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to EPA a delegation request for NPDES
permitting authority as part of the state
taking over issuances of federal permits
for discharge of produced water, hydrostatic test water and gas plant effluent
into Texas waters, he details.
However, EPA Region 6 Administrator Ken McQueen has expressed a
desire to delegate authority to Oklahoma,
Texas and New Mexico before year's
end, Paylor observes. McQueen also
has noted that TCEQ will bring in Erin
Chancellor, Region 6 chief of staff, to
head the state agency's legal services
department to assist TCEQ with the
NPDES application process.
According to Paylor, the state agency
is working to define produced wastewater,
a term for which the state has no official
definition, and also is striving to adopt
EPA regulatory language related to effluent
limitation guidelines for the oil and gas
extraction point source category and centralized waste treatment point source category 40 in the Code of Federal Regulations, parts 435 and 437.
TCEQ intends to define produced
wastewater as all wastewater associated
with oil and gas exploration, development
and production activities, with the exception of hydrostatic test water and gas
plant effluent, including all waste streams
regulated by 40 CFR part 435, he details.
The new rules were published in the
Texas Register in December, public hearings were held in early February and
adoption of the new rules is anticipated
by the end of May.
TCEQ also is working on amending
hydrostatic test general permits to account
for changes and has a current renewal
that ends in April, but the agency has expressed a desire to adopt new, amended
permits in November, Paylor says.
TCEQ staff indicated that any potential
NPDES violations could be covered under
the agency's current enforcement initiation
criteria, he says. Once the entire program
is under TCEQ control, the agency will
consider possible rule changes specific
to NPDES in the next revision of the categories, which are on a two-year revision
cycle, Paylor adds.

that TIPRO has been pushing back against
the regulations since 2016 because of
their disproportionate impact on smaller
oil and gas producers.
Therefore, he indicates, the association
applauds the Trump administration's quest
for reasonable air quality standards that
protect the environment and reduce unnecessary regulation. "It is also critically
important to highlight the proactive and
successful efforts of oil and natural gas
producers to reduce energy-related emissions through voluntary actions, industry
best practices and innovation," he adds.
During the past 20 years, the U.S. oil

and natural gas industry has invested
$300 billion in greenhouse gas mitigation
technologies, Longanecker points out.
Methane emissions from oil and natural
gas production fell 24% between 2011
and 2017, while oil and natural gas production rose 65% and 19%, respectively,
he says, citing EPA and U.S. Energy Information Administration statistics.
Since 2005, total U.S. GHG emissions
have fallen 12%, and total GHG emissions
from fossil fuel combustion have dropped
nearly 15% alongside the increased use
of natural gas for electricity generation,
Longanecker observes.

Air Quality
TIPRO in early 2020 submitted formal
comments to EPA over proposed policy
changes designed to improve the 2012 and
2016 New Source Performance Standards
for the oil and natural gas industry under
the Clean Air Act, Longanecker notes.
The 2016 standards were among the
most overreaching regulations for the
U.S. oil and natural gas industry adopted
during President Barack Obama's administration, Longanecker describes, adding
MARCH 2020 79

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American Oil and Gas Reporter - March 2020

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