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Guidance for Filing Environmental Permit Applications

Guidance for Filing Environmental Permit Applications. August 20, 2014 Rusty Woodburn Environmental Permits & Support. Synopsis. Review of the Surface Waste Management Manual (SWMM)* Locating the necessary information Accessible online resources Application information for all permits

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Guidance for Filing Environmental Permit Applications

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  1. Guidance for Filing Environmental Permit Applications August 20, 2014 Rusty Woodburn Environmental Permits & Support

  2. Synopsis • Review of the Surface Waste Management Manual (SWMM)* • Locating the necessary information • Accessible online resources • Application information for all permits • Guidance for each application • Rules associated with permits * www.rrc.state.tx.us/oil-gas/publications-and-notices/manuals/surface-waste-management-manual/

  3. What Requires a Permit? • Any person who transports, handles, stores, discharges, disposes or recycles oil and gas waste subject to the Commission’s jurisdiction must have authority from the Commission • Each operator must have an active P-5 (Organizational Report) • All permit applications require an original signature

  4. RRC Website Easiest way to locate the SWMM Type “RRC Surface Waste Management Manual” into a search engine (Google, Bing, etc.) Or go to the RRC Website www.rrc.state.tx.us/ Click the “Oil & Gas” tab

  5. How to Access Permit Information “Oil & Gas” drop down menu

  6. SWMM – General Information

  7. SWMM – Permit Types The following pages will contain information about the links for each of these permit types

  8. Waste Hauler Permits (WHP) Helpful links • RRC regulates the transport of oil and gas waste • A person who transports waste must have a WHP Forms • WH-1: Application for waste hauler permit • WH-2: Updated list of operating vehicles • WH-3: RRC permitted waste receiver • Disposal of Waste at Texas Commission on Environmental Quality (TCEQ) or non-RRC Facilities is authorized if the water generator submits documentation to the RRC For more information about WHP contact Candace Goodwin at (512) 463-3840

  9. Hydrostatic Test (HT) Permits • HT Discharges • Used to test the integrity of pipelines and tanks • When water enters the pipeline or tank, it is considered oil and gas waste • May not be discharged without a permit * • HT Discharge Application • List of 15 questions • $750 application fee for discharges to waters of the state • Review frequently asked questions (FAQs) • Multiple discharges at one location require multiple HT permits • Waste water analysis requirements • * Cases when HT permits are not required

  10. Minor and Other Permits • Minor Permits • Issued by the appropriate District Office • Review the “Guidelines for Minor Permits” • Notice and Protest Guidelines • Analytical Guidelines • Guidelines for Disposal of Oily Waste • Off-Lease Landfarming and Landtreatment • Disposal of Basic Sediment and Drilling Fluid • Other Permits • Methods not authorized by the RRC or not requiring a permit • Must be applied for by submitting a letter of request

  11. Pit Permits • Disposal or storage of waste shall not pollute surface or subsurface waters • List of authorized pits in Rule 8(d)(4) • List of prohibited pits in Rule 8(d)(2) reserve pits mud circulation pits completion/workover pits basic sediment pits flare pits fresh makeup water pits fresh mining water pits non-commercial fluid recycling pits water condensate pits saltwater disposal pits collecting pits skimming pits brine pits brine mining pits washout pits emergency saltwater storage pits gas plant evaporation/retention pits drilling fluid storage pits (other than mud circulation pits) drilling fluid disposal pits (other than reserve pits pits)

  12. Pit Applications • Form H-11 must be submitted • Complete Items 1 thru 23 • Include Instructions to Pit Application – Items A thru L • Common mistakes • Missing information, blank answers • Incorrect P-5 address • Detailed figures and descriptions • Commercial facilities • Commercial Disposal Pits • Requires 21 additional questions • Associated Rule 8 and 22

  13. Recycling Permits • RRC encourages recycling of O&G waste • Texas Administrative Code Chapter 4, Subchapter B • Division 1 outlines the definitions and general requirements for commercial recycling • Solid Recycling – Reuse as roadbase, drilling pads, etc. • Division 2: On-Lease solid waste recycling • Limited to any on-lease location for one year • Division 3: Off-Lease solid waste recycling • Limited to any location for two years • Division 4: Stationary solid waste recycling • Permitted for one location for five years

  14. Recycling Permits, Cont. • Fluid Recycling: Reuse of wellbore fluids • Authorized • On a lease associated with drilling permit, disposal well, or injection well • If used in the wellbore of an O&G well (frac fluid) • If reused for legitimate commercial use if water is distilled • Division 5: Off-Lease fluid recycling • Limited to any location for two years • Division 6: Stationary fluid recycling • Permitted for one location for five years

  15. Discharge Permits • HTs • Gas Plant Effluent Discharges • Produced Water Discharges • Inland waters • Gulf of Mexico • Storm water discharges • Non-contact storm water • RRC permit not required • EPA permit may be required • Contact storm water • Considered oil and gas waste • Must be disposed of in an authorized manner • Rule 93: Permits must be in compliance with state and federal laws • Rule 30: RRC and TCEQ jurisdiction

  16. Landfarm and Landtreatment • Landfarms • Authorized under the following conditions • Written consent is required from the surface owner • Wastes are disposed of on the lease they were generated • Wastes are restricted to water-based drilling fluids and associated cuttings • Chloride concentration is 3,000 mg/L or less • All other landfarming operations require a permit • Landtreatment • Any land spreading of oil-based drilling fluids and associated cuttings requires a permit • Land apply produced water • Sprinkler irrigation • Flood irrigation • Ridge and furrow irrigation • Surface spreading

  17. Reclamation Plants • Reclamation of oil and gas waste • Usually tank bottoms and • Other reclaimable hydrocarbons • Methods of separation • Application information • Submit a Form R-9 • Attach answers to Instructions to Form R-9 • Commercial Facilities • Rule 57 • Physical or mechanical • Chemical • Thermal

  18. Waste Separation Facilities • Waste is separated into solid and liquid components prior to disposal • No hydrocarbons are reclaimed

  19. Commercial Facilities • Operating a commercial facility • Receives compensation for handling, storing, reclaiming, treating, disposing, recycling of waste • Includes the following commercial permits • Pits • Recycling • Landfarm • Landtreatment • Reclamation • Waste separation • Statewide Rule 78 • Operator is required to provide financial security • Bond – Form CF-1 • Letter of Credit – Form CF-2 • Guidance for the forms

  20. Closure Cost Estimates • Closure cost estimate requirements • Show all assumptions used for estimate • Costs for transport, disposal, removal, backfill • Costs for crew, dozers, welders, cleaning, etc. • Based on worst case scenario • Prepared by a Professional Engineer licensed by the state • Restrictive Covenant Form • Property owner agrees material will be available for closure • Must be certified by the RRC

  21. Hazardous Waste Information • Hazardous Waste Manual • Hazardous waste determination • Exempt and Non-exempt wastes • Classification of wastes • Notification • Management Standards • Statewide Rule 98

  22. Naturally Occurring Radioactive Material • NORM jurisdiction • RRC regulates activities associated with disposal of O&G NORM waste • Texas Department of State Health Service (DSHS) • Regulates possession, use, transfer, transport, and storage • Website NORM descriptions • Radiation limits provided in tables • State regulation discussions b/w RRC and DSHS • NORM survey requirements • Additional information • Review NORM FAQs • NORM Rules - Chapter 4, Subchapter F

  23. Permit Applications Table Basic requirements for each application

  24. Renewals and Transfers • Renewals and Transfers by letter of request • Submit w/in 60 days of the expiration date or new operation • State if modifications have been or will be made to the facility • NORM surveys are required for existing facilities • Update financial security

  25. Amendments • Amendments by letter of request • Describe and explain the requested amendments • Provide all information about any changes • Submit new diagrams, descriptions, etc. • Update financial security if needed • Notice is required * All permits are subject to modification to update permit conditions

  26. Applicable Statewide Rules • Rule 8(3.8): Water Protection • Rule 22 (3.22): Protection of Birds • Rule 30 (3.30): Memorandum of Understanding between the RRC and TCEQ • Rule 57 (3.57): Reclaiming Tank Bottoms, Other Hydrocarbon Wastes, and Other Waste Materials • Rule 78 (3.78): Fees, Performance Bonds and Alternate Forms of Financial Security Required to be Filed • Rule 91 (3.91): Cleanup of Soil Contaminated by a Crude Oil Spill • Rule 93 (3.93): Water Quality Certification • Rule 98 (3.98): Standards for Management of Hazardous Oil and Gas Waste • Chapter 4, Subchapter B: Commercial Recycling • Chapter 4, Subchapter F: Oil and Gas NORM

  27. Online Resources • Current Environmental Permits • Permitted Commercial Disposal Facilities • Permitted O&G Waste Haulers and Disposal Wells • Available permit application forms - Form WH-1: Waste Hauler (WH) Permit Application - Form WH-2: WH List of Vehicles - Form WH-3: WH’s Authority to Use Waste Receiver - Form H-20: Hazardous Waste Generator Notification - Form H-21: Hazardous Waste Report - Form H-11: Pit Permit Application - Form R-2: Monthly Report for Reclaiming Oil - Form R-9: Reclamation Facility Application - Form CF-1: Commercial Facility Bond - Form CF-2: Commercial Facility Letter of Credit

  28. Online Resources, Cont. • Requirements for permit applications by letter of request • Discharge Hydrostatic Test Water • Discharge Gas Plant Effluent • Discharge Produced Water to Inland Waters • Discharge Produced Water to the Gulf of Mexico • Landfarm Water-Based Drilling Fluids • LandtreatOil-Based Drilling Fluids • Land Apply Produced Water • Operate a Commercial Waste Separation Facility • Operate a Commercial Recycling Facility

  29. Questions? Environmental Permits and Support Phone #: (512) 463-3840 Rusty Woodburn Phone #: (512) 463-9928 rusty.woodburn@rrc.state.tx.us

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