WEBVTT
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All right.
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So it's now 1:30.
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So we're going to go
ahead and get started
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with the second in
this series of webinars
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hosted by the Railroad Commission.
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If you were able to join us yesterday,
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we welcome you back
to the second webinar
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that's going to focus on the
voluntary cleanup program
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with the Railroad Commission today,
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as well as some other
resources available to Brownfields.
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I am gonna at the
end of this presentation
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also expand on some of the
topics we discussed yesterday.
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If you weren't able to join us yesterday
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then welcome for the first webinar here.
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And so we're gonna go
ahead and get started.
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Okay.
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Just so before we dive into everything,
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we wanted to give
you guys sort of a face
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to the voices that you're
going to be hearing today.
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My name is Leslie Bruce,
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I'm going to be the
main presenter today.
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I am the voluntary cleanup program
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and Brownfield program coordinator
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here at the Railroad Commission.
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If you joined us yesterday,
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you kind of already heard
about my background,
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but any of you who
are just joining us today,
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I received a BS in Geology
from university of South Carolina
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and an MS in Geology from UT Austin.
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I've been with the Railroad
Commission since 2017,
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working in two different
groups before I became the VCP
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and Brownfield
coordinator in April of 2019.
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And so today we also
have a couple of panelists
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that are joining us.
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Peter Pope,
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he's not actually going
to be able to join us today,
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but I wanna kind of introduce him
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since he plays a very important role
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in the voluntary cleanup program.
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He's who signs off on all of
our certificates of completion
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and has the final review
of all sites before closure.
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So Peter is the manager of
the site remediation section.
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He's been with the
Commission since 2001.
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He has a BS in Geology from Purdue
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and an MA in Geology from Rice.
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And he has more than
25 years of experience
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doing risk-based assessments.
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And then we also have
Art Correa with us today.
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He's the project manager of the
State Managed Cleanup Group,
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which we're gonna
talk about in our group,
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but I'm gonna let Art
introduce himself real quick.
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Thank you Leslie.
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Yes, welcome everybody.
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I hope you enjoy the webinar.
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My name is Art Correa,
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I've been with the Commission since 1991
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and been over the State Managed
Cleanup Program since 2014.
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And I've been out in this
industry for about 40 plus years.
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That's it, thank you.
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Thanks Art.
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Okay, and so Peter and I are going to
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help well, Art today is
going to help facilitate
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some questions that I
might not be able to answer
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for the State Managed Cleanup Program.
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And then we're also
going to have Keith May.
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So Keith is with the State
Funded Plugging Program,
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which we're also going to touch on
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and he will help answer
some questions at the end.
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Well Keith do you want to go ahead
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and introduce yourself as well?
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Leslie.
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Good afternoon, everybody,
my name's Keith May.
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Got my engineering degree
from UT Austin back in 2011.
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Worked for the industry
as a wireline engineer
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for a couple of years,
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then joined up with the
Commission on 2013.
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And I've been part of
the State Funded Program
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for a couple years now,
two or three years now.
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Yeah, thank you Leslie.
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Awesome, thank you Keith.
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All right, so today's agenda,
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we're going to go over kind of just
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what the Voluntary Cleanup Program is
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and what it's designed to do.
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We'll go over the property
eligibility, site enrollment,
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whether or not you should be
within the Railroad Commission
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or TCEQ's VCP program.
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We'll go over some,
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the application and approval process,
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your required documents
from start to finish
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within this program.
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Some oversight fees,
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since this is a program
that you have to pay to be in,
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and then some examples of VCP sites.
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And then near the end,
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we're going to dive into the statement
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cleanup program and state
funded plugging program,
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which we talked about yesterday,
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which have funds that are available
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for you for Brownfield's
participants or applicants.
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So just as a reminder,
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that if you have any
questions during this webinar,
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please submit them to the
SR-VCP-BRP@rrc.texas.gov
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So we're going to be
monitoring that email address
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and we'll answer questions at the end.
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And if we're not able to get
to all of the questions today,
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don't worry, we're going to
send each and every one of you
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an individual response.
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So I know where you're
going to get a response,
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either via email or on screen today.
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And then if you don't
have that written down yet,
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don't worry that email
address is going to be located
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at the bottom of each slide.
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So you'll be able to kind
of see that as we go along.
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Okay, so what is the
voluntary cleanup program?
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Why are you guys here today?
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Or why should you care?
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So the program is designed
to incentivize remediation
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of contaminated sites in Texas.
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And so the way we're
doing that is by providing
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regulatory oversight of that
remediation and assessment.
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And then, and especially
with Railway Commission,
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these are oil and gas sites.
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And once you've completed this program
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and we've provided
that regulatory oversight
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and given you approval
to appropriately close it out,
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you then will receive a
release of liability from the state.
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So one of the most
important things to take away
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from this webinar and
why VCP is so important
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is that release of liability.
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So you know, if you are
taking on the assessment
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and remediation of a site,
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you are taking on that liability,
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but if you go through our
program and appropriately
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clean it up per your closure strategy,
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you're going to receive
this release of liability
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from the state,
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which transfers to not only
you as the property owner,
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but also any future
property owners and lenders,
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any borrowers, any
leasers, anything like that,
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that's gonna be
associated with a property
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that release of liability is
also going to transfer to them.
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So, program eligibility.
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So the applicant can not have caused
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or contributed to the
contamination on the property.
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If you weren't sure you have caused
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or contributed contamination,
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you would likely be probably needing
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to be in the operator cleanup program.
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So that's a really big
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distinction here for this program.
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And then activities have
to be under the jurisdiction
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of the Railroad Commission.
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And there has to be
no unresolved federal
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or state enforcement on a property.
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And then similar to
the Brownfields program
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that we talked about yesterday,
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the applicant and the
landowner have to agree
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to cooperate with the
Railroad Commission.
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So here again, we just want to point out
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that you do not have to be the landowner
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to be the applicant,
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you can be, but it's not required.
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But if you are not the landowner,
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you have to have that
landowner's consent
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to be in the program.
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And so a lot of times
what we'll see is you'll have
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potentially the future landowner
is actually the applicant
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and they want to go through this process
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before they purchase
their property to ensure that,
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you know, they're not
taking on that liability
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before purchasing, or
sometimes the opposite
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where
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it's the current operators
going through this program
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on the contention that once they sell it
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to the new purchaser,
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that this will have been
taken care of by that point.
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Okay.
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So this is probably the
number one thing you need
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to ask yourself once you
probably get your phase one back
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for your site is, does this site belong
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with Railroad Commission
or TCEQ VCP's program
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or potentially another
program within TCEQ.
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So we really can't make
that determination for you
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because in order to
make that determination,
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you needed to make your application,
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submit your fees and
everything associated with it.
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And so instead of doing that,
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the best thing that
we can suggest to you
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is just to consult with
an oil and gas attorney
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to determine whether or
not to see which program
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would be more appropriate
or an environmental attorney,
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but you can also refer to the
memorandum of understanding
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between the Railroad
Commission and the TCEQ.
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So that can be found at the
16 Texas Administrative Code
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three point 30.
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And that kind of details
the jurisdictional divides
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between the two agencies.
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But I think it's also
important to point out
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that you can actually be duly enrolled
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in the Railroad Commission
and TCEQs VCP program
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at the same time.
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We have a lot of sites where
there's been historical oil
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and gas activities
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and then there's more
modern industrial activities.
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And you can clearly
distinguish the contamination
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and sources from both.
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And in that case, you know,
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the Railroad Commission
will deal with everything
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we have jurisdiction
over and TCEQ will deal
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with everything they
have jurisdiction over,
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and we'll talk amongst each
other to make sure, you know,
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we're not giving any
conflicting information
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between the two agencies.
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So the application approval process.
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So I like to call it the
application package
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because it's more
than just the application
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that you're required to submit
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when you're applying to our program.
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So obviously you'll have to
have the signed application
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and agreement, which
you can find on our website
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that you can download that.
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You download it and print it out
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and can fill it out
and then mail it to us.
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But also that along with that,
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you need the application fee of a $1,000
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and the surcharge of $1,500.
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And then you need a
phase one site assessment
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of the entire property
that is going to be enrolled.
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So we really ask that you
not submit your application
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until you have a phase one.
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Also because that phase one,
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that's gonna really
help you to determine
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which program your site belongs in.
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And then that phase one is
also going to help us dictate
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what needs to happen at the site.
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So really, do not submit an application
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without the phase one.
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So approval process,
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we'll review all the documents
that you submitted above
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and any reports that are also submitted.
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We'll also conduct a legal review,
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the applicant and the
property to ensure that
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that applicant did not cause
or contribute to contamination.
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And then within 45 days of receiving
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the full application package,
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we'll issue either an
approval or a denial letter.
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Okay.
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So closure options within
the voluntary cleanup program.
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So here it's important to point out
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that the applicant chooses
their own closure strategy
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at time of applying based on
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their desired future
use of the property,
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or the applicant can
choose their closure strategy
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based on site-specific conditions.
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So essentially if you've
already done say,
00:12:59.780 --> 00:13:02.450
phase one and phase two
or even more assessments
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before you apply, which
you're allowed to do,
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you can use the data to
drive your closure strategy.
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But if you've only done a
phase one and you know,
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you're not sure what the
data is going to provide
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but you know you
want to close residential
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or with no conditions, then
that's totally fine as well.
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The only thing is that we
essentially are asking that,
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you know, you have to demonstrate
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that your closure strategy,
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whichever one you choose
is going to be protective
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of human health and the
environment as laid out
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in the Texas risk reduction program.
00:13:38.069 --> 00:13:39.193
And then I also want to point out,
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cause this gets brought up a lot,
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do we, does the Railroad
Commission implement
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the Texas risk reduction
program that TCQ created?
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So yes, we are following
all those guidelines.
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And so all of your
assessments and cleanups
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need to be done to those standards.
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And then you can click,
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you can change your
closure strategy at any time.
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You, the only thing we request is that
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if you do change your closure strategy,
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you just resubmit the
application agreement
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to reflect that change.
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There won't be any
charges associated with that.
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We just want to document in the file
00:14:18.040 --> 00:14:19.407
that there's been a change.
00:14:27.647 --> 00:14:31.440
Okay, so let's go into your
different closure options.
00:14:31.440 --> 00:14:33.890
And especially, I like to clarify these
00:14:33.890 --> 00:14:36.480
since we get a lot of
questions about them.
00:14:36.480 --> 00:14:39.485
Since there are several
options you can go with,
00:14:39.485 --> 00:14:44.400
you're gonna find this on
page five of the application
00:14:44.400 --> 00:14:47.190
and page three of the agreement.
00:14:47.190 --> 00:14:51.440
So one option would be to
clean up to background levels.
00:14:51.440 --> 00:14:55.463
And so that would be
an unconditional closure,
00:14:56.530 --> 00:14:59.570
but background levels really is intended
00:14:59.570 --> 00:15:02.518
for metal and chloride contamination,
00:15:02.518 --> 00:15:05.940
where you can establish a
background concentration,
00:15:05.940 --> 00:15:08.513
and then you're cleaning
up the site to that level.
00:15:09.920 --> 00:15:13.410
The second option is going
to be a risk-based cleanup
00:15:13.410 --> 00:15:14.410
for residential levels.
00:15:14.410 --> 00:15:17.745
So again, another unconditional closure,
00:15:17.745 --> 00:15:19.650
but that one's going to be risk-based
00:15:19.650 --> 00:15:21.830
as opposed to background levels.
00:15:21.830 --> 00:15:26.430
And so risk-based, we're
going to be turning to
00:15:26.430 --> 00:15:28.210
the Texas risk production
00:15:28.210 --> 00:15:31.123
protective concentration
levels for that.
00:15:33.820 --> 00:15:35.160
Okay, so in next two slides we're going
00:15:35.160 --> 00:15:37.580
to talk about conditional closure.
00:15:37.580 --> 00:15:39.390
So these are going to be closures
00:15:39.390 --> 00:15:43.638
with a restrictive covenant
or institutional control.
00:15:43.638 --> 00:15:46.223
I think they're essentially
the same thing we just,
00:15:47.670 --> 00:15:49.183
and interchange those words.
00:15:50.620 --> 00:15:53.480
But so it's important here to now
00:15:53.480 --> 00:15:55.890
that a conditional closure,
00:15:55.890 --> 00:15:59.500
you can have a residential closure
00:15:59.500 --> 00:16:01.840
with an institutional control.
00:16:01.840 --> 00:16:05.140
In that case, it would just
be an institutional control
00:16:05.140 --> 00:16:06.803
for the groundwater use.
00:16:07.720 --> 00:16:11.000
So you can have residential
closure on the surface,
00:16:11.000 --> 00:16:13.130
groundwater use restriction.
00:16:13.130 --> 00:16:16.610
You could just have a surface
00:16:17.970 --> 00:16:19.440
land use restriction
00:16:19.440 --> 00:16:24.440
in which it's going to be to
commercial industrial uses,
00:16:24.700 --> 00:16:27.180
but have no ground
water use restriction,
00:16:27.180 --> 00:16:29.540
or you can have both
where you are limiting
00:16:29.540 --> 00:16:32.600
the use of that property to
just commercial industrial,
00:16:32.600 --> 00:16:35.790
and also limiting the
use of a certain amount
00:16:35.790 --> 00:16:38.470
of feet of groundwater.
00:16:38.470 --> 00:16:39.880
So these are kind of your,
00:16:39.880 --> 00:16:43.423
these are typically the
options that we come across.
00:16:45.670 --> 00:16:47.640
And then the last option,
00:16:47.640 --> 00:16:50.350
we really don't see many of these,
00:16:50.350 --> 00:16:51.790
but this is when you're going to be,
00:16:51.790 --> 00:16:54.200
you're going to have
an institutional control,
00:16:54.200 --> 00:16:55.033
but you're also going to have
00:16:55.033 --> 00:16:57.060
an engineering control with that.
00:16:57.060 --> 00:17:00.510
So this is going to be
like an engineering cap
00:17:01.420 --> 00:17:02.890
or ventilation system.
00:17:02.890 --> 00:17:03.810
There's other options,
00:17:03.810 --> 00:17:06.783
but those are probably one
of the two most common.
00:17:10.090 --> 00:17:12.730
Okay, so VCP application and agreement.
00:17:12.730 --> 00:17:16.433
Again, that's on our website,
that's a required document.
00:17:17.721 --> 00:17:20.150
A metes and bounds
description of your property
00:17:20.150 --> 00:17:21.860
is also required.
00:17:21.860 --> 00:17:24.760
This is really important cause
that's kind of documenting.
00:17:24.760 --> 00:17:27.840
This is exactly the
property metes and bounds
00:17:27.840 --> 00:17:29.770
where we did this assessment.
00:17:29.770 --> 00:17:32.890
And that is exactly where
the certificate of completion
00:17:32.890 --> 00:17:34.830
and release of liability extends to you.
00:17:34.830 --> 00:17:38.950
It does not go past metes and
bounds property description.
00:17:38.950 --> 00:17:41.350
And that's important in
case for whatever reason,
00:17:41.350 --> 00:17:42.680
your property,
00:17:42.680 --> 00:17:47.333
you gain another property
and kind of combine those two.
00:17:48.650 --> 00:17:52.850
So for the records, we
will want to clearly define
00:17:52.850 --> 00:17:56.523
which area has been
assessed appropriately.
00:17:57.690 --> 00:18:00.530
You can go ahead and send
that in with your application,
00:18:00.530 --> 00:18:03.410
that's probably the best thing to do,
00:18:03.410 --> 00:18:06.403
but you're not required to
send in with your application.
00:18:08.159 --> 00:18:10.360
And then, so you're required
a phase one site assessment
00:18:10.360 --> 00:18:12.470
and for anyone who
currently doesn't know,
00:18:12.470 --> 00:18:16.650
this is an assessment
that needs to be performed
00:18:16.650 --> 00:18:19.120
by a professional environmental firm.
00:18:19.120 --> 00:18:21.490
And they're gonna
essentially do a records review
00:18:21.490 --> 00:18:23.520
of the property.
00:18:23.520 --> 00:18:26.580
They'll look at sort of
the history of the site
00:18:26.580 --> 00:18:29.467
and interview people
who are familiar with it
00:18:29.467 --> 00:18:32.760
to get an idea of what might
have occurred on this property
00:18:32.760 --> 00:18:35.420
that might've caused contamination.
00:18:35.420 --> 00:18:37.780
And so they'll identify what we call
00:18:37.780 --> 00:18:40.020
recognize environmental conditions
00:18:40.020 --> 00:18:42.560
and all of those need to be assessed.
00:18:42.560 --> 00:18:44.940
And so the phase two is when actually,
00:18:44.940 --> 00:18:47.880
again, another engineering
firm needs to do this
00:18:47.880 --> 00:18:52.213
and have their PGS EGC
on it or engineering seal.
00:18:53.510 --> 00:18:56.760
But this is when they're
putting in soil samples
00:18:56.760 --> 00:19:00.390
and or groundwater monitoring wells
00:19:00.390 --> 00:19:03.550
to determine the extent
of any contamination
00:19:03.550 --> 00:19:05.263
that is potentially there.
00:19:06.810 --> 00:19:10.340
Another document I put it
under required documents,
00:19:10.340 --> 00:19:14.560
although it's not technically required,
00:19:14.560 --> 00:19:16.140
but it's the closure report.
00:19:16.140 --> 00:19:18.610
So this is going to be a
summary of everything
00:19:18.610 --> 00:19:20.600
that occurred at the site.
00:19:20.600 --> 00:19:23.050
We strongly encourage this just because
00:19:23.050 --> 00:19:26.870
that easily summarizes
everything for staff
00:19:26.870 --> 00:19:31.630
to be able to review it and
then more readily rate the
00:19:33.820 --> 00:19:35.763
certificate of completion for you.
00:19:37.419 --> 00:19:38.880
And then affidavit of completion.
00:19:38.880 --> 00:19:41.030
So that's going to be a document,
00:19:41.030 --> 00:19:43.930
it's sort of a template
document that the Commission
00:19:43.930 --> 00:19:47.570
will send to you once we've
given you final approval
00:19:47.570 --> 00:19:51.570
of closure and you're
essentially gonna sign
00:19:51.570 --> 00:19:53.730
and notarize it.
00:19:53.730 --> 00:19:56.450
And it's stating that, you know,
00:19:56.450 --> 00:19:59.770
everything's been appropriately
assessed and cleaned up
00:20:00.860 --> 00:20:04.750
to the appropriate standards
based on your closure strategy
00:20:04.750 --> 00:20:07.603
and that no further action
is needed at the site.
00:20:10.600 --> 00:20:12.763
So some as-needed documents,
00:20:13.950 --> 00:20:15.930
this would be like a
remedial action plan
00:20:15.930 --> 00:20:18.480
if you actually need to
do remediation at the site.
00:20:20.520 --> 00:20:23.520
You're not required to
submit a remedial action plan,
00:20:23.520 --> 00:20:26.990
but we really strongly encourage that
00:20:26.990 --> 00:20:29.750
because the last thing
you want is to go out
00:20:29.750 --> 00:20:31.830
and do all this remediation work,
00:20:31.830 --> 00:20:34.160
generate a final report,
00:20:34.160 --> 00:20:38.130
pay a lot of money to
mobilize those engineers,
00:20:38.130 --> 00:20:42.390
the engineering field staff,
and then to submit it to us,
00:20:42.390 --> 00:20:46.120
and then we have a lot of
additional questions or requests
00:20:46.120 --> 00:20:47.970
and we have to re-mobilize out there.
00:20:47.970 --> 00:20:50.880
So the best suggestion I can make
00:20:50.880 --> 00:20:53.560
is just go ahead and
submit a remedial action plan
00:20:53.560 --> 00:20:56.930
and let us review it and
make sure that, you know,
00:20:56.930 --> 00:21:00.047
we think it's appropriate and
everything's being addressed.
00:21:01.170 --> 00:21:05.850
The other one is if you do
have groundwater contamination,
00:21:05.850 --> 00:21:09.690
would be groundwater monitoring reports,
00:21:09.690 --> 00:21:11.000
we really request,
00:21:11.000 --> 00:21:14.950
we strongly encourage that
groundwater monitoring occurs
00:21:15.920 --> 00:21:19.280
or groundwater sampling
occurs on a quarterly basis
00:21:19.280 --> 00:21:22.280
until the concentrations
of your contaminant
00:21:22.280 --> 00:21:24.510
are stable or declining.
00:21:24.510 --> 00:21:27.450
We also request that if
you change the frequency
00:21:27.450 --> 00:21:32.280
of that sampling that
you notify us for doing so,
00:21:32.280 --> 00:21:34.270
and kind of get our sign off on it.
00:21:34.270 --> 00:21:36.110
That is not required,
00:21:36.110 --> 00:21:38.910
you're allowed to change
that whenever you'd like.
00:21:38.910 --> 00:21:40.670
But again,
00:21:40.670 --> 00:21:44.480
since this program is us
providing regulatory oversight,
00:21:44.480 --> 00:21:47.080
it's we really encourage
everyone to kind of get approval
00:21:47.080 --> 00:21:50.760
for that and make sure it's
appropriate for, you know,
00:21:50.760 --> 00:21:53.170
what we're seeing in groundwater.
00:21:53.170 --> 00:21:56.380
And then the other as-needed document
00:21:56.380 --> 00:21:57.580
would be a restrictive covenant
00:21:57.580 --> 00:22:00.160
or as I kind of referred
to it in the last slide,
00:22:00.160 --> 00:22:02.300
would be an institutional control.
00:22:02.300 --> 00:22:04.570
And that's if you're
going to close the site out
00:22:04.570 --> 00:22:06.330
with groundwater use restriction
00:22:06.330 --> 00:22:08.573
or land use restriction or both.
00:22:12.180 --> 00:22:13.110
Okay.
00:22:13.110 --> 00:22:14.883
So project timeline and schedule.
00:22:15.770 --> 00:22:18.730
Probably as you've
already started to figure out
00:22:18.730 --> 00:22:19.730
with this program,
00:22:19.730 --> 00:22:22.423
the applicant's determining
everything here, really.
00:22:23.310 --> 00:22:25.850
So you're, so the
applicant is going to create
00:22:25.850 --> 00:22:29.520
their own project schedule
and submittal deadlines.
00:22:29.520 --> 00:22:31.830
So on page four of the agreement,
00:22:31.830 --> 00:22:35.970
you'll see all the different
reports that, you know,
00:22:35.970 --> 00:22:38.920
you could submit to us and
there's kind of a blank next
00:22:38.920 --> 00:22:41.340
to them where you can type in a date
00:22:41.340 --> 00:22:43.190
of when you anticipate submitting it.
00:22:44.270 --> 00:22:46.430
If you don't have a date in mind,
00:22:46.430 --> 00:22:51.430
you can put to be
determined, that's totally fine.
00:22:51.600 --> 00:22:56.433
You know, we're not gonna
really go after you guys,
00:22:56.433 --> 00:22:58.850
if you know, it's a month later to
00:22:58.850 --> 00:23:02.120
or anything like that, just
kind of keep us in the loop
00:23:02.120 --> 00:23:03.490
of maybe why
00:23:05.002 --> 00:23:07.180
a report hasn't been submitted yet,
00:23:07.180 --> 00:23:10.323
and that it's, you know,
still coming eventually.
00:23:11.550 --> 00:23:12.463
And so,
00:23:14.280 --> 00:23:16.040
and then that also brings us to
00:23:16.040 --> 00:23:18.730
that's there's a list
of reports on this page
00:23:18.730 --> 00:23:22.570
of the agreement and
you're essentially determining
00:23:22.570 --> 00:23:25.430
what reports you're
going to submit to us
00:23:25.430 --> 00:23:27.330
based on site-specific information.
00:23:27.330 --> 00:23:28.720
So kind of like before,
00:23:28.720 --> 00:23:30.580
if you have groundwater contamination,
00:23:30.580 --> 00:23:35.460
then we would expect to have
groundwater monitoring reports
00:23:35.460 --> 00:23:38.050
submitted at some sort of frequency.
00:23:38.050 --> 00:23:39.920
So things like that, but again,
00:23:39.920 --> 00:23:42.383
the obligant is just
driving everything here.
00:23:45.670 --> 00:23:48.337
Okay, so certificate of completion,
00:23:48.337 --> 00:23:51.850
we will issue that once
00:23:51.850 --> 00:23:53.110
all recognized environmental
00:23:53.110 --> 00:23:55.750
conditions that are
identified in the phase one
00:23:56.830 --> 00:23:59.381
that are under the Railroad
Commission's jurisdiction
00:23:59.381 --> 00:24:01.580
have been assessed on the property
00:24:03.010 --> 00:24:07.010
that once the Commission
has kind of given you approval
00:24:07.010 --> 00:24:10.090
that no further action
is needed at the site,
00:24:10.090 --> 00:24:13.233
based on that closure
strategy that you chose.
00:24:14.540 --> 00:24:18.130
And the restrictive
covenant filed has been filed
00:24:18.130 --> 00:24:20.520
with the County as needed.
00:24:20.520 --> 00:24:22.837
So again, that's if you're going to have
00:24:22.837 --> 00:24:26.720
an Institute, a permanent
institutional control
00:24:26.720 --> 00:24:29.563
breeder land use for
groundwater or both as a site.
00:24:31.250 --> 00:24:32.440
And then we have to have
00:24:32.440 --> 00:24:34.770
the affidavit of completion submitted,
00:24:34.770 --> 00:24:36.523
and then as well as that property needs
00:24:36.523 --> 00:24:40.405
some balanced description.
00:24:40.405 --> 00:24:43.691
Okay, and then, so your,
a lot of people ask like
00:24:43.691 --> 00:24:46.442
what does the certificate
of completion look like?
00:24:46.442 --> 00:24:48.625
But actually the
certificate of completion
00:24:48.625 --> 00:24:50.440
is one single document,
00:24:50.440 --> 00:24:54.964
but you get this full
package when you get it.
00:24:54.964 --> 00:24:56.263
So you're going to get a cover letter
00:24:56.263 --> 00:24:58.041
that we also kind of refer to
00:24:58.041 --> 00:25:00.479
as the certificate of completion.
00:25:00.479 --> 00:25:04.374
And that cover letter will
detail the history of this site
00:25:04.374 --> 00:25:06.694
and then all the
environmental investigations
00:25:06.694 --> 00:25:09.767
or mediations that have occurred.
00:25:09.767 --> 00:25:11.617
And then you're going
to get a certificate,
00:25:11.617 --> 00:25:14.741
the actual certificate
of completion document.
00:25:14.741 --> 00:25:17.928
So that's going to encompass
that release of liability
00:25:17.928 --> 00:25:19.372
and I'll show you the language
00:25:19.372 --> 00:25:21.955
around the next slide for that.
00:25:22.888 --> 00:25:24.074
It's also, it's going to have a copy
00:25:24.074 --> 00:25:25.510
of that property metes
and bounds description
00:25:25.510 --> 00:25:27.010
affidavit of completion,
00:25:27.010 --> 00:25:30.110
and then a copy of
the restrictive covenant.
00:25:30.110 --> 00:25:33.140
And so with this certificate
of completion package,
00:25:33.140 --> 00:25:34.710
kind of the idea is that
00:25:36.020 --> 00:25:39.870
it encompasses almost
everything you need to know
00:25:39.870 --> 00:25:41.943
about that site all in one.
00:25:43.821 --> 00:25:45.440
And then if anyone, if that,
00:25:45.440 --> 00:25:47.330
if people want to dive into more detail,
00:25:47.330 --> 00:25:49.260
they can kind of go back
and look at the reports.
00:25:49.260 --> 00:25:50.190
But for the most part,
00:25:50.190 --> 00:25:52.491
you can get almost all
the information you need
00:25:52.491 --> 00:25:55.993
from this certificate
of completion package.
00:25:58.290 --> 00:26:01.633
So here is a certificate
of completion language.
00:26:02.650 --> 00:26:04.890
Hopefully you can read it.
00:26:04.890 --> 00:26:06.810
And I know that the
font is a little bit small,
00:26:06.810 --> 00:26:09.830
but the yellow
highlighted portion of this
00:26:09.830 --> 00:26:12.810
is really what I want
you guys to focus on.
00:26:12.810 --> 00:26:15.113
The reason why I'm putting it on here
00:26:15.113 --> 00:26:17.160
is to kind of showing what the language
00:26:17.160 --> 00:26:19.990
of that release of liability looks like.
00:26:19.990 --> 00:26:21.872
So here it says the
applicant is qualified
00:26:21.872 --> 00:26:25.532
to obtain the protection from liability
00:26:25.532 --> 00:26:28.480
provided by Chapter 91 Subchapter O,
00:26:28.480 --> 00:26:30.083
Texas natural resources code.
00:26:31.260 --> 00:26:34.650
So that is that language that
00:26:34.650 --> 00:26:37.173
that is going to be
that release of liability.
00:26:40.590 --> 00:26:41.550
So oversight costs.
00:26:41.550 --> 00:26:43.800
So again, as I told you,
00:26:43.800 --> 00:26:45.603
this is a program you pay to be in.
00:26:46.550 --> 00:26:49.453
As I mentioned, you have
an application fee of $1,000
00:26:50.410 --> 00:26:53.483
and that $1,000 is going to
be credited to your account.
00:26:54.810 --> 00:26:57.890
The oversight costs are $80 an hour.
00:26:57.890 --> 00:27:00.930
And so we're going to
begin drawing that against
00:27:00.930 --> 00:27:04.660
the initial $1,000
until that is exhausted.
00:27:04.660 --> 00:27:08.633
And so that amounts to about
to 12.5 hours of oversight.
00:27:09.470 --> 00:27:13.010
And so once we've exhausted
that 12.5 hours of oversight,
00:27:13.010 --> 00:27:16.500
and also exhausted that $1,000,
00:27:16.500 --> 00:27:19.970
we will start invoicing you
for any additional oversight
00:27:20.910 --> 00:27:23.963
needed for the project
until it's completed.
00:27:29.580 --> 00:27:31.830
So I just want to kind of
show you this on average
00:27:31.830 --> 00:27:34.890
since we get a lot of questions about
00:27:34.890 --> 00:27:36.630
how long does it take for a site to then
00:27:36.630 --> 00:27:38.930
go through the program?
00:27:38.930 --> 00:27:41.520
How much additional
costs should, you know,
00:27:41.520 --> 00:27:46.520
someone expect outside of
the application in surcharge?
00:27:46.550 --> 00:27:50.210
So typically, about
28 hours of oversight
00:27:50.210 --> 00:27:51.723
is spent on each site.
00:27:52.620 --> 00:27:56.360
Sites are enrolled in the
program for about three years
00:27:56.360 --> 00:28:00.460
and then typically applicants
pay an additional $1,300
00:28:00.460 --> 00:28:02.330
on oversight costs.
00:28:02.330 --> 00:28:04.810
And I also just want to point out,
00:28:04.810 --> 00:28:06.490
cause this might seem like an extreme,
00:28:06.490 --> 00:28:09.960
we have one site that has
been in our program for 14 years.
00:28:09.960 --> 00:28:12.050
I think that is
definitely it's an outlier
00:28:12.050 --> 00:28:16.120
that site has exchanged
property owners numerous times.
00:28:16.120 --> 00:28:19.313
And when that happens,
kind of slows down the process,
00:28:20.770 --> 00:28:22.610
you know, the new property owner
00:28:22.610 --> 00:28:23.940
has to kind of get up to speed.
00:28:23.940 --> 00:28:25.710
They might want a new environmental firm
00:28:25.710 --> 00:28:27.550
to come in and do the work.
00:28:27.550 --> 00:28:29.060
So a lot of things,
00:28:29.060 --> 00:28:33.740
so kind of changing property
owners during the process
00:28:33.740 --> 00:28:35.190
can definitely slow it down.
00:28:35.190 --> 00:28:37.723
And that's sort of what's
occurred at this site.
00:28:40.510 --> 00:28:43.100
Okay, so we're gonna
go through some examples
00:28:43.100 --> 00:28:44.340
of some VCP sites
00:28:44.340 --> 00:28:47.220
so you guys kind of get an
idea of different scenarios
00:28:47.220 --> 00:28:48.200
that you can have.
00:28:50.730 --> 00:28:54.560
Okay, so this
is a fairly recent,
00:28:54.560 --> 00:28:57.343
I guess I'll call it
graduate of the program.
00:28:58.780 --> 00:28:59.660
So this is
00:29:00.870 --> 00:29:03.630
so New Apartments in Houston.
00:29:03.630 --> 00:29:06.530
So the property in the phase one,
00:29:06.530 --> 00:29:09.200
they did not identify any
actual oil and gas wells
00:29:09.200 --> 00:29:10.270
on the property,
00:29:10.270 --> 00:29:12.800
but there was a tank
battery on the property
00:29:12.800 --> 00:29:16.000
from 1983 to 1995.
00:29:16.000 --> 00:29:18.156
So that required some investigation
00:29:18.156 --> 00:29:20.940
and they did soil investigations
00:29:21.780 --> 00:29:25.530
as well as installed some
groundwater monitoring wells.
00:29:25.530 --> 00:29:29.283
There was groundwater
contamination out at the site.
00:29:30.390 --> 00:29:32.840
I think there was either four or five
00:29:32.840 --> 00:29:35.133
sampling events on the property.
00:29:36.130 --> 00:29:39.530
And at that point, after
the last sampling of it,
00:29:39.530 --> 00:29:41.760
it was determined groundwater conditions
00:29:41.760 --> 00:29:44.523
were stable and declining.
00:29:44.523 --> 00:29:47.140
So based on that, the
Railroad Commission approved
00:29:47.140 --> 00:29:50.453
of placing restrictive
covenant on the property.
00:29:52.026 --> 00:29:53.630
And so that was done
and they were issued
00:29:53.630 --> 00:29:55.250
a certificate of completion.
00:29:55.250 --> 00:29:58.080
This site was only on the
voluntary cleanup program
00:29:58.080 --> 00:29:59.293
for 12 months.
00:30:00.430 --> 00:30:02.609
And I think it's
important to note for this
00:30:02.609 --> 00:30:04.930
that there was a lot of
work that was done up front
00:30:04.930 --> 00:30:07.900
before they actually
submitted the application.
00:30:07.900 --> 00:30:10.300
So the phase one, phase two,
00:30:10.300 --> 00:30:12.480
I think even a limited
site investigation
00:30:12.480 --> 00:30:15.020
and a groundwater monitoring report
00:30:15.020 --> 00:30:19.393
were all generated and
submitted with the application.
00:30:20.350 --> 00:30:23.288
So we had all of that
to sort of work off of
00:30:23.288 --> 00:30:25.793
as soon as they entered the program.
00:30:28.290 --> 00:30:32.280
So another really
interesting example is the
00:30:32.280 --> 00:30:33.870
Walmart in Kilgore.
00:30:34.740 --> 00:30:36.140
So this one I think
is really interesting
00:30:36.140 --> 00:30:38.840
because Walmart actually worked
00:30:38.840 --> 00:30:42.920
with a previous oil and
gas operator of this site
00:30:42.920 --> 00:30:45.500
to plug the eight wells.
00:30:45.500 --> 00:30:47.680
They were actually,
they were shut in wells
00:30:49.050 --> 00:30:50.443
or somewhat abandoned,
00:30:51.460 --> 00:30:55.680
but Walmart actually had
them come out, plug the wells
00:30:55.680 --> 00:30:59.340
and I believe that the
operators actually could pay
00:30:59.340 --> 00:31:01.140
for the plugging operations as well.
00:31:03.000 --> 00:31:05.430
And so that took care of
00:31:06.270 --> 00:31:08.410
that kind of immediate risk.
00:31:08.410 --> 00:31:12.190
And then they ended up
doing some soil sampling
00:31:12.190 --> 00:31:14.350
around the tank battery,
00:31:14.350 --> 00:31:18.490
and in that tank battery
there was some TPH content
00:31:18.490 --> 00:31:21.710
or petroleum contaminated soils.
00:31:21.710 --> 00:31:24.903
And so they ended
up excavating that area.
00:31:25.880 --> 00:31:30.880
And this site within our
program for close to three years,
00:31:31.970 --> 00:31:33.593
between 2002 and 2005.
00:31:38.180 --> 00:31:39.990
So here we have on the left,
00:31:39.990 --> 00:31:42.370
an image of that tank battery
00:31:42.370 --> 00:31:45.860
that had some soil
contamination around it.
00:31:45.860 --> 00:31:49.200
And then on the right, we have a view,
00:31:49.200 --> 00:31:52.320
this is from the soon-to-be
00:31:52.320 --> 00:31:55.433
or what now what now
is the Walmart parking lot.
00:31:56.474 --> 00:31:57.774
And we have that drill rig
00:31:59.290 --> 00:32:03.653
out there plugging one of
the wells on the property.
00:32:07.940 --> 00:32:10.050
So this one I really
wanted it around here
00:32:10.050 --> 00:32:13.223
because we seem to be getting
more and more of these sites.
00:32:14.767 --> 00:32:17.100
And I really want to highlight that
00:32:17.100 --> 00:32:18.920
this is definitely a possibility
00:32:18.920 --> 00:32:20.580
especially for any operators
00:32:20.580 --> 00:32:22.380
who might be listening in right now.
00:32:23.340 --> 00:32:26.333
So this is a site, it's
an oil and gas lease.
00:32:27.270 --> 00:32:30.145
And 11 tanks were struck by lightning.
00:32:30.145 --> 00:32:31.830
This is pretty recently,
00:32:31.830 --> 00:32:33.650
I think it was within the past year,
00:32:33.650 --> 00:32:38.650
and these tanks released
an unknown amount of product
00:32:38.680 --> 00:32:43.423
and the operator at the
time of the lightning strike
00:32:43.423 --> 00:32:47.340
would have needed to do
all of the response options
00:32:47.340 --> 00:32:50.050
for the Railway Commission's rules
00:32:50.050 --> 00:32:54.890
actually ended up selling
that lease to another operator.
00:32:54.890 --> 00:32:58.540
And because that new
operator was not the operator
00:32:58.540 --> 00:32:59.790
of the timing of the lightning strike,
00:32:59.790 --> 00:33:01.450
they did not cause or contribute
00:33:01.450 --> 00:33:03.363
to any contamination at the site.
00:33:04.360 --> 00:33:06.670
They were actually able to enter
00:33:06.670 --> 00:33:08.323
the voluntary cleanup program.
00:33:09.270 --> 00:33:10.240
And when this happens,
00:33:10.240 --> 00:33:13.613
when we have an operator
taking over a lease that
00:33:14.870 --> 00:33:17.890
has or has the potential
to have contamination,
00:33:17.890 --> 00:33:20.500
it's really important
as the new operator
00:33:20.500 --> 00:33:24.440
to get that phase one
for the entire property
00:33:25.430 --> 00:33:28.030
before you start any operations.
00:33:28.030 --> 00:33:29.800
So then you can clearly define
00:33:31.985 --> 00:33:35.526
what contamination
might be at the property
00:33:35.526 --> 00:33:39.220
before you started your operations
00:33:39.220 --> 00:33:42.680
so that you can very easily
get that release of liability.
00:33:42.680 --> 00:33:45.603
And so work at this site is ongoing,
00:33:46.610 --> 00:33:48.730
but the applicant, again,
that current operator,
00:33:48.730 --> 00:33:52.580
they're gonna receive a
release of liability from the state
00:33:52.580 --> 00:33:53.863
for this release.
00:33:54.849 --> 00:33:57.820
But I think it's really
important to note also
00:33:57.820 --> 00:34:01.220
for this site that the
00:34:01.220 --> 00:34:04.390
operator, the current
operator who's in VCP,
00:34:04.390 --> 00:34:06.730
if in the future after
they've successfully
00:34:06.730 --> 00:34:08.640
completed this program,
00:34:08.640 --> 00:34:11.710
if they have any subsequent releases
00:34:11.710 --> 00:34:13.570
after they've completed our program,
00:34:13.570 --> 00:34:15.710
they're not eligible for VCP.
00:34:15.710 --> 00:34:18.590
Then they would have to go
into the operator cleanup program
00:34:18.590 --> 00:34:22.673
at that point because they
would be a responsible party.
00:34:26.663 --> 00:34:30.313
Okay, so dual enrollment
and VCP and OCP.
00:34:31.163 --> 00:34:33.540
So OCP is our operator cleanup program.
00:34:33.540 --> 00:34:35.860
So this is a really
good example of that.
00:34:37.010 --> 00:34:38.763
I believe it was in 2013,
00:34:40.113 --> 00:34:43.410
a 16-inch transmission
pipeline released 700 barrels
00:34:43.410 --> 00:34:46.450
of crude into the Vince Bayou.
00:34:46.450 --> 00:34:49.390
I think this is in Pasadena, Texas.
00:34:49.390 --> 00:34:50.590
So Shell pipeline,
00:34:50.590 --> 00:34:54.150
it was the operator of
that transmission pipeline.
00:34:54.150 --> 00:34:57.310
And they performed all of the
immediate response actions
00:34:57.310 --> 00:35:00.310
and all of the cleanup
and investigation work.
00:35:00.310 --> 00:35:03.210
And they immediately entered
the operator cleanup program,
00:35:04.170 --> 00:35:08.250
but CenterPoint Energy Houston Electric
00:35:08.250 --> 00:35:09.520
was the property owner of
00:35:11.130 --> 00:35:13.730
that right of way.
00:35:13.730 --> 00:35:16.000
And so as the property owner,
00:35:16.000 --> 00:35:19.180
they entered the
voluntary cleanup program.
00:35:19.180 --> 00:35:21.380
So the operator, Shell pipeline,
00:35:21.380 --> 00:35:24.120
they're actually the ones
performing all the investigation
00:35:24.120 --> 00:35:26.683
or remediation work under OCP.
00:35:27.560 --> 00:35:31.150
But once this is all completed
00:35:31.150 --> 00:35:34.800
since CenterPoint is also in VCP,
00:35:34.800 --> 00:35:37.350
they're going to receive
a release of liability.
00:35:37.350 --> 00:35:40.260
So CenterPoint receives
a release of liability
00:35:40.260 --> 00:35:42.080
and then Shell will receive
00:35:42.080 --> 00:35:45.840
a no further action letter through OCP.
00:35:45.840 --> 00:35:48.650
So that can happen where, you know,
00:35:48.650 --> 00:35:50.460
if you can, as a property owner,
00:35:50.460 --> 00:35:52.690
have leveraged that there is an operator
00:35:52.690 --> 00:35:54.770
on your property and they have a release
00:35:54.770 --> 00:35:57.150
and they entered the
operator cleanup program,
00:35:57.150 --> 00:35:59.980
you can also request that they enter you
00:35:59.980 --> 00:36:02.900
as the property owner into VCP,
00:36:02.900 --> 00:36:04.980
and then you can kind of
work out amongst yourselves,
00:36:04.980 --> 00:36:06.793
how to pay for that and everything.
00:36:07.890 --> 00:36:09.757
But then you as a property owner
00:36:09.757 --> 00:36:12.140
will get a release
of liability at the end.
00:36:12.140 --> 00:36:15.450
So that can also be really powerful
00:36:15.450 --> 00:36:17.870
to kind of maybe help restore
00:36:19.190 --> 00:36:21.790
your property after that occurs
00:36:21.790 --> 00:36:25.460
not only from a
contamination standpoint,
00:36:25.460 --> 00:36:28.503
but from kind of a
real estate standpoint.
00:36:32.342 --> 00:36:35.010
Okay, so that's sort of, well,
00:36:35.010 --> 00:36:38.858
we have to discuss about
the voluntary cleanup program.
00:36:38.858 --> 00:36:40.190
And so I kind of want
to change gears a bit
00:36:40.190 --> 00:36:42.130
and dive a little bit deeper
00:36:42.130 --> 00:36:44.700
into some of the stuff we
talked about yesterday,
00:36:44.700 --> 00:36:47.230
which was funding available
00:36:47.230 --> 00:36:49.030
to the state managed cleanup program
00:36:49.030 --> 00:36:51.620
and the state funded cleanup program.
00:36:51.620 --> 00:36:54.803
And these are funds available
to the Brownfields program.
00:36:58.410 --> 00:37:00.650
Okay, so a little bit of history,
00:37:00.650 --> 00:37:03.200
the oil field cleanup fund,
00:37:03.200 --> 00:37:08.200
which was referred to as
OCU was created in 1991
00:37:08.300 --> 00:37:11.270
through Senate bill 1103.
00:37:11.270 --> 00:37:14.040
And the idea of this fund was
00:37:14.040 --> 00:37:18.760
to basically finance plugging
orphaned wells in Texas,
00:37:18.760 --> 00:37:21.673
as well as clean up
abandoned oil and gas sites.
00:37:23.094 --> 00:37:23.927
So when it was created,
00:37:23.927 --> 00:37:26.920
there was a 10 million unbalanced cap
00:37:28.100 --> 00:37:31.390
from Railroad Commission
penalties, fines, production fees,
00:37:31.390 --> 00:37:34.683
and application fees that
we place on operators.
00:37:36.783 --> 00:37:40.850
And so that was a huge
success when it first started.
00:37:40.850 --> 00:37:44.430
And so the Commission
started looking at ways
00:37:44.430 --> 00:37:47.050
to add this to its fund.
00:37:47.050 --> 00:37:50.083
And then in 2001 was Senate bill 310,
00:37:51.494 --> 00:37:54.170
the Commission created
universal bonding of operators
00:37:55.532 --> 00:37:58.000
and then some oil and gas
production fees increased.
00:37:58.000 --> 00:38:01.310
So that fund balance
00:38:01.310 --> 00:38:06.083
cap for OFC U increased
from $10 million to $20 million.
00:38:12.000 --> 00:38:13.660
Okay.
00:38:13.660 --> 00:38:17.910
And so then some other changes
occurred in 2011 and 2013.
00:38:19.950 --> 00:38:24.290
The oil spill cleanup fund
became the oil and gas regulation
00:38:24.290 --> 00:38:25.640
and cleanup fund.
00:38:25.640 --> 00:38:26.990
And so got a name change
00:38:28.484 --> 00:38:30.330
and that fund balance cap increased
00:38:30.330 --> 00:38:33.340
from 29 million to 30 million.
00:38:33.340 --> 00:38:35.880
Thanks to the introduction oF surcharges
00:38:36.970 --> 00:38:39.730
to various fees within the Commission,
00:38:39.730 --> 00:38:42.893
such as billing permit fees
that boost the application fee.
00:38:44.220 --> 00:38:49.310
And then also by, and
I think that was in 2013,
00:38:49.310 --> 00:38:51.520
the groundwater advisory unit moved
00:38:51.520 --> 00:38:54.060
from the Texas Commission
on environmental quality
00:38:54.060 --> 00:38:55.160
to the Railroad Commission.
00:38:55.160 --> 00:38:58.490
And we started issuing
groundwater determination letters,
00:38:58.490 --> 00:38:59.590
which also have a fee.
00:39:04.331 --> 00:39:05.164
Okay.
00:39:05.164 --> 00:39:06.580
So we're kind of going to go through
00:39:06.580 --> 00:39:09.240
what exactly these programs do.
00:39:09.240 --> 00:39:10.740
And then afterwards,
00:39:10.740 --> 00:39:13.823
we'll kind of talk about
how they're required
00:39:13.823 --> 00:39:15.693
to fund these brownfield sites.
00:39:17.400 --> 00:39:19.080
So these funds are used to assess
00:39:19.080 --> 00:39:21.800
and remediate contaminated sites.
00:39:21.800 --> 00:39:24.570
So, and these are
contaminated sites
00:39:24.570 --> 00:39:26.360
under the Railroad
Commission's jurisdiction.
00:39:26.360 --> 00:39:28.400
So that's kind of a
lot of different sites,
00:39:28.400 --> 00:39:32.260
but it includes so P-4
leases, disposal facilities,
00:39:32.260 --> 00:39:33.863
tank batteries, well heads,
00:39:34.800 --> 00:39:38.400
just, you know, several other things.
00:39:38.400 --> 00:39:39.233
And
00:39:40.480 --> 00:39:42.320
the point of the program
00:39:42.320 --> 00:39:44.980
is to inform environmental
investigations
00:39:44.980 --> 00:39:47.410
of these facilities
00:39:47.410 --> 00:39:51.530
by using professional
services such as, you know,
00:39:51.530 --> 00:39:55.090
doing geologic assessments,
water well samplings,
00:39:55.090 --> 00:39:56.843
then brownfield site assessments,
00:39:57.750 --> 00:39:59.843
remediation system designs.
00:40:00.870 --> 00:40:04.290
So the main point is to perform these
00:40:04.290 --> 00:40:06.440
environmental
investigations to hopefully,
00:40:06.440 --> 00:40:09.310
you know, to address these sites
00:40:09.310 --> 00:40:12.320
that have some sort of
potential contamination
00:40:12.320 --> 00:40:13.443
associated with them.
00:40:14.640 --> 00:40:19.080
So these funds can be used
when the responsible operator
00:40:19.080 --> 00:40:20.990
is unknown or cannot be found.
00:40:20.990 --> 00:40:23.540
So that's what we're kind
of defining as abandoned.
00:40:24.470 --> 00:40:25.990
But these ones are also kind of used
00:40:25.990 --> 00:40:29.310
in emergency situations sometimes,
00:40:29.310 --> 00:40:32.060
or when an operator fails
00:40:32.060 --> 00:40:34.603
or refuses to take any action.
00:40:36.100 --> 00:40:38.035
So a lot of times we
might have an operator
00:40:38.035 --> 00:40:41.040
is for a long time and actively engaged
00:40:41.040 --> 00:40:43.050
in operator cleanup program.
00:40:43.050 --> 00:40:44.850
But at some point, you know,
00:40:44.850 --> 00:40:48.670
they refuse to continue in the program.
00:40:48.670 --> 00:40:49.773
And in that case,
00:40:50.670 --> 00:40:53.110
the state managed
cleanup program will step in.
00:40:53.110 --> 00:40:55.900
However, when doing that,
00:40:55.900 --> 00:41:00.163
we are able to seek
reimbursement from that operator.
00:41:03.630 --> 00:41:05.513
So the state funded plugging program.
00:41:06.610 --> 00:41:09.820
So these funds are used
for pollution abatement
00:41:09.820 --> 00:41:11.610
or well plugging.
00:41:11.610 --> 00:41:15.050
So this is going to be when
we have a well that's abandoned
00:41:15.050 --> 00:41:17.480
or what we refer to as orphaned
00:41:17.480 --> 00:41:19.653
by say, a delinquent operator.
00:41:20.800 --> 00:41:23.230
If we find a well in the field
00:41:23.230 --> 00:41:26.380
that has never been
identified, might not be mapped,
00:41:26.380 --> 00:41:29.630
we have no idea who owns it.
00:41:29.630 --> 00:41:34.100
So we would use state
managed plugging funds for that,
00:41:34.100 --> 00:41:37.880
and then also for when
a well is actively leaking
00:41:37.880 --> 00:41:39.320
or likely to leak.
00:41:39.320 --> 00:41:42.113
And that leak is
serious enough to threat,
00:41:44.410 --> 00:41:47.260
to have a threat of pollution
or injury to public health,
00:41:48.280 --> 00:41:51.923
that responsible operator is
unknown or cannot be found,
00:41:52.760 --> 00:41:55.590
or that operator again is failing
00:41:55.590 --> 00:41:57.403
or refusing to take action.
00:42:00.770 --> 00:42:05.250
So a really important
note here is that the,
00:42:05.250 --> 00:42:07.860
these funds are not available
00:42:08.890 --> 00:42:11.240
to VCP applicants.
00:42:11.240 --> 00:42:12.890
However,
00:42:12.890 --> 00:42:16.340
if you are a VCP applicant
and decide to withdraw
00:42:16.340 --> 00:42:19.820
from the program or
terminate your agreement,
00:42:19.820 --> 00:42:22.860
we may end up using these funds
00:42:22.860 --> 00:42:25.950
to complete any needed cleanup
00:42:25.950 --> 00:42:29.350
if we can not identify
a responsible party.
00:42:29.350 --> 00:42:31.910
Now, on the other hand,
if you're a VCP applicant,
00:42:31.910 --> 00:42:34.140
you withdraw or
terminate your agreement,
00:42:34.140 --> 00:42:35.060
which you're allowed to do
00:42:35.060 --> 00:42:38.663
because it is a voluntary
cleanup program.
00:42:39.600 --> 00:42:43.540
And let's say we can
find the responsible party
00:42:43.540 --> 00:42:46.080
and you maybe you as an applicant
00:42:46.080 --> 00:42:47.920
knew the responsible
party but just decided
00:42:47.920 --> 00:42:49.870
to take it on on your own,
00:42:49.870 --> 00:42:51.630
we would probably
reach out to that operator
00:42:51.630 --> 00:42:56.630
to then take over kind of
where the applicant left off
00:42:56.630 --> 00:42:59.623
and enroll in the
operator cleanup program.
00:43:03.280 --> 00:43:07.080
So some examples of some
sites that have been used for,
00:43:07.080 --> 00:43:09.680
or that have used all
three funding sources,
00:43:09.680 --> 00:43:12.080
some of them we talked about yesterday,
00:43:12.080 --> 00:43:14.130
but there's a couple
of new ones in here.
00:43:16.100 --> 00:43:19.260
Okay, so the city of
Andrews Bird Viewing Park.
00:43:19.260 --> 00:43:21.150
For anyone who didn't
listen in yesterday,
00:43:21.150 --> 00:43:24.833
this is kind of in the
West to the city of Midland.
00:43:26.000 --> 00:43:28.990
But this site was in our program
00:43:28.990 --> 00:43:32.870
and the Brownfields
program from 2004 to 2006.
00:43:32.870 --> 00:43:37.280
And we used about
$30,000 of Brownfields funds
00:43:37.280 --> 00:43:40.280
to do assessment and cleanup work.
00:43:40.280 --> 00:43:44.147
And then we also used about $75,000
00:43:44.147 --> 00:43:46.970
of our state managed cleanup funds
00:43:46.970 --> 00:43:49.053
to do the cleanup at this site.
00:43:50.883 --> 00:43:53.750
And Art can correct me if I'm
wrong once we get to the end,
00:43:53.750 --> 00:43:56.110
but the Brownfields funds in this case,
00:43:56.110 --> 00:43:58.160
were used mostly for the assessment.
00:43:58.160 --> 00:44:00.250
And then the actual all
the cleanup work we did
00:44:00.250 --> 00:44:05.000
at this site was paid
for by state managed.
00:44:05.000 --> 00:44:08.510
And there was a salt
water disposal pit in the
00:44:08.510 --> 00:44:10.370
at the site with some product in it,
00:44:10.370 --> 00:44:14.140
as well as five leaking wooden tanks.
00:44:14.140 --> 00:44:17.890
So that helped kind of
that state managed funds
00:44:17.890 --> 00:44:20.430
helped the disposal of any product
00:44:20.430 --> 00:44:23.250
and the tanks and the
salt water disposal pit,
00:44:23.250 --> 00:44:28.593
and all that well excavation
that was required.
00:44:31.670 --> 00:44:35.150
So another example which
we kind of touched on yesterday
00:44:35.150 --> 00:44:38.443
is the Neuces County Water
quality improvement project.
00:44:40.391 --> 00:44:42.630
So between 2015 and today,
00:44:42.630 --> 00:44:45.480
so the site is still enrolled
in our Brownfields program.
00:44:46.820 --> 00:44:50.160
We've used almost
$100,000 of Brownfields funds
00:44:51.030 --> 00:44:55.650
and we've used almost $10,000
of our state managed funds
00:44:55.650 --> 00:44:56.583
at this site.
00:45:01.090 --> 00:45:02.398
Okay.
00:45:02.398 --> 00:45:04.340
And then, so Turtle
Bayou Nature Preserve,
00:45:04.340 --> 00:45:06.210
though this site is also still enrolled,
00:45:06.210 --> 00:45:10.513
but between 2010 and current,
00:45:12.030 --> 00:45:14.000
the brownfield funds have,
00:45:14.000 --> 00:45:17.870
we've spent about a little over $190,000
00:45:17.870 --> 00:45:21.873
of Brownfields funds for both
assessments and cleanups.
00:45:22.860 --> 00:45:25.450
The state managed
group has also contributed
00:45:25.450 --> 00:45:28.270
about $50,000 for this site
00:45:28.270 --> 00:45:30.530
when there was times
where the Brownfields funds
00:45:30.530 --> 00:45:31.430
couldn't cover it.
00:45:33.082 --> 00:45:35.868
And then the state
funded plugging program
00:45:35.868 --> 00:45:39.050
has spent almost $500,000
00:45:39.050 --> 00:45:43.160
at this site because there
are about eight abandoned,
00:45:43.160 --> 00:45:45.760
there's a total of eight
abandoned oil and gas wells
00:45:46.761 --> 00:45:49.540
that we see on the left hand in the top,
00:45:49.540 --> 00:45:53.160
there's a picture of one of the
wellheads that's abandoned.
00:45:53.160 --> 00:45:58.230
We have that almost
$500,000 was used to plug.
00:45:58.230 --> 00:46:00.420
Six of the eight
will still wait in line.
00:46:00.420 --> 00:46:05.060
Two more of the wells
to be plugged at this site.
00:46:05.060 --> 00:46:07.040
But again, all of that's
going to be paid for
00:46:07.040 --> 00:46:09.080
out of state funded plugging,
00:46:09.080 --> 00:46:10.310
which is also a great
00:46:12.210 --> 00:46:15.060
fund to have available
because many of these,
00:46:15.060 --> 00:46:17.310
if we didn't have that
available and the applicant
00:46:17.310 --> 00:46:19.180
would have to pay for that,
00:46:19.180 --> 00:46:22.020
we would have so many
sites that we just aren't able
00:46:23.250 --> 00:46:26.900
to take on or remediate
and bring back to sort of life
00:46:26.900 --> 00:46:27.733
because of that.
00:46:27.733 --> 00:46:31.700
So the state funded plugging funds is a,
00:46:31.700 --> 00:46:35.900
it's a really great funding source,
00:46:35.900 --> 00:46:39.420
and we can really tackle
some of these sites where,
00:46:39.420 --> 00:46:42.160
you know, it might
cost a lot to deal with
00:46:42.160 --> 00:46:43.823
the hazards associated with it.
00:46:47.010 --> 00:46:49.180
And so our last example is going to be
00:46:49.180 --> 00:46:51.350
the Jones State forest.
00:46:51.350 --> 00:46:54.240
So this site was enrolled
in the Brownfields program
00:46:54.240 --> 00:46:56.713
between 2006 and 2009.
00:46:57.780 --> 00:47:02.780
And we used almost
$150,000 of Brownfields funds
00:47:02.809 --> 00:47:05.600
to do the assessments and cleanups,
00:47:05.600 --> 00:47:07.670
and then state managed also stepped in
00:47:07.670 --> 00:47:09.830
with almost $12,000 of funds
00:47:09.830 --> 00:47:12.463
as well to do some more cleanup work.
00:47:13.450 --> 00:47:17.240
And then I believe
there were, there was one
00:47:19.590 --> 00:47:21.740
abandoned well at this site.
00:47:21.740 --> 00:47:25.723
And so the state funded
plugging program was able to,
00:47:27.460 --> 00:47:30.180
we were able to tap into about $50,000
00:47:30.180 --> 00:47:32.270
to close that well as well.
00:47:32.270 --> 00:47:36.810
So again, all of these resources
00:47:36.810 --> 00:47:39.470
are available to Brownfield's applicants
00:47:39.470 --> 00:47:40.440
and they can really
00:47:43.262 --> 00:47:45.050
help us as in the Brownfields
00:47:45.050 --> 00:47:46.533
to take on even bigger sites.
00:47:48.035 --> 00:47:51.073
And that had a lot of potential
costs associated with them.
00:47:53.220 --> 00:47:54.520
All right.
00:47:54.520 --> 00:47:59.270
So based on that, we're
going to open it up to questions.
00:47:59.270 --> 00:48:00.350
And so
00:48:01.440 --> 00:48:05.670
let me real quick, I
need to take a second to,
00:48:05.670 --> 00:48:08.970
since Peter's not able to join us today,
00:48:08.970 --> 00:48:11.090
pull up the email on...
00:48:16.658 --> 00:48:20.075
Let's see what kind
of questions we have.
00:48:28.920 --> 00:48:30.953
All right, let's see.
00:48:42.816 --> 00:48:46.680
So it currently looks like we
do not have any questions.
00:48:46.680 --> 00:48:50.240
I'd just like to open
it up to Keith and Art
00:48:50.240 --> 00:48:52.820
to see if you guys would
like to add anything else
00:48:52.820 --> 00:48:54.673
to this presentation.
00:48:55.830 --> 00:48:58.929
Anything you can add about
your two different programs
00:48:58.929 --> 00:49:00.279
that maybe we didn't cover.
00:49:04.830 --> 00:49:06.540
Yeah, this is Art, no,
00:49:06.540 --> 00:49:09.750
you did a very good job of
00:49:09.750 --> 00:49:12.917
presenting the state managed
plugging program anyway.
00:49:13.840 --> 00:49:16.740
But if anybody has
questions about the program,
00:49:16.740 --> 00:49:20.993
feel free to call me or
send me an email or,
00:49:22.840 --> 00:49:25.050
or respond to this webinar.
00:49:25.050 --> 00:49:25.883
Thank you.
00:49:28.120 --> 00:49:29.470
Yeah, thank you Art.
00:49:29.470 --> 00:49:31.290
Yeah if anyone,
00:49:31.290 --> 00:49:33.810
well, Keith, do you want
to say anything additional?
00:49:33.810 --> 00:49:35.983
Yeah, I was just
going to add real quick.
00:49:36.980 --> 00:49:40.490
You don't get calls about
wells on their property
00:49:40.490 --> 00:49:42.190
and trying to get unplugged.
00:49:42.190 --> 00:49:43.023
So
00:49:43.860 --> 00:49:46.660
we have like a ranking system
on how we plug these wells
00:49:46.660 --> 00:49:47.893
based on like the risks,
00:49:48.920 --> 00:49:50.240
you know, if we think
they're going to leak
00:49:50.240 --> 00:49:52.703
or if they seem like
they're pretty safe for now,
00:49:52.703 --> 00:49:54.000
we'll kind of hold off on them.
00:49:54.000 --> 00:49:55.760
The reason being is we have a population
00:49:55.760 --> 00:49:58.010
of like over 6,000 orphan wells.
00:49:58.010 --> 00:50:01.173
So we have to, you know,
00:50:02.250 --> 00:50:03.680
prioritize which ones
we want to go after.
00:50:03.680 --> 00:50:06.680
We can't just plug every
single well, you know,
00:50:06.680 --> 00:50:09.340
today you have to
kind of plan them out so.
00:50:09.340 --> 00:50:11.450
And then if you have a
leaking well on your property
00:50:11.450 --> 00:50:12.840
or something that's,
you're concerned with,
00:50:12.840 --> 00:50:14.870
you can always call your district office
00:50:14.870 --> 00:50:17.400
and have it inspected
and see if that's something
00:50:17.400 --> 00:50:19.250
state managed plugging can help with.
00:50:21.290 --> 00:50:22.840
Yeah, that's all I want to add.
00:50:23.700 --> 00:50:25.470
Awesome, yeah, I
think Keith that you bring up
00:50:25.470 --> 00:50:26.720
a really good point about
00:50:28.330 --> 00:50:31.740
sort of, kind of a
priority list of these wells
00:50:31.740 --> 00:50:32.830
that need to be unplugged.
00:50:32.830 --> 00:50:36.680
So the state managed group,
as well as kind of Brownfields,
00:50:36.680 --> 00:50:40.060
we have sort of a priority list of sites
00:50:40.060 --> 00:50:41.670
that we need to get to.
00:50:41.670 --> 00:50:43.340
Currently at Brownfields
we do have a little bit
00:50:43.340 --> 00:50:46.220
of a backlog that we're catching up with
00:50:46.220 --> 00:50:48.000
and taking care of those sites.
00:50:48.000 --> 00:50:50.243
We are still accepting applicants,
00:50:51.290 --> 00:50:54.163
but for state managed
Art you can elaborate more,
00:50:55.340 --> 00:50:57.270
there is a priority list.
00:50:57.270 --> 00:51:00.215
And each year we kind of
look through that priority list
00:51:00.215 --> 00:51:04.200
and find the sites that
we need to address
00:51:04.200 --> 00:51:06.803
with the money that
we currently are allotted.
00:51:07.680 --> 00:51:12.680
And that's kind of based on,
you know, risk to human health,
00:51:13.140 --> 00:51:15.053
risks to environment,
00:51:16.480 --> 00:51:18.320
as well as some other factors.
00:51:18.320 --> 00:51:21.863
Do you want to elaborate
on that a little bit more Art?
00:51:21.863 --> 00:51:23.670
Sure.
00:51:23.670 --> 00:51:25.570
So we do have a ranking system as well,
00:51:25.570 --> 00:51:29.370
and we rank our sites A, B and C.
00:51:29.370 --> 00:51:33.128
We, once we identify a
site that's going to become
00:51:33.128 --> 00:51:35.363
a candidate,
00:51:36.603 --> 00:51:37.960
we go on and do
00:51:37.960 --> 00:51:42.009
an internal assessment
and we determine, you know,
00:51:42.009 --> 00:51:44.783
the ranking at that point,
00:51:46.180 --> 00:51:49.950
we typically address A and B sites.
00:51:49.950 --> 00:51:54.450
If there's a seaside nearby
and they're in or near B,
00:51:54.450 --> 00:51:57.870
we'll clean that up as
well while we're there,
00:51:57.870 --> 00:52:00.050
save some over demo cost.
00:52:00.050 --> 00:52:04.233
Otherwise, I think if I have other
00:52:06.990 --> 00:52:11.620
other comments from you
Leslie, I can answer them.
00:52:11.620 --> 00:52:13.680
Okay, awesome.
00:52:13.680 --> 00:52:16.660
Well, I think that's
pretty much everything.
00:52:16.660 --> 00:52:17.970
I'm sure there's probably a little bit,
00:52:17.970 --> 00:52:20.760
there's, I definitely think
there's more questions
00:52:20.760 --> 00:52:25.220
for VCP that people might think of
00:52:25.220 --> 00:52:28.610
after they've watched
the video or webinar,
00:52:28.610 --> 00:52:31.930
but feel free to reach out to any of us
00:52:31.930 --> 00:52:36.493
as you're watching or any
questions you have about VCP.
00:52:37.880 --> 00:52:41.120
Feel free to reach out about
operator cleanup if you'd like,
00:52:41.120 --> 00:52:44.670
or state managed or
state managed plugging.
00:52:44.670 --> 00:52:48.490
You have our contact
information here right down.
00:52:48.490 --> 00:52:50.590
I'd also like to point
out that right now,
00:52:51.640 --> 00:52:53.990
I believe this is same
for Art and maybe Keith,
00:52:54.831 --> 00:52:57.700
but my phone number listed
here, you can still call that.
00:52:57.700 --> 00:53:02.030
I can answer that and it goes
we're telecommuting right now,
00:53:02.030 --> 00:53:06.790
but all of my phone calls
are sent through my laptop.
00:53:06.790 --> 00:53:09.860
So feel free to call me
that number still works
00:53:09.860 --> 00:53:12.233
or just email me whichever you prefer.
00:53:16.010 --> 00:53:17.123
And I think with that,
00:53:17.970 --> 00:53:20.923
we will go ahead and
close it out a little bit early.
00:53:22.830 --> 00:53:24.900
And again, I just want to thank everyone
00:53:24.900 --> 00:53:27.630
for joining us today and
thank you for everyone
00:53:27.630 --> 00:53:29.785
who made this webinar possible
00:53:29.785 --> 00:53:32.373
and to all of our panelists for joining.
00:53:34.090 --> 00:53:36.590
Thanks everybody,
have a good afternoon.