TCEQ outlines draft state plan to implement EPA methane rules for existing oil and gas sources

Texas Commission on Environmental Quality staff on Nov. 6 told stakeholders the agency will develop a state implementation plan to adopt U.S. Environmental Protection Agency requirements in 40 CFR part 60, subpart OOC for existing oil- and gas-sector sources.

Agency presenters said the plan is intended to preserve state authority to regulate emissions from existing crude oil and natural gas operations while setting specific monitoring and control requirements intended to reduce methane emissions from production, processing, transmission and storage facilities. The agency described timelines, inspection frequencies and control performance targets and invited written comments through Dec. 31.

The presenters said the federal rulemaking timeline gives states 24 months to develop and submit a state plan after EPA’s Federal Register publication; the presentation said the 60-day clock after publication began May 8 and included a reference to May 7, 2024 as an associated start date. Once a state plan is approved, the presenters said facilities would have up to 36 months after plan submission to reach final compliance, which the presentation characterized as an overall five-year window for existing sources.

TCEQ staff summarized who and what the rule covers and what it excludes. Covered sectors listed in the presentation include production (wells and tank batteries), processing plants, compressor stations, transmission and storage facilities. Presenters said distribution lines serving customers and refining operations generally are not covered by this subpart and may be regulated under other standards.

The presentation outlined key compliance elements described in the federal requirements and proposed for the state plan: inspection and monitoring regimes (audio-visual-olfactory, optical gas imaging and Method 21 as alternatives), component-level fugitive monitoring with different inspection frequencies by facility type, and controls to limit routine venting and high-emitting events. For some venting and flare/flash emissions the presentation cited a 95% reduction performance expectation; for certain tanks and routes the presenters said operators must route emissions to sales, reuse or 95% control if routing for sale is not practicable. The presentation used the term “40 TPI” when describing a production-related threshold; that term and its units were used in the slides as presented.

Equipment standards described included a zero-emissions expectation for pneumatic controllers and certain pumps when those devices operate on natural gas unless they are designed to be self-contained or are routed to a closed-vent system and control device. The presentation also discussed replacement or repair timelines for leaking components and different monitoring cadences: quarterly AVO (audio-visual-olfactory) inspections for single-well sites, bimonthly AVO and quarterly OGI for some multi-well sites, and monthly AVO for compressor stations, among other examples described in the slides.

Presenters referenced a new Appendix K proposed alongside the methane rules that would set protocols for OGI monitoring—camera specifications, performance verification, monitoring procedures and operator training requirements—applied specifically to natural gas processing plants. They also noted reporting updates required by EPA and said certain marginal or low‑producing wells may be subject to closure or additional closure-survey and corrective-action steps if emissions are detected during abandonment or end-of-life procedures.

TCEQ staff framed the stakeholder meetings as informal information‑gathering rather than a formal rulemaking hearing; they said written comments will be accepted through Dec. 31 via the agency’s public comment portal, fax or other submission methods and listed additional in-person stakeholder meetings scheduled for Nov. 14 in Arlington and Nov. 20 in Midland. The agency provided a project number in the presentation materials for public reference.

The presentation identified next steps as drafting the state plan, holding required hearings as part of the formal rulemaking process, and submitting the plan to EPA within the statutory window. Staff encouraged questions during the live Q&A and said detailed guidance and slide materials would be posted on the project webpage.

Speakers quoted or paraphrased in this article spoke during the TCEQ stakeholder webinar and included TCEQ presenters Adán Sims and David Mozhenheimer, who led the technical and state-plan portions of the presentation, respectively.