EPA v. SN Operating-2018 Eagle Fort Flyover-Hausser D, G, J Sites-AOC_NOV

Case summary

EPA contracted helicopter flyovers of a portion of the Eagle Ford Shale area during May 8-16, 2018, to assess emission sources using Optical Gas Imaging (OGI) technology. OGI video captures for these oil and gas facilities showed unauthorized hydrocarbon emissions at the Facilities. EPA sent SN Operating a letter on February 14, 2019, regarding observations of unauthorized hydrocarbon emissions made during the helicopter flyovers. The letter included a disc with the OGI video captures of the Facilities. SN Operating verified ownership of the Facilities in the company's email response dated February 28, 2019. Specific SIP violation citations are provided as follows: 1. General Requirements not being met as required under 30 TAC 106.4(b) and (c). 2. Failure to establish and maintain a program to replace, repair, and/or maintain facilities to keep them in good working order, in a manner consistent with good air pollution control practices, as required under 30 TAC 106.359(c)(1) and (2). 3. General Requirements not being met as required under 30 TAC 116.620. 4. Tanks with unauthorized emissions in violation of permit representations made under section (e)(6) of the Air Quality Standard Permit for Oil and Gas Handling and Production Facilities, effective November 8, 2012. Failure to establish and maintain a program to replace, repair, and/or maintain facilities to keep them in good working order, in a manner consistent with good air pollution control practices, as required under sections ( e )(1 )(A) and (C) of the Air Quality Standard Permit for Oil and Gas Handling and Production Facilities, effective November 8, 2012.

Defendants (1)

• Sanchez Oil & Gas Corporation (dba SN Operating)Named in complaintNamed in settlement

Facilities (3)

• SN OPERATING-HAUSSER G PAD

  SEE COMMENTS AND LAT/LONG, DILLEY, TX, 78017

  Registry ID: 110070526449

• SN OPERATING-HAUSSER J PAD

  SEE LAT/LONG AND COMMENTS, DILLEY, TX, 78017

  Registry ID: 110070526451

• SN OPERATING-HAUSSER D PAD

  SEE LAT/LONG AND COMMNETS, DILLEY, TX, 78017

  Registry ID: 110070526327

Statutes cited

• CAA PARTD — New Source Review Permit Requirements
• CAA 173 — New Source Review Permit Requirements

Enforcement conclusions (1)

• SN Operating-2018 Eagle Fort Flyover-Hausser D, G, J Sites-AOC_NOVentered 2019-07-08

  Primary law: CAA

Timeline (5 milestones)

• 2019-04-12Enforcement Action Data Entered
• 2019-07-08Final Order Issued
• 2019-10-21Compliance Achieved
• 2019-10-28Air Resolved
• 2019-11-05Enforcement Action Closed