Regulatory Advisories

Regulatory Advisories

The EPA and TCEQ web sites are excellent sources of information concerning current agency compliance initiatives. EPA priority rulemaking activities are summarized here. Sign up for TCEQ email updates here.

Approaching Deadlines

TCEQ provides a summary of compliance dates here: https://www.tceq.texas.gov/assistance/resources/due-dates.html

  • Annual Waste Summary Due January 25 (Paper Reports) or March 1 (STEERS)
  • Tier 2 Due March 1
  • Emissions Inventory due March 31
  • Stormwater Hazardous Metals Analysis and Discharge Monitoring Reports (March 1 if applicable)
  • Toxics Release Inventory due July 1 (best if completed prior to submittal of Annual Waste Summary and Point Source Emissions Inventory)
  • Deviation Reports Every Six Months
  • Semi-Annual Compliance Certifications (Facility-Specific Due Dates)
  • NESHAP Compliance Certifications (Industry and Facility Specific)
Rule Updates

Maintenance, Startup and Shutdown (MSS) emissions at Oil and Gas Handling and Production Facilities must be authorized by January 5, 2014.

Historically, MSS activities have not specifically required authorization. However, January 5, 2014, is the deadline for oil and gas sites to authorize planned MSS emissions. PBR 106.359 does not require registration or a fee.

The Texas Environmental, Health and Safety Audit Privilege Act has been revised.

Guidance regarding the audit privilege act is available here. The Act was modified to accommodate findings that are made in the course of due diligence reviews prior to a real estate transaction.

Agency Compliance Initiatives

EPA has updated the National Enforcement Initiatives for Years 2017-2019.

Air

  • Reducing Air Pollution from the Largest Sources
  • Cutting Hazardous Air Pollutants (Expanded initiative for FY17-19)
  • Energy Extraction
  • Ensuring Energy Extraction Activities Comply with Environmental Laws

Hazardous Chemicals

  • Reducing Pollution from Mineral Processing Operations (Returning to base program level in FY17)
  • Reducing Risks of Accidental Releases at Industrial and Chemical Facilities
  • (New initiative for FY17-19)

Water

  • Keeping Raw Sewage and Contaminated Stormwater Out of Our Nation’s Waters
  • Preventing Animal Waste from Contaminating Surface and Ground Water
  • Keeping Industrial Pollutants Out of the Nation’s Waters (New initiative for FY17-19)
Guidance Documents

TCEQ provides excellent compliance checklists for many industries. Click here for the link to the surface coater's compliance checklist and here for the link to the metal finisher's checklist.

Common Environmental Requirements for Regulated Oil and Gas Operations