Chairman Christi Craddick
Commissioner Ryan Sitton
Commissioner Wayne Christian
May 2017
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Discharge of Oil and Gas Waste
Tiffany Humberson
Environmental Permits and Support
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Goal for Texas Waters
It is the goal of Texas Railroad Commission to maintain
and protect the quality of surface water and
groundwater in the State. Policies shall be consistent
with public health and welfare, and facilitate oil and
gas industries, taking into consideration the economic
development of the state.
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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Disclaimer
• This presentation is a quick overview and not
intended to be a complete guide for filing
discharge applications
• Each application is reviewed by an analyst and
additional information and clarifications may be
required
• Please read all of the rules that are specific to
your type of discharge
• Contact Environmental Permits and Support for
help should you have any questions (512-4633840)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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Topics for Discussion
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•
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Laws and Rules
Federal and State Jurisdiction
RRC Definition of Surface Water
Types of Discharges
Required Testing
Stormwater Discharges
Other Permitting Options
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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Laws and Rules
• Federal
• Clean Water Act (CWA)
• State
• Texas Commission of Environmental
Quality (TCEQ)
• Texas Surface Water Quality Standards
(TSWQS)
• Railroad Commission of Texas (RRC)
provides discharge permits for oil and gas
activities.
• Memorandum of Understanding (MOU)
• Rule §3.30
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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Federal and State Jurisdiction
• The Environmental
Protection Agency (EPA)
implements the NPDES
permit program
• The RRC regulates the
disposal of all oil and gas
wastes
• Discharges to surface
waters of the State must
be permitted by both the
EPA and the RRC
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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RRC Responsibility
• TAC Title 16, Part 1, Chapter §3.8 (Statewide
Rule 8) – Water Protection
• No person subject to RRC may cause or allow
pollution of surface or subsurface water
• No person may discharge of (or recycle) oil and
gas waste except as authorized or permitted by
RRC
http://texreg.sos.state.tx.us/public/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc
=&p_tloc=&p_ploc=&pg=1&p_tac=&ti=16&pt=1&ch=3&rl=8
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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Texas Surface Water Quality Standards
• Establish explicit
goals for the quality
of streams, rivers,
lakes, and bays
throughout the state
• Permit restrictions
are based on water
quality and
concentration after
discharge to the
receiving body
http://tceq.maps.arcgis.com/apps/webappviewer/index.html?id=b0ab6bac411a4918910
6064b70bbe778
Railroad
Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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RRC Definition of Surface Water
Surface water - lakes, bays, ponds, impounding
reservoirs, springs, rivers, streams, creeks,
estuaries, marshes, inlets, canals, the Gulf of
Mexico inside the territorial limits of the state,
and all other bodies of surface water, natural or
artificial, inland or coastal, fresh or salt,
navigable or non-navigable, and including the
beds and banks of all watercourses and bodies
of surface water, that are wholly or partially inside
or bordering the state or inside the jurisdiction of
10
Defined by Rule §3.8(a)(29)
the state.
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Discharge Permit Standards
• May not cause a violation of the Texas Surface
Water Quality Standards (TSWQS)
• Each discharge has specific effluent testing and
limitations based on the location and the
wastewater analyses provided with application
• Additional testing parameters and limitations
may be added based on chemicals added to the
discharge
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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Types of Discharges
A discharge may occur at the surface (ground)
or be to surface waters Three most common
types of discharges:
• Hydrostatic Test Water (HT) minor permit
• Gas Plant Effluent (GPE)
• Produced Water (Inland and Offshore)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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Hydrostatic Test (HT) Discharges
• Hydrostatic tests are
preformed to pressure test
pipelines and tanks
• Authorized by a minor
permit issued from the
Austin office and is valid for
60 days. Must file two
copies of the applications
and attachments
• Contact EPA Region 6 to
determine federal
permitting requirements to
surface waters
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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HT Permit Typical Testing Requirements
Discharge to surface (ground)
Discharge to surface (water)
Parameter
Limitation
Parameter
Limitation
Benzene
0.5 mg/l
Benzene
0.05 mg/l
O&G
15 mg/l
O&G
15 mg/l
COD
Report
COD
Report
Conductivity
Report
Conductivity
Report
TSS
Report
TSS
Report
• Analytical results must be reported within one
month after the discharge is complete
• Pictures of the effluent treatment and fluid
system
must
beMaster
included
the report
Railroad dispersal
Commission of Texas | June
27, 2016 (Change
Date In First
Slide)
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Gas Plant Effluent Discharges
• Common waste streams
include:
• Cooling tower blow-down
• Reverse Osmosis (RO)
reject wastewater
• Compressor
condensation
• Contact stormwater
• Requires Individual EPA
permit (zinc, chromium)
http://www.houstonchronicle.com/business/energy/a
rticle/Two-more-gas-export-plants-proposed-forTexas-6154035.php
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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Produced Water Discharge Zones
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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West of 98th
• Not covered by an EPA general
permit, but are covered under
effluent guidelines found in 40
CFR Part 435, Subpart E
• Individual EPA Permit may be
required
• Produced water must be
beneficially used for agricultural
or wildlife use when discharged
into navigable waters
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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East of 98th
• Covered by EPA
General Permit TXG
330000 which is up for
renewal in July 2017
• Notice of Intent (NOI)
• Produced water must
be from Carrizo/Wilcox,
Reklaw, or Bartosh
formations
• Discharges into
impaired waters may
require an individual
permit
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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Testing and Limitations (East 98th)
• Oil and Grease
• Daily max: 35 mg/l
• Monthly average: 25 mg/l
• Total Dissolved Solids (TDS) < 3,000 mg/l
• 24-hour acute WET test required
• Additional testing parameters and limitations
may be added based results of Water Analysis
or chemicals in the discharge
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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Territorial Seas
• Covered by EPA General
Permit TXG260000
(renewed February 2017)
• Notice of Intent (NOI)
• Measured from the line of
ordinary low water along
that portion of the coast
which is in direct contact
with the open sea and the
line marking the seaward
limit of inland waters, and
extending seaward a
distance of three miles
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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Coastal Management Program
• Managed General Land
Office (GLO)
• Protects natural habitats
and wildlife
• Discharges must not
adversely affect any critical
area
• Coastal wetlands
• Oyster reefs
• Submerged aquatic
vegetation
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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Outer Continental Shelf
• Covered by EPA General
Permit GMG290000 which
is up for renewal in
September 2017
• Notice of Intent (NOI)
• Authorized discharges for
drilling fluids, drill cuttings,
and produced water
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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Testing and Limitations (Offshore)
• Oil and Grease
• Daily max: 42 mg/l
• Monthly average: 29 mg/l
• Acute and 7-day Chronic WET Test (Territorial
Seas)
• 7-day Chronic WET Test (Outer Continental)
• Additional testing parameters and limitations
may be added based results of Water Analysis
or chemicals in the discharge
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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Complete Water Analysis
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Whole Effluent Toxicity (WET) Test
• WET test measures the effluents effects on test
organism’s (fresh or marine) ability to survive,
grow, and reproduce
• Measures the potential toxicity of all chemicals in
the solution
• Used to prevent the discharge of toxic amounts of
pollutants to surface waters
• Test organisms include vertebrates and
invertebrates
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Whole Effluent Toxicity (WET) Test
• Acute testing focuses on the survival of the
organism
• Chronic testing evaluates growth and reproduction
• A WET test is passed by recording No Observable
Effect Concentration (NOEC) at the calculated
critical dilution concentration
Daphnid (Ceriodaphnia dubia)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Picture by Konrad P. Schmidt
Stormwater Discharges
Two types of Stormwater:
• Noncontact - rainfall that does not come in contact
with oil and gas wastes
• RRC discharge permit not required
• Contact - rainfall that accumulates in waste
management units or contacts oil and gas wastes in
active operation areas
• RRC discharge permit required
• Collected in pits or tanks
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Best Management Practices
Best Management Practices (BMPs) must be
utilized at all authorized and permitted facilities:
• Use of berms, grading, or curbing to prevent
runoff of contaminated fluids
• Perimeter berms are usually required around
facilities
• Secondary containment requirements for
storage tanks, pits, frac tanks, or other vessels
containing wastes
• Good Housekeeping and Inspections
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Other Permitting Options
Land Apply Produced Water
• Must be not be detrimental
to wildlife or agricultural
Potential Sources:
• Produced water
• Noncontact stormwater
• Soil sampling and
complete water analyses
required
• Prevent runoff and pooling
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Land Apply Permit Considerations
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Water quality of the effluent
Soils/acreage to be irrigated
Annual precipitation/evaporation
Application method (sprinklers, gate valves,
etc.)
• Run-off prevention (berms), silt fencing,
channels, etc…
• Soil sampling parameters are based on the
background sampling
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Recycling Alternatives
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Thank you!
Tiffany Humberson
Environmental Permits and Support
512-463-4990
[email protected]
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)