Emissions Event Reporting: TCEQ Rules and Deadlines

Updated March 2026 · 9 min read

When an unplanned or unauthorized emission occurs at a Texas oil and gas facility, TCEQ requires prompt reporting. Emissions event reporting is governed by 30 TAC Chapter 101, Subchapter F, and failure to report properly is one of the most common — and most avoidable — violations that operators face.

This guide covers what constitutes a reportable emissions event, the notification and reporting timelines, and how to handle the process correctly.

What Is a Reportable Emissions Event?

An emissions event is any upset event, unscheduled maintenance, startup, or shutdown that results in unauthorized emissions from a regulated entity. Under TCEQ rules, an emissions event is reportable if it meets any of the following criteria:

• Emissions exceed the reportable quantity for any air contaminant within a 24-hour period
• Emissions are not authorized by a permit, PBR, or standard permit
• The event is opaque (visible emissions exceeding opacity limits)
• The event results in a nuisance condition (odor complaints, health effects)

Common Reportable Quantities

TCEQ's reportable quantities (RQs) for common oil and gas air contaminants include:

• Volatile Organic Compounds (VOCs): 100 pounds in any 24-hour period
• Sulfur Dioxide (SO2): 500 pounds in any 24-hour period
• Hydrogen Sulfide (H2S): 100 pounds in any 24-hour period
• Nitrogen Oxides (NOx): 500 pounds in any 24-hour period
• Carbon Monoxide (CO): 5,000 pounds in any 24-hour period
• Particulate Matter: 200 pounds in any 24-hour period

These quantities may seem large, but during equipment malfunctions, compressor blowdowns, tank venting events, or uncontrolled flaring, they can be exceeded quickly.

Notification Timeline

Initial Notification — 24 Hours

You must notify TCEQ within 24 hours of discovering a reportable emissions event. Notification is made through TCEQ's Air Emissions Event online reporting system (STEERS). The initial notification must include the facility name and TCEQ regulated entity number, the date and time the event began, the type of event (startup, shutdown, malfunction, maintenance), the air contaminants released and estimated quantities, the cause of the event, and the actions taken to minimize emissions.

Final Report — 2 Weeks

A final written report must be submitted within two weeks of the end of the emissions event. The final report must include all information from the initial notification plus more detailed emissions calculations, the root cause analysis, a complete description of corrective actions taken, and measures implemented to prevent recurrence. The final report is submitted through the same STEERS system and becomes part of your facility's public compliance record.

Affirmative Defense

TCEQ provides an affirmative defense for emissions events that meet all of the following criteria:

• The event was not caused by an intentional act or reckless disregard
• The event was not caused by poor or inadequate maintenance
• The event was not reasonably preventable
• All reasonable steps were taken to minimize emissions during the event
• Proper notification and reporting were completed on time

The affirmative defense is exactly that — a defense. It does not prevent TCEQ from investigating or issuing an NOV, but it can be used to avoid penalties if the criteria are met. The burden of proof is on the operator to demonstrate compliance with all five criteria.

Scheduled Maintenance vs. Emissions Events

Emissions from planned maintenance, startup, or shutdown activities are treated differently from upset events. Scheduled maintenance shutdowns and startups should be reported if they result in emissions above reportable quantities, but they are more likely to qualify for the affirmative defense if properly planned and documented. The key is to estimate emissions in advance, take all feasible steps to minimize them, and document everything.

Common Mistakes in Emissions Event Reporting

• Late notification: Missing the 24-hour window is itself a violation, regardless of the underlying event
• Underestimating emissions: Conservative emission estimates that are later found to be inaccurate can undermine your credibility and affirmative defense
• Incomplete final reports: Missing root cause analysis or prevention measures weakens your position
• Not reporting "minor" events: If emissions exceed reportable quantities, the event must be reported regardless of how minor you believe the impact to be
• Failure to document corrective actions: TCEQ wants to see that you have taken steps to prevent recurrence

Be Prepared for Emissions Events

Every operator should have a written procedure for emissions event reporting that includes TCEQ hotline numbers and STEERS login credentials, a list of reportable quantities for chemicals at your facilities, emission estimation methods for common event types, templates for initial notifications and final reports, and assigned responsibilities for reporting. CompliantIntel helps operators maintain emissions event preparedness as part of a comprehensive compliance program.