Transcript TCEQ and the Oil and Gas Industry - Permian Basin STEPS

The Texas Commission on
Environmental Quality
and the
Oil and Gas Industry
An Overview
TCEQ Regulates:
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Air
Waste
Water
Construction
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Processing
Treating
X
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Exploration
Production
Texas Railroad
Commission
Air
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Permits by Rule
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Standard Air Permits
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Concrete Batch Plants, etc.
State Permits
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Chapter 106
25 tpy of VOC or SO2 or PM10
250 tpy of CO or NOx
PSD (Prevention of Significant Deterioration)
General Operating Permits – Federal
Site Operating Permits - Federal
NSR and Title V Perspective
DM
Minor
PBR
GOP
Standard Permit
State Permit
SOP
NNSR & PSD Federal Permit
NSR
Title V
Upset Conditions
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Emission Events
Must notify regional office within 24 hours of
discovery
 For “affirmative defense” must include all
information required in a timely manner
 Submit “Final” report within 2 weeks
 Some emission events result in enforcement
action, depending on the cause and or
quantity of the release.
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Emission Inventories
Point sources
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reported emissions by Industry
Area sources
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TCEQ developed (Painting, gas stations, dry
cleaners, etc.
Mobile sources
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TCEQ developed (On-road and non-road)
Biogenic sources
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TCEQ developed (trees, eatc.)
Point Sources
 Major or minor source under §116.12 (New
Source Review)
 Dependent on potential to emit (PTE) PTE and
actual emissions thresholds for regulated pollutants
 Location of source
 Attainment vs Non-attainment
 Boilers and Heaters
 Flares
 Fugitives
 Loading Operations
Permits by Rule
Chapter 103.261/262 pertaining to Oil and
Gas Facilities is currently being re-written
to become more specific with regard to
day-to-day operations
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Topics to include:
 Blowdowns
 Degreasing,
Lubrication
 Tank Cleaning
 Thief hatches
Common Air Violations
Failure to obtain authorization for
equipment that requires permitting or
Permit By Rule registration
 Failure to operate the equipment as
registered
 Failure to submit reports in a timely
manner
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Waste
O&G waste generated on the drilling site is
RRC jurisdiction
 Industrial Hazardous waste
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Solvents, etc.
Universal waste
Fluorescent light bulbs
 Paint and paint related waste
 Batteries
 Mercury – containing Equipment
 Pesticides
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Common Waste Violations
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Notification
Hazardous waste identification (Class 1,2 &3)
 Generator Status
 Annual waste Summary
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Hazardous Waste Management
Tanks
 Container Storage Area
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Paperwork Violations
Hazardous waste determinations
 Manifests
 Annual waste summaries
 Inspections
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Storage Areas – weekly
 Tanks- daily
 Container
 Safety
 Fire
and Spill Equipment
 Internal Communications or Alarm System
 Letters to Police, Fire and Hospitals
 Personnel Training
 Emergency Reporting
Water
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Public Water Systems
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Serve 25 or more for at least 60 days per year
Waste water discharges
Discharge Monitoring Report (DMR)
 NetDMR highly encouraged (replaced eDMR)
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Multi-Sector General Permit
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May be required if you have had a reportable
spill at the site in the last 10 years
Common Water Violations
Microbiological Sampling
 Inadequate or Non-Submittal of
Disinfectant Level Quarterly and monthly
Operating Reports
 Inadequate Cross Connection Program
 Non-Submittal of new facilities plans
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Water violations, con’t
No annual inspection of storage tanks
(including pressure tanks)
 Disinfectant residual (lots of issues)
 Low distribution water pressure
 Un-locked facility fencing
 Water Wells
 Storage tanks
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Storm Water Construction Permits
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EPA – National Pollutant Discharge
Elimination System (NPDES)
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Oil and Gas Exploration and Production
TCEQ – Texas Pollutant Discharge
Elimination System (TPDES) or
Construction Storm Water Permit
O&G Processing and Treating
 TXR150000
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SW Construction Permits
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Large construction site (>5 acres)
Require Notice of Intent
 Storm water pollution prevention plan
 Includes <5 acre sites that are part of a larger
common plan of development
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Small construction sites (<5 acres)
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Require Storm water pollution prevention plan
Less than 1 acre, not regulated
Compliance Assistance
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Small Business (<100 employees)
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SBLGA Hotline 1-800-447-2827
Site Visit Program
Environmentor Program
Large Businesses
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Pollution Prevention and Education
SAV+
Clean Texas Program
Environmental Management Systems
512-239-3100
Other Programs
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Dam Safety
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Portable “facilities”
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PE required for drilling <500 ft. from dam
Use registered sludge transporter
Water Rights (surface water)
Temporary permits <1 acre-foot. One year
 Regional approval, not renewable
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Region 7 counties
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Andrews
Borden
Crane
Dawson
Ector
Gaines
Glasscock
Howard
Loving
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Martin
Midland
Pecos
Reeves
Terrell
Upton
Ward
Winkler
Contact information
TCEQ Region 7
3300 N. “A” St. Bldg 4 Ste. 107
Midland, TX 79705
432 570-1359
Fax 432 570 4795
Jeff Bertl, Regional Director
 Alice Cone, Air Section Work Leader
 Michael, Waste/Water Section Work Leader
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Contact Information
Janet Prim
Compliance Specialist
 Small Business and Local Government
Assistance
 432-620-6116
 [email protected]
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Contact Information
Christine Hammit, PG
IHW Investigator
 Midland
Regional Office
 (432) 570-1359
 [email protected]