Railroad Commission of Texas

Transcription

1 Railroad Commission of Texas Site Remediation Cleanup Programs Cleanup Rules Peter G. Pope, P.G. Site Remediation Section 1

2 Cleanup Programs Topics Covered Regulatory Authority Rules State Managed Cleanup Program Operator Cleanup Program Voluntary Cleanup Program Brownfields Response Program 2

3 Railroad Commission of Texas History 1891 Railroad Commission of Texas Created 1917 Regulation of Pipelines; Conservation laws relating to oil and natural gas production 3

4 Railroad Commission of Texas Mission Statement The Railroad Commission serves Texas through: our stewardship of natural resources and the environment; our concern for personal and community safety; and our support of enhanced development and economic vitality for the benefit of Texans. 4

5 RRC Jurisdiction Regulation of: Oil and natural gas primary production Pipelines Natural gas processing and natural gas utilities Salt dome cavern storage Bulk storage of crude oil RRC commercial disposal facilities Liquid propane gas (LPG), compressed natural gas (CNG), and liquid natural gas (LNG) 5

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7 Eagle Ford Statistics 10,255 on schedule Permits issued: 26 (2008) to 4,260 (9/2014) Oil production ~ 917,993 Bbl/day Gas Production ~ 4,337,372 Mcf/day Condensate ~ 249,480 Bbl/day as of Oct 22,

8 Texas Pipelines June

9 RRC Cleanup Authority Broad Statutory Authority Regarding the Control of Pollution Resulting from Oil and Gas Waste Natural Resources Code , adopted in 1977 Texas Water Code Section , adopted in

10 Oil and Gas Division Districts Nine District Offices for 12 Geographical Districts 10

11 RRC Cleanup Rules 3.8 Water Protection Rule 3.20 Notification Requirements 3.91 Cleanup of Soil Contaminated by a Crude Oil Spill 3.98 Standards for Management of Hazardous Oil & Gas Waste 4 D Voluntary Cleanup Program 4 F Disposal of NORM Waste *Note: Does not include well plugging and other safety rules. 11

12 RRC Cleanup Rules Statewide Rule 8 - Water Protection SWR 8(b): No pollution. No person conducting activities subject to regulation by the commission may cause or allow pollution of surface or subsurface water in the state. 12

13 Amendments to SWR 8 Amended April 2013 Encourages water conservation Authorizes non-commercial fluid recycling Streamlines permitting requirements Improves safety in waste hauling

14 RRC Cleanup Rules Statewide Rule 20 - Release Notification Rule Operators shall give immediate notice of a fire, leak, spill, or break to the appropriate commission district office. Notice shall be followed by a letter with full description of the event, volume of crude oil, gas, geothermal resources, other well liquids, or associated products lost. 14

15 RRC Cleanup Rules Statewide Rule 30 Waste Jurisdiction Memorandum of Understanding between RRC and Texas Commission on Environmental Quality (TCEQ) Railroad Commission of Texas solely responsible for the control and disposition of waste and the abatement and prevention of pollution of surface and subsurface water in the state from activities associated with the exploration, development, and production of oil and gas. 15

16 RRC Cleanup Rules Statewide Rule 91 Crude Oil Spills in non-sensitive areas Crude oil in non-sensitive areas to be cleaned up to 1% total petroleum hydrocarbons (TPH) Does not apply to condensate, crude oil spilled in sensitive areas or crude oil spills that occurred prior to November 1,

17 RRC Cleanup Rules Statewide Rule 91 Summary Removal of free oil Horizontal & vertical delineation Excavate and dispose or if handling onsite: Prevent stormwater contamination Cleanup to less than1% TPH as soon as technically feasible but no later than one year. Cleanup of spills in sensitive areas are evaluated on a case-by-case basis. 17

18 RRC Cleanup Rules Sensitive defined in Rule 91: *Proximity to surface water, wildlife refuges, commercial or residential areas. The definition applies to sites where there is shallow groundwater or possible pathways for communication with deeper groundwater or discharges to surface waters. *Proximity is not defined. 18

19 Cleanup Guidance For condensate and crude spills in sensitive areas

20 Cleanup Guidance Other guidance available on request: COC Guidelines for Substances Released Produced Water Institutional Controls OCP Deliverables NORM

21 RRC Cleanup Rules Statewide Rule 98 - Hazardous Oil & Gas Waste Exempt Waste Wastes uniquely associated with primary field productions Non-Exempt Waste Wastes that are not uniquely associated with an E&P activity EPA Guidance for Oil and Gas exemption (en Español, tambien!) EPA 530-K (October 2002) ( 21

22 RRC Cleanup Rules Statewide Rule 4 Subchapter F Naturally Occurring Radioactive Materials (NORM) Regulates disposal of NORM associated with oil and gas E&P activities Requires identification of NORM contaminated equipment 22

23 RRC Cleanup Programs Site Remediation Section State Managed Cleanup Program (SMCP) Operator Cleanup Program (OCP) Voluntary Cleanup Program (VCP) Brownfields Response Program (BRP) 23

24 STATE MANAGED CLEANUP PROGRAM Use of State Funds for Cleanup When Responsible Operator fails or refuses to take action. Responsible Operator is unknown or cannot be found. Fund utilized to cleanup pollution of abandoned sites. Prioritization is based on public health, safety and the protection of the environment.

25 STATE MANAGED CLEANUP PROGRAM TYPES OF CLEANUP ACTIVITIES Emergencies Cleanups Assessments Abatements

26 Oil & Gas Regulation and Cleanup SB 310 Funding Sources Regulatory fees, fines, penalties, and charges for goods and services. Applications for exceptions to RRC rules Natural Gas Policy Act (15 U.S.C. Section application). Administrative penalties for violations of rules pertaining to E&P and pipelines. Drilling permit fees (to drill, deepen, plug back, or reenter a well).

27 State Managed Site Remediation Program Completed Cleanup Activities for Fiscal Years 1992 June 2014 Fiscal Year Cleanup Candidates PER FISCAL YEAR CUMULATIVE FY Completions Yearly Costs Completions Cumulative Costs 1992 N/A 53 $47, $47, N/A 79 $72, $120, N/A 93 $112, $233, N/A 144 $269, $502, N/A 155 $402, $905, N/A 213 $651, $1,556, N/A 281 $1,199, ,018 $2,756, N/A 291 $1,618, ,309 $4,375, N/A 233 $2,192, ,542 $6,567, N/A 229 $6,563, ,771 $13,131, , $4,099, ,126 $17,230, , $4,405, ,452 $21,635, , $4,137, ,765 $25,772, , $3,416, ,057 $29,189, , $3,866, ,382 $33,056, , $8,343, ,690 $41,399, , $4,500, ,983 $45,900, , $4,678, ,306 $50,578, , $2,841, ,497 $53,420, , $1,822, ,697 $55,243, , $5,291, ,950 $60,534, , $4,056, ,230 $64,590, , $2,521, ,468 $67,111,886.30

28 Operator Cleanup Program Oversight of Operator-led cleanups to ensure compliance with RRC rules. District Office - Non-sensitive area cleanups. Site Remediation Section in Austin - Oversight of sensitive area/complex site cleanups. Complexity = special assessment needs, risk-based cleanup, case-by-case 28

29 Operator Cleanup Program Case-by-Case generally means: Risk-based site assessment Risk-based cleanup TRRP process* * Texas Commission on Environmental Quality Texas Risk Reduction Program (TRRP) rule 29

30 Operator Cleanup Program Examples of COCs Crude Oil (BTEX, PAHs, TPH) Condensate (BTEX, PAHs, TPH) Drilling Mud (water-based) (TPH, Metals, ph, Chloride, Sodium, Electrical Conductivity) Produced Water/Brine (BTEX, Chloride, Metals) Tank Bottoms (BTEX, PAHs, Metals, ph, TPH) Mercury Meters (Mercury, ph) BTEX = Benzene, toluene, ethylbenzene, and xylenes PAHs = Polycyclic aromatic hydrocarbons 30

31 Active Operator Cleanups by District Operator Cleanup Program Projects As of 6 June

32 Operator Cleanup Program Public GIS Map Viewer for Oil, Gas and Pipeline Data Map View of Operator Cleanup Program sites Select Identify Operator Cleanup Site under Map Tools, and click on a green (active) or black triangle (closed). Pop-up box with Site identification. 32

33 Public GIS Map Viewer OCP ID 1774 SITE NAME Chapman Ranch STATUS Active COUNTY Nueces DISTRICT 04 LATITUDE LONGITUDE

34 Voluntary Cleanup Program Provides incentive to lenders, developers, owners, and operators who did not cause or contribute contamination. Applies to waste cleanups under Railroad Commission jurisdiction. Offers the applicant a release of liability to the state. 34

35 RRC Brownfields Program U.S. Environmental Protection Agency State Brownfields Program "brownfield means real property, the expansion, redevelopment, or reuse of which may be complicated by the presence or potential presence of a hazardous substance, pollutant, or contaminant. Helping local communities!

36 RRC Brownfields Program Offer free Assessments and Cleanup to local governments, non-profits, schools, churches Brownfields Certificate of Completion Contact Kelly Wilson for information (512) Helping local communities!

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38 Trends/Developing Issues State Managed Offshore Cleanups Waste Management Operator Cleanup Urban Encroachment Enforcement Cases Voluntary Cleanup/Brownfields Increased applications 38

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44 State Managed Recycling Facility

45 30,000 BBL Storage Tank

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49 Operator Cleanup Program Samson Young Gas Unit, Well #3, Rusk County Landowner complaint about distressed vegetation in a boggy area Salinity contamination in creek Electromagnetic survey identified a flow-back pit Removed 6,000 cubic yards of reserve/flow-back pit soils Installed monitoring wells and a sump to remove contaminated groundwater 49

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55 Mg/L Operator Cleanup Program Samson Young Gas Unit, Well #3, Rusk County Pumped 39,434 barrels of water from the sump Chloride in MW-3 Date 55

56 Operator Cleanup Program Historic Pipeline Release, Montgomery County Landowner complaint of hydrocarbons seeping through cracks in concrete wall of swimming pool Identified exposed pipeline near the pool Montgomery County Appraisal files indicate a 1954 inactive crude oil pipeline easement transects the property 56

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59 Abandoned Pipeline 59

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61 Northview Apartments, Kilgore Affordable Housing 61

62 Northview Apartments Application received November 2008 Phase II ESA performed by RRC No impacts identified Cost savings $21K Site closed March construction jobs and two permanent positions created Leveraging with $2M loan with TDHCA 62

63 Turtle Bayou Site, Chambers County 522-Acre Site slated to be used for water quality protection and a nature preserve managed by the Galveston Bay Foundation Actions 18 abandoned oil and gas wells being plugged with state funds Delineating hydrocarbons and chloride impacts Benefits Green space, wildlife habitat, water quality.

64 Turtle Bayou Site, Chambers County 64

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66 Any Questions? Aimee Beveridge, P.G Peter G. Pope, Site Remediation Pe