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State & Federal Environmental Compliance Seminar 2014 Alliance Expo and Annual Meeting Byron Ellington Terracon Consultants April 22, 2014 Landfarming.

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Presentation on theme: "State & Federal Environmental Compliance Seminar 2014 Alliance Expo and Annual Meeting Byron Ellington Terracon Consultants April 22, 2014 Landfarming."— Presentation transcript:

1 State & Federal Environmental Compliance Seminar 2014 Alliance Expo and Annual Meeting Byron Ellington Terracon Consultants April 22, 2014 Landfarming Oil & Gas Waste And Spill Cleanups using Risk- Based Corrective Action (RBCA) _____________________ Best Practices

2 Landfarming Oil & Gas Waste  Landfarming (and other allowed waste disposal options) oil and gas waste are generally controlled by 16TAC3.8 (SWR8).  Also consistent with SWR 91 and the RCRA Exemption.

3 Surface Waste Disposal Allowed Without a Permit  On lease disposal of low chloride drilling fluid, including cuttings from oil based drilling mud (§3.8(d)(3) Authorized disposal methods).  Best Practice: –Use pit/site only once, or for one well. –Remove free liquids and free oil before placement. –Backfill pits on, or ahead, of schedule.

4 Surface Waste Disposal Allowed Without a Permit (cont.)  Basic sediment pits for lease generation of tank bottoms (§3.8(d)(4) Authorized pits).  Best Practice: –Avoid. –Use pit only once. Do not exceed rule volumes or footprint requirements. –Remove free liquids and free oil before placement. –Backfill pits on, or ahead, of schedule.

5 Surface Waste Disposal Allowed Without a Permit (cont.)  Flare pits for upset conditions (§3.8(d)(4) Authorized pits.).  Best Practice: –Line pit to not allow fluid migration. –Lining material must be able to withstand flare and maintenance. –Remove fluids/replace cover material on schedule.

6 Surface Waste Disposal Allowed Without a Permit (cont.)  Water condensate pits for fresh water (§3.8(d)(4) Authorized pits).  Best Practice: –Avoid. –Instead design a lined sump system routed to separator and/or send to SWD.

7 Surface Waste Disposal Allowed With a Minor Permit  Off Lease Landfarming – Water Based Drilling, including cuttings from oil based drilling mud, (§3.8(d)(6)(G).  Permit Requirements –Remove free water and oil; after mix/till chlorides <3,000 ppm; EC<4mmhos/cm; pH 6 to 10; TPH<5% initial, <1%final. Submit analytical. –100 feet from surface water. –Slope <5%, unless district ok. –Tillable soil 20 inches +. –Not in 100 year flood plain.

8 Surface Waste Disposal Allowed With a Minor Permit (cont.)  Off Lease Landfarming – Water Based Drilling, including cuttings from oil based drilling mud, (§3.8(d)(6)(G).  Permit Requirements –Distance to sensitive receptors (SWR 91) case-by-case. –Written permission of landowner. –Application thickness <3 inches and <2000 bbls/acre. –Other requirements/secondary containment: case-by-case. –<5 wells or 30,000 bbls, which ever occurs first. –One permit per site per single surface owner. Site >1/2 mile distance can be considered separate site. Site <1/2 mile considered on case-by-case. –No repeat applications. –Record keeping for each load for three years.

9 Surface Waste Disposal Allowed With a Minor Permit (cont.)  Off Lease Landfarming – Water Based Drilling, including cuttings from oil based drilling mud, (§3.8(d)(6)(G))  Best Practices: –Clean operation. –Keep good records. –Landowner relations. –Avoid hot buttons, even where allowed by rule.

10 Surface Waste Disposal Allowed With a Minor Permit (cont.)  Oily Waste - RCRA Exempt(§3.8(d)(6)(G)).  Permit Requirements: –Landfarm - Same technical and administrative requirements as those for landfarming for drilling mud except application rate is allowed to be 8 inches rather than 3 inches. –Firewall application – Same technical and administrative requirements as those for landfarming except application rate not specified and final TPH of < 5%. Assumes no mix/till.

11 Surface Waste Disposal Allowed With a Minor Permit (cont.)  Oily Waste - RCRA Exempt(§3.8(d)(6)(G)).  Permit Requirements: –Lease or County Road – Same technical and administrative requirements as for firewall except requires landowner or county commissioner written concurrence. –Burial – Same technical and administrative requirements as for landfarm application with the addition that benzene cannot exceed 0.05 mg/kg and the location >150 feet from a water well.

12 Surface Waste Disposal Allowed With a Minor Permit (cont.)  Oily Waste - RCRA Non-Exempt (§3.8(d)(6)(G)).  Permit Requirements: –Landfarm, firewall, lease/county road, and burial applications have the same technical and administrative requirements as exempt waste except for the need to determine if the waste is characteristic hazardous.

13  Oily Waste - RCRA Non-Exempt (gas plants, compressor stations, transmission line spills, etc. (§3.8(d)(6)(G)).  Best Practice: –Clean operation. –Keep good records. –Landowner relations. –Avoid hot buttons, even where allowed by rule. Surface Waste Disposal Allowed With a Minor Permit (cont.)

14 Commercial Surface Waste Landfarm/Landtreatment Permits  Landfarm – Water based drilling mud with chlorides not to exceed 3,000 mg/kg.  Landtreatment – Other oil and gas waste such tank bottoms, HC impacted soil, discarded oil based drilling mud.

15  Permits - generally controlled by SWR8 and consistent with SWR 91 and the RCRA Exemption.  Technical Requirements - similar to disposal under minor permit process. However much more science, engineering, and financial sophistication involved: –Groundwater monitoring almost always required. –Wetlands, surface water, sensitive receptors, set backs. –Storm water plans. –Application rates. –Native soil characteristics, including natural EC and SAR value. Commercial Surface Waste Landfarm/Landtreatment Permits

16  Technical Requirements (cont.) –Operations schedule such as mix/till frequency. –Source of waste (RCRA exempt, NORM, pit bottoms. –Plans for testing of incoming waste. –Record keeping. –Analytical monitoring plan. –Plans fro routine inspection, maintenance, and monitoring. –Duration of landfarm (permits usually issued for 5 years increments w/ procedures to renew). –Access control. Commercial Surface Waste Landfarm/Landtreatment Permits (cont.)

17  Technical Requirements –Engineering Specification of Liner, if used –Landowner concurrence. –Notice to offset surface owners. –General public notice. –Target remediation levels. –Accurate plats and maps with the footprint of the cells, facility boundary, and all set back features accurately depicted. –Detailed closure plan and demonstrated financial assurance (SWR 78). –Separate permit required for use of remediated material (e.g. road base).

18  Best practices while seeking a permit: –Start early. –Budget adequately for the process. –Know your footprint (size). Your footprint drives the permitting process. –Know your financial assurance to the RRC and secure it. –Clear up any outstanding NOVs, P5 issues, state tax issues. –Know that the agency and its staff are on your side. –Make the permit reviewer’s job easy. Commercial Surface Waste Landfarm/Landtreatment Permits (cont.)

19 Part II - Spill Cleanups using Risk Based Corrective Action (RBCA) Risk-based corrective action (RBCA) is a generic term for corrective action strategies that categorize sites according to risk and move all sites toward completion using appropriate levels of action and oversight. The ASTM standard is a good example of a framework for implementing a RBCA strategy. With this process, regulators can make sound, quick, consistent management decisions for a variety of sites using a three-tiered approach to data collection and site review contained in ASTM's E1739 standard guide for "Risk-Based Corrective Action applied at Petroleum Release Sites." - Michigan DEQ  RBCA Defined:

20 RBCA is an outgrowth of the risk assessment methodologies developed under CERCLA and have been used to calculate generic, yet defensible cleanup values that can be widely applied. RBCA programs have also developed methodologies to develop site specific cleanup values where and when appropriate. “In Texas RBCA embraces the concepts of eliminating exposure pathways, removing sources of contamination, and protecting further impacts to resources” - Byron Ellington, CPG Part II - Spill Cleanups using Risk Based Corrective Action (RBCA)  RBCA Defined:

21 Release Notification Initial Response Site Assessment(s) Closure Option Selection/Remedy Standard Selection Tiered PCL Evaluation When Required Response Action Post-Response Action Care No Further Action / VCP Certificates Part II - Spill Cleanups using Risk Based Corrective Action (RBCA)

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23 “Yikes, what a mess. Get the backhoe and start digging.” “Be sure to put the dirty soil on plastic.” “How clean is clean anyway????” Part II - Spill Cleanups using Risk Based Corrective Action (RBCA)

24  RRC Cleanup Standards in Soil –Crude Oil, Non-Sensitive: TPH<10,000 mg/kg (SWR 91) –Gas Condensate, Web Guidance: RRC Field Guide for the Assessment and Cleanup of Soil and Groundwater Contaminated with Condensate From a Spill Incident Table 2 - Groundwater Protection Values: TPH10,000 mg/kg Benzene0.026 mg/kg Toluene8.2 mg/kg Ethylbenzene7.6 mg/kg Xylenes120 mg/kg Part II - Spill Cleanups using Risk Based Corrective Action (RBCA)

25  RRC Cleanup Standards in Soil –NORM Waste (16TAC, Chapter 4, Subchapter F) Radium pCi/g Radium pCi/g Other radionuclide 150 pCi/g Part II - Spill Cleanups using Risk Based Corrective Action (RBCA)

26  RRC Cleanup Standards in Soil –Produced Water Salinity (EC)4 mmhos/cm soil (SWR 8) Chlorides 3,000 mg/kg (SWR 8) Part II - Spill Cleanups using Risk Based Corrective Action (RBCA)

27  RRC Cleanup Standards in Soil –A few Chemicals of Concern outside of SWR 91 or any other RRC standard of guidance: SVOCs? Pesticides? Lube Oil? Metals (barium, chromium) ? Glycols? Part II - Spill Cleanups using Risk Based Corrective Action (RBCA)

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29 “Wow, this stuff goes deep. It must have been leaking a long time…. “ “Bring out the trackhoe…..” Part II - Spill Cleanups using Risk Based Corrective Action (RBCA)

30 “What!!!!! 40 feet of excavation and we still have not hit clean????” “By the way, has anyone made a spill report?” “If the landowner comes by say you are doing routine maintenance” “Better call the lawyers.” Part II - Spill Cleanups using Risk Based Corrective Action (RBCA)

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32  Managing Risks: –Receptors –Regulatory –Operationally –Civil Liability –Financial Liability Part II - Spill Cleanups using Risk Based Corrective Action (RBCA)

33  Time to reassess where you are and develop risk management strategies: –Stopped/removed source –Managed disposition of the soil –Collect/analyze bottom hole and sidewall samples –Decision has been made to not excavate further. Place marker plastic at base of excavation. Backfill excavation with clean soil. Part II - Spill Cleanups using Risk Based Corrective Action (RBCA)

34  Receptor strategy –Conduct a water well survey, usually ¼ mile is adequate –Sample all domestic, livestock, or irrigation well –Sample all springs/surface waters that could be a receptor. –Sample any other data point (abandoned wells) Part II - Spill Cleanups using Risk Based Corrective Action (RBCA)

35 Release Notification Initial Response Site Assessment(s) Closure Option Selection/Remedy Standard Selection Tiered PCL Evaluation When Required Response Action Post-Response Action Care No Further Action / VCP Certificates Part II - Spill Cleanups using Risk Based Corrective Action (RBCA)

36  Regulatory Strategy –Probably time to follow up with the regulator and sharing your initial thoughts. –If appropriate, ask that the cleanup oversight be transferred to the program than can best handle the complex issues. –Time to know your closure options and develop a collaborative team approach - moving the site toward closure. –Design the first phase of your intrusive site assessment Part II - Spill Cleanups using Risk Based Corrective Action (RBCA)

37  Regulatory Strategy –As the conceptual site model converges with the closure options you next steps may include: Development of your second phase of field work. Ability to further refine your path toward closure. Establishment of long-term monitoring wells and points. Sharing of your ideas with your regulatory cleanup coordinator. Part II - Spill Cleanups using Risk Based Corrective Action (RBCA)

38  Take Aways: –RBCA approaches can guide you to a more thoughtful path toward regulatory closure and help reduce uncertainty with regards to civil and financial liability. –Need to educate our operations personnel of when to call for help. –When a release seems large, it probably is. –Deal with possible exposure issues first. –Know that the default/low cleanup values will probably not get you to closure on long-term (or unknown) spills. Part II - Spill Cleanups using Risk Based Corrective Action (RBCA)

39 Byron Ellington Terracon Consulting


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