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

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).

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

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? http://www.RRC.Texas.Gov/oil-gas/applications-and-permits/environmental-permit-types-information/

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

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.

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

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

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)

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

Applicable Statewide Rules Chapter 3.8 : Water Protection Chapter 3.22 : Protection of Birds Chapter 3.30 : Memorandum of Understanding between RRC & TCEQ Chapter 3.57 : Reclaiming Tank Bottoms, other Hydrocarbon Wastes Chapter 3.78 : Performance Bonds & Financial Security

Applicable Statewide Rules Chapter 3.91 : Cleanup of Soil by a Crude Oil Spill Chapter 3.93 : Water Quality Certification Chapter 3.98 : Hazardous Oil & Gas Wastes Chapter 4, Subchapter B: Commercial Recycling Chapter 4, Subchapter F: Oil and Gas NORM

Environmental Permits and Support Questions? Environmental Permits and Support Phone #: (512) 463-3840 Grant Chambless, P.G. Phone #: (512) 463-4354 Grant.Chambless@RRC.Texas.Gov