1. Which Type of Facility Represents your Class I Injection Well Operations?
Jan Bates, P.E.
Underground Injection Control Permits Section
Radioactive Materials Division
Texas Commission on Environmental Quality
TCEQ Trade Fair May 15, 2019

2. Facility Type Quandary
Class I Injection Well Facility Type
Facility Type Quandary

3. Types of Facility
On-site
Off-site
Captured
Non-commercial
Commercial

4. Factors that determine Type of Facility
Property boundaries
Facility boundaries
Who owns the facility
Who operates the facility

5. Factors that determine Type of Facility (cont.)
Location of waste generation
Who generates the waste
Location of waste management units
Who uses the waste management units
Who operates the waste management units

6. Definitions Related to Facility
Class I Injection Well Facility Type
Definitions Related to Facility

7. Facility §335.1(61) Includes all contiguous land
Includes structures, appurtenances, improvements on the land used for storing, processing and disposing of waste
May be different when implementing Corrective Action for SWMUs

8. On-site §331.2(81) Contiguous property
May be divided by rights-of way if entrance and exit between the properties is at a cross-roads intersection
Noncontiguous property owned by the same person if a right-of-way connects the properties, is controlled by the owner, and is not accessible to the public

9. Off-site
§331.2(80)
Property not characterized as on-site

10. Captured Facility §331.2(22) Manufacturing or production facility
Generates waste that is routinely sorted, processed, or disposed of on a shared basis in an integrated waste management unit
Located within a contiguous manufacturing complex

11. Non-commercial Well §331.2(77) Disposes wastes generated on-site
Disposes waste generated at a captured facility
Disposes waste generated at other facilities owned or effectively controlled by the owner/operator

12. Non-commercial Facility
§331.2(75)
Operates only non-commercial wells

13. Commercial Well §331.2(29) Disposes of wastes for a charge
Except for a captured facility
Except for a facility owned or effectively controlled by the owner/operator

14. Commercial Facility §331.2(27)
Where one or more commercial wells are operated

15. Class I Injection Well Facility Type
Case Studies

16. Facility Boundary & On-site/Off-site
Case Study 1
Facility Boundary & On-site/Off-site

17. Facility Boundary, On-site/Off-site & Captured Facility
Case Study 2
Facility Boundary, On-site/Off-site & Captured Facility

18. Case Study 3
On-site/Off-site

19. Case Study 4
Captured Facility

20. Case Study 5
Captured Facility

21. Case Study 6
Commercial Facility

22. Facility Type Summary Property & facility boundaries
Owner & operator of the facility
Location & generator of waste
Location & user of waste management units
Owner & operator of waste management units

23. UIC Program Contact Info
Jan Bates, P.E. Underground Injection Control Permits Section Radioactive Materials Division (512) (512)