# Matagorda County emissions

do not contribute to ozone

formation in HGB

traffic and commuting, growth,

meteorology, topography, and emissions

do not contribute to HGB Ozone formation

# Declining Emissions and Declining

Growth Do Not

Support Nonattainment

• Matagorda County is a Micropolitan Statistical Area

• Emission Corrections ( 2008 )

• Emission Reductions ( 2008

- 2010 )

• Emission Corrections (Oil and Gas lb/BBL local data)

• VOC Emissions are not driving ozone formation in HGB

– TCEQ Apportionment Analysis

– Area Source VOC Reduction Analysis for Counties Outside of

HGB



## • Wind trajectory does not override declining emissions,

declining growth and additional technical data

# Matagorda County is in a

Micropolitan Statistical Area

• CAA only designates Metropolitan Statistical Areas or

CMSA for use with Serious, Severe or Extreme

nonattainment areas

.

• Matagorda does not have sufficient “social or economic

ties" to be included in the 10 county Houston

Metropolitan Statistical Area ("Houston Metro")

.

• Instead, EPA uses the CSA, which only requires a

minimal 15 % employment interchange with another

county

.

• This use of CSA is particularly arbitrary when the actual

CSA basis, VMT and population, for Matagorda County,

has declined from 2008

- 2010

.

# Emission Corrections (2008)

• Nonroad NOx

– 7

, 007 tpy in TSD

– ( 2

, 928 ) tpy (TCEQ January 11

, 2012 Letter to EPA, p

. 2 )

– 4

, 079 Revised total NOx



### • Nonroad VOC

– 3

, 153 tpy in TSD

– ( 664 ) tpy (TCEQ 1 / 12 / 12 EI Discrepancy Table)

– 2

, 489 Revised Nonroad VOC



### • Oil and Gas VOC emissions

– 14

, 662 tpy VOC in 2008 for oil and gas area sources

– Local VOC lb/BBL data should be used (next slide)



### • Pneumatic Controllers

– VOC Reductions associated with Hood and Wise Counties

– Suspect same should be attributed to Matagorda County

# Emission Corrections

Oil and Gas Condensate Tank

Emissions

Source VOC

Lbs/BBL Basis of Estimate 2008 TPY

VOCs 2010 TPY

VOCs

Current TCEQ/TERC

Report 33.3

lbs/BBL Statewide default

emission factor

from TCEQ study 13,302.03 7,570

Local

Option

1 TCEQ/TERC

– weighted average

for production

rates (See Table

3

- 3) 16.75

lbs/BBL TCEQ statewide

factor weighted

for production

(BBL/day) at well 6,716 3,808

Local

Option

2 TCEQ/TERC

–

modified for MC

like wells (psig

less than 50) (See

Table 3

- 3 and 3

- 1) 6.972

lbs/BBL TCEQ statewide

factor modified

for discharge

pressure 2,796 1,585

Local

Option

3 Matagorda

County 2.5 lbs/BBL MC Condensate

sample taken

from separator

before discharge

to tank 1,002 568

# Oil and Gas Analysis

by PSI, lb/BBL and County

0 20 40 60 80 100 120 140 160 180 200

TERC

(Denton

Only) TERC (All

Sites) TERC

(Without

Denton) Matagorda

County

(MC)

specific PSI Avg lb/BBL Avg



# *

# * Avg. PSI based upon

preliminary estimates

from operators of 35% of

2008 condensate BBL

produced in MC.

# Based upon site

specific sampling and

modeling of one of the

largest 2010 condensate

producing leases in MC. Texas Environmental Research Consortium (TERC) Report on VOC

Emissions from Olil and Condensate Strorage Tanks found at

http://files.harc.edu/Projects/AirQuality/Projects/H051C/H051CFinalRep

ort.pdf

# Oil and Gas Analysis

by PSI, lb/BBL and County

TERC

(Denton Only) TERC

(All Sites) TERC

(Without Denton) Matagorda County

Specific

PSI Avg 200 119.1 45.7 45.4 *

VOC lb/BBL Avg 56.58 33.3 12.11 2.5 #

* Avg. PSI based upon preliminary estimates from operators of 35% 2008

condensate BBL produced in Matagorda County



### .

# Based upon site specific sampling and modeling of one of the largest

2010 condensate producing leases in Matagorda County.

# Emission Reductions

2008

- 2010

• NOx Reductions to 2010

– ( 180

. 86 ) tpy NOx emission reductions 2008 to 2010 from point sources

– VMT Reduction by 1 %



### • VOC Reductions to 2010

– TCEQ estimates 8

, 758 tpy VOCs from oil and gas operations

• ( 5

, 904 ) tpy VOC emission reductions from 2008 to 2010 from area sources (TCEQ Emission Inventory)

– Local VOC lb/BBL data should be used (previous slides)

– VMT Reduction by 1 %

# VOC Emissions Do Not Drive

Ozone Formation in HGB

EPA has approved the current SIP strategy based

upon primarily on NOx reductions with targeted

HRVOC controls:

These [Texas SIP] revisions result from more recent information on ozone

formation in the Houston/Galveston area indicating that a combination of

controls on oxides of Nitrogen (NOx) and highly reactive volatile organic

compounds (HRVOCs) should be more effective in reducing ozone than the

measures in the previously approved plan which relied almost exclusively on

control of NOx

.

EPA's proposed approval of TCEQ's HRVOC SIP rule, 70 FedReg 58119 (October 5

, 2005 )

# HGB Attainment Demonstration SIP Revision for

the 1997 Eight

- Hour Ozone Standard

(Project No. 2009

- 017

- SIP

- NR)

Adoption Date: 03/10/2010

# Reduction of 273 tpd VOCs (99,645 tpy VOCs) from

several counties within 200 km of HGB, including

Matagorda County, resulted in no change to the

Wallisville Monitor 2018 future case.

HGB Attainment Demonstration SIP Revision for the 1997 Eight

- Hour

Ozone Standard (Project No. 2009

- 017

- SIP

- NR) Adoption Date:

03/10/2010

# Eliminating All VOC and NOx Emissions

From Matagorda County Will Not

Meaningfully Contribute to Ozone

Reduction

TCEQ Technical Analysis Support Documentation by the TCEQ

Regarding U.S. EPA Responses to State and Tribal 2008 Ozone

Designation Recommendations All Matagorda County Emissions Contribute

Less than 0.20 ppb in 2018 APCA Modeling

# D.C. Circuit requires a "rational

connection between the facts found and

the choices made"

In the recent ATK designation decision out of the D

. C

. Circuit :

Growth was a factor : "A county with rapid population or VMT growth is generally an integral part of an urban area and is likely to be contributing to fine particulate

concentrations in the area

. " EPA TSD for county designated nonattainment

.

– The proposed counties at issue in ATK had double digit, higher than expected growth

in population and VMT

.

Topography and Meteorology : Without seasonal inversions, trapped by the mountains,

Salt Lake City would not be in violation of the air quality standards

. ATK Launch Systems Inc

. v

. EPA (February 24

, 2012 )

.

– EPA's RTC recognized that the closed air basin trapped the emissions for several

days regardless of the wind patterns tracked in the wind trajectories

.

Emissions impact was exaggerated because trapped by mountains :

– One proposed county had the second highest PM 2

. 5 carbon emissions in the

proposed area

.

## In case

- by

- case analysis, Matagorda County Wind

Trajectory Data Does Not Outweigh Declining Growth,

Declining Emissions and more Detailed Modeling Data

Declining emissions and population and VMT growth is well documented

.

No meaningful contribution to HGB ozone levels

.

• 2005

– 2010 data

– Wind data shows only 0

. 43 %

- 1

. 9 %

, at most, of the wind impacting an

elevated monitor potentially originated in Matagorda County

. (TCEQ

January 11

, 2012 Letter, p

. 16

. )

– Within this small percentage of time, the greatest impact expected from all

combined mobile, non

- road, point and area sources Matagorda County

emissions, as modeled by TCEQ, is an average of

. 18 and a max of 1

. 54

ppb for 2005 and 2006

. (TCEQ January 11

, 2012 Letter as corrected in

discussions between EPA and TCEQ

. )

No meaningful contribution potential to Ozone formation or reduction

– 2018 TCEQ sensitivity analysis demonstrated that 273 tpd had no ozone

reduction impact on the Wallisville monitor

.

– 2018 TCEQ APCA results for all MC emissions indicates, that if all combined

mobile, non

- road, point and area sources were eliminated, the greatest

reduction impact would be 0

. 20 ppb at the Wallisville monitor

.