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Discharge of Oil and Gas Waste

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1 Discharge of Oil and Gas Waste
Tiffany Humberson Environmental Permits and Support

2 Disclaimer This presentation is a quick overview and not intended to be a complete guide for filing discharge applications. Each application is reviewed by an analyst and additional information may be required. Read the rules that are specific to your discharge and contact Environmental Permits and Support should you have any questions. 2

3 Outline Laws and Rules Federal and State Jurisdiction
EPA,TCEQ,TSWQS, and the RRC Define Surface Water Types of Discharges- Applications Hydrostatic Pressure Test Discharges Gas Plant Discharges Produced Water Discharges Testing Storm Water Discharges/ On-Site Septic Question and Answer Session 3

4 Laws and Rules Clean Water Act (CWA)- primary federal law in the U.S governing water pollution.(NPDES program) Texas Surface Water Quality Standards(TSWQS) from Texas Commission of Environmental Quality (TCEQ) are in Texas Administrative Code (TAC), Title 30, Chapter 307. Section (b) of the Texas Water Code prohibits the Railroad Commission from issuing a permit for a discharge that will cause a violation of the Texas Surface Water Quality Standards adopted by the Texas Commission on Environmental Quality (TCEQ). The basic trickle down theory, RRC must comply with all federal and state regulations related to water quality for discharges to surface water.. 4

5 Federal and State Jurisdiction
The EPA has not authorized the RRC to implement a National Pollutant Discharge Elimination System (NPDES) permit program. RRC regulates the disposal of all oil and gas wastes. Discharges to surface water must be permitted by both EPA and RRC.

6 Texas Surface Water Quality Standards
Establish explicit goals for the quality of streams, rivers, lakes, and bays throughout the state Permit restrictions based on water quality and dilution of the receiving body Receiving bodies organized into segments All water discharge permits have to meet TSWQS. Chapter 307 Rule Amendment adopted on February 12, 2014 6

7 Define Surface Water Defined by Rule §3.8(a)(29)
Navigable or non-navigable waters, (unlike CWA)and includes beds and banks of all water courses and bodies of water. Surface water refers to water on ground surface or water collection areas including lakes, ponds, wetlands, intermittent streams, drainage ditches, canals, fresh or salt water, etc., but excluding artificial water containment where storm water runoff cannot enter. Rule §3.8(a)(29) 7

8 Types of Discharges Three major categories of discharges to surface waters: Hydrostatic Test Water (HT); most common Gas Plant Effluent(GPE); Produced Water Inland Offshore

9 Hydrostatic Test (HT) Discharges
Hydrostatic tests are preformed to pressure test pipelines and tanks. Authorized by a minor permit issued from the Austin office and is valid for 60 days. Must file two copies of the applications and attachments. Currently, a person may be required to obtain a federal permit and a state permit to discharge oil and gas wastes to surface water in the state. You may contact EPA Region 6 for more information. 9

10 HT Permit Not Required A permit is not required if all the following conditions are met: The pipeline is a gathering line. The pipe is new. The test water is a good quality water source. The volume of test water discharges is 10,000 gallons or less. The test water is kept on the pipeline right-of-way and the landowner(s) has been notified and not objected. Gathering line:Gathering line means a pipeline that transports gas from a current production facility to a transmission line or main. 10

11 Type of Pipeline to be Tested
Transmission line means a pipeline, other than a gathering line, that: (1) Transports gas from a gathering line or storage facility to a distribution center, storage facility, or large volume customer that is not down-stream from a distribution center; (2) operates at a hoop stress of 20 percent or more of SMYS (Specified Minimum Yield Strength); or (3) transports gas within a storage field. Gathering line means a pipeline that transports gas from a current production facility to a transmission line or main. Distribution line means a pipeline other than a gathering or transmission line. Definitions from 49 CFR § Code of Federal Regulations Hoop stress-it is the stress imposed by fluid on all sides of the pipe when fluid flows inside the pipe or circumferential stress. Pipe wall thickness

12 Application for HT Minor Permit
Operator information Filtration system, erosion control devices Description of pipeline or tank to be tested Frac tanks? H2S > 100 ppm? Landowner notification Source of water Cleaning information(used) Chemicals, concentrations, and MSDS Application fee for discharge to surface waters($750) Dates of test and discharge Signature and certification Volume and rate of discharge File two copies of the application, including all attachments with Technical Permitting in Austin Location of discharge (Latitude/Longitude) Map that shows fill point and discharge point Permits generally issued within days. --- cover common errors. Description must include length, diameter, type, and use. P-5 Organization Report required 12

13 HT Permit Typical Testing Requirements
Frac tanks used? Yes New pipe and discharge volume < 100,000 gal No Tanks used after test? No Yes No Test beginning, midpoint, and end for: Test each tank for: Yes Discharge to surface Parameter Limitation Benzene 0.5 mg/l O&G 15 mg/l COD Report Conductivity TSS Discharge to surface water Parameter Limitation Benzene 0.05 mg/l O&G 15 mg/l COD Report Conductivity TSS Used pipelines always require testing. No testing required (gathering line) 13

14 Gas Plant Effluent Discharges (GPE)
Common waste streams include: Cooling tower blowdown RO reject stream Compressor condensation Individual EPA permit May not cause a violation of the Texas Surface Water Quality Standards The RRC permit will be consistent with all EPA permits. 14

15 Application for Gas Plant Effluent Discharge Permit
Identify the plant by operator information Provide notice to waterfront surface owners from the point of discharge to ½ mile downstream (If to discharge is to watercourse) Indicate the operations carried out at the plant include the type of gas plant and waste stream(s) Permission from flood control owner (if to a ditch or canal) Drawing and description of any treatments Application fee($750) Pits? Form H-11 required Signature and certification Identify any chemicals, provide concentration, and MSDS Complete Water Analysis Latitude and Longitude County Highway Map Plat drawn to scale with tract boundaries and discharge point Evaporation pit common. Notice includes a copy of the application and the statement that any protest to the application should be filed within 15 days. Are the waste streams combined, need the path for all streams from origin to discharge location. 15

16 Gas Plant Effluent Required Testing and Limitations
pH: 6.0 to 9.0 Biochemical oxygen demand (BOD) Daily max: 30 mg/l Monthly average: 20 mg/l Additional testing parameters and limitations may be added based on results of Water Analysis or chemicals added to discharge. RO water generally has a chloride reporting requirement. TSWQS-usually range for Oil & Grease Daily max: 10 mg/l, Monthly average: 15 mg/ 16

17 Produced Water Discharges
3 nautical miles East of 98th meridian West of 98th meridian Territorial Seas Texas split into 4 different sections for permitting. All must adhere to TSWQS Outer Continental Shelf Not to scale 17 9 nautical miles

18 Produced Water Discharged West of 98th Meridian
Not covered by an EPA general permit; but under effluent guidelines in 40 CFR Part 435, Subpart E Individual EPA Permit Produced water must be beneficially used for agricultural or wildlife use when discharged into navigable waters. May not cause a violation of the Texas Surface Water Quality Standards § Effluent limitations guidelines-(a) There shall be no discharge of waste pollutants into navigable waters from any source (other than produced water) associated with production, field exploration, drilling, well completion, or well treatment (i.e., drilling muds, drill cuttings, and produced sands). 18

19 Produced Water Discharged East of 98th Meridian
EPA General Permit TXG (existing facilities in the Stripper Subcategory). Produced water must be from Carrizo/Wilcox, Reklaw, or Bartosh formations. Discharges into impaired waters may require an individual permit. May not cause a violation of the Texas Surface Water Quality Standards Exceptions listed on pages 9-14 of the general permit. How to see Texas 303(d) list on the handout. 19

20 Application for a Permit to Discharge Produced Water to Inland Waters
Provide notice to waterfront surface owners from the point of discharge to ½ mile downstream (If to discharge is to watercourse) Operator Information Indicate county, field, lease identification, well numbers for the produced discharge Permission from flood control owner (if to ditch or canal) Include the average and maximum water production rates, well-by-well. Application fee($750) Drawing and description of any treatments Is the water for agricultural or wildlife use? Pits? Form H-11 required Signature and certification Identify any chemicals, provide concentration, and MSDS Complete Water Analysis Latitude and Longitude County Highway Map Notice includes a copy of the application and the statement that any protest to the application should be filed within 15 days. 20

21 Produced Water Required Testing and Limitations
Oil and Grease Daily max: 35 mg/l Monthly average: 25 mg/l Total Dissolved Solids (TDS) < 3,000 mg/l (Produced water E. of 98th meridian only) 24-hour acute WET test required for E. of 98th meridian Additional testing parameters and limitations may be added based results of Water Analysis or chemicals in the discharge Includes Oil &Grease ( 25mg/L average and 35mg/L max), TDS (cannot exceed 3000 mg/l) , WET maybe required annually, flow (monthly) and possibly zinc and or mercury or impaired waters. Discharge prohibited into DO impaired waters. 21

22 Produced Water Discharged to the Territorial Seas
Covered by EPA General Permit TXG260000 Authorized discharge of produced water RRC and EPA require the discharge to pass Whole Effluent Toxicity (WET) tests Toxicity testing results must pass both acute and chronic limits prior to any discharge May not cause a violation of the Texas Surface Water Quality Standards discharge of drilling fluids and drill cuttings is prohibited. Flow, flow rate decides the WET parameters, Oil and Grease(29 mg/L average and 42 mg/L maximum). Permittees discharging produced water at a rate greater than 25,000 bbl/day shall determine the critical dilution using CORMIX version 4.2 GT (or the most current version of CORMIX) with the input parameters shown above. 22

23 Coastal Management Program
Discharges must not adversely affect any critical area Examples of critical areas are a coastal wetland, oyster reefs, hard substrate reefs, submerged aquatic vegetation, or tidal sands or mud flats Discharge of produced water to bays, estuaries, and tidal areas with the exception of the Gulf of Mexico, is no longer permitted The CMP is managed by the Texas Land Commissioner. Rule §3.8(j)(B)(iii) For more info on what constitutes a critical area, see Texas Natural Resources Code, §33.203 23

24 Produced Water Discharged to the Outer Continental Shelf
Covered by EPA General Permit GMG290000 Authorized discharges for drilling fluids, drill cuttings, and produced water RRC and EPA require the discharge to pass Whole Effluent Toxicity (WET) test (7-day chronic) May not cause a violation of the Texas Surface Water Quality Standards Discharges authorized are drilling fluids, drill cuttings, and produced water. Those discharges have a high potential to impact marine life; therefore, the general permit contains a number of requirements to control the toxicity of the discharges. 24

25 Application for a Permit to Discharge Produced Water to Gulf of Mexico
Operator Information Signature and certification Indicate county, field, lease identification, well numbers for the produced discharge Include the average and maximum water production rates, well-by-well Depth at which the discharge occurs Drawing and description of any treatments Identify any chemicals, provide concentration, and MSDS Complete Water Analysis Latitude and Longitude Application fee($750) Notice includes a copy of the application and the statement that any protest to the application should be filed within 15 days. EPA General Permit TXG and EPA General Permit GMG290000 25

26 Offshore Produced Water Required Testing and Limitations
Oil and Grease Daily max: 42 mg/l Monthly average: 29 mg/l 7-day chronic WET test 24-hour acute WET test (Territorial Seas only) 26

27 Water Analysis 27 General Parameters Temperature (oF) Calcium
pH (standard units) Magnesium Dissolved Oxygen Sodium Hardness (mg/l as CaCO3) Potassium Total Suspended Solids Iron Total Dissolved Solids Manganese Chlorides Oil & Grease Sulfates Total Organic Carbon Sulfides Phenols Ammonia Nitrogen Naphthalene Parameter MAL(mg/l) Aluminum 0.03 Arsenic* 0.01 Barium* Benzene Cadmium* 0.001 Chromium* Hexavalent* Chromium Copper Cyanide 0.02 Lead* 0.005 Parameter MAL(mg/l) Mercury* 0.0002 Nickel 0.01 Selenium* Silver* 0.002 Zinc 0.005 Toxic pollutants above the minimum analytical limit (MAL)s must be reported. Supply all results with the application. Detection limit: is the lowest concentration level that can be determined to be statistically different from a blank. Minimum analytical limit is the limit at which the lab can reasonably tell the difference between two different values. 35 parameters total 27

28 Whole Effluent Toxicity
Whole Effluent Toxicity (WET) refers to the aggregate toxic effect to aquatic organisms from all pollutants contained in a facility's wastewater (effluent). In a WET test, aquatic organisms from fresh or saline water are placed in a mixture of the receiving water diluted with the discharged effluent. WET tests determine the acute and chronic effects on the aquatic organisms. A WET test is passed by recording No Observable Effect Concentration at the calculated critical dilution concentration. Critical dilution is based on the flow rate, flow must be recorded and reported. Acute testing duration for 96 hours, use lethality as the measure. Chronic testing duration is 7 days, use impairment or reproduction reduction as a measure. 28

29 WET Test for Offshore Discharge
The critical dilution used in the chronic 7-day WET test for Territorial Seas and Outer Continental Shelf discharges can be determined from tables in their respective general permits based on: The highest monthly average discharge rate over the three months prior to the sample, Discharge pipe diameter, and Depth between the base of the discharge pipe and sea floor. The critical dilution for the acute 24-hour LC50 test at 100 percent concentration. LC50 (lethal concentration) is a test used to determine if 50 percent of the test population survives in the effluent over a given time 29

30 Storm Water Discharges
Permits will distinguish between contact storm water and non-contact storm water. Non-contaminated storm water 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 storm water. Contact storm water is considered oil and gas waste and must be managed, stored and contained separate from non-contact storm water and disposed of in an authorized manner. Discharge of contact storm water is prohibited. 33 U.S.C. §1342(l)(2) and §1362(24) 16 TAC §3.30(b)(2)(B)(ii)(I) 30

31 On-Site Sewage Facility (OSSF)
On-Site Sewage Facilities (OSSFs) are under the jurisdiction of the Texas Commission on Environmental Quality (TCEQ). Unless the OSSF is located at a well site under the jurisdiction of RRC or a RRC-permitted facility. Do not need a permit if; The waste is not commingled with any other waste stream; designed by a professional engineer or sewage system installer; the construction, operation, and maintenance of the OSSF complies with all applicable local, county, and state requirements. PE registered in the State of Texas, or licensed in texas

32 Additional Comments Storm water should not be commingled with the effluent prior to the discharge point. Septic and gray water should not be commingled with the effluent prior to the discharge point. Technical Permitting does not allow any additives that contain chromium or zinc to be discharged. 32

33 Summary Roles of the RRC, EPA, and TCEQ
Discharge types and applications common application problems Water quality testing and parameters. WET testing Unauthorized discharges 33

34 Contact Information Environmental Permits & Support (Main) Tiffany Humberson (512) (Direct) 34


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