During May 8-16, 2018, EPA conducted helicopter flyovers of the Eagle Ford Shale area to assess energy extraction facility emissions using Optical Gas Imaging (OGI) technology. On July 19, 2018, EPA sent Respondent OGI video captures of an unlit flare at the Facility emitting unburned hydrocarbons. Based upon its review of the images obtained during the flyovers and preliminary permit information available from online state databases for oil and gas facilities, EPA Region 6 notified Respondent and TCEQ of violations of the Texas SIP on July 19, 2018. On July 24, 2018, Respondent and EPA Region 6 conferred regarding violations of the Texas SIP at the Facility. On July 31, 2018, Respondent provided information to EPA that they have taken corrective action measures at the Facility to address
compliance issues observed during the flyovers.