WEBVTT 00:00:02.970 --> 00:00:04.060 <v Leslie>All right.</v> 00:00:04.060 --> 00:00:05.900 So it's now 1:30. 00:00:05.900 --> 00:00:08.700 So we're going to go ahead and get started 00:00:08.700 --> 00:00:11.890 with the second in this series of webinars 00:00:11.890 --> 00:00:13.590 hosted by the Railroad Commission. 00:00:15.150 --> 00:00:17.570 If you were able to join us yesterday, 00:00:17.570 --> 00:00:21.470 we welcome you back to the second webinar 00:00:21.470 --> 00:00:24.750 that's going to focus on the voluntary cleanup program 00:00:24.750 --> 00:00:26.160 with the Railroad Commission today, 00:00:26.160 --> 00:00:30.233 as well as some other resources available to Brownfields. 00:00:31.332 --> 00:00:33.010 I am gonna at the end of this presentation 00:00:33.010 --> 00:00:38.010 also expand on some of the topics we discussed yesterday. 00:00:38.520 --> 00:00:40.520 If you weren't able to join us yesterday 00:00:41.840 --> 00:00:45.753 then welcome for the first webinar here. 00:00:47.325 --> 00:00:49.525 And so we're gonna go ahead and get started. 00:00:59.940 --> 00:01:01.270 Okay. 00:01:01.270 --> 00:01:03.660 Just so before we dive into everything, 00:01:03.660 --> 00:01:05.620 we wanted to give you guys sort of a face 00:01:05.620 --> 00:01:09.880 to the voices that you're going to be hearing today. 00:01:09.880 --> 00:01:11.070 My name is Leslie Bruce, 00:01:11.070 --> 00:01:13.270 I'm going to be the main presenter today. 00:01:13.270 --> 00:01:15.760 I am the voluntary cleanup program 00:01:15.760 --> 00:01:18.350 and Brownfield program coordinator 00:01:18.350 --> 00:01:20.430 here at the Railroad Commission. 00:01:20.430 --> 00:01:22.810 If you joined us yesterday, 00:01:22.810 --> 00:01:25.600 you kind of already heard about my background, 00:01:25.600 --> 00:01:29.250 but any of you who are just joining us today, 00:01:29.250 --> 00:01:33.480 I received a BS in Geology from university of South Carolina 00:01:33.480 --> 00:01:36.710 and an MS in Geology from UT Austin. 00:01:36.710 --> 00:01:39.510 I've been with the Railroad Commission since 2017, 00:01:39.510 --> 00:01:44.370 working in two different groups before I became the VCP 00:01:44.370 --> 00:01:47.913 and Brownfield coordinator in April of 2019. 00:01:49.730 --> 00:01:52.240 And so today we also have a couple of panelists 00:01:52.240 --> 00:01:53.830 that are joining us. 00:01:53.830 --> 00:01:54.663 Peter Pope, 00:01:54.663 --> 00:01:57.240 he's not actually going to be able to join us today, 00:01:57.240 --> 00:01:59.620 but I wanna kind of introduce him 00:01:59.620 --> 00:02:01.340 since he plays a very important role 00:02:01.340 --> 00:02:03.250 in the voluntary cleanup program. 00:02:03.250 --> 00:02:07.610 He's who signs off on all of our certificates of completion 00:02:07.610 --> 00:02:12.470 and has the final review of all sites before closure. 00:02:12.470 --> 00:02:16.630 So Peter is the manager of the site remediation section. 00:02:16.630 --> 00:02:20.564 He's been with the Commission since 2001. 00:02:20.564 --> 00:02:22.040 He has a BS in Geology from Purdue 00:02:22.040 --> 00:02:23.900 and an MA in Geology from Rice. 00:02:23.900 --> 00:02:27.110 And he has more than 25 years of experience 00:02:27.110 --> 00:02:30.430 doing risk-based assessments. 00:02:30.430 --> 00:02:33.690 And then we also have Art Correa with us today. 00:02:33.690 --> 00:02:36.730 He's the project manager of the State Managed Cleanup Group, 00:02:36.730 --> 00:02:39.380 which we're gonna talk about in our group, 00:02:39.380 --> 00:02:42.223 but I'm gonna let Art introduce himself real quick. 00:02:45.500 --> 00:02:46.610 <v Art>Thank you Leslie.</v> 00:02:46.610 --> 00:02:48.623 Yes, welcome everybody. 00:02:49.784 --> 00:02:52.283 I hope you enjoy the webinar. 00:02:53.250 --> 00:02:54.410 My name is Art Correa, 00:02:54.410 --> 00:02:57.120 I've been with the Commission since 1991 00:02:57.120 --> 00:03:01.723 and been over the State Managed Cleanup Program since 2014. 00:03:02.930 --> 00:03:07.403 And I've been out in this industry for about 40 plus years. 00:03:09.640 --> 00:03:10.903 That's it, thank you. 00:03:12.560 --> 00:03:13.820 <v Leslie>Thanks Art.</v> 00:03:13.820 --> 00:03:18.063 Okay, and so Peter and I are going to 00:03:19.000 --> 00:03:22.060 help well, Art today is going to help facilitate 00:03:22.060 --> 00:03:24.700 some questions that I might not be able to answer 00:03:24.700 --> 00:03:26.600 for the State Managed Cleanup Program. 00:03:28.386 --> 00:03:31.090 And then we're also going to have Keith May. 00:03:31.090 --> 00:03:34.120 So Keith is with the State Funded Plugging Program, 00:03:34.120 --> 00:03:35.520 which we're also going to touch on 00:03:35.520 --> 00:03:38.020 and he will help answer some questions at the end. 00:03:38.020 --> 00:03:39.227 Well Keith do you want to go ahead 00:03:39.227 --> 00:03:40.783 and introduce yourself as well? 00:03:42.350 --> 00:03:43.340 <v Keith>Leslie.</v> 00:03:43.340 --> 00:03:45.573 Good afternoon, everybody, my name's Keith May. 00:03:46.860 --> 00:03:50.960 Got my engineering degree from UT Austin back in 2011. 00:03:52.360 --> 00:03:54.600 Worked for the industry as a wireline engineer 00:03:54.600 --> 00:03:56.440 for a couple of years, 00:03:56.440 --> 00:03:59.160 then joined up with the Commission on 2013. 00:03:59.160 --> 00:04:01.580 And I've been part of the State Funded Program 00:04:01.580 --> 00:04:04.243 for a couple years now, two or three years now. 00:04:05.160 --> 00:04:06.860 Yeah, thank you Leslie. 00:04:08.099 --> 00:04:09.303 <v Leslie>Awesome, thank you Keith.</v> 00:04:10.650 --> 00:04:12.610 All right, so today's agenda, 00:04:12.610 --> 00:04:14.880 we're going to go over kind of just 00:04:14.880 --> 00:04:16.800 what the Voluntary Cleanup Program is 00:04:16.800 --> 00:04:18.313 and what it's designed to do. 00:04:19.310 --> 00:04:23.930 We'll go over the property eligibility, site enrollment, 00:04:23.930 --> 00:04:27.100 whether or not you should be within the Railroad Commission 00:04:27.100 --> 00:04:30.160 or TCEQ's VCP program. 00:04:30.160 --> 00:04:31.400 We'll go over some, 00:04:31.400 --> 00:04:34.360 the application and approval process, 00:04:34.360 --> 00:04:36.950 your required documents from start to finish 00:04:36.950 --> 00:04:38.143 within this program. 00:04:39.440 --> 00:04:41.110 Some oversight fees, 00:04:41.110 --> 00:04:43.810 since this is a program that you have to pay to be in, 00:04:44.930 --> 00:04:47.863 and then some examples of VCP sites. 00:04:49.451 --> 00:04:50.380 And then near the end, 00:04:50.380 --> 00:04:52.250 we're going to dive into the statement 00:04:52.250 --> 00:04:54.390 cleanup program and state funded plugging program, 00:04:54.390 --> 00:04:55.670 which we talked about yesterday, 00:04:55.670 --> 00:04:59.770 which have funds that are available 00:04:59.770 --> 00:05:03.773 for you for Brownfield's participants or applicants. 00:05:06.200 --> 00:05:07.570 So just as a reminder, 00:05:07.570 --> 00:05:10.770 that if you have any questions during this webinar, 00:05:10.770 --> 00:05:15.497 please submit them to the SR-VCP-BRP@rrc.texas.gov 00:05:19.000 --> 00:05:21.970 So we're going to be monitoring that email address 00:05:23.733 --> 00:05:26.180 and we'll answer questions at the end. 00:05:26.180 --> 00:05:29.450 And if we're not able to get to all of the questions today, 00:05:29.450 --> 00:05:31.630 don't worry, we're going to send each and every one of you 00:05:31.630 --> 00:05:33.860 an individual response. 00:05:33.860 --> 00:05:36.320 So I know where you're going to get a response, 00:05:36.320 --> 00:05:38.913 either via email or on screen today. 00:05:40.320 --> 00:05:42.980 And then if you don't have that written down yet, 00:05:42.980 --> 00:05:47.010 don't worry that email address is going to be located 00:05:47.010 --> 00:05:49.710 at the bottom of each slide. 00:05:49.710 --> 00:05:52.360 So you'll be able to kind of see that as we go along. 00:05:58.160 --> 00:06:01.030 Okay, so what is the voluntary cleanup program? 00:06:01.030 --> 00:06:02.965 Why are you guys here today? 00:06:02.965 --> 00:06:04.880 Or why should you care? 00:06:04.880 --> 00:06:08.290 So the program is designed to incentivize remediation 00:06:08.290 --> 00:06:10.620 of contaminated sites in Texas. 00:06:10.620 --> 00:06:13.920 And so the way we're doing that is by providing 00:06:13.920 --> 00:06:18.793 regulatory oversight of that remediation and assessment. 00:06:20.240 --> 00:06:22.750 And then, and especially with Railway Commission, 00:06:22.750 --> 00:06:24.750 these are oil and gas sites. 00:06:24.750 --> 00:06:29.280 And once you've completed this program 00:06:29.280 --> 00:06:31.660 and we've provided that regulatory oversight 00:06:31.660 --> 00:06:35.350 and given you approval to appropriately close it out, 00:06:35.350 --> 00:06:39.810 you then will receive a release of liability from the state. 00:06:39.810 --> 00:06:42.850 So one of the most important things to take away 00:06:42.850 --> 00:06:46.130 from this webinar and why VCP is so important 00:06:46.130 --> 00:06:48.043 is that release of liability. 00:06:49.010 --> 00:06:53.390 So you know, if you are taking on the assessment 00:06:53.390 --> 00:06:54.990 and remediation of a site, 00:06:54.990 --> 00:06:56.650 you are taking on that liability, 00:06:56.650 --> 00:07:00.460 but if you go through our program and appropriately 00:07:01.540 --> 00:07:04.568 clean it up per your closure strategy, 00:07:04.568 --> 00:07:07.166 you're going to receive this release of liability 00:07:07.166 --> 00:07:08.870 from the state, 00:07:08.870 --> 00:07:13.740 which transfers to not only you as the property owner, 00:07:13.740 --> 00:07:17.667 but also any future property owners and lenders, 00:07:17.667 --> 00:07:21.502 any borrowers, any leasers, anything like that, 00:07:21.502 --> 00:07:23.010 that's gonna be associated with a property 00:07:23.010 --> 00:07:26.933 that release of liability is also going to transfer to them. 00:07:30.080 --> 00:07:31.843 So, program eligibility. 00:07:32.830 --> 00:07:35.900 So the applicant can not have caused 00:07:35.900 --> 00:07:40.460 or contributed to the contamination on the property. 00:07:40.460 --> 00:07:42.040 If you weren't sure you have caused 00:07:42.040 --> 00:07:44.250 or contributed contamination, 00:07:44.250 --> 00:07:46.180 you would likely be probably needing 00:07:46.180 --> 00:07:48.520 to be in the operator cleanup program. 00:07:48.520 --> 00:07:49.780 So that's a really big 00:07:51.720 --> 00:07:54.870 distinction here for this program. 00:07:54.870 --> 00:07:56.890 And then activities have to be under the jurisdiction 00:07:56.890 --> 00:07:58.620 of the Railroad Commission. 00:07:58.620 --> 00:08:01.850 And there has to be no unresolved federal 00:08:01.850 --> 00:08:03.723 or state enforcement on a property. 00:08:04.620 --> 00:08:06.590 And then similar to the Brownfields program 00:08:06.590 --> 00:08:08.670 that we talked about yesterday, 00:08:08.670 --> 00:08:10.810 the applicant and the landowner have to agree 00:08:10.810 --> 00:08:13.054 to cooperate with the Railroad Commission. 00:08:13.054 --> 00:08:15.150 So here again, we just want to point out 00:08:15.150 --> 00:08:18.300 that you do not have to be the landowner 00:08:18.300 --> 00:08:19.650 to be the applicant, 00:08:19.650 --> 00:08:22.240 you can be, but it's not required. 00:08:22.240 --> 00:08:24.330 But if you are not the landowner, 00:08:24.330 --> 00:08:26.980 you have to have that landowner's consent 00:08:26.980 --> 00:08:28.493 to be in the program. 00:08:29.771 --> 00:08:32.321 And so a lot of times what we'll see is you'll have 00:08:33.990 --> 00:08:37.400 potentially the future landowner is actually the applicant 00:08:37.400 --> 00:08:39.090 and they want to go through this process 00:08:39.090 --> 00:08:43.793 before they purchase their property to ensure that, 00:08:46.310 --> 00:08:48.030 you know, they're not taking on that liability 00:08:48.030 --> 00:08:51.510 before purchasing, or sometimes the opposite 00:08:51.510 --> 00:08:52.343 where 00:08:53.890 --> 00:08:57.450 it's the current operators going through this program 00:08:57.450 --> 00:09:00.170 on the contention that once they sell it 00:09:00.170 --> 00:09:03.110 to the new purchaser, 00:09:03.110 --> 00:09:06.093 that this will have been taken care of by that point. 00:09:08.584 --> 00:09:09.810 Okay. 00:09:09.810 --> 00:09:13.740 So this is probably the number one thing you need 00:09:13.740 --> 00:09:17.520 to ask yourself once you probably get your phase one back 00:09:18.830 --> 00:09:21.410 for your site is, does this site belong 00:09:21.410 --> 00:09:24.600 with Railroad Commission or TCEQ VCP's program 00:09:24.600 --> 00:09:27.063 or potentially another program within TCEQ. 00:09:28.307 --> 00:09:30.010 So we really can't make that determination for you 00:09:30.010 --> 00:09:31.760 because in order to make that determination, 00:09:31.760 --> 00:09:33.970 you needed to make your application, 00:09:33.970 --> 00:09:38.540 submit your fees and everything associated with it. 00:09:38.540 --> 00:09:40.100 And so instead of doing that, 00:09:40.100 --> 00:09:42.460 the best thing that we can suggest to you 00:09:42.460 --> 00:09:45.640 is just to consult with an oil and gas attorney 00:09:45.640 --> 00:09:48.390 to determine whether or not to see which program 00:09:48.390 --> 00:09:52.373 would be more appropriate or an environmental attorney, 00:09:53.220 --> 00:09:55.890 but you can also refer to the memorandum of understanding 00:09:55.890 --> 00:09:58.957 between the Railroad Commission and the TCEQ. 00:09:58.957 --> 00:10:03.230 So that can be found at the 16 Texas Administrative Code 00:10:03.230 --> 00:10:04.263 three point 30. 00:10:05.470 --> 00:10:08.100 And that kind of details the jurisdictional divides 00:10:08.100 --> 00:10:09.900 between the two agencies. 00:10:09.900 --> 00:10:11.660 But I think it's also important to point out 00:10:11.660 --> 00:10:13.550 that you can actually be duly enrolled 00:10:13.550 --> 00:10:16.300 in the Railroad Commission and TCEQs VCP program 00:10:16.300 --> 00:10:18.230 at the same time. 00:10:18.230 --> 00:10:22.580 We have a lot of sites where there's been historical oil 00:10:22.580 --> 00:10:24.330 and gas activities 00:10:24.330 --> 00:10:27.900 and then there's more modern industrial activities. 00:10:27.900 --> 00:10:32.580 And you can clearly distinguish the contamination 00:10:32.580 --> 00:10:35.330 and sources from both. 00:10:35.330 --> 00:10:37.530 And in that case, you know, 00:10:37.530 --> 00:10:39.990 the Railroad Commission will deal with everything 00:10:39.990 --> 00:10:42.360 we have jurisdiction over and TCEQ will deal 00:10:42.360 --> 00:10:44.460 with everything they have jurisdiction over, 00:10:44.460 --> 00:10:47.613 and we'll talk amongst each other to make sure, you know, 00:10:48.792 --> 00:10:51.880 we're not giving any conflicting information 00:10:51.880 --> 00:10:53.373 between the two agencies. 00:10:56.990 --> 00:10:59.860 So the application approval process. 00:10:59.860 --> 00:11:02.410 So I like to call it the application package 00:11:02.410 --> 00:11:05.250 because it's more than just the application 00:11:05.250 --> 00:11:06.753 that you're required to submit 00:11:08.660 --> 00:11:10.890 when you're applying to our program. 00:11:10.890 --> 00:11:14.310 So obviously you'll have to have the signed application 00:11:14.310 --> 00:11:16.490 and agreement, which you can find on our website 00:11:16.490 --> 00:11:17.840 that you can download that. 00:11:18.898 --> 00:11:20.650 You download it and print it out 00:11:20.650 --> 00:11:24.010 and can fill it out and then mail it to us. 00:11:24.010 --> 00:11:25.730 But also that along with that, 00:11:25.730 --> 00:11:28.660 you need the application fee of a $1,000 00:11:28.660 --> 00:11:30.417 and the surcharge of $1,500. 00:11:32.520 --> 00:11:35.150 And then you need a phase one site assessment 00:11:35.150 --> 00:11:38.580 of the entire property that is going to be enrolled. 00:11:38.580 --> 00:11:42.890 So we really ask that you not submit your application 00:11:42.890 --> 00:11:45.030 until you have a phase one. 00:11:45.030 --> 00:11:46.210 Also because that phase one, 00:11:46.210 --> 00:11:48.220 that's gonna really help you to determine 00:11:48.220 --> 00:11:51.103 which program your site belongs in. 00:11:52.180 --> 00:11:54.750 And then that phase one is also going to help us dictate 00:11:54.750 --> 00:11:57.220 what needs to happen at the site. 00:11:57.220 --> 00:12:00.270 So really, do not submit an application 00:12:00.270 --> 00:12:01.803 without the phase one. 00:12:03.580 --> 00:12:05.540 So approval process, 00:12:05.540 --> 00:12:08.137 we'll review all the documents that you submitted above 00:12:08.137 --> 00:12:11.340 and any reports that are also submitted. 00:12:11.340 --> 00:12:14.090 We'll also conduct a legal review, 00:12:14.090 --> 00:12:16.770 the applicant and the property to ensure that 00:12:17.690 --> 00:12:21.998 that applicant did not cause or contribute to contamination. 00:12:21.998 --> 00:12:24.660 And then within 45 days of receiving 00:12:24.660 --> 00:12:27.000 the full application package, 00:12:27.000 --> 00:12:30.363 we'll issue either an approval or a denial letter. 00:12:33.760 --> 00:12:34.593 Okay. 00:12:34.593 --> 00:12:39.153 So closure options within the voluntary cleanup program. 00:12:40.120 --> 00:12:42.220 So here it's important to point out 00:12:42.220 --> 00:12:44.760 that the applicant chooses their own closure strategy 00:12:44.760 --> 00:12:47.491 at time of applying based on 00:12:47.491 --> 00:12:50.023 their desired future use of the property, 00:12:51.110 --> 00:12:54.450 or the applicant can choose their closure strategy 00:12:54.450 --> 00:12:56.250 based on site-specific conditions. 00:12:56.250 --> 00:12:59.780 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 00:13:02.450 --> 00:13:05.208 before you apply, which you're allowed to do, 00:13:05.208 --> 00:13:09.510 you can use the data to drive your closure strategy. 00:13:09.510 --> 00:13:12.930 But if you've only done a phase one and you know, 00:13:12.930 --> 00:13:14.700 you're not sure what the data is going to provide 00:13:14.700 --> 00:13:17.360 but you know you want to close residential 00:13:17.360 --> 00:13:21.603 or with no conditions, then that's totally fine as well. 00:13:22.770 --> 00:13:26.860 The only thing is that we essentially are asking that, 00:13:26.860 --> 00:13:28.240 you know, you have to demonstrate 00:13:28.240 --> 00:13:29.745 that your closure strategy, 00:13:29.745 --> 00:13:32.950 whichever one you choose is going to be protective 00:13:32.950 --> 00:13:34.980 of human health and the environment as laid out 00:13:34.980 --> 00:13:36.883 in the Texas risk reduction program. 00:13:38.069 --> 00:13:39.193 And then I also want to point out, 00:13:39.193 --> 00:13:41.770 cause this gets brought up a lot, 00:13:41.770 --> 00:13:43.937 do we, does the Railroad Commission implement 00:13:43.937 --> 00:13:47.640 the Texas risk reduction program that TCQ created? 00:13:47.640 --> 00:13:51.000 So yes, we are following all those guidelines. 00:13:51.000 --> 00:13:54.060 And so all of your assessments and cleanups 00:13:54.060 --> 00:13:57.143 need to be done to those standards. 00:13:58.680 --> 00:14:00.230 And then you can click, 00:14:00.230 --> 00:14:04.009 you can change your closure strategy at any time. 00:14:04.009 --> 00:14:06.670 You, the only thing we request is that 00:14:06.670 --> 00:14:09.000 if you do change your closure strategy, 00:14:09.000 --> 00:14:11.130 you just resubmit the application agreement 00:14:11.130 --> 00:14:12.710 to reflect that change. 00:14:12.710 --> 00:14:15.560 There won't be any charges associated with that. 00:14:15.560 --> 00:14:18.040 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 <v Art>Yeah, this is Art, no,</v> 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 <v ->Yeah, thank you Art.</v> 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 <v Keith>Yeah, I was just going to add real quick.</v> 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 <v Leslie>Awesome, yeah, I think Keith that you bring up</v> 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 <v Art>Sure.</v> 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 <v Leslie>Okay, awesome.</v> 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 <v Keith>Thanks everybody, have a good afternoon.</v>