS). The HPMS is another VMT estimation system that is also calibrated to 

actual ground counts. The DFW and HGB travel demand models are subjected to 

extensive review processes in order to be validated for use in VMT development of 

a SIP revision. The VMT used in this EI SIP revision are documented in Appendices 

I andJ. 

The emissions and VMT values documented in the report Development of Oil and 

Gas Mobile Source Inventory in the Barnett Shale in the 12-County Dallas-Fort 

Worth Area were developed using the best information that could be obtained 

using the available resources for the subject vehicles, which is a very small subset 

of the vehicles operating the DFW metropolitan planning area. As intended, the 

study provides preliminary information concerning on-road vehicles operating at 

oil and gas sites. The TCEQ is assessing how to use the activity information and 

assessing next steps. However, because the on-road SIP emissions inventories set 

motor vehicle emissions budgets for transportation conformity, the information is 

not yet comprehensive enough to incorporate into the on-road SIP emissions 

inventory process. No changes were made in response to this comment. 

One individual commented that the C02 emissions from trucks transporting waste water from oil 

production wells, as represented in the report Development of Oil and Gas Mobile Source 

Inventory in the Barnett Shale in the 12-County Dallas-Fort Worth Area, Final Report, August 

2012, North Central Texas Council of Governments reaches a level of 200,000 pounds a day. 

The C02 emissions are not a required element for this SIP revision. This SIP 

revision provides a basis for the DFW and HGB nonattainment areas for the 2008 

eight-hour ozone standard. Inventory values for NOx and VOC are included in the 

EI SIP revision as required by FCAA, §182 and EPA's Implementation of the 2008 

National Ambient Air Quality Standard for Ozone: State Implementation Plan 

Requirements. No changes were made in response to this comment. 

The Sierra Club and one individual commented that the TCEQ 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 and beyond. Sierra Club 

stated that future year inventories will be less accurate because the TCEQ did not use the October 

2012 database when developing the 2011 on-road inventory. 

The TCEQ is required to use the latest available on-road emissions estimation 

model when developing Eis for SIP revisions. The October 2012 Motor Vehicle 

Emission Simulator (MOVES) database was not available at the time the 2011 onroad EI was developed. However, the MOVES October 2012 database only affects 

emissions for analysis years 2020 and beyond. Therefore, use of the October 2012 

database would have no effect on the 2011 Eis presented in the EI SIP revision. No 

changes were made in response to these comments. 

Page 34 of 34 

-
RECOMMENDATION 
REVISIONS TO THE STATE OF TEXAS AIR QUALITY 

IMPLEMENTATION PLAN FOR THE CONTROL OF OZONE AIR 

POLLUTION 

EMISSIONS INVENTORY FOR THE 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 FOR THE 2008 EIGHT-HOUR OZONE 

NATIONAL AMBIENT AIR QUALITY STANDARD FOR THE 

HOUSTON-GALVESTON-BRAZORIA AND DALLAS-FORT 

WORTH AREAS 

Project Number 2013-016-SIP-NR 

Adoption 

July 2, 2014 
This page intentionally left blank 
EXECUTIVE SUMMARY 

The Federal Clean Air Act (FCAA) requires states to submit emissions inventory (EI) 

information for all relevant sources in areas that are designated nonattainment for 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 per billion) 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. The ten-county DFW area includes Collin, 

Dallas, Denton, Ellis, .Johnson, Kaufman, Parker, Rockwall, Tarrant, and Wise Counties. 

According to FCAA, §172(c)(3) and §182(a)(1), states are required to submit "a comprehensive, 

accurate, current inventory of actual emissions from all sources," within two years of the 

effective date of nonattainment 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 by the 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 of designations 

under the 2008 eight-hour ozone standard (July 20, 2014) and then updated every three years 

thereafter (2017, 2020, etc.). The EPA specified that states use 2011 as a base year 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 many pollutants including ozone 

precursors (volatile organic compounds and nitrogen oxides) from point, area, on-road mobile, 

non-road mobile, and biogenic emissions source categories. This EI SIP revision is the baseline 

EI for the 2008 eight-hour ozone NAAQS and the AERR EI submittals every three years 

thereafter will satisfy the periodic EI requirements. 

ES-1 
SECTIONV-A: LEGALAUTHORITY 

General 

The Texas Commission on Environmental Quality (TCEQ) has the legal authority to implement, 

maintain, and enforce the National Ambient Air Quality Standards (NAAQS) and to control the 

quality of the state's air, including maintaining adequate visibility. 

The first air pollution control act, known as the Clean Air Act of Texas, was passed by the Texas 

Legislature in 1965. In 1967, the Clean Air Act of Texas was superseded by a more 

comprehensive statute, the Texas Clean Air Act (TCAA), found in Article 4477-5, Vernon's Texas 

Civil Statutes. The legislature amended the TCAA in 1969, 1971, 1973, 1979, 1985, 1987, 1989, 

1991, 1993, 1995, 1997, 1999, 2001, 2003, 2005, 2007, 2009, 2011, and 2013. In 1989, the TCAA 

was codified as Chapter 382 of the Texas Health and Safety Code. 

Originally, the TCAA stated that the Texas Air Control Board (TACB) is the state air pollution 

control agency and is the principal authority in the state on matters relating to the quality of air 

resources. In 1991, the legislature abolished the TACB effective September 1, 1993, and its 

powers, duties, responsibilities, and functions were transferred to the Texas Natural Resource 

Conservation Commission (TNRCC). With the creation of the TNRCC, the authority over air 

quality is found in both the Texas Water Code and the TCAA. Specifically, the authority of the 

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 of the TNRCC, and the 

responsibilities and authority of the executive director. Chapter 5 also authorizes the TNRCC to 

implement action when emergency conditions arise and to conduct hearings. Chapter 7 gives the 

TNRCC enforcement authority. In 2001, the 77th Texas Legislature continued the existence of 

theTNRCC until September 1, 2013, and changed the name of the TNRCC to the TCEQ. In 

2009, the 81st Texas Legislature, during a special session, amended section 5.014 of the Texas 

Water Code, changing the expiration date of the TCEQ to September 1, 2011, unless continued in 

existence by the Texas Sunset Act. In 2011, the 82nd Texas Legislature continued the existence 

of the TCEQ until 2023. 

The TCAA specifically authorizes the TCEQ to establish the level of quality to be maintained in 

the state's air and to control the quality of the state's air by preparing and developing a general, 

comprehensive plan. The TCAA, Subchapters A-D, also authorize the TCEQ to collect 

information to enable the commission to develop an inventory of emissions; 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, and practicability and reasonableness; to conduct 

hearings; to establish air quality control regions; to encourage cooperation with citizens' groups 

and other agencies and political subdivisions of the state as well as with industries and the 

federal government; and to establish and operate a system of permits for construction or 

modification of facilities. 

Local government authority is found in Subchapter E of the 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 of the TCEQ that affects their 

territorial jurisdiction, may bring enforcement actions, and may execute cooperative agreements 

with the TCEQ or other local governments. In addition, a city or town may enact and enforce 

ordinances for the control and abatement of air pollution not inconsistent with the provisions of 

the TCAA and the rules or orders of the commission. 

ii 
Subchapters G and H of the TCAA authorize the TCEQ to establish vehicle inspection and 

maintenance programs in certain areas of the state, consistent with the requirements of the 

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; and fund 

and authorize participating counties to implement vehicle repair assistance, retrofit, and 

accelerated vehicle retirement programs. 

Applicable Law 

The following statutes and rules provide necessary authority to adopt and implement the state 

implementation plan (SIP). The rules listed below have previously been submitted as part of the 

SIP. 

Statutes 

All sections of each subchapter are included, unless otherwise noted. 

Texas Health and Safety Code, Chapter 382 

Texas Water Code 

Chapter 5: Texas Natural Resource Conservation Commission 

Subchapter A: General Provisions 

September1,2013 

September 1, 2013 

Subchapter B: Organization of the Texas Natural Resource Conservation Commission 

Subchapter C: Texas Natural Resource Conservation Commission 

Subchapter D: General Powers and Duties of the 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 of Hearings 

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) 

Chapter 7: Enforcement 

Subchapter A: 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 of the following rules are found in 30 Texas Administrative Code, as of the following latest 

effective dates: 

Chapter 7: Memoranda of Understanding, §§7.110 and.7.119 

December 13, 1996 and May 2, 2012 

Chapter 19: Electronic Reporting 

Chapter 35: Subchapters A-C, K: Emergency and Temporary Orders and 

Permits; Temporary Suspension or Amendment of Permit Conditions 

iii 

November 11, 2010 

July 20, 2006 
Chapter 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: General Air Quality Rules June 12, 2013 

Chapter 106: Permits by Rule, Subchapter A May 15, 2011 

Chapter 111: Control of Air Pollution from Visible Emissions and Particulate 

Matter February 6, 2014 

Chapter 112: Control of Air Pollution from Sulfur Compounds July 16, 1997 

Chapter 113: Standards of Performance for Hazardous Air Pollutants and for 

Designated Facilities and Pollutants May 14, 2009 

Chapter 114: Control of Air Pollution from Motor Vehicles March 6, 2014 

Chapter 115: Control of Air Pollution from Volatile Organic Compounds 

Chapter 116: Permits for New Construction or Modification 

Chapter 117: Control of Air Pollution from Nitrogen Compounds 

Chapter 118: Control of Air Pollution Episodes 

Chapter 122: §122.122: Potential to Emit 

iv 

November14,2013 

August 16, 2012 

May2, 2013 

March 5, 2000 

December 11, 2002 
SECTION VI: 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 of Nitrogen (No change) 

G. Sulfur Dioxide (No change) 

H. Conformity with the National Ambient Air 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) 

v 
TABLE OF CONfENTS 

Executive Summary 

Section V-A: Legal Authority 

Section VI: Control Strategy 

Table of Contents 

List of Acronyms 

List of Tables 

List of Appendices 

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 

vi 
LIST OF ACRONYMS 

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 marine vessel 

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 Protection Agency 

Eastern Research Group 

Federal Clean Air Act 

Federal Motor Vehicle Control Program 

Geographic Information Systems 

Houston Advanced Research Center 

Houston-Galveston-Brazoria 

highly reactive volatile organic compounds 

inspection and maintenance 

Memorandum of Understanding 

Motor Vehicle Emissions Simulator 

National Ambient Air Quality Standard 

National Emissions Inventory 

NOx nitrogen oxides 

NESHAP National Emission Standards for Hazardous Air 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 of Texas 

state implementation plan 

State of Texas Air Reporting System 

Texas Administrative Code 

vii 
TACB 

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 per year 

Texas Low Emission Diesel 

vehicle miles traveled 

volatile organic compounds 

viii 
LIST OF TABLES 

Table 2-1: HGB 2011 NOx and VOC Emissions for Point Sources (tons per day and tons per year) 

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 and VOC Emissions for Area Sources (tons per day and tons per year) 

Table 2-4: DFW 2011 NOx and VOC Emissions for Area Sources (tons per day and tons per year) 

Table 2-5: HGB 2011 NOx and VOC Emissions for Non-road Categories (tons per day and tons 

per year) 

Table 2-6: DFW 2011 NOx and VOC Emissions for Non-road Categories (tons per day and tons 

per year) 

Table 2-7: HGB 2011 NOx and VOC Emissions for On-road Mobile Sources (tons per day and 

tons per year) 

Table 2-8: DFW 2011 NOx and VOC Emissions for On-road Mobile Sources (tons per day and 

tons per year) 

Table 2-9: Summary of HGB 2011 NOx and VOC Emissions (tons per day and tons per year) 

Table 2-10: Summary of DFW 2011 NOx and VOC Emissions (tons per day and tons per year) 

ix 
Appendix 

Appendix A 

Appendix B 

AppendixC 

AppendixD 

AppendixE 

AppendixF 

AppendixG 

AppendixH 

Appendix I 

AppendixJ 

AppendixK 

LIST OF APPENDICES 

Appendix Name 

Characterization of Oil and Gas Production Equipment and Develop a 

Methodology to Estimate Statewide Emissions 

Condensate Tank Oil and Gas Activities 

Development of 2008 Annual and Ozone Season Daily Emissions 

Inventories and Activity Data for Non-road Sources within the Texas 

NONROAD Model (TexN) 

Development of Statewide Annual Emissions Inventory and Activity Data 

for Airports 

Development of Annual Emissions Inventories and Activity Data for 

Airports in the 12-County Dallas-Fort Worth Area 

Development of 2011 Statewide Toxics and Actual Annual and Ozone 

Season Weekday Emissions Inventories for Commercial Marine Vessels 

Development of Texas Statewide Drilling Rigs Emissions Inventories for 

the Years 1990,1993, 1996, and 1999 through 2040 

2011 Texas Railroad Emission Inventory Report 

Development of 2011 On-road Mobile Source Actual Annual and Summer 

Weekday Emissions Inventories for All Texas Cotmties (Except for 12 

Counties in the Dallas-Fort Worth Area), and Winter Weekday Emissions 

Inventories for El Paso: Houston-Galveston-Brazoria Area 

Development of 2011 On-road Mobile Source Actual Annual and Summer 

Season Weekday Emissions Inventories for 12 Counties in the Dallas-Fort 

Worth Metropolitan Statistical Area-Amendment 

Point Source HGB and DFW Site Level Emissions 

X 
CHAPTER1: GENERAL 

1.1BACKGROUND 

"The History of the Texas State Implementation Plan (SIP)," a comprehensive overview of the 

SIP revisions submitted to the United States Environmental Protection Agency (EPA) by the 

State of Texas, is available on the Introduction to the SIP Web page 

(http:/ jwww.tceq.texas.govjairqualityjsipjsipintro.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 Protection Agency (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 per billion) 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. The ten-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: State Implementation Plan Requirements; Proposed Rule (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 of the July 20, 2012 effective date of designations for the 

2008 eight-hour ozone NAAQS. The FCAA requires that Eis be prepared for nonattainment 

areas generally, and provides 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 the presence of sunlight, states are 

required to compile information on key sources of these precursor pollutants. The Eis provide 

data for a variety of air 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 

of emissions sources: point, area, on-road mobile, non-road mobile, and biogenic. 

The EPA specified in the proposed 2008 ozone standard SIP requirements rule that states use 

2011 as a base year for EI SIPs to address the EI requirements. The year 2011 is also a year for a 

required EI submission under the 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 of air emissions of both criteria and hazardous air 

pollutants. As directed by the AERR, the NEI includes statewide coverage. Annual and summer 

day emissions are reported on a three-year cycle for the AERR. States can rely on these periodic 

AERR EI submittals to satisfy ongoing SIP EI submission requirements every three years. The 

periodic EI SIP revision submission requirements fall on the same years as the AERR 

submittals. 

1-1 
1.3 HEALTH EFFECTS 

In 2008, the EPA revised the primary ozone standard to 0.075 ppm. To support the 2008 eighthour primary ozone standard, the EPA provided information that suggested that health effects 

may potentially occur at levels lower than the previous o.o8o ppm standard. Breathing 

relatively high levels of ground-level ozone can cause acute respiratory problems like cough and 

respiratory irritation and can aggravate the symptoms of asthma. Repeated exposures to high 

levels of ozone 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 

they breathe more air per pound of body weight than adults and because children's respiratory 

systems are still developing. Children also spend a considerable amount of time outdoors during 

summer and during the start of the 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 HEARING AND COMMENT INFORMATION 

The commission held public hearings on this SIP revision on January 14, 2014 at 2:00p.m. in 

Houston at the Houston-Galveston Area Council of Governments and on January 16, 2014 at 

2:00p.m. in Arlington at the Arlington City Hall Building. Notice of the public hearings for this 

SIP revision was published in the Texas Register and the Austin American-Statesman, the Fort 

Worth Star-Telegram, and Houston Chronicle newspapers. 

The public comment period opened on December 13, 2013 and closed on January 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 

Houston hearing from the Houston Regional Group ofthe Sierra Club (Sierra Club). Oral 

comments were received at the Arlington hearing from DFW Regional Concerned Citizens, 

Downwinders at Risk (Downwinders), the Lone Star Chapter of Sierra Club (Sierra Club), Public 

Citizen, and five citizens. The TCEQ received written comments from DFW Regional Concerned 

Citizens, the Sierra Club, and two citizens. A summary of the comments and the TCEQ response 

is provided as part of this SIP revision in the Response to Comments. 

An electronic version of this SIP revision and appendices can be found at the TCEQ's Air 

Pollution from Ozone Web page (http:/ jwww.tceq.texas.govjairquality/sipjsipplans.html). 

1.5 SOCIAL AND 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 FISCAL AND MANPOWER RESOURCES 

The TCEQ has determined that its fiscal and manpower resources are adequate and will not be 

adversely affected through the implementation of this plan. 

1-2 
CHAPTER 2: EMISSIONS INVENTORIES (EI) 

2.1 INTRODUCTION 

The Federal Clean Air Act (FCAA) requires that Els be prepared for 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 the presence 

of sunlight. The Texas Commission on Environmental Quality (TCEQ) maintains a current EI 

for sources of NOx and VOC that identifies the types of emissions sources present in an area, the 

amount of each pollutant emitted, and the types of processes and control devices employed at 

each facility or source category. The EI provides data for a variety of air quality planning tasks, 

including establishing baseline emissions levels, calculating federally required emission 

reduction targets, developing emissions inputs for air quality models, and tracking emissions 

reductions over time. The total inventory of NOx and VOC emissions for an area is derived from 

estimates developed for five general categories of emissions sources: point, area, non-road 

mobile, on-road mobile, and biogenic. 

The federal Air Emissions Reporting Requirements (AERR) rule requires states to develop and 

submit periodic Eis to the United States Environmental Protection Agency (EPA) every three 

years. The 2011 inventory was the first periodic emissions inventory (PEI) submitted under the 

AERR. In accordance with theAERR, the 2011 PEI was reported to the EPA's National 

Emissions Inventory (NEI) as a comprehensive and detailed estimate of air emissions, including 

ozone precursors (NOx and VOC). As directed by the AERR, the Texas 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 

Stationary point source emissions data are collected annually from sites that meet the reporting 

requirements of 30 Texas Administrative Code (TAC) §101.10. To collect the data, the TCEQ 

sends emissions inventory questionnaire (EIQ) courtesy notification letters to all sites identified 

as meeting the reporting requirements of 30 TAC §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), and to provide samples of calculations used 

to determine reported emissions in accordance with detailed guidance. The guidance documents 

are available at the TCEQ Point Source Emissions Inventory Web page 

(http: I lwww. tceq. texas.gov I airquality I point -source-eij psei.html). Information characterizing 

the process equipment, the control devices, and the emissions points is also required. Data 

submitted to the TCEQ are reviewed for quality assurance purposes and then stored in the State 

of Texas Air Reporting System (STARS) database. 

The 2011 base year point source EI data were extracted from STARS on April1, 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 or before the extract date. Site level 2011 NOx and VOC emissions data are 

summarized and provided in Appendix K: Point Source HGB and DFW Site Level Emissions. 

Further information, including 2011 unit-level NOx and VOC emissions data, is available upon 

request. 

2-1 
A 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 VOC Emissions for Point 

Sources (tons per day and tons per year), and Table 2-2: DFW 2011 NOx and VOC Emissions 

for Point Sources (tons per day and tons per year). 

2.2.2 HGB Point Source EI 

Table 2-1: HGB 2011 NOx and VOC Emissions for Point Sources (tons per day and 

tons per year) 

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 DFW Point Source EI 

Table 2-2: DFW 2011 NOx and VOC Emissions for Point Sources (tons per day and 

tons per year) -:--:=-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 AREA SOURCES 

Stationary source emissions data from sites and processes 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 

2-2 
calculated and recorded on the 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 underground tank filling, and vehicle refueling 

operations. Examples of fuel combustion emissions sources include: stationary source fossil fuel 

combustion, outdoor refuse burning, and structural fires. With some exceptions, area source 

emissions are calculated by multiplying an established emissions factor (emissions per unit of 

activity) by the appropriate activity or activity surrogate responsible for generating emissions. 

Population is one of the more commonly used activity surrogates for area sources. Other activity 

data include the amount of gasoline sold in an area, employment by industry type, and crude oil 

and natural gas production. 

2.3.1 Area Source EI Development 

The 2011 area source EI was developed according to the AERR reporting requirements, using a 

combination of methodologies and data: EPA-generated Eis, TCEQ-contracted projects, TCEQ 

staff projects, 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) and Annual Energy Outlook (AEO). 

The EPA developed Eis for states to use for many source categories as part of the 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 

limited to industrial coatings; degreasing; residential, commercial/institutional, and industrial 

fuel use; commercial cooking; aviation fuel use; and consumer products. For some source 

categories, the TCEQ developed state-specific emissions estimates by acquiring current state 

specific activity data and applying appropriate emissions factors. These source categories 

include but are not limited to: 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 

inventory production categories for 2011. The improvements included the development and 

refinement of a 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 of the oil and gas emissions calculator can be found in Appendix A: 

Characterization of Oil and Gas Production Equipment and Develop 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 

in Appendix 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 VOCEmissionsfor Area Sources (tons per day and tons per year). 

2-3 
Table 2-3: HGB 2011 NOx and VOC Emissions for Area Sources (tons per day and 

tons per year) 

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 DFW Area Source EI 

County-level totals from the 2011 area source EI for the DFW area are presented in Table 2-4: 

DFW 2011 NOx and VOC Emissions for Area Sources (tons per day and tons per year). 

Table 2-4: DFW 2011 NOx and VOC Emissions for Area Sources (tons per day and 

tons per year) 

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-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 of a diverse 

collection of equipment, many of which are powered by 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 (CMV). For the 2011 EI, emissions inventories for non-road 

2-4 
sources 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 of the EPA's latest NONROAD 2008a model, called the Texas 

NONROAD (TexN) model, was used to calculate emissions from all non-road mobile source 

equipment and recreational vehicles, with the exception of airports, locomotives, CMVs, and 

drilling rigs. The TexN model allows TCEQ staff to replace the EPA NONROAD model's default 

data with more specific local survey data per EPA recommendations. Several equipment survey 

studies have been conducted which focused on various equipment categories operating in 

different areas in Texas. The resulting survey data are used as inputs to the TexN model to more 

accurately estimate non-road emissions for the state of Texas. The 2011 non-road category EI 

development used the same methodology found in the report Development of 2008 Annual and 

Ozone Season Daily Emissions Inventories and Activity Data for Non-Road Sources within the 

Texas NONROAD Model (TexN). A copy of the ERG report and associated inputs and 

meteorological data are provided in Appendix C: Development of 2008 Annual and Ozone 

Season Daily Emissions Inventories and Activity Data for Non-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 Federal Aviation 

Administration's Emissions and Dispersion Modeling System (EDMS) was used to 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 of methods and procedures 

used in developing HGB area 2011 airport EI can be found in Appendix D: Development of 

Statewide Annual Emissions Inventory and Activity Datafor Airports. Documentation of 

methodology and procedures used to develop the DFW airport Eis can be found in Appendix E: 

Development of Annual and Emissions Inventories and Activity Data for Airports in the 12-

County Dallas-Fort Worth Area. 

The 2011 CMV inventory was developed based on multiple recent studies and datasets. The 2011 

activity data were compiled using local port data and the United States Department of 

Transportation Maritime Administration. 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 of methodologies and procedures used in developing the CMV Eis can be found 

in Appendix F: Development of 2011 Statewide Taxies and Actual Annual and Ozone Season 

Weekday Emissions Inventories for Commercial Marine Vessels. 

The 2011 EI for the drilling rig diesel engines was developed as part of a statewide EI 

improvement study. Well activity data were obtained through the acquisition of the "Drilling 

Permit Master and Trailer" database from the Railroad Commission of Texas (RRC) and 

through a survey of oil and gas exploration and production companies, which was used to 

develop improved drilling rig emissions characterization profiles. Documentation of methods 

and procedures used in developing the drilling rig diesel engine Eis can be found in Appendix G: 

Development of Texas Statewide Drilling Rigs Emissions Inventories for the Years 1990, 1993, 

2-5 
1996, and 1999 through 2040. An improvement made for the 2011 inventory involved updating 

the projected 2011 drilling activity data from the study with actual 2011 drilling activity data 

-obtained from the RRC. 

The 2011 Texas locomotive EI includes Class I, II, and III locomotive activity and emissions by 

rail segment for all counties within Texas. Locomotive line haul and yard activity data were 

compiled from companies operating in Texas to create a county-level Class I line haul inventory. 

Data developed by the Eastern Regional Technical Advisory Committee in collaboration with the 

Federal Railroad Administration, the American Short Line and Regional Railroad Association 

(ASLRRA), and members of the Class II and III railroad communities used 2008 activity and 

emissions profiles for Class II and Class III railroads. To calculate annual gallons of fuel used by 

railroads, data compiled by ASLRRA 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 on the 

United States Energy Information Administration's latest AEO, 2008 fuel usage values were 

grown to estimate 2011 emissions. Documentation of methods and procedures used in 

developing the locomotive Eis can be found in Appendix 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 VOC Emissions for 

Non-Road Categories (tons per day and tons per year). 

Table 2-5: HGB 2011 NOx and VOC Emissions for Non-Road Categories (tons per 

day and tons per year) 

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 the ten-county DFW 2008 eight-hour 

ozone nonattainment area are presented in Table 2-6: DFW 2011 NOx and VOC Emissions for 

Non-Road Categories (tons per day and tons per year). 

2-6 
Table 2-6: DFW 2011 NOx and VOC Emissions for Non-Road Categories (tons per 

day and tons per year) 

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-road mobile emission sources consist of automobiles, trucks, motorcycles, and other motor 

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 estimated for vehicle engine exhaust. Evaporative hydrocarbon emissions 

are estimated for the fuel tank and other evaporative leak sources on the vehicle. To calculate 

emissions, both the rate of emissions per unit of activity (emissions factors) and the number of 

units of activity must be determined. The emissions factors for on-road mobile sources are 

determined using models developed and approved by the 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 output from the highway 

performance monitoring system, and speed models. 

2.5.1 On-Road Mobile 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. Changes in the 

inventories can be expected when a SIP is revised if there have been changes in any of the 

underlying tools or data used in the inventory development. On-road mobile source category Eis 

presented in this SIP revision used emissions factors developed from the EPA's Motor Vehicle 

Emissions Simulator (MOVES) model and methods consistent with both the EPA SIP inventory 

development guidance and with the requirements of transportation 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 opportunity to 

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 of the onroad fleet, and the emission rates are multiplied by the activity level of each vehicle type or 

source use type. 

2-7 
During the development phase of the 2011 AERR inventories, the EPA released multiple 

versions of the MOVES model. The EPA prefers that states use the latest version of MOVES that 

is available. According to the EPA's guidance, if states have completed significant work on an 

inventory for periodic reporting or for a SIP revision when a new version of MOVES is released, 

such work can be completed and submitted to EPA using the previous version of the model. The 

EPA released MOVES2010a in August of 2010 and MOVES2010b in April2012. The EPA 

originally released MOVES201ob in April 2012 to allow MOVES users to benefit from several 

improvements to general model performance relative to MOVES2010a. The difference in the 

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 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 2011 AERR emissions estimates for all pollutants, precursors, or toxics were not affected by 

which version of the MOVES model was used. The inventories for reporting under the AERR for 

which significant work had been completed by April 2012 were developed using MOVES2010a. 

The AERR inventories developed after April2012 used MOVES201ob (April2012). The AERR 

inventory development schedule for HGB required the use of MOVES2010a. The AERR 

inventory development schedule for DFW allowed the use ofMOVES2o10b (April2012). 

The MOVES model may be run usi:rig default information, or the default information may be 

modified to simulate the driving behavior, meteorological conditions, and vehicle characteristics 

specific to a particular area. Because modifications to the inputs significantly influence the 

emissions factors calculated by the MOVES model, input parameters reflecting local conditions 

were used instead of relying on national default values for the development of the 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 of miles traveled for each vehicle type, type of 

inspection and maintenance (I/M) program, fuel control programs, and gasoline vapor pressure 

controls. 

To estimate on-road mobile source emissions, emissions rates calculated by the MOVES model 

must be multiplied by the level of vehicle activity. On-road mobile source emissions factors are 

expressed in units of grams per mile; therefore, the activity information that is required to 

complete the inventory calculation is vehicle miles traveled (VMT) in units of miles per day. The 

level of vehicle travel activity is developed using a travel demand model (TDM) run by the Texas 

Department of Transportation or by the local metropolitan planning organizations. The TDMs 

are validated against a large number of ground counts, i.e., traffic passing over counters placed 

in various 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 of traffic counters. 

In addition to the number of miles traveled on each roadway link, the speed on each roadway 

type or segment is also needed to complete an on-road EI. Roadway speeds, required inputs for 

the MOVES model, are calculated by using the activity volumes from the TDM and a postprocessor speed model. 

A summary of the annual and daily DFW and HGB 2011 on-road mobile source NOx and VOC 

emissions levels is presented in Sections 2.5.2: HGB On-road Mobile Source EI and 2.5.3: DFW 

On-road Mobile Source EI. The inventory development methods, MOVES inputs, and the 

results are documented in Appendix I: Development of 2011 On-Road Mobile Source Actual 

Annual and Summer Weekday Emissions Inventories for All Texas Counties (Exceptfor 12 

2-8 
Counties in the Dallas-Fort Worth Area), and Winter Weekday Emissions Inventories for El 

Paso: Houston-Galveston-Brazoria Area and Appendix J: Development of 2011 On-Road 

Mobile Source Actual Annual and Summer Season Weekday Emissions Inventories for 12 

Counties in the Dallas-Fort Worth Metropolitan Statistical Area- Amendment. 

2.5.2 HGB On-Road Mobile 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 of the MOVES 

model. All control strategies implemented by 2011 were included in the input to the EI 

development for the 2011 on-road mobile source base year EI. Those controls include the effects 

of the federal motor vehicle control program (FMVCP), reformulated gasoline (RFG), the HGB 

vehicle I/M program, and the Texas Low Emission Diesel (TxLED) program. 

The VMT 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 of the EI is presented in Table 2-7: HGB 2011 NOx and VOC Emissions for 

On-road Mobile Sources (tons per day and tons per year). Complete documentation of the 

development of the EI and details on MOVES model inputs are provided in Appendix I. 

Table 2-7: HGB 2011 NOx and VOC Emissions for On-Road Mobile Sources (tons 

per day and tons per year) 

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-Road Mobile 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 of the MOVES 

model. All control strategies implemented by 2011 were included in the input to the EI 

development for the 2011 on-road mobile source base year EI. Those controls include the effects 

of the FMVCP; RFG, the DFW vehicle I/M program, and the TxLED program. 

The VMT was developed using the latest activity estimates from the DFW TDM 2011 network. 

The activity levels used to calculate the EI reflect the 2011 roadway network with 2011 VMT and 

speeds. A summary of the EI is presented in Table 2-8: DFW 2011 NOx and VOC Emissions for 

On-Road Mobile Sources (tons per day and tons per year). Complete documentation of the 

development ofthe EI and details on MOVES model inputs are provided in Appendix J. 

2-9 
Table 2-8: DFW 2011 NOx and VOC Emissions for On-Road Mobile Sources (tons 

per day and tons per year) 

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, and trees as well as a small 

amount ofNOx emissions from soils. Plants are sources ofVOC emissions such as isoprene, 

monoterpene, and alpha-pinene. Biogenic emissions are estimated by the EPA using its biogenic 

emissions inventory tool. 

2.7 EMISSIONS SUMMARY 

The 2011 NOx and VOC 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 

VOC Emissions (tons per day and tons per year) and Table 2-10: Summary of DFW 2011 NOx 

and VOC Emissions (tons per day and tons per year). 

Table 2-9: Summary ofHGB 2011 NOxand VOC Emissions (tons per day and tons 

per year) 

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 

2-10 
Table 2-10: Summary of DFW 2011 NOx and VOC Emissions (tons per day and tons 

per year) 

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 
Appendices Available Upon Request 

Brian Foster 

SIP Project Manager 

brian.foster@tceq.texas.gov 

512.239.1930 
TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

,_ -

ORDER ADOPTING 

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 of 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-Fort Worth (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 satisfy the 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 authority to control the quality of the state's air and to issue orders consistent with the 

policies and purposes of the Texas Clean Air Act, Chapter 382 of the Tex. Health & Safety 

Code. Notice of the proposed SIP revision was published for comment in the December 27, 

2013 issue of the Texas Register (38 TexReg 9666). 

Pursuant to 40 Code of Federal 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 prior to the dates of 

the hearings. Public hearings were held in Houston on January 14, 2014 and in Arlington on 

January 16, 2014. 

The Commission circulated hearing notices of its intended action to the public, 

including interested persons, the Regional Administrator of the EPA, and all applicable local 

air pollution control agencies. The public was invited to submit data, views, and 

recommendations on the proposed SIP revision, either orally or in \'VTiting, at the hearings or 

during the comment period. Prior to the scheduled hearings, copies of the SIP revision were 

available for public inspection at the Commission's central office and on the Commission's 

Web site. 

Data, views, and recommendations of interested persons regarding the proposed SIP 

revision were submitted to the Commission during the comment period, and were considered 

by the Commission as reflected in the analysis of testimony incorporated by reference to this 

Order. The Commission finds that the analysis of testimony includes the names of all 

interested groups or associations offering comment on the proposed SIP revision and their 

position concerning the same. 

IT IS THEREFORE ORDERED BY THE COMMISSION that the revision to the SIP 

incorporated by reference to this Order is hereby adopted. The adopted re-vision to the SIP is 

incorporated by reference in this Order as if set forth at length verbatim in this Order. 
' / ; 

, , , ,',IT lS FUitTHER ORDERED BY THE COMMISSION that on behalf of the Commission, 

tlie,ci~aS~\nvnfsho~ld transmit a copy of this Order, together with the adopted revision to the 

SIP; to U~e \~egi0ria1 Administrator of EPA as a proposed revision to the Texas SIP pursuant to 

the Fed~rafClean'Air Act, codified at 42 U.S. Code Ann.§§ 7401- 7671q, as amended. -,, ,' ' 

Ifany'portion of this Order is for any reason held to be invalid by a court of competent 

jurisdiction, the invalidity of any portion shall not affect the validity of the remaining 

portions. 

Date issued: J U l 1 0 20 14 

TEXAS COMMISSION ON 

ENVIRONMENTAL QUALITY