1. Oil & Gas Waste Stream Management and Permitting Options
August 9, 2017
Grant Chambless, P.G.
Manager, Environmental Permits & Support

2. 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 either directly or in conjunction with an Operator who does.
Each permit applicant must have an active Organizational Report (P-5).

3. Where do I start? What is your goal? Waste Stream Management
What is your geographic location?
Environmental & Operational factors will limit management options
What are your options?
Disposal or Recycling?
Apply for your own permit or sub-contract it out?
What is most Cost Effective?
Must be determined internally

4. Where do I start?
What types of permits are issued by the Railroad Commission’s Technical Permitting Section?
Surface or Sub-surface Disposal and Recycling: What are my best option(s)?
Are permits necessary to recycle waste streams?
How to locate the necessary information?
Is it accessible online?
Is there application information for all permits?
Is there guidance for each waste application?
What are the rules associated with the permits?

5. Permit Types Permits offered by Environmental Permitting Pits
(Title 16 Texas Administrative Code (TAC): Chapters 3 & 4)
Pits
Reclamation Facilities
Minor Permits
Discharges
Landfarm and Landtreatment Facilities
Recycling Facilites
Hazardous Waste
Naturally Occurring Radioactive Materials (NORM)
Permit Renewals, Transfers and Amendments

6. Permit Types, Cont.
Requirements for permit applications by letter of request
Discharge of Hydrostatic Test Water.
Discharge of Gas Plant Effluent.
Discharge of Domestic Wastewater (on lease).
Discharge of Produced Water to Inland Waters.
Discharge of Produced Water to the Gulf of Mexico.
Land farming of Water-Based Drilling Fluids.
Land treatment of Oil-Based Drilling Fluids.
Land Application of Produced Water.
Commercial Waste Separation Facility.
Commercial Recycling Facility.

7. Commercial Recycling Permits
Texas Administrative Code (TAC) Title 16; Part 1
Chapter 4, Subchapter B
Division 1 outlines definitions & general requirements Solid Recycling – Reuse as road base, drill pads, lease roads, county roads etc., & Treated Aggregate for berms, cell caps, & construction fill at industrial sites.
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

8. Commercial Recycling Permits, Cont.
Fluid Recycling: Reuse of wellbore fluids
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

9. Commercial Recycling Permits, Cont.
Fluid Recycling: Reuse of wellbore fluids
Authorized if the fluid is:
Generated and recycled on a lease associated with a drilling permit, disposal well, or injection well,
Used in the wellbore of an Oil &Gas well (frac fluid or mud or cement make up fluid),
Pit that is dedicated to hold the fluid is also authorized (NCFR pit)

10. Online Resources Available permit application forms:
Form H-11: Pit Permit Application
Form R-9: Reclamation Facility Application
Form R-2: Monthly Reclamation Report
Form CF-1: Commercial Facility Bond
Form CF-2: Commercial Facility Letter of Credit
Form H-20: Hazardous Waste Generator Notice
Form H-21: Hazardous Waste Report

11. Applicable Statewide Rules
Chapter : Water Protection
Chapter : Protection of Birds
Chapter : Memorandum of Understanding between
RRC & TCEQ
Chapter : Reclaiming Tank Bottoms, other
Hydrocarbon Wastes
Chapter : Performance Bonds & Financial Security

12. Applicable Statewide Rules
Chapter : Cleanup of Soil by a Crude Oil Spill
Chapter : Water Quality Certification
Chapter : Hazardous Oil & Gas Wastes
Chapter 4, Subchapter B: Commercial Recycling
Chapter 4, Subchapter F: Oil and Gas NORM

13. Environmental Permits and Support
Questions?
Environmental Permits and Support
Phone #: (512)
Grant Chambless, P.G.
Phone #: (512)