WEBVTT
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Good afternoon.
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My name is Christopher Straub
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and I'm an engineering specialist
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with the Railroad Commission
of Texas Oil and Gas Division.
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My co-presenters and I
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represent the Environmental
Permitting and Support Group.
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I am presenting here today
with Riley Monk and Abby Klein.
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This presentation is called
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Oil and Gas Waste Stream
Management and Permits Part Two
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and will cover the commercial
facility requirements.
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Before we start, here's a link
to download the presentation
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if you would like to have
a copy for future reference.
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The link can be found
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in the Q&A at the bottom of the screen.
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Some of the topics we will
cover today will be permit types,
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guidance for potential
locations, pits, reclamation plants,
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waste separation facilities,
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commercial recycling,
notice requirements,
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additional commercial
facility requirements
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pertaining to financial
security, closure cost estimates,
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restrictive covenants, and NORM surveys.
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Permit types.
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The Environmental
Permitting and Support Group
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manages many different permit types
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that include waste hauler, minor,
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hydrostatic test discharge,
domestic wastewater,
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landspreading, pits, reclamation plants,
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waste separating facility,
and recycling permits.
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If "a facility whose owner or operator
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receives compensation from others
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for the storage, reclamation,
treatment, or disposal
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of oil field fluids or
oil and gas wastes
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that are wholly or partially
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trucked or hauled to the facility
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and whose primary business
provide these services"
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it is considered a commercial facility.
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Guidance for potential locations.
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A surface lease agreement
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between the operator and land owner
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must be provided for all facilities
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if the P-5 operator does
not own the property.
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Submitted lease agreements are reviewed
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by the Office of General Council
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to ensure all legal
requirements are met.
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Flood prone areas, wetland
environments, groundwater,
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soils and geology,
major and minor aquifers,
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and karst features are
important environmental factors
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to consider when selecting
a potential location.
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This is not an exhaustive list
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of environmental risk factors.
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Other factors may exist
on a case-by case-basis
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and a hydro geologic
review of the proposal location
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will be conducted to access
these environmental factors
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by environmental
permitting and support staff.
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Facilities are normally prohibited
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from building in a Federal
Emergency Management Agency,
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or FEMA, 100-year floodplain,
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but not all areas of Texas are mapped.
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For areas where the floodplain
is not mapped by FEMA,
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the RRC may require a
base flood elevation map
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to be submitted.
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Depending on the frequency
of extreme regional rainfall,
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the operator may be required
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to satisfy more stringent
floodplain requirements.
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Statewide Rule 8 and Chapter
4 prohibit authorized pits
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and recycling within
the 100-year floodplain.
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The term 100-year floodplain
is somewhat misleading
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and does not mean that the
area will flood every 100 years.
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The term means that there is a 1% chance
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that the area will flood each year.
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The 500-year floodplain
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is an area with a 0.2%
chance of flood every year.
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Wetland conservation is mandated
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at the federal and state level.
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Facility boundaries
must be at least 150 feet
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from a designated wetland.
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A jurisdictional determination letter
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from the US Army Corps of Engineers
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will be required for
application approval.
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If a shallow aquifer is determined
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by a groundwater
investigation and soil borings
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to be within 100 feet of the
location's surface elevation,
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a minimum of three
groundwater monitoring wells
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may be required to be installed.
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An unconfined shallow aquifer
found on the proposed location
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may lead to the
application being denied.
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This map from the Texas
Water Development Board
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shows all major aquifers found in Texas.
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When choosing a potential
location for your facility,
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please refer to this map to determine
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which aquifer your facility
will be constructed over.
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Underlying soil and geologic
features are important factors
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when determining risk at
a proposed facility location.
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An ideal location includes stable soils,
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moderately to slowly permeable soils,
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a continuous fat clay layer,
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or layers confining the local aquifer.
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Underlying bedrock should
have a low permeability
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and be stable, and have
no local or regional karsts.
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The Google Map image shows
regions where surface karsts
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are found exposed.
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This map does not include regions
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where karsts exist in the subsurface.
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Karst environments are widespread
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in areas of economic value,
such as the Permian Basin.
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This diagram shows an
idealized karst system.
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Karst systems are often
formed conduits that allow
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quick surface water
communication with groundwater.
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For this reason,
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a local groundwater
table within a karst system
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can be deeper than
100 feet from the surface,
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but the pollution
risk may still be high.
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Groundwater tends to flow
quickly through karst systems
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so groundwater monitoring wells
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may also be rendered ineffective.
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Sensitive receptors are areas
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where occupants are more susceptible
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to adverse effects of
exposure to pollutants.
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A few example of these
are hospitals, schools,
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water wells, and residential areas.
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All facility boundaries must be 500 feet
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from all sensitive receptors.
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Here are some examples
of sensitive receptors.
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A neighborhood, a water
well, a school, and a hospital.
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Applications for commercial facilities
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must identify the distance
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from the facility's outer
most perimeter boundary
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to water wells, residences,
schools, churches, or hospitals
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that are within 500
feet of the boundary.
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Does anyone have any
questions at this point?
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No questions.
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Pits.
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Disposal or storage of
oil and gas wastes in a pit
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may be allowed if the
activity does not result
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in the pollution of ground soils,
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surface water, and subsurface water.
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Pits are categorized as authorized,
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non-commercial, and commercial.
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You have a pit if it is in
contact with the ground,
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but not an above ground
storage tank, it's below grade,
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it's a concrete structure
that cannot be moved quickly
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and easily to check for leaks,
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it's a steel containment
ring with a liner,
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and it's a sump larger than 500 gallons.
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All pits must have a
natural or synthetic liner
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with a hydraulic conductivity
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no greater than 1.0 times 10
to negative seven centimeters.
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Concrete is considered a synthetic liner
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and should be steel-reinforced
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with a six-inch minimal thickness.
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Commercial disposal pits, brine pits,
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and other large-scale
liquid waste storage pits
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must have a dual synthetic liner
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with a leak detection system.
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Action Leakage Rate
calculations are required
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to demonstrate how the liner system
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can handle the specified flow of fluids
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in the event of a leak or
failure from the primary liner.
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A primary liner failure
is typically calculated
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at 1,000 gallons per
acre or 100 gallon per acre
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for a disposal pit
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unless the liner system
cannot handle the flow rate.
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Berms or containment
structures must be constructed
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around all pits and must
be constructed of a material
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and compacted to meet or exceed
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95% standard proctor, ASTMD698,
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or 90 to 92% modified
proctor, ASTMD1557 density,
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or have a hydraulic
conductivity no greater than
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1.0 times 10 to the negative
seven centimeters per second.
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Each berm must consist
of a slope no steeper
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than a three-to-one
horizontal to vertical ratio
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on both sides,
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unless constructed of
concrete or equivalent material.
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These structures must
be designed to divert
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non-contact storm water around the pit
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and contain and isolate
waste and stormwater
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within the management units.
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Pits designed to store
waste above ground level
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must be designed under the
seal of a professional engineer
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licensed in the state of Texas.
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At least two feet of freeboard
must always be maintained
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between the fluid level of the pit
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and the top of the pit berms,
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and an annual
inspection will be required
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for a pit without a dual liner
and leak detection system.
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Any pit with a dual liner
and leak detection system
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must be monitored regularly.
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Example of commercial
pits are disposal pits,
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collecting pits, washout pits,
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and off-lease fluid recycling pits.
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An operator must submit a complete
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Application for Permit
to Maintain and Use a Pit,
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a form H-11.
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All instruction to pit
application, notice,
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and commercial facility
requirements if applicable
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must be included in the submission.
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A form H-11 must be filled
out for each individual pit.
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This is page one of
two of the form H-11.
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On this first page, operators
will be required to fill out
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every box that is found on this form.
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Boxes one, two, and five
pertain to operator information,
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boxes two, four, six
through nine, and 11
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pertain to location information,
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boxes 10 and 12 through
20 pertained to pit information,
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boxes 21 and 22 pertain to
environmental information.
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An active P-5 number is
required to submit a form H-11.
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This is page two of
two of the form H-11.
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On this second page titled
Instructions to Pit Application,
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operators will be required to submit
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all supplemental information
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required by the form H-11, A through L,
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which includes notification
to the surface owner,
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a plat showing the
size of the lease or tract
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and location of the pit
with the lease or tract,
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a county highway map
showing the location of the pit,
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a drawing of two perpendicular
cross-sectional views
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of the pit bottoms, sides,
dikes, and the natural grade,
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data on liner material if lined,
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identification and description
of the soil or subsoil
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that will make up the
pit's sides and bottom,
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attach an engineering
design drawing of the pit,
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and the leak detection system.
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If not equipped with the
league link detection system,
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describe procedures
for periodic maintenance
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in determining liner integrity.
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If the pit is an
emergency saltwater pit,
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attach justification for pit
size based on water production
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of the lease.
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Do we have any questions?
00:13:52.860 --> 00:13:55.230
We have a few, but
I'll answer them in the Q&A.
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Thank you, Chris.
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Okay, I will
turn it over to Riley then.
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Thank you, Chris.
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Hello, everyone, my name is Riley,
00:14:11.540 --> 00:14:15.480
and today I will start by
discussing reclamation plants
00:14:15.480 --> 00:14:17.683
and their application requirements.
00:14:19.860 --> 00:14:22.270
So the Commission
encourages the reclamation
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of oil and gas streams
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to preserve the natural
resources of Texas.
00:14:26.690 --> 00:14:28.680
The primary function of this process
00:14:28.680 --> 00:14:32.180
is to reclaim hydrocarbons
from heavy wastes
00:14:32.180 --> 00:14:35.400
and wastes that
require active separation.
00:14:35.400 --> 00:14:38.720
Reclamation is governed
by Statewide Rule 57
00:14:38.720 --> 00:14:41.270
and covers wastes such as tank bottoms,
00:14:41.270 --> 00:14:44.200
also referred as basic
sediment and water,
00:14:44.200 --> 00:14:48.080
and other hydrocarbon
wastes or oily waste materials
00:14:48.080 --> 00:14:51.200
which have been generated
in connection with activities
00:14:51.200 --> 00:14:54.880
associated the exploration,
development, and production
00:14:54.880 --> 00:14:57.783
of oil and gas or geothermal resources.
00:14:58.630 --> 00:15:02.910
Examples of these other
wastes would be pit hydrocarbons,
00:15:02.910 --> 00:15:06.450
skim oil, leakage of
crude oil or condensate
00:15:06.450 --> 00:15:09.930
from producing lease
or pipeline storage tanks,
00:15:09.930 --> 00:15:11.850
and crude oil or condensate
00:15:11.850 --> 00:15:15.243
associated with pipeline
ruptures and other spills.
00:15:18.600 --> 00:15:20.320
Reclamation typically occurs
00:15:20.320 --> 00:15:23.010
by three main methods of separation:
00:15:23.010 --> 00:15:25.660
mechanical, chemical, and thermal.
00:15:25.660 --> 00:15:28.750
It should be noted that if
applying for an R-9 permit,
00:15:28.750 --> 00:15:31.620
three-phase centrifuges are required
00:15:31.620 --> 00:15:35.600
if the facility intends to
separate the waste mechanically.
00:15:35.600 --> 00:15:38.900
Gravity separation alone
is not a sufficient method
00:15:38.900 --> 00:15:40.003
to merit a permit.
00:15:40.950 --> 00:15:44.410
The primary goal of reclamation
is hydrocarbon recovery
00:15:44.410 --> 00:15:47.500
so applicants must
demonstrate an understanding
00:15:47.500 --> 00:15:50.623
of current reclamation
practices in their application.
00:15:52.080 --> 00:15:56.190
After separation, stored
hydrocarbons are typically sold
00:15:56.190 --> 00:15:58.630
while liquid wastes are to be recycled
00:15:58.630 --> 00:16:01.260
or disposed of at an injection well,
00:16:01.260 --> 00:16:04.223
and solids are to be
disposed of at a landfill.
00:16:05.130 --> 00:16:06.500
Facilities that are permitted
00:16:06.500 --> 00:16:10.330
must also actively be
reclaiming hydrocarbons
00:16:10.330 --> 00:16:12.360
in order to maintain their permit.
00:16:12.360 --> 00:16:16.150
So any facility that ceases
operations for over 12 months
00:16:16.150 --> 00:16:18.593
will result in the
cancellation of their permit.
00:16:22.510 --> 00:16:26.120
So now we'll delve
into the application itself
00:16:26.120 --> 00:16:28.200
and the requirements.
00:16:28.200 --> 00:16:30.450
The most basic requirements
that are requested
00:16:30.450 --> 00:16:33.830
for all permit applications
include the operator,
00:16:33.830 --> 00:16:36.490
location, and design information,
00:16:36.490 --> 00:16:38.490
and this must be submitted by hard copy
00:16:38.490 --> 00:16:42.133
to Technical Permitting in
Austin with original signatures.
00:16:43.280 --> 00:16:46.960
All attachments from the
instructions for the form R-9
00:16:46.960 --> 00:16:48.290
must be included
00:16:48.290 --> 00:16:51.033
and it will be discussed
in the next few slides.
00:16:51.900 --> 00:16:53.850
Included with the
application requirements,
00:16:53.850 --> 00:16:56.410
a brief description of
the treatment process
00:16:56.410 --> 00:16:58.080
must be provided.
00:16:58.080 --> 00:16:59.960
This includes how the incoming wastes
00:16:59.960 --> 00:17:02.600
will be stored and
received at the facility,
00:17:02.600 --> 00:17:04.160
a description of the processes
00:17:04.160 --> 00:17:06.520
used to separate the crude oil,
00:17:06.520 --> 00:17:09.340
the location of the
stored separated products,
00:17:09.340 --> 00:17:11.920
and the location of where
all the separated wastes
00:17:11.920 --> 00:17:13.283
will be disposed of.
00:17:17.100 --> 00:17:19.100
So here we have the front page
00:17:19.100 --> 00:17:21.780
of the R-9 application template.
00:17:21.780 --> 00:17:24.290
This is where the operator
and facility information
00:17:24.290 --> 00:17:26.720
can be described, as
well as requirements
00:17:26.720 --> 00:17:30.290
such as driving directions
from the nearest town,
00:17:30.290 --> 00:17:33.390
vehicle information for
the transport of materials,
00:17:33.390 --> 00:17:36.720
and identifying any oil
and gas related facilities
00:17:36.720 --> 00:17:38.693
within 100 yards of the facility,
00:17:39.570 --> 00:17:42.943
which are more specific
for an R-9 application.
00:17:45.850 --> 00:17:49.990
So the back of the application
goes over filing requirements
00:17:49.990 --> 00:17:53.470
and attachments needed
to complete the application.
00:17:53.470 --> 00:17:55.840
Every operator who
wishes to conduct business
00:17:55.840 --> 00:17:58.570
with the Commission
must first have an active P-5
00:17:58.570 --> 00:18:01.240
before the application can proceed,
00:18:01.240 --> 00:18:02.640
but if submitting an R-9,
00:18:02.640 --> 00:18:05.140
our address is listed
here for convenience
00:18:05.140 --> 00:18:08.320
and must also be sent to
the respective district office
00:18:08.320 --> 00:18:10.290
of the facility's location.
00:18:10.290 --> 00:18:12.340
And we'll go over more
of the requirements
00:18:12.340 --> 00:18:13.333
on the next slide.
00:18:16.870 --> 00:18:19.960
So if the facility intends to
separate the hydrocarbons
00:18:19.960 --> 00:18:22.510
by any form of chemical separation,
00:18:22.510 --> 00:18:25.710
safety data sheets must
be included in the application
00:18:25.710 --> 00:18:28.470
for any and all chemicals proposed.
00:18:28.470 --> 00:18:32.030
A site plan or facility
schematic must also be included
00:18:32.030 --> 00:18:33.890
and provide a detailed account
00:18:33.890 --> 00:18:38.780
of the facility's security
fences, roads, and paved areas,
00:18:38.780 --> 00:18:40.520
as well as accurate depictions
00:18:40.520 --> 00:18:42.950
of all tanks and equipment onsite
00:18:42.950 --> 00:18:47.650
with descriptions of their
size, contents, and materials.
00:18:47.650 --> 00:18:50.240
Cost closure estimates
will be required for review
00:18:50.240 --> 00:18:53.820
by our technical reviewers
and once approved,
00:18:53.820 --> 00:18:57.010
financial security in the form
of a bond or letter of credit
00:18:57.010 --> 00:18:59.040
will be requested.
00:18:59.040 --> 00:19:01.350
Notice requirements
for reclamation facilities
00:19:01.350 --> 00:19:04.060
will also be required
and further discussed
00:19:04.060 --> 00:19:05.543
later in this presentation.
00:19:09.220 --> 00:19:13.300
So reclamation plant permits
do not transfer or expire
00:19:13.300 --> 00:19:16.610
so renewal is not required once
the permit has been approved
00:19:16.610 --> 00:19:18.500
by Technical Permitting,
00:19:18.500 --> 00:19:23.208
however, if the facility
changes operators,
00:19:23.208 --> 00:19:25.450
(Riley clears throat)
00:19:25.450 --> 00:19:26.283
excuse me,
00:19:30.670 --> 00:19:33.470
and a new operator
wishes to conduct business
00:19:33.470 --> 00:19:36.730
at the facility, a new
and completed application
00:19:36.730 --> 00:19:39.680
from the new operator will
need to be submitted for review.
00:19:42.430 --> 00:19:45.693
So now we will move on to
our waste separation section.
00:19:48.570 --> 00:19:52.320
Oil and gas waste separation
facilities are generally known
00:19:52.320 --> 00:19:56.950
and referred to as stationary
treatment facilities, or STFs.
00:19:56.950 --> 00:20:01.010
This category encompasses
facilities that receive, store,
00:20:01.010 --> 00:20:03.880
handle, treat, recycle, and dispose
00:20:03.880 --> 00:20:07.550
of certain nonhazardous
oil and gas wastes.
00:20:07.550 --> 00:20:11.690
The separation of the waste
into liquid and solid components
00:20:11.690 --> 00:20:15.580
may be achieved by using
gravity, physical, mechanical,
00:20:15.580 --> 00:20:18.780
thermal, and or chemical methods.
00:20:18.780 --> 00:20:21.680
Similar to reclamation
plants, the separated fluid
00:20:21.680 --> 00:20:25.970
is transported to a class
two injection well for disposal
00:20:25.970 --> 00:20:29.300
and the solids are disposed
of at a permitted landfill
00:20:29.300 --> 00:20:30.243
or a disposal pit.
00:20:31.660 --> 00:20:34.680
STFs are commonly paired
with other types of permits
00:20:34.680 --> 00:20:36.720
to be operated at the same facility,
00:20:36.720 --> 00:20:41.160
such as pits, reclamation
plants, or recycling permits.
00:20:44.730 --> 00:20:48.730
So there's no specific
form for an STF application,
00:20:48.730 --> 00:20:50.760
but the full application requirements
00:20:50.760 --> 00:20:53.970
are located on our
website for submittal.
00:20:53.970 --> 00:20:57.250
It requires the operator
and location information
00:20:57.250 --> 00:21:00.680
of the proposed facility,
environmental factors
00:21:00.680 --> 00:21:04.010
ranging from information
about the subsurface
00:21:04.010 --> 00:21:06.530
to listing all domestic water wells
00:21:06.530 --> 00:21:10.913
within a one-mile radius,
as well as other factors.
00:21:11.910 --> 00:21:14.550
A description of the facility design
00:21:14.550 --> 00:21:16.800
detailing all of the
visibility equipment
00:21:16.800 --> 00:21:19.410
and waste processing information.
00:21:19.410 --> 00:21:22.810
And again, if the facility
intends to utilize any chemicals
00:21:22.810 --> 00:21:25.660
in the separation
process, safety data sheets
00:21:25.660 --> 00:21:29.230
must be provided for
all chemicals proposed.
00:21:29.230 --> 00:21:32.640
A collection of maps and
figures may also be requested
00:21:32.640 --> 00:21:35.503
to represent the facility
and surrounding area,
00:21:36.370 --> 00:21:38.190
as well as more specific requirements
00:21:38.190 --> 00:21:40.820
detailed out on our webpage,
00:21:40.820 --> 00:21:44.350
all of which will need to
be submitted by hard copy
00:21:44.350 --> 00:21:46.720
with original signatures.
00:21:46.720 --> 00:21:50.540
And a cost closure estimate
and specific notice requirements
00:21:50.540 --> 00:21:53.780
will also be required
with a submittal, but again,
00:21:53.780 --> 00:21:56.890
the full requirements needed
to apply for a waste separation
00:21:56.890 --> 00:22:00.513
or STF permit can be found
in more detail on the website.
00:22:03.870 --> 00:22:07.840
So before I continue, does
anyone have any questions
00:22:07.840 --> 00:22:11.873
over reclamation plants or
waste separation facilities?
00:22:14.600 --> 00:22:16.840
No questions, Riley.
00:22:16.840 --> 00:22:17.673
Okay.
00:22:17.673 --> 00:22:18.506
Well, we will move on.
00:22:20.380 --> 00:22:23.140
So the last topic that I
will be going over today
00:22:23.140 --> 00:22:26.023
will be commercial
solid and fluid recycling.
00:22:27.220 --> 00:22:30.440
Statewide Rule 8 and Chapter 4B
00:22:30.440 --> 00:22:32.720
have been written and amended
00:22:32.720 --> 00:22:36.310
in order to encourage
recycling in the oil field.
00:22:36.310 --> 00:22:38.060
The commercial recycling rules
00:22:38.060 --> 00:22:40.660
are divided into five separate divisions
00:22:40.660 --> 00:22:43.910
based on the type of oil
and gas waste being treated
00:22:43.910 --> 00:22:47.880
and the location and duration
of the treatment operations.
00:22:47.880 --> 00:22:49.980
The most common of these wastes include,
00:22:49.980 --> 00:22:52.180
but are not limited to:
00:22:52.180 --> 00:22:56.200
separated solids from exploration
and production activities,
00:22:56.200 --> 00:22:59.780
produced formation water,
fracture flow-back water,
00:22:59.780 --> 00:23:02.623
and completion or workover fluids.
00:23:05.770 --> 00:23:10.770
Solid recycling is covered
in Divisions 2, 3, and 4.
00:23:10.920 --> 00:23:13.310
Division 2, or more commonly known
00:23:13.310 --> 00:23:15.260
as our mobile recycling permit,
00:23:15.260 --> 00:23:18.730
is an on-lease solid
waste recycling facility
00:23:18.730 --> 00:23:21.670
that is limited to operate on each lease
00:23:21.670 --> 00:23:23.720
for a maximum of one year.
00:23:23.720 --> 00:23:26.680
Application information
for Division 2 recycling
00:23:26.680 --> 00:23:30.510
must include a typical
layout of the facility,
00:23:30.510 --> 00:23:34.393
processing information, and
storage and liner information.
00:23:35.260 --> 00:23:38.280
Off-lease or centralized
solid waste recycling
00:23:38.280 --> 00:23:42.820
is covered in Division 3
and is limited to any location
00:23:42.820 --> 00:23:45.320
for a maximum of two years.
00:23:45.320 --> 00:23:47.840
And since the facility
will be at one location
00:23:47.840 --> 00:23:48.810
for more than a year,
00:23:48.810 --> 00:23:52.660
environmental and property
information, financial security,
00:23:52.660 --> 00:23:56.170
monitoring wells, and the surface owner,
00:23:56.170 --> 00:23:59.690
and adjacent landowner
notifications will be required
00:23:59.690 --> 00:24:01.630
in addition to the requirements listed
00:24:01.630 --> 00:24:03.433
for the Division 2 application.
00:24:05.300 --> 00:24:08.720
Division 4, or stationary
solid waste facilities
00:24:08.720 --> 00:24:12.590
are permitted for a single
location for up to five years
00:24:12.590 --> 00:24:14.320
and can be renewed.
00:24:14.320 --> 00:24:16.790
The application
requirements of Division 4
00:24:16.790 --> 00:24:19.440
include those of Divisions 2 and 3,
00:24:19.440 --> 00:24:22.493
but must also include
proper published notice.
00:24:26.140 --> 00:24:29.270
Solid recycling physically
and chemically stabilizes
00:24:29.270 --> 00:24:33.000
E&P solids to be reused
as two main products:
00:24:33.000 --> 00:24:35.110
roadbase and reusable product.
00:24:35.110 --> 00:24:39.740
Roadbase is primarily spread
and used for lease roads
00:24:39.740 --> 00:24:42.860
and well pads, and if granted
the proper authorization,
00:24:42.860 --> 00:24:46.060
can also be used for
private and county roads.
00:24:46.060 --> 00:24:47.850
Reusable product on the other hand,
00:24:47.850 --> 00:24:50.880
requires of a letter of
authority for each use,
00:24:50.880 --> 00:24:55.840
but can be used for non-load
bearing construction fill,
00:24:55.840 --> 00:24:59.100
cement bulking agents,
landfill capping material,
00:24:59.100 --> 00:25:02.770
or berm material for
commercial and industrial sites.
00:25:02.770 --> 00:25:06.780
It should be noted that
while applications to recycle
00:25:07.734 --> 00:25:10.870
road base and reusable
product are similar,
00:25:10.870 --> 00:25:12.940
they do have different
testing parameters
00:25:12.940 --> 00:25:15.783
depending on which
end product is applied for.
00:25:19.650 --> 00:25:23.170
So each solid recycling
facility that is permitted
00:25:23.170 --> 00:25:26.793
must complete a trial run
before operations may start.
00:25:26.793 --> 00:25:30.950
1,000 cubic yards must be
sampled, analyzed, and approved
00:25:30.950 --> 00:25:32.880
to demonstrate the facility's ability
00:25:32.880 --> 00:25:35.730
to comply with environmental standards.
00:25:35.730 --> 00:25:38.470
If a facility intends
to switch the product
00:25:38.470 --> 00:25:41.400
between roadbase or reusable material
00:25:41.400 --> 00:25:43.900
during any time while
they operate a permit,
00:25:43.900 --> 00:25:47.220
a new trial run will be required
00:25:47.220 --> 00:25:49.443
with the new analytical parameters.
00:25:50.510 --> 00:25:54.760
A notice to operators was
issued in December of 2014
00:25:54.760 --> 00:25:57.330
to maintain that used
drilling mud or fluid
00:25:57.330 --> 00:26:00.450
is under the jurisdiction
of the Commission.
00:26:00.450 --> 00:26:03.930
However, a permit is not
required if used drilling mud
00:26:03.930 --> 00:26:07.920
is treated on a Commission-issued
lease or drilling unit,
00:26:07.920 --> 00:26:10.170
and any resulting refined product
00:26:10.170 --> 00:26:12.933
is also not under the
jurisdiction of the Commission.
00:26:17.670 --> 00:26:21.720
All fluid recycling is
covered by Divisions 5 and 6
00:26:21.720 --> 00:26:25.040
to reuse fluid for downhole purposes.
00:26:25.040 --> 00:26:29.340
Division 5 consists of
off-lease or centralized recycling
00:26:29.340 --> 00:26:33.000
for a maximum of two
years at any location
00:26:33.000 --> 00:26:35.260
and requires the same
application requirements
00:26:35.260 --> 00:26:38.590
described for Division
3, while Division 6
00:26:38.590 --> 00:26:41.900
consists of stationary
fluid recycling facilities
00:26:41.900 --> 00:26:44.200
that are permanent for up five years
00:26:44.200 --> 00:26:47.313
and have similar application
requirements to Division 4.
00:26:51.000 --> 00:26:54.160
So as mentioned, these recycled fluids
00:26:54.160 --> 00:26:56.460
may only be used for downhole purposes
00:26:56.460 --> 00:27:00.090
such as drilling fluid, frack fluid,
00:27:00.090 --> 00:27:03.213
concrete makeup water, among other uses.
00:27:06.610 --> 00:27:09.100
So earlier I briefly explained
00:27:09.100 --> 00:27:11.930
what may be needed
to apply for each facility,
00:27:11.930 --> 00:27:15.610
but each division rule for
both solid and fluid recycling
00:27:15.610 --> 00:27:18.970
acts as a permitting guide
to apply for an application
00:27:18.970 --> 00:27:22.570
and further explains what
requirements are necessary.
00:27:22.570 --> 00:27:25.250
All applications must be
submitted by hard copy
00:27:25.250 --> 00:27:28.650
to Technical Permitting in
Austin with original signatures,
00:27:28.650 --> 00:27:33.210
and include the operator,
location, and design information,
00:27:33.210 --> 00:27:36.350
plus the specific attachments
and notice requirements
00:27:36.350 --> 00:27:39.033
required by the division
of the desired permit.
00:27:40.120 --> 00:27:42.540
Applications for all recycling permits
00:27:42.540 --> 00:27:45.973
must also include a cost
closure estimate for review.
00:27:49.420 --> 00:27:52.970
Recent legislation
passed in the 87th session
00:27:52.970 --> 00:27:54.760
will require the Railroad Commission
00:27:54.760 --> 00:27:57.550
to establish or rely on current rules
00:27:57.550 --> 00:28:00.213
for the recycling of
commercial fluid recycling.
00:28:02.860 --> 00:28:07.100
So that concludes my
portion of the presentation
00:28:07.100 --> 00:28:08.340
for you today.
00:28:08.340 --> 00:28:10.713
I will open up the
floor for any questions.
00:28:13.870 --> 00:28:15.650
No questions, Riley.
00:28:15.650 --> 00:28:16.780
All right.
00:28:16.780 --> 00:28:19.470
Well, if you have any
further questions in the future,
00:28:19.470 --> 00:28:21.493
my contact information is here,
00:28:22.540 --> 00:28:25.670
but for now, I will go ahead
and turn it over to Abby.
00:28:25.670 --> 00:28:26.503
Thank you.
00:28:28.730 --> 00:28:30.320
Thank you, Riley.
00:28:30.320 --> 00:28:32.750
Hello, my name is Abby Klein,
00:28:32.750 --> 00:28:34.530
and I will begin by talking about
00:28:34.530 --> 00:28:36.663
the notice requirements by rule.
00:28:37.950 --> 00:28:41.350
Notice requirements
under Statewide Rule 8
00:28:41.350 --> 00:28:45.960
apply to all hydrostatic
test discharges, pits,
00:28:45.960 --> 00:28:50.010
landspreading, and
waste separation facilities.
00:28:50.010 --> 00:28:54.180
Reclamation facilities have
their own specific requirements
00:28:54.180 --> 00:28:56.283
under Statewide Rule 57.
00:28:58.290 --> 00:29:01.270
Recycling Divisions 2 through 6
00:29:01.270 --> 00:29:03.540
each have their own notice requirements
00:29:03.540 --> 00:29:08.540
under 16 Texas Administrative
Code Chapter 4, Subchapter B.
00:29:09.660 --> 00:29:13.410
Any facility that falls
under the category
00:29:13.410 --> 00:29:18.410
of a commercial disposal
facility such as a commercial pit,
00:29:18.740 --> 00:29:21.990
landspreading, or
waste separation facility
00:29:21.990 --> 00:29:23.990
must complete notice requirements
00:29:23.990 --> 00:29:27.883
under the Texas Natural
Resources Code Chapter 91.
00:29:29.730 --> 00:29:30.830
Now that you know
00:29:30.830 --> 00:29:34.290
which rule each facility
is categorized under,
00:29:34.290 --> 00:29:36.550
I will talk about the
notice requirements
00:29:36.550 --> 00:29:38.570
stated in each rule.
00:29:38.570 --> 00:29:42.490
Statewide Rule 8 requires
the operator to provide notice
00:29:42.490 --> 00:29:45.680
to the surface owner where
disposal will take place
00:29:45.680 --> 00:29:48.490
and to the city clerk or other official
00:29:48.490 --> 00:29:52.400
if the facility is located
within corporate limits.
00:29:52.400 --> 00:29:55.630
If the facility is
categorized as commercial,
00:29:55.630 --> 00:29:58.230
the operator is required
to provide notice
00:29:58.230 --> 00:30:01.400
to adjacent landowners
within a half mile
00:30:01.400 --> 00:30:03.400
from the facility boundaries.
00:30:03.400 --> 00:30:05.550
Additionally, under Rule 8,
00:30:05.550 --> 00:30:08.320
the director of the Oil and Gas Division
00:30:08.320 --> 00:30:11.730
can require an operator
to notice additional parties,
00:30:11.730 --> 00:30:15.173
such as local authorities,
on a case-by-case basis.
00:30:17.530 --> 00:30:21.480
Notice given under Rule 8
must be mailed or delivered
00:30:21.480 --> 00:30:24.320
on or before the date
the application is mailed
00:30:24.320 --> 00:30:27.100
or delivered to the
Commission in Austin,
00:30:27.100 --> 00:30:30.790
however, it is recommended
that notice should not be given
00:30:30.790 --> 00:30:33.853
more than 15 days before
the application is submitted.
00:30:36.780 --> 00:30:40.480
Statewide Rule 57 requires
the operator applying
00:30:40.480 --> 00:30:43.560
for a reclamation plant
permit provide notice
00:30:43.560 --> 00:30:45.640
to the surface owner and county clerk
00:30:45.640 --> 00:30:48.800
where the facility will be located.
00:30:48.800 --> 00:30:52.050
Notice must also be
provided to the city clerk
00:30:52.050 --> 00:30:54.720
if the location is
within corporate limits
00:30:54.720 --> 00:30:58.390
and published in a
newspaper of general circulation
00:30:58.390 --> 00:31:00.023
in the corresponding county.
00:31:01.820 --> 00:31:06.590
Notice given under Rule 57
must be mailed or delivered
00:31:06.590 --> 00:31:09.030
and published on or before the date
00:31:09.030 --> 00:31:11.360
the application is mailed or delivered
00:31:11.360 --> 00:31:13.670
to the Commission in Austin.
00:31:13.670 --> 00:31:17.220
Again, it's recommended that
notice should not be published
00:31:17.220 --> 00:31:20.623
more than 15 days before
the application is submitted.
00:31:22.141 --> 00:31:26.490
Chapter 4, Subchapter B,
which governs recycling facilities,
00:31:26.490 --> 00:31:30.740
requires the operator to provide
notice to the surface owner
00:31:30.740 --> 00:31:33.550
where the recycling
facility will be located
00:31:33.550 --> 00:31:34.830
and to the city clerk
00:31:34.830 --> 00:31:37.920
if the location is
within corporate limits.
00:31:37.920 --> 00:31:41.320
Notice must also be given
to adjacent landowners
00:31:41.320 --> 00:31:45.150
within a half mile of
the facility boundaries.
00:31:45.150 --> 00:31:48.540
For commercial recycling
facility applications
00:31:48.540 --> 00:31:52.320
under Division 4 and 6,
notice must be published
00:31:52.320 --> 00:31:55.240
in a newspaper of general circulation
00:31:55.240 --> 00:31:56.983
in the corresponding county.
00:31:58.800 --> 00:32:01.650
Notice for cycling facility applications
00:32:01.650 --> 00:32:05.810
should be mailed or
delivered on or after the date
00:32:05.810 --> 00:32:07.750
the application is mailed or delivered
00:32:07.750 --> 00:32:10.220
to the Commission in Austin.
00:32:10.220 --> 00:32:13.690
Published notice
should occur once a week
00:32:13.690 --> 00:32:17.800
for two consecutive weeks,
with the first publication
00:32:17.800 --> 00:32:22.330
occurring not earlier than
the date the application is filed
00:32:22.330 --> 00:32:24.800
and not later than the 30th day
00:32:24.800 --> 00:32:28.523
after the application is
received by the Commission.
00:32:30.620 --> 00:32:34.610
Chapter 91 of the Texas
Natural Resources Code
00:32:34.610 --> 00:32:38.883
requires that commercial
disposal facilities publish notice
00:32:38.883 --> 00:32:41.790
in a newspaper of general circulation
00:32:41.790 --> 00:32:45.340
for the county where
the facility will be located.
00:32:45.340 --> 00:32:48.780
Published notice must occur once a week
00:32:48.780 --> 00:32:52.540
for two consecutive weeks,
with the first publication
00:32:52.540 --> 00:32:56.620
occurring not earlier than
the date the application is filed
00:32:56.620 --> 00:32:59.150
and not later than the 30th day
00:32:59.150 --> 00:33:02.293
after the application is
received by the Commission.
00:33:03.830 --> 00:33:07.960
Operators must give notice
when filing a new application
00:33:07.960 --> 00:33:12.050
or renewal or requesting
a major amendment.
00:33:12.050 --> 00:33:15.420
Renewal applications
have the same requirements
00:33:15.420 --> 00:33:19.210
as a brand new application
and amendment requirements
00:33:19.210 --> 00:33:22.333
are determined on a case-by-case basis.
00:33:25.070 --> 00:33:28.780
When giving notice to surface
owners, adjacent landowners,
00:33:28.780 --> 00:33:31.887
or local officials, the
notice must include
00:33:31.887 --> 00:33:34.840
the complete copy of the application,
00:33:34.840 --> 00:33:37.110
the instructions for protest,
00:33:37.110 --> 00:33:40.150
the mailing address
for Technical Permitting,
00:33:40.150 --> 00:33:43.610
and the description of
the facility's operations.
00:33:43.610 --> 00:33:46.230
Protest deadlines vary under each rule
00:33:46.230 --> 00:33:49.510
so make sure to check
each application requirement
00:33:49.510 --> 00:33:51.853
to provide the correct instructions.
00:33:53.750 --> 00:33:56.370
When publishing notice in the newspaper,
00:33:56.370 --> 00:33:58.160
the notice must include the date
00:33:58.160 --> 00:34:03.080
the application was or will
be filed, the facility location,
00:34:03.080 --> 00:34:07.400
including the county, serving
name, and object number,
00:34:07.400 --> 00:34:11.070
the direction and distance
from the nearest city
00:34:11.070 --> 00:34:14.950
or municipality, the
name of the surface owner,
00:34:14.950 --> 00:34:16.860
the name of the applicant,
00:34:16.860 --> 00:34:20.640
the type of waste that will
be disposed of at the facility,
00:34:20.640 --> 00:34:23.430
the disposal methods
that will take place,
00:34:23.430 --> 00:34:26.010
and the procedure for
protesting the application.
00:34:26.010 --> 00:34:29.280
The recommended published notice form
00:34:29.280 --> 00:34:31.110
can be found on our website
00:34:31.110 --> 00:34:33.363
and is linked on the
notes of this slide.
00:34:35.610 --> 00:34:37.940
Operators must provide proof of notice,
00:34:37.940 --> 00:34:41.200
which must include a
copy of the notice letter
00:34:41.200 --> 00:34:43.750
or a signed statement
from the effected party
00:34:43.750 --> 00:34:46.090
that the application was received.
00:34:46.090 --> 00:34:49.530
It is recommended that
certified mail be used
00:34:49.530 --> 00:34:52.810
and that certified mail
receipts be provided as proof
00:34:52.810 --> 00:34:55.080
that proper notice was given.
00:34:55.080 --> 00:34:57.830
The tear sheets from
the published newspaper
00:34:57.830 --> 00:35:01.330
must be provided, as
well as a sworn affidavit
00:35:01.330 --> 00:35:03.113
from the newspaper publisher.
00:35:04.140 --> 00:35:07.523
A recommended affidavit form
can be found on our website.
00:35:09.960 --> 00:35:12.760
A summary table that
lists the applicable rules
00:35:12.760 --> 00:35:17.220
to each type of application
can be found on our website.
00:35:17.220 --> 00:35:20.700
It is recommended that
operators refer to this table
00:35:20.700 --> 00:35:23.673
when determining the notice
required for their application.
00:35:27.150 --> 00:35:30.860
If the operator owns the
land of the proposed facility,
00:35:30.860 --> 00:35:33.760
then landowner notice is not required.
00:35:33.760 --> 00:35:37.660
If providing a telephone
number when giving notice,
00:35:37.660 --> 00:35:40.040
make sure that the correct phone number
00:35:40.040 --> 00:35:43.660
for the Environmental Permits
and Support Division is used.
00:35:43.660 --> 00:35:45.740
If an incorrect number is provided,
00:35:45.740 --> 00:35:47.400
notice will not be accepted
00:35:47.400 --> 00:35:49.760
and the application may be returned
00:35:49.760 --> 00:35:52.593
so make sure to use
the number on this slide.
00:35:55.610 --> 00:35:57.370
Failure to provide proper notice
00:35:57.370 --> 00:36:00.060
can result in the
application being returned
00:36:00.060 --> 00:36:02.100
or the permit being canceled.
00:36:02.100 --> 00:36:04.010
Protests can not be accepted
00:36:04.010 --> 00:36:07.700
outside of the timeframe
specified in each rule.
00:36:07.700 --> 00:36:11.620
If late protests are received,
they can only be accepted
00:36:11.620 --> 00:36:14.853
as a public comment
to be included in the file.
00:36:18.060 --> 00:36:19.860
If there are any questions at this time,
00:36:19.860 --> 00:36:22.490
I'll pause for a moment
to give you an opportunity
00:36:22.490 --> 00:36:23.840
to enter them into the Q&A.
00:36:24.680 --> 00:36:26.530
Are there any questions at this time?
00:36:32.250 --> 00:36:34.010
There's one
question that I'm answering,
00:36:34.010 --> 00:36:35.210
you're good to go, Abby.
00:36:36.390 --> 00:36:38.063
All right, let's move on then.
00:36:41.090 --> 00:36:43.460
I'll now move on to
additional requirements
00:36:43.460 --> 00:36:46.720
for commercial facility
applications which include
00:36:46.720 --> 00:36:48.700
a financial security
00:36:48.700 --> 00:36:51.637
and the corresponding
closure cost estimate,
00:36:51.637 --> 00:36:55.120
and restrictive covenant if needed,
00:36:55.120 --> 00:36:58.690
and naturally occurring
radioactive materials
00:36:58.690 --> 00:37:01.950
or a NORM survey for existing facilities
00:37:01.950 --> 00:37:05.403
that are conducted every
five years or during renewal.
00:37:07.660 --> 00:37:10.220
I will cover each of
these topics individually,
00:37:10.220 --> 00:37:12.400
starting with financial security
00:37:12.400 --> 00:37:14.173
and the closure cost estimate.
00:37:16.040 --> 00:37:20.120
Under Statewide Rule 78,
commercial facilities are required
00:37:20.120 --> 00:37:23.950
to maintain a financial
security equal to or greater
00:37:23.950 --> 00:37:28.170
than the maximum amount
necessary to close the facility
00:37:28.170 --> 00:37:30.763
at any time during
the life of the permit.
00:37:31.860 --> 00:37:34.770
In order to determine its closure cost,
00:37:34.770 --> 00:37:37.240
the applicant must submit what is called
00:37:37.240 --> 00:37:39.440
a closure cost estimate.
00:37:39.440 --> 00:37:44.240
A closure cost estimate,
or CCE, is a written estimate
00:37:44.240 --> 00:37:48.080
approved by the Commission
and is equal to or greater
00:37:48.080 --> 00:37:50.580
than the maximum amount necessary
00:37:50.580 --> 00:37:53.410
to close the commercial facility.
00:37:53.410 --> 00:37:57.200
The full rules can be found
in the Statewide Rule 78
00:37:57.200 --> 00:37:59.560
and the CCE must be approved
00:37:59.560 --> 00:38:02.483
prior to submitting
the financial security.
00:38:04.570 --> 00:38:07.080
Since financial security is required
00:38:07.080 --> 00:38:11.700
for all commercial facilities,
a CCE must be provided
00:38:11.700 --> 00:38:15.230
for any commercial facility application.
00:38:15.230 --> 00:38:19.870
An updated CCE is required
for a renewal application
00:38:19.870 --> 00:38:22.350
or every five years.
00:38:22.350 --> 00:38:24.170
If an applicant is requesting
00:38:24.170 --> 00:38:27.260
to transfer a
commercial facility permit,
00:38:27.260 --> 00:38:29.903
the new operator must submit a CCE.
00:38:31.000 --> 00:38:34.540
At any time an amendment is required,
00:38:34.540 --> 00:38:37.180
a new estimate maybe required.
00:38:37.180 --> 00:38:40.170
This is determined on
a case-by-case basis,
00:38:40.170 --> 00:38:41.890
but a good rule of thumb
00:38:41.890 --> 00:38:46.270
is that if the closure costs
will increase by more than 10%,
00:38:46.270 --> 00:38:49.900
a new closure cost
estimate will be required.
00:38:49.900 --> 00:38:54.500
The CCE must be approved
and the financial security provided
00:38:54.500 --> 00:38:57.723
before any approved
modifications can take place.
00:38:59.990 --> 00:39:03.470
This is a list of the main
components that must be included
00:39:03.470 --> 00:39:05.840
in a closure cost estimate.
00:39:05.840 --> 00:39:09.720
Since the estimate must reflect
the maximum amount necessary
00:39:09.720 --> 00:39:11.177
to close the facility
00:39:11.177 --> 00:39:14.450
and must assume the worst case scenario,
00:39:14.450 --> 00:39:17.820
and that no waste can
be disposed of onsite,
00:39:17.820 --> 00:39:21.130
therefore, the CCE must include the cost
00:39:21.130 --> 00:39:23.330
for offsite waste disposal,
00:39:23.330 --> 00:39:26.490
along with waste
loading and transportation,
00:39:26.490 --> 00:39:29.490
tank and concrete cleaning and disposal,
00:39:29.490 --> 00:39:34.490
contaminated soil
remediation, site restoration,
00:39:34.500 --> 00:39:38.180
soil sampling, monitor well plugging,
00:39:38.180 --> 00:39:41.900
and any oversight and contingency costs.
00:39:41.900 --> 00:39:46.130
Post closure activities may
include groundwater monitoring
00:39:46.130 --> 00:39:50.560
and disposal pit inspections
for five years after closure.
00:39:50.560 --> 00:39:53.990
If NORM is determined
to be present at a facility,
00:39:53.990 --> 00:39:57.830
the cost to decontaminate
any effected equipment
00:39:57.830 --> 00:40:01.343
under the State Health
Services rules must be included.
00:40:03.650 --> 00:40:06.740
The operator must include
all assumptions used
00:40:06.740 --> 00:40:09.920
to determine their closure cost estimate
00:40:09.920 --> 00:40:11.490
and as previously mentioned,
00:40:11.490 --> 00:40:14.480
must be based on the
worst case scenario.
00:40:14.480 --> 00:40:16.210
For example, it must be assumed
00:40:16.210 --> 00:40:19.340
that the facility is at full capacity
00:40:19.340 --> 00:40:23.020
and all pits and or tanks are full.
00:40:23.020 --> 00:40:24.840
The CCE cannot assume
00:40:24.840 --> 00:40:27.360
that any equipment will stay on location
00:40:27.360 --> 00:40:30.870
as that does not represent
the worst case scenario.
00:40:30.870 --> 00:40:34.830
If a CCE assumes that backfill
material from the property
00:40:34.830 --> 00:40:38.080
will be used as agreed by the landowner,
00:40:38.080 --> 00:40:40.440
a restrictive covenant must be provided,
00:40:40.440 --> 00:40:42.243
which I will cover in a few slides.
00:40:44.150 --> 00:40:48.700
Once an application is
complete and the CCE approved,
00:40:48.700 --> 00:40:52.390
Technical Permitting will
issue a CCE approval letter
00:40:52.390 --> 00:40:56.370
documenting the required
amount of financial security.
00:40:56.370 --> 00:40:59.530
The operator can file financial security
00:40:59.530 --> 00:41:02.700
in the form of a bond
or a letter of credit.
00:41:02.700 --> 00:41:05.950
Any questions related
to filing financial security
00:41:05.950 --> 00:41:09.390
should be directed
to the P-5 department.
00:41:09.390 --> 00:41:12.990
The financial security must
be provided and approved
00:41:12.990 --> 00:41:16.633
prior to beginning operations
at the permitted facility.
00:41:18.210 --> 00:41:21.330
This means that during
the renewal, transfer,
00:41:21.330 --> 00:41:23.840
or amendment of an active facility,
00:41:23.840 --> 00:41:26.160
financial security must be provided
00:41:26.160 --> 00:41:28.793
before a new permit can be issued.
00:41:29.850 --> 00:41:32.410
The financial security
must be maintained
00:41:32.410 --> 00:41:34.370
until the facility has been closed
00:41:34.370 --> 00:41:36.433
according to permit conditions.
00:41:38.410 --> 00:41:39.740
As previously mentioned,
00:41:39.740 --> 00:41:41.993
I will now cover restrictive covenants.
00:41:44.420 --> 00:41:47.650
A restrictive covenant is
a deed restriction stating
00:41:47.650 --> 00:41:50.130
that a specified soil material
00:41:50.130 --> 00:41:53.403
will be used and restricted
for closure activities.
00:41:54.960 --> 00:41:57.080
A restrictive covenant is required
00:41:57.080 --> 00:41:59.680
if fill dirt used to close the site
00:41:59.680 --> 00:42:02.563
will be stored or
excavated from the property.
00:42:04.480 --> 00:42:08.420
A restrictive covenant form
is available on our website
00:42:08.420 --> 00:42:10.390
and includes a deed restriction
00:42:10.390 --> 00:42:14.360
stating that the soils will
be available for closure.
00:42:14.360 --> 00:42:18.320
It includes the location,
type, and volume of material.
00:42:18.320 --> 00:42:21.320
And lastly, two exhibits
must be attached
00:42:21.320 --> 00:42:24.800
that have been certified by
a professional land surveyor
00:42:24.800 --> 00:42:27.033
registered in the state of Texas.
00:42:28.610 --> 00:42:30.720
To file a restrictive covenant,
00:42:30.720 --> 00:42:32.600
the operator must submit a draft
00:42:32.600 --> 00:42:34.613
to be reviewed by legal counsel.
00:42:35.450 --> 00:42:38.223
Once the draft is approved,
along with the CCE,
00:42:39.160 --> 00:42:42.130
the operator must submit
a restrictive covenant
00:42:42.130 --> 00:42:44.673
signed by the operator and landowner.
00:42:45.680 --> 00:42:49.170
A representative from the
Commission will sign the copy
00:42:49.170 --> 00:42:51.670
and return it to the operator.
00:42:51.670 --> 00:42:55.110
The operator must then
file the restrictive covenant
00:42:55.110 --> 00:42:57.140
in the corresponding county
00:42:57.140 --> 00:43:00.750
and provide the proof of
filing back to the Commission.
00:43:00.750 --> 00:43:03.690
This must be done before
operations can commence
00:43:03.690 --> 00:43:05.253
at the permitted facility.
00:43:06.930 --> 00:43:09.713
Lastly, I will cover NORM
and NORM surveys.
00:43:11.320 --> 00:43:15.370
NORM stands for Naturally
Occurring Radioactive Material,
00:43:15.370 --> 00:43:19.460
which is often encountered
in oil and gas exploration,
00:43:19.460 --> 00:43:23.330
development, and production
operations, and originates
00:43:23.330 --> 00:43:27.210
from the subsurface
formation encountered by wells.
00:43:27.210 --> 00:43:29.080
NORM typically accumulates
00:43:29.080 --> 00:43:32.500
in the solids found at the
bottom of pits and tanks
00:43:32.500 --> 00:43:37.230
sometimes referred to as
sludge, tank bottoms, or BS&W,
00:43:37.230 --> 00:43:39.990
basic sediment and waste.
00:43:39.990 --> 00:43:43.150
Commission rules related
to NORM can be found
00:43:43.150 --> 00:43:47.853
in 16 Texas Administrative
Code Chapter 4, Subchapter F.
00:43:49.650 --> 00:43:51.160
NORM is regulated
00:43:51.160 --> 00:43:54.430
by the Texas Department
of State Health Services,
00:43:54.430 --> 00:43:58.470
which governs the possession,
use, transfer, transport,
00:43:58.470 --> 00:44:01.430
and storage of NORM waste.
00:44:01.430 --> 00:44:05.170
The Commission can authorize
the disposal of NORM waste
00:44:05.170 --> 00:44:07.563
in NORM-approved injection wells.
00:44:09.180 --> 00:44:11.570
A NORM survey must be completed
00:44:11.570 --> 00:44:15.180
during the renewal of an
existing commercial facility
00:44:15.180 --> 00:44:17.500
or every five years.
00:44:17.500 --> 00:44:19.430
As previously mentioned,
00:44:19.430 --> 00:44:22.720
if NORM is found to
be present at a facility,
00:44:22.720 --> 00:44:26.720
the cost to dispose of the
NORM waste must be included
00:44:26.720 --> 00:44:28.450
in the closure cost estimate
00:44:28.450 --> 00:44:30.893
and corresponding financial security.
00:44:32.520 --> 00:44:36.590
A NORM survey is conducted
using a scintillation meter.
00:44:36.590 --> 00:44:39.450
When providing the
results of the survey,
00:44:39.450 --> 00:44:42.730
the operator should
include the date of the survey
00:44:42.730 --> 00:44:46.630
and the instrument used,
including the calibration records.
00:44:46.630 --> 00:44:49.830
The results should include
a background reading
00:44:49.830 --> 00:44:53.700
and the results of the NORM
readings from any tanks, pits,
00:44:53.700 --> 00:44:54.823
and other equipment.
00:44:56.860 --> 00:44:59.670
If NORM is detected at a facility,
00:44:59.670 --> 00:45:01.700
the NORM-contaminated equipment
00:45:01.700 --> 00:45:04.360
must be clearly labeled as NORM
00:45:04.360 --> 00:45:06.833
in legible and waterproof writing.
00:45:09.750 --> 00:45:12.560
This concludes the
part two presentation.
00:45:12.560 --> 00:45:15.690
We would like to thank
everybody for joining us today.
00:45:15.690 --> 00:45:17.510
If there are any last questions,
00:45:17.510 --> 00:45:21.100
please don't hesitate to
enter them into the Q&A
00:45:21.100 --> 00:45:24.190
or reach out to a member of our team.
00:45:24.190 --> 00:45:26.290
Are there any last
questions at this time?
00:45:31.620 --> 00:45:33.260
There's no
questions right now.
00:45:33.260 --> 00:45:35.564
We can give them a minute or so.
00:45:35.564 --> 00:45:36.397
Okay.
00:45:58.860 --> 00:46:00.970
Well, I don't see
anything coming in Abby,
00:46:00.970 --> 00:46:05.750
so we will end and let people go.
00:46:05.750 --> 00:46:10.750
So I'll just say, we'd
like to invite all attendees
00:46:11.060 --> 00:46:14.960
to complete an evaluation
about our presentation today.
00:46:14.960 --> 00:46:17.060
It's been recorded and will be available
00:46:17.060 --> 00:46:20.783
on our webinar homepage
and thank you for coming.