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RAILROAD COMMISSION OF TEXAS Discharge of Oil and Gas Waste Tiffany Humberson Environmental Permits and Support.

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Presentation on theme: "RAILROAD COMMISSION OF TEXAS Discharge of Oil and Gas Waste Tiffany Humberson Environmental Permits and Support."— Presentation transcript:

1 RAILROAD COMMISSION OF TEXAS 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). 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 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. 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.EPA Region 6 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. 10

11  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. Type of Pipeline to be Tested

12 Application for HT Minor Permit 1.Operator information 2.Description of pipeline or tank to be tested 3.H 2 S > 100 ppm? 4.Source of water 5.Chemicals, concentrations, and MSDS 6.Dates of test and discharge 7.Volume and rate of discharge 8.Location of discharge (Latitude/Longitude) 9.Map that shows fill point and discharge point 10.Filtration system, erosion control devices 11.Frac tanks? 12.Landowner notification 13.Cleaning information(used) 14.Application fee for discharge to surface waters($750) 15.Signature and certification 16.File two copies of the application, including all attachments with Technical Permitting in Austin 12 minor-and-other-permits/hydrostatictestwater1change /

13 HT Permit Typical Testing Requirements 13 New pipe and discharge volume < 100,000 gal No Yes Test beginning, midpoint, and end for: Discharge to surface ParameterLimitation Benzene0.5 mg/l O&G15 mg/l CODReport ConductivityReport TSSReport Discharge to surface water ParameterLimitation Benzene0.05 mg/l O&G15 mg/l CODReport ConductivityReport TSSReport Tanks used after test? Test each tank for: No Yes No testing required (gathering line) Frac tanks used? No Yes

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 14

15 Application for Gas Plant Effluent Discharge Permit 1.Identify the plant by operator information 2.Indicate the operations carried out at the plant include the type of gas plant and waste stream(s) 3.Drawing and description of any treatments 4.Pits? Form H-11 required 5.Identify any chemicals, provide concentration, and MSDS 6.Complete Water Analysis 7.Latitude and Longitude 8.County Highway Map 9.Plat drawn to scale with tract boundaries and discharge point 10.Provide notice to waterfront surface owners from the point of discharge to ½ mile downstream (If to discharge is to watercourse) 11.Permission from flood control owner (if to a ditch or canal) 12.Application fee($750) 13.Signature and certification 15 information/discharges/gasplanteffluent /

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. 16

17 Produced Water Discharges 3 nautical miles 9 nautical miles Territorial Seas Outer Continental Shelf Not to scale West of 98 th meridian East of 98 th meridian 17

18 Produced Water Discharged West of 98 th Meridian 18  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

19 Produced Water Discharged East of 98 th 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 19

20 Application for a Permit to Discharge Produced Water to Inland Waters 1.Operator Information 2.Indicate county, field, lease identification, well numbers for the produced discharge 3.Include the average and maximum water production rates, well-by-well. 4.Drawing and description of any treatments 5.Pits? Form H-11 required 6.Identify any chemicals, provide concentration, and MSDS 7.Complete Water Analysis 8.Latitude and Longitude 9.County Highway Map 10.Provide notice to waterfront surface owners from the point of discharge to ½ mile downstream (If to discharge is to watercourse) 11.Permission from flood control owner (if to ditch or canal) 12.Application fee($750) 13.Is the water for agricultural or wildlife use? 14.Signature and certification 20 information/discharges/producedtoinland/

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 98 th meridian only)  24-hour acute WET test required for E. of 98 th meridian  Additional testing parameters and limitations may be added based results of Water Analysis or chemicals in the discharge 21

22 Produced Water Discharged to the Territorial Seas  Covered by EPA General Permit TXG  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 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 23

24 Produced Water Discharged to the Outer Continental Shelf  Covered by EPA General Permit GMG  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 24

25 Application for a Permit to Discharge Produced Water to Gulf of Mexico 1.Operator Information 2.Indicate county, field, lease identification, well numbers for the produced discharge 3.Include the average and maximum water production rates, well-by-well 4.Depth at which the discharge occurs 5.Drawing and description of any treatments 6.Identify any chemicals, provide concentration, and MSDS 7.Complete Water Analysis 8.Latitude and Longitude 9.Application fee($750) 10.Signature and certification 25 water-to-gom/

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 ( o F)Calcium pH (standard units)Magnesium Dissolved OxygenSodium Hardness (mg/l as CaCO 3 )Potassium Total Suspended SolidsIron Total Dissolved SolidsManganese ChloridesOil & Grease SulfatesTotal Organic Carbon SulfidesPhenols Ammonia NitrogenNaphthalene ParameterMAL(mg/l) Aluminum0.03 Arsenic*0.01 Barium*0.01 Benzene0.01 Cadmium*0.001 Chromium*0.01 Hexavalent* Chromium 0.01 Copper0.01 Cyanide0.02 Lead*0.005 ParameterMAL(mg/l) Mercury* Nickel0.01 Selenium*0.01 Silver*0.002 Zinc0.005

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. 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. 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. 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.

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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