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

2. Agenda
Jurisdiction
Regulations
Management
Disposal Options

3. 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 §
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

4. 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

5. 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.”

6. 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

7. 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

8. 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

9. 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?

10. 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?

11. 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?

13. 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

14. Thank you