railroad commission of t › media › 38161 › bfi_waste_systems... · 2017-02-01 · david...

DAVID PORTER, CHAIRMAN LORI WROTENBERY CHRISTI CRADDICK, COMMISSIONER DIRECTOR, OIL AND GAS DIVISION RYAN SITTON, COMMISSIONER LESLIE SAVAGE, P.G. ASSISTANT DIRECTOR, TECHNICAL PERMITTING

RAILROAD COMMISSION OF TEXAS OIL AND GAS DIVISION

1701 NORTH CONGRESS AVENUE � POST OFFICE BOX 12967 � AUSTIN, TEXAS 78711-2967 � PHONE: 512/463-3840 � FAX: 512/463-6780

TDD 800/735-2989 OR TDY 512/463-7284� AN EQUAL OPPORTUNITY EMPLOYER� http://www.rrc.texas.gov

PERMIT TO STORE, HANDLE, AND TREAT CERTAIN NON-HAZARDOUS OIL AND GAS WASTES

Permit No. STF-086 Washout Pit Permit Nos. P012163, P012164, and P012165A/B/C/D/E/F

Collecting Pit Permit Nos. P012213, P012214, P012215, P012216 and P012217

BFI WASTE SYSTEMS OF NA, LLC 7000 IH 10 EAST SAN ANTONIO, TX 78219 Based on information contained in your application, received July 10, 2014 and subsequent information received to date, you are hereby authorized to receive, store, handle, and treat certain oil and gas wastes as specified below at the following facility: Commercial Stationary Treatment Facility (STF) Tessman Road Landfill TCEQ Permit No. MSW-1410C 19.61 acres of Juan Jose Sanchez Survey No. 34 Latitude/Longitude: 29.440833°, -98.344444° Bexar County, Texas RRC San Antonio, District 01 NARRATIVE DESCRIPTION OF PROCESS: Incoming oil and gas waste is offloaded into one of four Collecting Pits (P012214, P012215, P012216, and P012217) or into aboveground storage tanks. The oil and gas waste from the collecting pits is then directed to a shaker tank for separation of fluids and solids. Removed solids will be conveyed to a solids bin, while fluids will drop into a receiving tank and will then be metered and transferred to a feed tank for processing by centrifuge. The centrifuge system will include a feed polymer flocculent mixture to enhance phase separation. Separated water and hydrocarbon will be pumped to dedicated storage tanks, and any solids will be directed to a solids bin. Processed solids are then conveyed to the onsite Texas Commission on Environmental Quality (TCEQ) landfill pits for interment. The separated liquid waste will be transported to a Railroad Commission of Texas (RRC) permitted Class II injection well for disposal or solidified and interred in the TCEQ landfill. The recovered hydrocarbon fraction will be transported to a permitted off-site oil reclamation plant.

BFI Waste Systems of NA, LLC of 11

Collecting Pit P012213 will be used to collect spills or leaks from the truck loading area.

The truck washout facility will consist of six (6) washout bays (P012165A/B/C/D/E/F) and drain to a trough (P012164) and then to a collection sump (P012163). Solids collected in the trough will be removed by a front-end loader and transported to either the centrifuge facility or the TCEQ-regulated landfill for disposal. Liquids from the truck washout will flow to a sump where it will be pumped to a storage tank at the centrifuge facility for treatment and processing.

Authority is granted to receive, store, handle, and treat certain oil and gas wastes in accordance with Texas Administrative Code (TAC) Title 16, Part 1, Chapter 3.8 (Statewide Rule 8) and Chapter 4, Subchapter B subject to the following minimum conditions:

I. GENERAL PERMIT CONDITIONS

A. The effective date of this permit is March 8, 2016, and the authority granted by this permit expires on March 7, 2021.

B. The permittee shall maintain financial security in the amount of $311,852.00 until this facility, including all associated pits, has been closed in accordance with this permit. Technical Permitting reserves the right to revise this amount, as necessary. Prior to any modification of this facility that would require increased financial security, an updated closure cost estimate must be submitted to Technical Permitting in Austin, and any additional financial security must be filed with and approved by the RRC prior to making that modification.

C. Technical Permitting in Austin and the appropriate District Office must be notified in writing when construction of the facility begins, and when the facility is complete. The permittee may not receive, store, handle, or treat oil and gas waste at the facility until the appropriate District Office has performed its inspection of the completed facility and has verified that it is constructed in accordance with the application and this permit.

D. The permittee may not receive, store, handle, or treat oil and gas waste at the facility until all necessary air permits (if any) are obtained from the TCEQ.

E. One (1) on-site 100-foot soil boring should be drilled near the center of the facility that will demonstrate the presence or absence of groundwater. If the boring identified groundwater after a 24-hour stabilization period, groundwater monitor wells must be installed.

F. This permit may be considered for administrative renewal upon review by the RRC. Any request for renewal should be received at least 60 days prior to the permit expiration date.

G. This permit is not transferable without the consent of the RRC. Any request for transfer of this permit must be filed with Technical Permitting in Austin at least 60 days before the permittee wishes the transfer to take place.

H. Any deviation from this permit must be approved by amendment from Technical Permitting in Austin before implementation.

I. Unless otherwise required by conditions of this permit, construction, use, and maintenance of the facility must be in accordance with the information represented in the permit application and attachments thereto. When construction of the facility is


completed, submit “as-built” plans to be incorporated as part of the permit application.

J. This permit does not authorize discharge from the facility of any oil and gas waste, including contaminated stormwater.

K. The permittee must post a sign at the facility entrance, which must show the permit number in numerals at least three inches in height.

L. Any soil, media, or other debris contaminated by a spill of waste or any other materials at the facility must be cleaned up immediately and processed through the facility or disposed of in an authorized manner.

M. Safety Data Sheets (SDS) must be submitted to Technical Permitting in Austin for any chemical proposed to be used in the treatment of waste at the facility. Use of the compound is contingent upon RRC approval.

N. All chemical laboratory analyses required to be performed in accordance with this permit must be performed using appropriate Environmental Protection Agency (EPA) methods or Standard Methods by an independent National Environmental Laboratory Accreditation Program (NELAP) certified laboratory neither owned nor operated by the permittee. Any sample collected for chemical laboratory analysis must be collected and preserved in a manner appropriate for that analytical method as specified in 40 CFR Part 136. All geotechnical testing must be performed by a laboratory certified to conduct geotechnical testing according to the standards specified by ASTM International (ASTM).

O. The permittee must make all records required by this permit available for review and copying during normal business hours upon request of RRC personnel.

P. The permittee must submit a Quarterly Report containing information required in Permit Conditions III.F., IV.M., VI.D, and VIII.H. of this permit.

The reporting periods are from January 1 through March 31, April 1 through June 30, July 1 through September 30, and October 1 through December 31 of each year.

The Quarterly Reports must be submitted to Technical Permitting in Austin and the appropriate District Office no later than the 31st day of the month following each reporting period, or each May 1, July 31, October 31, and January 31, respectively.

Q. All hydrocarbons recovered by the separation facility must be sent to an offsite RRC permitted reclamation plant for further processing.

R. A site-specific Spill Prevention, Control and Countermeasure (SPCC) Plan must be provided to and approved by Technical Permitting. A copy of the approved SPCC Plan must be maintained on-site and made available to Commission staff for review and inspection upon request.

S. Failure to comply with any provision of this permit will be cause for modification, suspension or termination of this permit.


II. AUTHORIZED WASTES

A. Only oil and gas wastes subject to the jurisdiction of the RRC that are non-hazardous or exempt from the Resource Conservation and Recovery Act (RCRA), Subtitle C may be received. You may receive, store, handle, treat and process only the following non-reclaimable oil and gas wastes:

1. Water-based drilling fluids and associated cuttings;

2. Oil-based drilling fluids and associated cuttings; and

3. Hydraulic fracturing flowback water.

B. No oil and gas Naturally Occurring Radioactive Material (NORM) waste as defined in 16 TAC §4.603 (Oil and Gas NORM) or waste from a facility that is licensed by the Texas Department of State Health Services to process or treat oil and gas NORM waste may be received at this facility.

C. No asbestos-containing material regulated under the Clean Air Act or Polychlorinated Biphenyl (PCB) containing material regulated under the Toxic Substances Control Act may be accepted for processing at the facility.

D. This permit does not authorize the active reclamation of crude oil from oil and gas waste. A request for authorization under 16 TAC §3.57 (Statewide Rule 57) must be submitted to and approved by Technical Permitting in Austin prior to any reclamation activities at the referenced facility.

E. The permittee shall not accept waste from a waste hauler unless the waste hauler has an RRC issued waste hauler permit and is authorized to deposit waste at this facility.

III. WASTE TESTING AND RECORD KEEPING REQUIREMENTS

A. For the purposes of this permit, a representative sample of incoming waste is defined as a composite sample composed of one grab sample from each 50 cubic yards of waste material from each job (e.g., from each well, pit, spill location.)

B. Prior to receipt at the site, representative samples of waste from commercial oil and gas facilities must be analyzed and may not exceed the limit for the following parameter:

PARAMETER LIMITATION

Total Organic Halides (TOX) 100 mg/l (EPA Method 9020B)

or

Extractable Organic Halides (EOX) 100 mg/kg (EPA Method 9023)

Special authorization for receipt of waste with a TOX > 100 parts per million (ppm) may be considered. Authority must be obtained from Technical Permitting in Austin prior to processing of waste.

C. Each load of incoming waste, other than water-based drilling fluids and associated cuttings, or oil-based drilling fluid and associated cuttings, must be scanned for the presence of NORM using a scintillation meter with a sodium iodide detector. Any


load with a reading of 50 microroentgens per hour or greater may not be unloaded or processed at the facility unless further analysis of the waste demonstrates that the waste does not exceed 30 picocuries per gram Radium-226 combined with Radium-228, and 150 picocuries per gram of any other radionuclide.

D. The permittee must maintain the following records on each load of waste received at the facility for a period of three years from the date of receipt:

1. Description of the site where the waste was generated, including:

i. Generator name;

ii. Lease name, lease number and well number, or gas ID number, or American Petroleum Institute (API) well number;

iii. County; and

iv. Waste hauler name;

2. Volume of waste material received (specify units);

3. Type and description of waste (e.g. oil-based drilling fluid, water-based drilling fluid, etc.). For soils contaminated with produced water, crude oil or condensate, indicate how it was determined that the waste is exempt from RCRA, Subtitle C; and

4. Copies of all laboratory analytical results and chains of custody required by Permit Conditions III.B. and III.C.

E. The permittee shall maintain the following records on each load of outgoing waste sent from the referenced facility to an authorized disposal facility for a period of three (3) years from the date of shipment:

1. Description of the facility to where the waste is sent to for disposal, including:

i. Receiving disposal facility operator name;

ii. Receiving disposal facility permit number(s);

iii. County; and

iv. Waste hauler name and permit number;

2. Volume of waste material (specify units); and

3. A detailed description of the type of waste material.

F. A report of the records required by Permit Conditions III.D. and III.E. must be submitted to Technical Permitting in Austin as part of the Quarterly Report required in Condition I.P. of this permit. If no waste was received within a reporting period, a written statement indicating that no waste was received must be submitted to Technical Permitting in Austin as part of the Quarterly Report.

IV. GENERAL FACILITY CONSTRUCTION AND DESIGN

A. The general layout and arrangement of the facility must be consistent with the “Future Expanded Centrifuge Processing Facility Site Plan (Figure D-6A)” schematic, attached and incorporated into this permit as Permit Appendix A, and the “Centrifuge Processing Facility Plan (Figure D-7)” schematic, attached and


incorporated into this permit as Permit Appendix B. The initial facility will include the northern centrifuge processing area, as shown in Permit Appendix A. The facility may be expanded with a second centrifuge processing area, which will correspond to the schematic in Permit Appendix B.

B. The centrifuge facility area will have a secondary containment liner composed of 2 feet of cover material underlain by a 60-mil high-density polyethylene (HDPE) geomembrane liner with a minimum two foot high containment berm.

C. A perimeter berm must be constructed to surround the entire facility and must be designed to prevent stormwater run-on and prevent stormwater runoff from the site. The perimeter berm must be constructed to a minimum height of two feet above land surface with a slope no steeper than a three to one (horizontal to vertical) ratio on each side.

D. Berms or containment structures must be constructed around all waste management units and must be compacted or constructed of material that meets or exceeds 95% Standard Proctor (ASTM D698) or 90-92% Modified Proctor (ASTM D1557) density. Each berm shall maintain a slope no steeper than a three to one (horizontal to vertical) ratio unless constructed of concrete or equivalent material (firewalls). These structures must be used to divert non-contact stormwater around the waste management areas and contain and isolate stormwater within the waste management units.

E. Any regulated material used in the treatment process must be stored in vessels designed for the safe storage of the particular chemical and these vessels must be maintained in a leak free condition within secondary containment. No material at the facility may be placed directly on the ground.

F. The facility shall maintain security to prevent unauthorized access from vehicles or livestock. The surrounding landfill facility must be fenced to prevent unauthorized access to the site. Access must be secured by a locked gate when the landfill is closed or unattended.

G. The centrifuge facility shall consist of the following equipment:

• Four centrifuges

• Four 500 bbl emulsion tanks

• Four 500 bbl water clarifying tanks

• Four 400 bbl fresh water tanks

• Four 142 cubic yard solids bins

• Eight 71 cubic yard solids bins

• Four 400 bbl shaker/receiving tanks

• Eight 500 bbl centrifuge feed tanks

• Two 400 bbl wash water storage tanks

• One 400 bbl wash water return storage tank


H. The maximum volumes of waste to be stored at any time at this facility are up to 10,000 bbls of unprocessed waste, 1,200 cubic yards of processed solids, 6,000 bbls of processed liquids, and 2,000 bbls of unprocessed liquid hydrocarbons.

I. Incoming waste must be unloaded directly from the transport truck or trailer into Collecting Pits (P012214, P012215, P012216, and P012217), or pumped into above ground storage tanks. Waste may not be unloaded onto the ground.

J. The facility must be inspected weekly. All berms, pits, aboveground storage tanks, processing equipment and facility areas must be inspected weekly for containment integrity, deterioration, leaks and spills.

K. All treated and untreated waste shall be contained in above-ground tanks or in permitted pits.

L. Tanks must be maintained in a leak-free condition. If inspection of a tank reveals deterioration or leaks, the tank must be repaired before resuming use of the tank.

M. The permittee must maintain a record of when the facility is inspected and the results of each inspection. A copy of the inspection records must be submitted to Technical Permitting in Austin as part of the Quarterly Report required in Condition I.P.

N. Appropriate measures must be taken to control dust to the extent necessary to comply with air quality standards regulated by the TCEQ.

V. PIT CONSTRUCTION AND OPERATION

A. CONSTRUCTION

1. Washout Pits – (P012163, P012164, and P012165A/B/C/D/E/F) must be constructed and arranged as shown on the washout pit diagram received September 19, 2014, included as the "Truck Washout Area Plan (Figure D-11)” schematic and incorporated into this permit as Permit Appendix C. The Truck Washout Area shall consist of up to six (6) washout bays (P012165A/B/C/D/E/F) which drain to a trough (P012164) and sump (P012163) combination. Each washout bay has a capacity of 159 bbls, the trough has a capacity of 278 bbls, and sump has a capacity of 144 bbls. The truck washout area shall be constructed of reinforced concrete including a 12-inch perimeter containment curb, and shall have secondary containment liner composed of 2 feet of cover material above a geosynthetic clay liner (GCL).

2. Collecting Pits (P012214, P012215, P012216, and P012217) may store unprocessed waste and must be constructed and arranged as shown on the Centrifuge Processing Facility Plan provided in, Permit Appendix B. The Collecting Pits are constructed of reinforced concrete. No more than 1,000 bbls of unprocessed waste may be stored in each pit for a total of 4,000 bbls.

3. Loading Area Collecting Pit (P012213) will be used to collect spills or leaks from the truck loading area and must be constructed and arranged as shown on the Centrifuge Processing Facility Plan provided in Permit Appendix B. Any spills occurring in this area will drain to a concrete sump where it will be pumped to an aboveground storage tank for treatment. The Loading Area Collecting Pit (P012213) is to be constructed of reinforced concrete including 12-inch high concrete containment curbs with a total capacity of 473 bbls.


B. OPERATION

1. Collecting Pits (P012214, P012215, P012216, and P012217), the Loading Area Collecting Pit (P012213), and the Truck Washout Pits (P012163, P012164, and P012165A/B/C/D/E/F) must be emptied and visually inspected annually for liner integrity or deterioration and leaks. The appropriate District Office must be notified by phone or email at least 48 hours before each pit inspection. If inspection reveals a leak or deterioration of the pit liners or components, repairs and re-inspection by RRC personnel must be performed before resuming use of the pit.

2. A sign must be posted at each pit, which must show the respective pit permit numbers in numerals at least three inches in height.

3. At least two feet of freeboard must be maintained in Collecting Pits (P012214, P012215, P012216, and P012217) between the level of waste in the pit and the top of the containment berm for each pit. At least two feet of freeboard must be maintained in the Truck Washout Trough and Sump between the level of waste in the pits and the top curb around the pits.

4. The Loading Area Collecting Pit (P012213) shall only be used for temporary storage of waste and any waste collected must be immediately pumped into an above-ground storage tank at the centrifuge facility.

5. All waste received in the Truck Washout Bays (P012165A/B/C/D/E/F) must be able to flow directly into the Truck Washout Trough (P012164) without exceeding the two feet of freeboard in the Trough.

6. Unless otherwise required by conditions of this permit, construction, use, and maintenance of Collecting Pits (P012214, P012215, P012216, and P012217), the Loading Area Collecting Pit (P012213), and the Truck Washout Pits (P012163, P012164, and P012165A/B/C/D/E/F) must be in accordance with the information represented in their respective applications (Form H-11) and attachments thereto.

VI. GROUNDWATER MONITORING

A. If required by Permit Condition I.E., groundwater monitor wells must be installed and numbered as represented on the “Soil Boring / Monitor Well Locations Plan (Figure D-6)” schematic attached and incorporated into this permit as Permit Appendix D.

1. The wells must be completed by a certified water well driller in accordance with 16 TAC Part 4, Chapter 76 (Water Well Drillers and Water Well Pump Installers).

2. The wells must be completed to penetrate the shallowest groundwater zone, and the completion must isolate that zone from any deeper groundwater zone.

3. The screened interval of the wells must be designed to intercept at least five feet of groundwater.

4. Provision must be made to protect the well heads from damage by vehicles and heavy equipment.


5. The wells must be water tight at the surface and fitted with a lockable water tight expansion cap.

6. The following information must be submitted after the wells are completed:

a. A soil boring lithological log for the well, with the soils described using the Unified Soil Classification System (equivalent to ASTM D 2487 and ASTM D 2488). The log must also include the method of drilling, well specifications, slot size, riser and screen length, bentonite and cement intervals, total depth, and the top of the first encountered water or saturated soils. The sand pack size should be compatible with the well screen slot size, as well as the local lithology.

b. A well installation diagram detailing construction specifications for each well.

c. A survey elevation for each well head reference point (top of casing) relative to a real or arbitrary benchmark and mean sea level.

d. A potentiometric map showing static water levels, the estimated direction of groundwater flow, and the calculated gradient.

C. The monitor wells must be sampled or monitored for the following parameters after installation and quarterly thereafter:

1. Static water level. 8. Nitrates 2. Benzene 9. Carbonates 3. Total Petroleum Hydrocarbon (TPH) 10. Calcium 4. Total Dissolved Solids (TDS) 11. Magnesium 5. Chlorides 12. Sodium 6. Bromides 13. Potassium 7. Sulfates

D. Copies of the results must be filed with Technical Permitting as part of the Quarterly Report required in Condition I.P. of this permit.

VII. STORMWATER MANAGEMENT

A. A discharge permit from the EPA may be required for non-contact stormwater discharges. If required, the permit from the EPA must be in place prior to commencement of discharge operations.

B. The facility must be designed and constructed to capture and contain contact stormwater should there be an internal berm failure, and prevent run-on of non-contact stormwater. The centrifuge processing facility must be designed so that stormwater flows to a contact stormwater storage area on the southeastern side of the facility, where it will be collected and pumped to the centrifuge facility for processing, transported to the on-site solidification facility, or transported to a permitted off-site disposal well. The location of the contact stormwater storage area is shown in the “Centrifuge Processing Facility Plan (Figure D-7)” schematic in Permit Appendix B.


C. The Loading Area Collecting Pit (P012213) must have 12-inch concrete perimeter curbs to prevent stormwater run-on or run-off. Stormwater that collects in the pit will flow to a sump where it will be pumped to the centrifuge facility for processing, transported to the on-site solidification facility, or transported to a permitted off-site disposal well.

D. Any stormwater within the facility’s outer most berm will be considered contact stormwater. Contact stormwater must be collected immediately and put into on-site aboveground storage tanks or into an active collecting pit and must be subsequently disposed of in an authorized manner or used in the treatment process.

E. Non-contact stormwater shall be prevented from entering the waste processing and storage areas. Areas outside of the bermed centrifuge processing facility and truck washout facility shall be sloped to prevent non-contact stormwater from contacting waste.

F. Contact stormwater must be collected within 24 hours of accessibility and disposed of in an authorized manner.

VIII. FACILITY CLOSURE

A. Technical Permitting in Austin and the appropriate District Office must be notified in writing 45 days prior to commencement of closure activities.

B. Collecting Pits (P012214, P012215, P012216, and P012217), the Loading Area Collecting Pit (P012213), and the Truck Washout Pits (P012163, P012164, and P012165A/B/C/D/E/F) must be dewatered, emptied, cleaned, demolished, backfilled, and compacted within 120 days of final cessation of use of the pits. Final closure of each pit must be accomplished in such a manner that rainfall will not collect at the former pit location after pit closure. Upon final closure, Technical Permitting in Austin and the appropriate District Office must be notified in writing.

C. All waste, chemicals or related waste materials must be processed and removed from the facility for authorized reuse, or disposed of in an authorized manner.

D. Processing equipment, aboveground storage tanks, and any other equipment or piping must be removed from the facility.

E. Concrete pads, the HDPE liner and cover material in the centrifuge facility, and the GCL and cover material in the truck wash area must be removed and disposed of in an authorized manner.

F. Provisions must be taken to prevent erosion both during operation and following closure, as specified in the Stormwater Pollution Prevention Plan (SWPPP).

G. A minimum of four representative soil samples per acre must be taken to characterize the scope of any contamination at the facility. Samples must be taken from around the berms, storage, tanks, and processing equipment and from underneath the Collecting Pits (P012214, P012215, P012216, and P012217), the Loading Area Collecting Pit (P012213), and the Truck Washout Pits (P012163, P012164, and P012165A/B/C/D/E/F). Those samples must be analyzed for the following constituent levels:

APPENDIX A

Future Expanded Centrifuge Processing Facility Site Plan (Figure D-6A)

Appendix A

APPENDIX B

Centrifuge Processing Facility Diagram (Figure D-7)

P012213

P0

12

21

4P0

12

21

5

Appendix B

APPENDIX C

Truck Washout Area Plan (Figure D-11)

Appendix C

P0

12

16

4

P0

12

16

3P012165A

P012165B

P012165C

P012165D

P012165E

P012165F

APPENDIX D

Soil Boring / Monitor Well Locations Plan (Figure D-6)

Ap

pe

nd

ix D

Proposed Soil Boring / Monitor WellSOIL BORING / MONITOR WELL LOCATIONS PLAN

railroad commission of t › media › 38161 › bfi_waste_systems... · 2017-02-01 · david...

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