oil and gas waste stream management and additional ......applicable rules & publications:...
TRANSCRIPT
![Page 1: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/1.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Oil and Gas Waste Stream Management and Additional Requirements for Commercial Facilities
August 2019
1
![Page 2: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/2.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Topics of Discussion
• Introduction
• Applicable Rules & Publications
• Permit Types
• Application Process
• Lease Agreements
• Notice Requirements
• Renewal, Transfer & Amendments
• NORM Surveys
• Closure Cost Estimates & Restrictive Covenants
2
![Page 3: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/3.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Introduction
Environmental Permits and Support
• Regulates the management methods of oil and gas waste treatment and disposal at or near the land surface
• All handling, storage, treatment, recycling and disposal methods other than injection wells are managed by the Environmental Permit team.
3
![Page 4: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/4.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Introduction
Our mission is to serve Texas by our stewardship of natural resources and the environment, our concern for personal and community safety, and our support of enhanced development and economic vitality for the benefit of Texans.
4
![Page 5: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/5.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Applicable Rules&
Publications
![Page 6: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/6.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Applicable Rules & Publications
Statewide Rules (16 TAC Part 1 Chapter 3)
• SWR 8 – Water Protection
• SWR 22 – Protection of Birds
• SWR 57 – Reclamation
• SWR 78 – Fees and Financial Security
• SWR 98 – Hazardous Oil and Gas Waste
• Chapter 4, Subchapter B – Commercial Recycling
• Surface Waste Management Manual
6
![Page 7: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/7.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Applicable Rules & Publications: SWR 8
Water Protection: Authority for Environmental Permitting
• Subsection B – No Pollution
• Subsection D – Pollution Control
7
![Page 8: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/8.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Applicable Rules & Publications: SWR 22
• Operator must take protective measures to prevent harm to birds
• The operator may incur liability under federal and state wildlife protection laws, such as the Migratory Bird Treaty Act
8
![Page 9: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/9.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Applicable Rules & Publications: SWR 57
Reclaiming Tank Bottoms, Other Hydrocarbon Wastes, and Other Waste Materials:
• Applicable to wastes generated through exploration, development, production (including transportation) of crude oil and other waste materials containing hydrocarbons (see 16 TAC §3.8(a)(30))
• Removal of tank bottoms or other hydrocarbon wastes from any producing lease tank, pipeline storage tank, or other production facility, for reclaiming by any person, is prohibited unless such person has either obtained a permit to operate a reclamation plant or is an authorized person. 9
![Page 10: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/10.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Applicable Rules & Publications: SWR 78
Commercial Facility – A facility whose owner or operator receives compensation from others for the storage, reclamation, treatment or disposal of oil field fluids or oil and gas wastes that are wholly or partially trucked or hauled to the facility and whose primary business purpose is to provide these services for compensation if the facility:
• Is permitted under SWR 8 (Water Protection)
• Is permitted under SWR 57 (Reclamation)
• Is permitted under SWR 9 with a pit permitted under SWR 8 located at the facility
• Chapter 4, Subchapter B10
![Page 11: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/11.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Applicable Rules & Publications: SWR 98
Standards for management of hazardous oil and gas waste
A facility authorized for:
• Recycling or Reclamation
• Treatment, Storage or Disposal
Must also receive an EPA permit under 40 CFR, Parts 270 and 124 or Part 271
Hazardous Waste Manual
11
![Page 12: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/12.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Applicable Rules & Publications: Chapter 4(B)
Provisions apply to these categories of commercial recycling:
• Division 2 – On-lease solid recycling
• Division 3 – Off-lease or centralized solid recycling
• Division 4 – Stationary solid recycling
• Division 5 – Off-lease fluid recycling
• Division 6 – Stationary fluid recycling
12
![Page 13: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/13.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Applicable Rules & Publications: Surface Waste
• Offers guidelines for the management of oil and gas wastes.
• Private Facilities: Waste generated on-lease for one operator
• Centralized Facilities: Waste generated from multiple leases, owned by one operator and centrally located
• Commercial Facilities: Receive compensation for handling, storing, reclaiming, treating, disposing or recycling of waste
13
![Page 14: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/14.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Questions
Questions?
14
![Page 15: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/15.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types
![Page 16: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/16.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types
• Minor Permits
• Letter of Authority / Letter of Clarification
• Discharges
• Pits
• Landspreading
• Reclamation (R9)
• Recycling
• Stationary Treatment Facilities (STF)
16
![Page 17: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/17.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Minor Permits
• Hydrostatic Test Water Discharge
– Valid for 60 days
– Must file two copies of the application
– Contact EPA Region 6 forfederal requirements if tosurface water
• Recycling of Domestic Wastewater
17
![Page 18: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/18.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Minor Permits
Hydrostatic Test Water Discharges:
• Analytical results reported within one month after discharge is complete
• Pictures of effluent treatment and fluid dispersal system must be included the report
18
![Page 19: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/19.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Minor Permits
• Recycling of Domestic Wastewater
• Waste streams include: (1) Treated domestic wastewater or (2) Mobile drinking water treatment system wastewater. This is waste from the unit, like reverse osmosis reject water
Two recycling options include:
1. Down-hole operations
2. Surface application
These two options have different testing parameters.
19
![Page 20: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/20.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types:Letter of Authority/Letter of Clarification
• Letter of Authority – Oil and gas waste disposal methods that are not authorized by Commission rules and do not have a permit application form or permit application outlined in the Surface Waste Management Manual may be applied for by submitting a letter of request.
• Letter of Clarification – Letter written to clarify permit conditions.
20
![Page 21: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/21.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Discharges
Types of Discharges:
• Gas Plant Effluent (GPE)
• Produced Water
21
![Page 22: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/22.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Discharges
Additional information about discharges:
• Environmental Protection Agency (EPA) has not authorized the RRC to implement a National Pollutant Elimination System (NPDES) permit program
• Discharges to surface waters of the State must be permitted by the RRC and may require an EPA permit.
• Texas Water Code prohibits the RRC from permitting a discharge that violates the Texas Surface Water Quality Standards adopted by TCEQ (Section 24.131(b))
22
![Page 23: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/23.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Discharges
Additional information about discharges:
• Each discharge has specific effluent testing and limitations based on location and the wastewater analyses
• Additional testing parameters may be added based on chemicals added to the discharge
23
![Page 24: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/24.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Discharges
Coastal Management Program:
• General Land Office (GLO)
• Protects natural habitatsand wildlife
• Discharges must not adversely affect these critical areas:
– Coastal Wetlands
– Oyster Reefs
– Submerged Aquatic Vegetation
24
![Page 25: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/25.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Discharges
A complete Water Analysis is required for all discharge applications.
25
![Page 26: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/26.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Discharges
Gas Plant Effluent Discharges:
Common waste streams include:
• Cooling tower blowdown
• Reverse Osmosis (RO) reject wastewater
• Compressor condensation
• Contact stormwater
Requires an individual EPA permit
26
![Page 27: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/27.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Discharges
Produced Water Discharges:
27
![Page 28: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/28.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Discharges
West of the 98th:
• Individual EPA Permit is required unless a GeneralPermit becomes available
• Still covered undereffluent guidelines in 40 CFR Part 435, Subpart E
• Produced water must be beneficially used for agriculture or wildlife when discharged into navigable waters
28
![Page 29: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/29.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Discharges
East of the 98th:
• Covered by EPA General Permit TXG 330000
• File Notice of Intent (NOI)
• Produced water must be fromCarrizo-Wilcox, Reklaw or Bartoshformations
• Discharges into impaired waters may require an individual permit from the EPA
29
![Page 30: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/30.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Discharges
Territorial Seas:
• Covered by EPA General Permit TXG 260000
• File Notice of Intent (NOI)
• Line of ordinary low water along coast which is in direct contact with open sea and the line marking seaward limit of inland waters, extending seaward a distance of three miles
30
![Page 31: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/31.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Discharges
Outer Continental Shelf:
• Covered by EPA General Permit TXG 290000
• File Notice of Intent (NOI)
• Authorizes discharges for drilling fluids, drill cuttings andproduced water
• From 3 miles to 9 miles seaward (beyond are Federal Waters)
31
![Page 32: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/32.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Discharges
Discharge Testing Parameters:
• Oil and Grease
• Total Dissolved Solids (except Continental Shelf)
• Whole Effluent Toxicity (WET) Test
32
![Page 33: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/33.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Pits
Some pits authorized by SWR 8 (e.g. Reserve Pits, NCFR)
Not authorized pits that require a permit:
• Commercial Fluid Recycling Pit
• Disposal Pit
• Collecting Pit
• Emergency Saltwater Storage Pit
• Brine Pit
• Washout Pit
• Skimming Pit
• Gas Plant Evaporation/Retention Pit
33
![Page 34: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/34.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Pits
You have a pit if…
• It’s in contact with the ground but not an above ground storage tank
• If it’s below grade
• If it’s a concrete structure that cannot be moved quickly and easily to check for leaks
• If it’s a steel containment ring with a liner
• If it’s a “sump” larger than 500 gal
34
![Page 35: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/35.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Pits
Am I a pit?
35
![Page 36: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/36.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Pits
Am I a pit?
36
![Page 37: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/37.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Landspreading
Land-spreading includes landfarming, landtreatment, and the land applying of oil and gas waste.
Disposal of low toxicity wastes
• Uses soil-plant systems
• Applied to land surface or injected
• Natural attenuation of metals
Landfarm – Water base drilling muds/cuttings
Landtreatment – Oil base drilling muds/cuttings
Land Apply – Produced Water and Gas Plant Effluent
37
![Page 38: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/38.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Landspreading
Landfarm, Landtreatment and Land Apply Factors :
• Soil grain size and thickness (20 inches, slope less than 5%)
• Runoff
• Overloading
• Precipitation and evaporation
• Depth to Groundwater
• Distance from surface water features
• 100-year floodplain
38
![Page 39: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/39.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Landspreading
Landfarming authorized by SWR 8 (without a permit):
• Wastes disposed of on the lease where they are generated
• Written consent of the surface owner
• Water base drilling fluids with a chloride concentration below 3000 mg/L
• Drill cuttings, sands and silts obtained while using water base drilling fluids with a chloride concentration of 3000 mg/l or less
• Wash water used for cleaning drill pipe and other equipment at the well site
39
![Page 40: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/40.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Reclamation
Reclamation of oil and gas waste:
• Usually tank bottoms
• Other waste with reclaimable hydrocarbons
• Methods of separation
– Mechanical
– Chemical
– Thermal
40
![Page 41: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/41.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Reclamation
Plants are designed for the recovery of hydrocarbons, not just the separation of waste material
• Submit a Form R-9
• Attach answers to Instructions to Form R-9
• Notice and financial security is required
• Additional information may be required to complete the application
• Reclamation plant permits will be canceled if operations are inactive for more than 12 months.
41
![Page 42: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/42.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Waste Separation
Waste is separated into solid and liquid components prior to disposal
• Thermal, chemical, or physical separation
• Liquids disposed of at an injection well
• Notice and financial security is required
• Solids disposed of at a landfill
• Application information will vary depending on the type of facility.
• Incidental hydrocarbons may be recovered
42
![Page 43: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/43.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Recycling
RRC encourages the recycling of oil and gas waste.
Rules are divided into separate division based on:
• Type of oil and gas waste being treated
• Location
• Duration of the treatment operations
43
![Page 44: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/44.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Permit Types: Stationary Treatment Facility (STF)
An “umbrella” permit type offered to include various oil and gas operations.
44
![Page 45: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/45.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Questions
Questions?
45
![Page 46: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/46.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process
![Page 47: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/47.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process
• Application Received
• Administrative Review
• Technical Review
• Application Disposition
–Permit granted
–Hearing
47
![Page 48: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/48.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process
48
![Page 49: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/49.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Application Received
• All documents must be submitted Hardcopy
–Applications, Responses, Requests, etc.
–Mail or Hand Deliver
• Documents are date stamped and reviewed in the order received
• Incomplete applications and partial responses will not be reviewed. The review time will start once all materials have been received.
49
![Page 50: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/50.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Application Received
• Texas Administrative Code (TAC) Title 16, Part 1, Chapter 1.201 (c) (4)
–The applicant has two supplemental filings to satisfy the application deficiencies identified in the written correspondences provided by Technical Permitting
50
![Page 51: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/51.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Administrative Review
• Organization Report (Form P-5)
–Status, Officers and SB 639
• Original Signatures on official forms
–H-11 and Reclamation Plant Application
• Incomplete Application Package
–Missing information (one sheet of paper requests)
• Fee Submitted
–Discharges (if applicable)
51
![Page 52: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/52.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Technical Review
General Requirements:
• Site Information
• Process Information
• Facility Design Construction
• Facility Monitoring and Duration
• Site Closure
Commercial Facility Requirements:
• Notification
• Closure Cost Estimate (CCE)
52
![Page 53: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/53.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Technical Review
Site Information:
Property
• Survey/Lease
• Landowner
• Adjacent Landowners
• Receptors
Environmental
• Soil, Geology, Surface Water, Groundwater, Wetlands, Floodplains, etc.
53
![Page 54: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/54.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Technical Review
Property: Survey/Lease
54
![Page 55: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/55.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Technical Review
Property: Surface owner/Adjacent Surface owners
55
![Page 56: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/56.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Technical Review
Property: Receptors within 500 feet
56
![Page 57: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/57.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Technical Review
Process Information:
• Written narrative describing processing and treatment from the time waste enters the facility
• Provide a list and the function of all processes, equipment, chemicals, aggregates and waste management units
• Flow diagram of the process that matches the narrative
57
![Page 58: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/58.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Technical Review
Process/Treatment Flow Diagram
58
![Page 59: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/59.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Technical Review
Facility Design:
• Diagrams
–must be drawn to scale, include a title block, north arrow, legend
–Access control
–Locations, dimensions, material and volumes of waste management units, berms, equipment, buildings, access roads, etc.
59
![Page 60: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/60.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Technical Review
60
![Page 61: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/61.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Technical Review
Facility Design:
• Pits
–Two perpendicular cross-sections
–Liner information, including Leak Detection Systems (LDS) and Leachate Collection Systems (LCS)
–Capacities
61
![Page 62: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/62.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Technical Review
Stormwater Management Plan
• Permits will distinguish between contact stormwater and non-contact stormwater
• Non-contact stormwater may be discharged without a permit from RRC. A permit from EPA may be required
• Best Management Practices (BMPs) should be followed when managing non-contact stormwater
• Contact stormwater is considered oil and gas waste and must be managed, stored and contained separate from non-contact stormwater and disposed of in an authorized manner
• Discharge of contact stormwater is prohibited
62
![Page 63: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/63.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Technical Review
Stormwater Management Plan
• Establish BMPs to reduce the discharge and potential discharge of pollutants:
–Use grading, berming, or curbing
–Locate materials, equipment and activities so that leaks are contained in existing containment
–Clean up spills and leaks promptly
–Use spill/overflow protection equipment (level alarms, sluice gates, etc.)
63
![Page 64: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/64.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Technical Review
Stormwater Management Plan
64
![Page 65: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/65.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Technical Review
Facility Monitoring and Duration:
• Waste Acceptance Plan
–RCRA-exempt waste
–RCRA non-exempt waste
–Define sampling procedures• Product/Disposal Assurance
–Paint Filter Test
–Is the waste less than 7% TPH?
–Roadbase sampling – TxDOT
65
![Page 66: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/66.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Technical Review
Facility Monitoring and Duration:
• Inspection
–Facility and berm integrity
–Condition of the Groundwater Monitoring Wells
–LCS and LDS records
66
![Page 67: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/67.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Technical Review
Site Closure:
• Detailed Closure Plan
–Remove all tanks and equipment
–Empty all pits and dispose of liners
–Clean, break up and dispose of all concrete
–Final Sampling of soils and groundwater
–Demo berms, backfill pits, restore site to natural grade and revegetate
–Post-closure monitoring
–Financial Security (CCE, Restrictive Covenant)
67
![Page 68: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/68.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Permit Disposition
Hearing:
Hearing Memo is drafted if the facility is protested:
• Permit is drafted by staff
• Application must be administratively complete before being referred to the Hearings Division
68
![Page 69: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/69.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Application Process: Permit Disposition
Permit:
Once the application process is complete the permit will be mailed to the operator.
69
![Page 70: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/70.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Questions
Questions?
70
![Page 71: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/71.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Lease Agreements
![Page 72: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/72.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Lease Agreements
• A surface lease agreement must be between the P-5 operator that is applying for the permit and the surface owner(s)
• A surface lease agreement must be provided for all facilities where the P-5 operator does not own the property
• RRC Leases and Surface Leases are different and serve different purposes
• Lease agreements are also reviewed by the Office Of General Council Staff
72
![Page 73: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/73.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Questions
Questions?
73
![Page 74: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/74.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements
![Page 75: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/75.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements
• Requirements by Rule
• When to Notice
• Types of Notice
• Notice by Application Type
• Proof of Notice
• General Comments
75
![Page 76: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/76.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Requirements by Rule
Requirements by Rule:
• Statewide Rule 8
–Discharges
–Pits
–Landspreading Facilities
–Waste Separation Facilities
• Statewide Rule 57
–Reclamation Facilities
76
![Page 77: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/77.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Requirements by Rule
Requirements by Rule:
• 16 TAC Chapter 4 Subchapter B
–Division 2, 3, 4, 5 and 6 Recycling
• Texas Natural Resources Code Chapter 91
–Commercial Disposal Facilities
• Commercial Disposal Pits
• Commercial Landspreading
•Waste Separation Facilities
77
![Page 78: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/78.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Requirements by Rule
Statewide Rule 8:• Notice to surface owner where disposal will take
place• Notice to City Clerk if located within corporate limits• Notice to surface owner of discharge and one-half
mile downstream• The applicant shall mail or deliver the required notice
to the surface owners and the city clerk or other appropriate official on or before the date the application is mailed or delivered to the commission in Austin
78
![Page 79: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/79.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Requirements by Rule
Statewide Rule 8:
• Notice shall consist of a copy of the application together with a statement that any protest to the application should be filed with the commission within 15 days of the date the application is filed with the commission
• The notice shall be published once each week for two consecutive weeks by the applicant in a newspaper of general circulation in the county where the pit will be located or the disposal will take place
79
![Page 80: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/80.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Requirements by Rule
Statewide Rule 57:
• Notice to the County Clerk
• Notice to City Clerk if located within corporate limits
• Notice to County and City Clerk must be given on or before the date the application is mailed to or filed with the commission
• Notice shall be published once in a newspaper of general circulation for the county where the reclamation plant is to be located
• Publication shall occur on or before the date the application is mailed to or filed with the commission
80
![Page 81: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/81.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Requirements by Rule
16 TAC Chapter 4 Subchapter B:
• Publish notice of the application in a newspaper of general circulation in the county in which the proposed facility will be located at least once each week for two consecutive weeks with the first publication occurring not earlier than the date the application is filed with the Commission and not later than the 30th day after the date on which the application is filed with the Commission
81
![Page 82: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/82.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Requirements by Rule
16 TAC Chapter 4 Subchapter B:
• The applicant shall mail or deliver notice on or afterthe date the application is filed with the Commission's headquarters office in Austin:
–Surface owner
–City Clerk
–Adjacent Surface Owners
82
![Page 83: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/83.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Requirements by Rule
Texas Natural Resources Code Chapter 91:
• Requirements for Published Notice Only
• At least once each week for two consecutive weeks with the first publication occurring not earlier than the date the application is filed and not later than the 30th day after the date on which the application is filed
• In a newspaper of general circulation in the county in which the proposed disposal would occur
83
![Page 84: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/84.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
General Notice Requirements: When to Notice
When to Notice:
• New Applications, Renewal Applications, Major Amendments*
–Most rules require that notice to Surface Owners be provided
–If the applicant is required to publish notice
•The notice shall be published in a newspaper of general circulation for the county were the facility/operations is to be located
84
![Page 85: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/85.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Types of Notice
Types of Notice:
• Notice to Surface Owners, Adjacent Surface Owners and City/County Clerk Officials
–A full copy of the application
–A statement that any protest to the application should be filed with the Commission within 15 days of the date the application is filed with the Commission
–The mailing address for Technical Permitting
–Description of facility/operations
85
![Page 86: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/86.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Types of Notice
Newspaper Publication Template
86
![Page 87: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/87.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
Discharge - New (Initial) Applications:
–Notice requirements found in 16 TAC §3.8(d)(6)(C) and 16 TAC §3.8(d)(6)(G)
87
![Page 88: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/88.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
• One half mile downstream starts from the point of discharge – in most cases where the effluent leaves the pipe.
• The point of discharge and the facility location are not always one in the same.
88
![Page 89: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/89.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
89
![Page 90: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/90.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
Pits – New (Initial) Application:
–Notice requirements found in 16 TAC §3.8(d)(6)(C)
90
![Page 91: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/91.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
Property: Surface owner/Adjacent Surface owners
91
![Page 92: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/92.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
92
![Page 93: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/93.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
Landspreading - Landfarm, Landtreatment, Land Apply:
–Notice requirements found in 16 TAC §3.8(d)(6)(C)
93
![Page 94: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/94.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
Commercial Landspreading Facilities:
Notice requirements found in 16 TAC §3.8 (d)(6)(C)
• Additional requirements found in Texas Natural Resources Code (HB 480*) §§ 91.116 and 91.117
• Under HB480 "commercial surface disposal facility" means a facility whose primary business purpose is to provide, for compensation, surface disposal of oil field fluids or oil and gas wastes, including land application for treatment and disposal
94
![Page 95: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/95.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
Commercial Landspreading Facilities:
• According to HB 480 §91.116 (d), notice must be published:
–At least once each week for two consecutive weeks with the first publication occurring not earlier than the date the application is filed and not later than the 30th day after the date on which the application is filed
–In a newspaper of general circulation in the county in which the proposed disposal would occur
95
![Page 96: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/96.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirement: Notice by Application Type
Reclamation (R9):
–Notice requirements found in 16 TAC §3.57(c)*
96
![Page 97: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/97.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
On-lease Commercial Solid Oil and Gas Waste Recycling (Division 2):
• Also referred to as Mobile Recycling
• The permittee is required to obtain written permission from the surface owner of the lease upon which recycling will take place and notify the appropriate Commission district office 72 hours before operations commence on each lease
97
![Page 98: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/98.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
On-lease Commercial Solid Oil and Gas Waste Recycling (Division 2):
–Notice requirements found in 16 TAC § 4.218
98
![Page 99: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/99.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
Off-lease or Centralized Solid Oil and Gas Waste Recycling (Division 3):
–Notice requirements found in 16 TAC §4.238
99
![Page 100: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/100.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
Stationary Commercial Solid Oil and Gas Waste Recycling (Division 4):
–Notice requirements found in 16 TAC §4.254
100
![Page 101: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/101.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
Stationary Commercial Solid Oil and Gas Waste Recycling (Division 4):
• According to 16 TAC §4.254 (a)(1) notice must be published:
–in a newspaper of general circulation in the county in which the proposed facility will be located
–at least once each week for two consecutive weeks with the first publication occurring not earlier than the date the application is filed with the Commission and not later than the 30th day after the date on which the application is filed with the Commission
101
![Page 102: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/102.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
Off-Lease Commercial Recycling of Fluid (Division 5):
–Notice requirements found in 16 TAC §4.270
102
![Page 103: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/103.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
Stationary Commercial Recycling of Fluid (Division 6):
–Notice requirements found in 16 TAC §4.286
103
![Page 104: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/104.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
Stationary Commercial Recycling of Fluid (Division 6):
• According to 16 TAC §4.286 (a)(1) notice must be published:
–in a newspaper of general circulation in the county in which the proposed facility will be located
–at least once each week for two consecutive weeks with the first publication occurring not earlier than the date the application is filed with the Commission and not later than the 30th day after the date on which the application is filed with the Commission
104
![Page 105: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/105.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
Disposal Pits – New (Initial) Application:
–Notice requirements found in 16 TAC §3.8 (d)(6)(C)
–Additional requirements found in Texas Natural Resources Code (HB 480) §§ 91.116 and 91.117
105
![Page 106: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/106.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
Commercial Disposal Pits:
Notice requirements found in 16 TAC §3.8 (d)(6)(C)
• Additional requirements found in Texas Natural Resources Code (HB 480*) §§ 91.116 and 91.117
• Under HB480 "commercial surface disposal facility" means a facility whose primary business purpose is to provide, for compensation, surface disposal of oil field fluids or oil and gas wastes, including land application for treatment and disposal
106
![Page 107: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/107.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Notice by Application Type
Commercial Disposal Pits :
• According to HB 480 §91.116 (d), notice must be published:
–At least once each week for two consecutive weeks with the first publication occurring not earlier than the date the application is filed and not later than the 30th day after the date on which the application is filed
–In a newspaper of general circulation in the county in which the proposed disposal would occur
107
![Page 108: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/108.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Proof of Notice
Providing Proof of Notice:
• Must include a copy of the notification letter(s) provided to surface owner/offset landowner(s)
• Certified mail is recommended*
• If published notice is required:
–Tear sheets of the notice are required. Entirety, Not Altered.
–Scans of print, clippings from the newspaper and drafts of the notice are NOT acceptable
–Publisher’s Affidavit is required
108
![Page 109: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/109.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: Proof of Notice
Affidavit
109
![Page 110: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/110.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: General Comments
General Comments:
• Adjacent landowners must be notified for any commercial environmental permit application, excluding On-Lease Commercial Solid Oil and Gas Waste Recycling (Division 2) and Reclamation permits*
• If you are providing a telephone number, be sure to provide the CORRECT phone number (512-463-3840). The fax number is not acceptable
• Landowner Notice is not required if the facility will be located on land owned by the applicant
110
![Page 111: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/111.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Notice Requirements: General Comments
General Comments:
• Failure to publish notice, in accordance with the rule will result in the application being returned
• Failure to provide proper notice may result in an application not being approved or cancellation of a permit after issuance if it is found that proper notice was not provided (refer to the specific rules)
111
![Page 112: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/112.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Questions
Questions?
112
![Page 113: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/113.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Renewals, Transfers and Amendments
113
![Page 114: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/114.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Renewals, Transfers and Amendments
• Reclamation (R9)
• Renewals
• Transfers
• Amendments*
114
![Page 115: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/115.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Renewals, Transfers and Amendments: Reclamation
Reclamation Plants (R9):
• Do NOT Renew or Transfer
• Change in operator will require submittal of a complete application, including all additional requirements (Diagrams, Notice, Financial Security, etc.)
115
![Page 116: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/116.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Renewals, Transfers and Amendments: Renewals
• Most permits issued by Environmental Permits & Support are renewable. These permits are typically issued for a period of five years and expire automatically unless renewal is requested by the Permittee.
• To request renewal of a RRC environmental permit, the Permittee must send a complete renewal application to Technical Permitting in Austin, and to the appropriate District Office, requesting renewal at least 60 days prior to the expiration of the permit.
116
![Page 117: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/117.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Renewals, Transfers and Amendments: Renewals
Discharge Renewals Require:
• Request Letter
• Application Fee (if applicable)
• Notice (if applicable)
–Surface owner at point of discharge
–Surface owners ½ tract downstream
–City Clerk or other appropriate official
• Water Analysis
117
![Page 118: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/118.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Renewals, Transfers and Amendments: Renewals
Private Permit Renewals Require:
• Request Letter
• Notice (if applicable)
–Landowner
–Adjacent landowner
–City Clerk or other appropriate official
• New Form H-11 (Pits Only)
• Noncommercial Pit Permits do NOT require Notice
118
![Page 119: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/119.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Renewals, Transfers and Amendments: Renewals
Centralized Permit Renewals Require:
• Request Letter
• CCE (if applicable)
• Notice (if applicable)
–Landowner
–Adjacent landowner
–City Clerk or other appropriate official
• NORM Survey (excluding Landspreading)
• New Form H-11 (pits only)
• Noncommercial Pit Permits do NOT require Notice
119
![Page 120: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/120.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Renewals, Transfers and Amendments: Renewals
Commercial Permit Renewals Require:
• Request Letter
• CCE
• Notice (if applicable)
–Landowner
–Adjacent landowner
–Publication (excluding Collecting Pit)
–City Clerk or other appropriate official
• NORM (excluding Landspreading)
• New Form H-11 (pits only)
120
![Page 121: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/121.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Renewals, Transfers and Amendments: Transfers
• To transfer a RRC environmental permit, the Operator who will be the new Permittee after the transfer must send a letter to Technical Permitting in Austin requesting transfer of the permit(s).
121
![Page 122: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/122.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Renewals, Transfers and Amendments: Transfers
• The transfer request should be received after ownership has been transferred, but 60 days before the new Operator begins operations.
• A transfer request does not guarantee approval of a permit transfer and the permit may be subject to modification.
122
![Page 123: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/123.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Renewals, Transfers and Amendments: Transfers
• Commercial permits and discharges associated with a Form P-4 must transfer the Form P-4 before the environmental permit can be transferred.
• Non-commercial pit permits associated with a RRC-designated lease will require a transfer request when the Form P-4 is transferred to the new Operator unless otherwise stated in the current permit.
123
![Page 124: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/124.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Renewals, Transfers and Amendments: Transfers
• Transfer of Discharge:
–Request
–Water Analysis
• Transfer of Private/Centralized:
–Request
–New Form H-11 (pits only)
• Transfer of Commercial:
–Request
–NORM (excluding Landspreading)
–New Form H-11 (pits only)
–CCE124
![Page 125: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/125.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Renewals, Transfers and Amendments: Amendments
• To request an amendment of a RRC environmental permit, the Permittee must send to Technical Permitting in Austin a letter describing the requested amendments that should explain why the amendments are necessary.
• Any change to operations regarding the permit should be noted. Any change to Diagrams, descriptions, etc. should be included.
125
![Page 126: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/126.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Renewals, Transfers and Amendments: Amendments
• If the permit requires financial security and the amendments to the permit would increase the cost of closure, a new Closure Cost Estimate (CCE) must be submitted.
• Depending on the significance of the permit amendments, surface owner, adjacent landowner, and published notice may be required.
126
![Page 127: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/127.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Renewals, Transfers and Amendments: Amendments
• An amendment request does not guarantee approval of a permit amendment and the permit may be subject to modification.
• Do not implement any changes subject to the amendment request prior to issuance of the amended permit, authorization from Technical Permitting and approval of the revised financial security (if financial security is required).
127
![Page 128: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/128.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Renewals, Transfers and Amendments: Amendments
• Amendment Requirements are case by case and determined based on significance of change.
• Examples:
–Volume/Capacity
–Surface Area
–Location
–Operational change
–Waste Streams
–Equipment
128
![Page 129: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/129.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Renewals, Transfers and Amendments: Amendments
• Amendments Require:
–Request Letter
–Detailed Description of change and any applicable Diagrams
• Amendments May Require:
–NORM Survey
–CCE
–Notice
129
![Page 130: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/130.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Questions
Questions?
130
![Page 131: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/131.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
NORM Surveys
![Page 132: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/132.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
NORM Surveys
Naturally Occurring Radioactive Material (NORM)
• Definition
• Jurisdiction
• When a NORM Survey is required
• What to include in NORM Survey
132
![Page 133: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/133.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
NORM Surveys: Definition
Naturally Occurring Radioactive Material (NORM) is encountered in oil and gas exploration, development and production operations, and originates in subsurface formations
• NORM accumulates within the sludge found in oilfield pits and tanks (tank bottoms). These solids become sources of oil and gas NORM waste
• NORM Rules found in 16 TAC Chapter 4, Subchapter F
133
![Page 134: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/134.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
NORM Surveys: Jurisdiction
– Texas Department of State Health Service (DSHS)
Regulates possession, use, transfer, transport, and storage
– The RRC gives authority to dispose of NORM waste in NORM authorized injection wells or private landfarms.
134
![Page 135: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/135.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
NORM Surveys: When a NORM Survey is Required
– Renewal applications for commercial facilities
– Transfer of commercial facilities* that have not been surveyed in over five (5) years
– The presence of NORM will affect the financial security
135
![Page 136: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/136.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
NORM Surveys: What to Include in a NORM Survey– The date of the survey
– The instrument used, the last calibration date, and a copy of the calibration records
– A background reading
– A site diagram showing where all readings, including the background, were taken. All tanks, pits and equipment are required to be surveyed
– The readings (in microroentgens per hour)
136
![Page 137: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/137.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
NORM Surveys: What to Include in a NORM Survey
– Identification of Equipment Contaminated with NORM
– RULE §4.605 states that the operator must identify NORM-contaminated equipment.
NORMNORM
137
![Page 138: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/138.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Questions
Questions?
138
![Page 139: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/139.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Closure Cost Estimates
![Page 140: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/140.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Closure Cost Estimates
• Definition
• When a CCE is Required
• Major CCE Components
• Assumptions
• Filing Financial Security
140
![Page 141: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/141.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Closure Cost Estimates: Definition
• A Closure Cost Estimate (CCE) is:
– A CCE is a “written estimate approved by the Commission or its delegate as being equal to or greater than the maximum amount necessary to close the commercial facility” (see Statewide Rule 78 (l)(4)(A))*
– Statewide Rule 78: Requirements
– Financial Security (FS) required for commercial facilities is separate from FS filed for wells**
– Provides available funds for the RRC to close a facility, if necessary
141
![Page 142: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/142.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Closure Cost Estimates: When a CCE is Required
• When is a CCE Required?
– Required for Commercial Facilities
• The amount of financial security to be maintained throughout the duration of the permit is determined by the CCE
– New Applications
– Renewal Applications*
– Transfer Application**
– Major Amendments***
142
![Page 143: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/143.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Closure Cost Estimates: Major CCE Components
• Major CCE Components:
– Offsite Waste Disposal Costs*
– Waste Loading & Transportation Costs
– Tank Cleaning/Removal/Disposal*
– Concrete Cleaning/Removal/Disposal
– Contaminated Soil Removal/Disposal
– Site Restoration
– Soil Sampling /Tilling (if applicable)
– Monitor Well Plugging
– Closure Soil Sampling
– Oversight & Contingencies
– Post Closure Activities143
![Page 144: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/144.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Closure Cost Estimates: Assumptions
– Show all assumptions for estimated costs.
• Remove all waste from entire facility
• Transport, disposal, removal, backfill
• Crew, dozers, welders, cleaning, etc.
– Based on worst case scenario (i.e., all pits/tanks are full)*
– The facility is operated at permitted capacity with no pollution violations
– Restrictive Covenants**
• Property owner agrees material will be available for closure
• Must be certified by the RRC144
![Page 145: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/145.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Closure Cost Estimates: Filing Financial Security
– Technical Permitting will issue a “CCE Approval” letter when the application is complete
– P-5 Department processes all financial security documents*
• Bond – Form CF-1
• Letter of Credit – Form CF-2
– A facility may not receive, store, handle, treat or dispose of oil and gas wastes or fluids at the facility until financial security is provided and approved by the RRC**
145
![Page 146: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/146.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Closure Cost Estimates: Filing Financial Security
• Filing Financial Security
– When transferring a permit, financial security must be on file with the RRC before the transferred permit will be issued.
– Financial Security must be maintained until the facility has been closed in accordance with the permit
146
![Page 147: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/147.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Questions
Questions?
147
![Page 148: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/148.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Restrictive Covenant
![Page 149: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/149.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Restrictive Covenant
• Definition
• It is required?
• Components
• Filing
149
![Page 150: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/150.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Restrictive Covenant: Definition
• What is a Restrictive Covenant (RC)?
– Deed restriction stating that soil material will be used for closure
150
![Page 151: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/151.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Restrictive Covenant: Is it Required?
• Is a RC Required or Optional?
– Not required
– A Restrictive Covenant is required if fill dirt will be excavated from the property to use for any backfilling or grading
151
![Page 152: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/152.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Restrictive Covenant: Components
• Major Restrictive Covenant Components:
– A deed restriction stating that soil will be available for closure
– The location of the material
– Type of material
– Volume/amount of material
152
![Page 153: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/153.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Restrictive Covenant: Filing
1. Operator submits a draft RC2. Technical Permitting approves the closure cost
estimate and the closure plan3. Operator submits a signed RC with signatures
– The landowner– the operator
4. RRC signs the RC5. RRC returns the RC to the Operator6. Operator shall file the signed RC to the property
records of the county where the property is located
7. The Operator shall provide a certified copy of the RC back to the RRC
153
![Page 154: Oil and Gas Waste Stream Management and Additional ......Applicable Rules & Publications: Surface Waste •Offers guidelines for the management of oil and gas wastes. •Private Facilities:](https://reader030.vdocuments.net/reader030/viewer/2022040905/5e79c826e3bf16350d6e6c76/html5/thumbnails/154.jpg)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Heidi [email protected]
Krystal [email protected]
Environmental Permit & Supports512-463-3840
Questions?