On January 9, 2024, the U.S. Environmental Protection Agency (EPA) proposed amendments to its Clean Air Act (CAA) Title V operating permit rules to clarify the scope of an “applicable requirement” that can be implemented...more
Starting November 1, 2022, Texas Commission on Environmental Quality (TCEQ) will require applicants who are applying for a new registration, permit, or activity, or making certain changes to an existing registration, permit,...more
On October 12, 2022, the Office of Environmental Justice and External Civil Rights of the U.S. Environmental Protection Agency (EPA) issued a Letter of Concern setting forth its initial analysis and recommendations in...more
What?
The U.S. Environmental Protection Agency (EPA) has announced that it is conducting helicopter flyovers of oil and gas operations in the Permian Basin to identify and pursue enforcement for unauthorized emissions of...more
The Texas Commission on Environmental Quality (TCEQ) has taken various actions and posted guidance to help regulated entities address operational issues and environmental noncompliance that resulted from power outages, water...more
Key Takeaways:
• What: The Texas Commission on Environmental Quality (TCEQ) has revised its policy on calculating monetary penalties for administrative enforcement actions.
• Who Is Affected: Entities with...more
Key Takeaways -
• What: The U.S. Environmental Protection Agency (EPA)’s scientific work on ethylene oxide (EO) has been central to the basis of claims in recent toxic tort suits based on EO exposures; the Biden...more
Key Takeaways:
What: The Texas Commission on Environmental Quality (TCEQ) has developed a “Find It and Fix It” program for oil and gas facility air compliance....more
Key Takeaways -
• What Happened: TCEQ issues draft Penalty Policy and plans to propose Compliance History Rule revisions...
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Key Takeaways -
• What Happened: EPA urges self-audits for facilities subject to RCRA Parts 264/265 Subparts AA, BB and CC air emission standards to avoid potential for substantial penalties and injunctive relief
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The Texas Commission on Environmental Quality (TCEQ) yesterday issued guidance (below) for submitting enforcement discretion requests during the COVID-19 pandemic. In this guidance, Ramiro Garcia, TCEQ’s Deputy Director of...more
On December 19, 2019, the U.S. Environmental Protection Agency (EPA) announced a self-audit program that will be available to existing owners of upstream oil and gas facilities for a limited sign-up period of twelve months....more
The Texas Commission on Environmental Quality (“TCEQ”) has prepared a rulemaking that will consolidate for certain New Source Review (“NSR”) air permit applications the Notice of Receipt of Application and Intent to Obtain...more
Pipeline safety and infrastructure issues have gained attention in recent years due to tight oil resources production, changes in regulations, and several high-profile incidents. On Thursday, August 3, the U.S. Government...more