Pre-injection Unit Registration Application Revisions and Renewal Issues

1. Pre-injection Unit Registration Application Revisions and Renewal Issues Kathryn Hoffman, P.E. and Jan Bates, P.E. Underground Injection Control Permits Section Radioactive Materials Division Texas Commission on Environmental Quality TCEQ Trade Fair May 7, 2014

2. PIU Registration Application Revisions Background

3. Pre-injection Unit (PIU) Registration Application Revisions • Pre-injection Units are the on-site above-ground appurtenances, structures, equipment, and other fixtures including the injection pumps, filters, tanks, surface impoundments, and piping for wastewater transmission between any such facilities and the well. [30 TAC §331.2(83)]

4. PIU Registration Application Revisions • The TCEQ adopted rules in January 2003 allowing permittees the option to authorize PIUs associated with nonhazardous noncommercial Class I injection wells by a PIU registration processas an alternative to permitting them under the Class I UIC permit. [28 TexReg 340]

5. PIU Registration Application Revisions • PIUs associated with nonhazardous noncommercial Class I Underground Injection Control (UIC) wells must be authorized by one of the two above-mentioned methods. • It is the permittee’s option whether to permit the PIUs under the UIC permit or authorize them under a PIU registration.

6. PIU Registration Application Revisions • Permittees seeking to register existing unauthorized PIUs need to submit theapplication on or before the date the injection well permit renewal application is submitted. [30 TAC §331.17(c)(1)(B)] • Because the PIU registration process became effective 11 years ago, most previously unauthorized PIUs should be covered by now.

7. PIU Registration Application Revisions • For permittees that miss the previously-mentioned deadline, the permittee must cease operation of any PIU if the registration application for an existing unauthorized PIU hasnot been submitted before approval of the injection well permit renewal. [30 TAC §331.17(c)(2)(A)]

8. PIU Registration Application Revisions • For any proposed (i.e., planned or pre-operational) PIU to be authorized by registration, the permittee must obtain approval of the PIU registration before operating the PIU. [30 TAC §331.17(c)(1)(A)]

9. PIU Registration Application Revisions Update

10. PIU Registration Application Revisions • The Class I UICpermit application was revised about a year ago, including Section XII, “Pre-injection Unit Engineering Report.” • The revisions included updates and clarifications of technical information required for PIUs.

11. PIU Registration Application Revisions • The PIU registration application was revised last month to make it consistent with the Class I UIC permit application. • Whether PIUs are authorized under the Class I UIC permit or by PIU registration, the technical standards and documentation requirements are the same. • PIUs authorized by registration are not subject to a contested case hearing.

12. PIU Registration Application Revisions Highlights of Updates

13. PIU Registration Application Revisions • The revised PIU registration application now specifies what information needs to be submitted for major amendments, minor amendments and transfers of PIU registrations. • According to the rules, notice is provided only for new applications, renewals and major amendments.

14. PIU Registration Application Revisions • In addition to the requirement for P.E. seals on all engineering work submitted to the TCEQ, all engineering documents released, issued or submitted by a licensee shall clearly indicate the firm name and registration number of the engineering firm by which the engineer is employed. [30 TAC §305.45(a)(8), §305.50(a)(7) and 22 TAC §137.33]

15. PIU Registration Application Revisions • The application was reformatted to clarify the difference between the P.E. seal requirement and the statement certifying compliance with 30 TAC Chapter 217 • The application requires a detailed description of the process flow of waste from the point of generation to deep well injection

16. PIU Registration Application Revisions • The revised application requires: • a list of all pre-injection units to be authorized • a detailed engineering description of each pre-injection unit • plans for any secondary containment for each unit

17. PIU Registration Application Revisions • a description of any corrosion protection, run-on prevention, spill and overflow prevention, and air pollution controls • plans for unit closure including waste disposal, unit decontamination and soil sampling and analysis

18. PIU Registration Application Revisions • The application better defines information required for surface impoundment design including location of 100-year flood zone, liner specifications and installation methods, and any leachate collection and/or leak detection system plans

19. PIU Registration Application Revisions • The revised application has been posted on the TCEQ website at the following web address:http://www.tceq.texas.gov/permitting/waste_permits/uic_permits/UIC_Guidance_Class_1.html

20. PIU Registration Application Revisions • The information in this presentation pertains to PIUs associated with nonhazardous noncommercial Class I UIC wells. • PIUs associated with hazardous waste wells must meet the requirements of the Resource Conservation and Recovery Act (RCRA).

21. PIU Registration Application Revisions • PIUs associated with nonhazardous commercial Class I UIC wells must be permitted under either a • consolidated UIC/Industrial and Hazardous Waste (IHW) permit; or • a separate IHW permit.

22. PIU Registration Application Renewal Issues

23. PIU Registration Application Renewal Issues • Question: • How will these application revisions affect your renewal applications? • Answer: • Renewal applications must be revised to include all information required by the revised application.

24. PIU Registration Application Renewal Issues • Make sure the engineering report and all associated engineering work is prepared, sealed, signed and dated by a licensed Texas P.E. • If needed, provide P.E. assessment that a unit is adequately designed, has sufficient structural strength and is constructed according to the plans and specifications.

25. PIU Registration Application Renewal Issues • All units that collect, handle, store, and/or process waste prior to disposal in an injection well must be registered as PIUs • May need to reevaluate the point of generation of waste disposed in the well and determine if additional units should be added to the application

26. PIU Registration Application Renewal Issues • May need to add detailed engineering description of each PIU, including spill prevention & run-on, run-off controls • May need to add information on corrosion protection & air pollution controls • May need to add information on secondary containment

27. PIU Registration Application Renewal Issues • May need to add a plan for closure, waste removal, decontamination, and soil sampling • May need to add additional information on surface impoundment design to include liner specifications, installation methods, 100-yr flood zone, leachate collection, and leak detection design

28. PIU Registration Application Renewal Issues • Question: • Are you unsure what to include in the renewal application? • Answer: • Schedule a pre-application meeting to discuss your questions.

29. Kathryn Hoffman, P.E. Underground Injection Control Permits Section Radioactive Materials Division (512) 239-6890 kathryn.hoffman@tceq.texas.gov Jan Bates, P.E. Underground Injection Control Permits Section Radioactive Materials Division (512) 239-6627 jan.bates@tceq.texas.gov