Update on TCEQ’s Role in Oil & Gas Waste Management Chance Goodin MSW Permits Section Waste Permits Division TCEQ

Agenda Jurisdiction Regulations Management Disposal Options

Jurisdiction TCEQ: RRC: THSC § 361.003(34) Storage of crude oil at refineries Waste management and reclamation for wastes other than those associated with E&P Wastes generated at facilities, other than actual exploration, development, or production sites (field sites), where oil and gas industry workers are trained TNRC § 91.1011 Storage of crude oil before it enters a refinery Separation & treatment of produced fluids in the field or at natural gas processing plants Wastes generated at facilities where materials, processes, and equipment associated with O&G industry operations are researched, developed, designed, and manufactured

Jurisdiction TCEQ: RRC: Injection wells used to dispose waste other than O&G waste Disposal of NORM which is not oil & gas NORM waste Transportation of refined products by pipeline Transportation of crude oil & natural gas by railcar, truck, barge or oil tanker Injection wells used to dispose O&G waste Disposal of oil & gas NORM waste Transportation of crude oil by pipeline prior to arrival at a refinery Transportation of natural gas by pipeline prior to its use in any manufacturing process or as a residential/industrial fuel disposal wells

Regulations Title 30 TAC 330.3 (148) – Municipal Solid Waste Rules: O&G wastes to be processed, treated, or disposed of at an MSW facility, authorized by TCEQ, are “special wastes.”

TCEQ - RCC MEMORANDUM OF UNDERSTANDING RRC must specifically authorize management of wastes under its jurisdiction at facilities regulated by TCEQ Concurrence of the TCEQ is required to manage "special waste" under the jurisdiction of the RRC at a facility regulated by the TCEQ

Disposal Options MSW Landfills Special waste – requires authorization from MSW Permits Section, if not in Special Waste Acceptance Plan Class 1 waste –petroleum substances or contain contamination from petroleum substances are Class 1 waste until TPH reduced to 1,500 ppm No free liquids

Disposal Options Non-commingled domestic portable toilet septage from a RRC regulated facility may be managed at a TCEQ permitted facility without specific authorization from TCEQ or RRC RRC regulated waste sludge may not be applied to the land at a facility permitted by the TCEQ for beneficial use of sewage sludge or water treatment sludge

Examples of Special Waste Empty Bags, Paper Empty Containers Fiberglass Tanks Empty Pipes, Rags, Gloves Uncont. Wooden Pallets RCRA Exempt? NO TCEQ Approval Required? Treatment or Testing? RRC Authority Required?

Examples of Special Waste –Cont. Waste Oil Filters Sacks of Unused Drilling Mud, Soil Cont. Lube Oil & Hydrocarbons Cont. Concrete O&G facilities Sorbent Pads with Lube Oil RCRA Exempt? NO TCEQ Approval Required? YES Treatment or Testing? RRC Authority Required?

Examples of Special Waste –Cont. Drill Cuttings Drilling Muds Sand produced during E&P Filters (glycol, cooling tower saltwater) Soil with crude oil hydrocarbons RCRA Exempt? YES TCEQ Approval Required? Treatment or Testing? RRC Authority Required?

Compliance Guidance RG-003 – Disposal of Special Wastes Associated with Development of Oil, Gas, and Geothermal Resources RG-029 – Special Waste Regulations in Texas RG-482 – Common Environmental Requirements for Regulated Oil and Gas Operations

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