Texas Commission on Environmental Quality (TCEQ) Railroad Commission of Texas (RRC) Oil and Gas Waste Management 20

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Texas Commission on Environmental Quality (TCEQ) Railroad Commission of Texas (RRC) Oil and Gas Waste Management 2014 Update. TCEQ Christine M. Bergren, Waste Permits Division Diane Goss, Environmental Law Division RRC David Cooney, Enforcement Division
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Texas Commission on Environmental Quality (TCEQ) Railroad Commission of Texas (RRC)Oil and Gas Waste Management2014 Update TCEQ Christine M. Bergren, Waste Permits Division Diane Goss, Environmental Law Division RRC David Cooney, Enforcement Division David Wuerch P.G., Environmental Permits Division TEXAS
  • Natural Resources Code §91.1001 defines oil and gas (O&G) waste
  • RRC regulates O&G waste
  • Texas Health & Safety Code §361.003(34) excludes O&G exploration and production (E&P) waste from definition of “solid waste”
  • TCEQ regulates solid waste
  • RRC
  • RRC regulates O&Gwaste in Texas
  • RRC issues permits for commercial & non-commercial management of O&G waste
  • Surface Waste Management Manual Statewide Rule 8 (16 TAC § 3.8)
  • Hazardous Oil and Gas Waste Statewide Rule 98 (16 TAC § 3.98)
  • Memorandum of Understanding
  • MOU between RRC and TCEQ
  • Need for Agreement
  • Statement of how RRC and TCEQ implement the division of jurisdiction 16 Tex. Admin. Code § 3.30
  • O&G Waste at TCEQ Facilities
  • The RRC must specifically authorize management of wastes under its jurisdiction at facilities regulated by TCEQ
  • Concurrence of TCEQ is required to manage O&G an Waste under RRC jurisdiction at a TCEQ facility
  • Subject to TCEQ rules for “special waste” and industrial waste 30 Tex. Admin. Code §330.3(148) 16 Tex. Admin. Code §3.30.(e)(3)
  • Disposal at Municipal Solid Waste (MSW) Landfills
  • Oil and Gas waste disposed at an MSW landfill authorized by TCEQ under 30 Tex. Admin. Code, Chapter 330
  • Disposal of O&G waste as special waste must be authorized by
  • Facility Permit, or
  • Case-by-Case via TCEQ Form -0152
  • Disposal at MSW Landfills
  • Certain criteria must be met
  • No free liquids - “paint filter test”
  • Constituents of concern (COC) Table 1, Appendix 1 of 30 TAC, 335 Subchapter R Can’t exceed hazardous limits Class 1 limits Benzene and RCRA 8 metals
  • Total petroleum hydrocarbons (TPH) TPH <1,500 ppm – Type I Landfill TPH > 1,500 ppm - Class 1 cell
  • No free liquids
  • Total Petroleum Hydrocarbons (TPH)
  • Constituents of Concern (COC)
  • What’s New? Separation at MSW Landfills
  • RRC issues permits authorizing oil and gas waste separation activities conducted at MSW Landfills
  • State wide Rule 3.8 Water Protection
  • State wide Rule 3.78 Financial Security (16 TAC 3.8 & 3.78)
  • What’s New?Temporary Living Quarters
  • Household like garbage
  • Located on oil and gas lease housing
  • Not in the immediate vicinity of a rig
  • Not comingled with oilfield wastes
  • Managed as MSW and is not required to be managed as special waste
  • MSW Landfills 195 Active Landfills 100 Type I Landfills 11 Landfills Class 1 Cells Summary
  • RRC has Jurisdiction over O&G waste
  • Concurrence of RRC and TCEQ is required to manage oil and gas waste at TCEQ facilities
  • Summary
  • Household like garbage from oil and gas worker housing not comingled with oilfield wastes isn’t subject to special waste requirements
  • RRC Issues Permits to conduct oil and gas waste separation at TCEQ Landfills
  • Questions?
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