51
Storm Water, SPCC & Waste Management Tools for the Oil & Gas Industry Juliana Morelli, PG, REM - Atkins
Storm Water, SPCC & Waste Management
Tools for the Oil & Gas Industry Juliana Morelli, PG, REM - Atkins
Overview • Storm Water Regulations
– NPDES – Applicability, Exemptions & Other Regulatory Drivers – Landowner Relations & Asset Protection – Best Management Practices (BMPs)
• Spill Prevention Control & Countermeasures (SPCC) Programs – Applicability & Exemptions – General Requirements – O&G Specific Requirements
• Fundamentals of Waste Management – Agency Jurisdiction – Waste Stream Evaluation – Transportation and Disposition
Storm Water
Overview • NPDES Exemption for Oil & Gas Industry • Landowner Relations, Asset Management, Other
Regulations • Best Management Practices
– Erosion versus Sedimentation – Other Common Terminology – Erosion and Sediment Controls – Inspection Criteria – Pre Construction Vs Operation & Maintenance
NPDES Exemption for O&G • Clean Water Action – Section 402(l)(2) – exempts
oil and gas production and transmission facilities from storm water permitting requirements unless: – They have had a discharge of pollutants over an RQ – They are degrading receiving water quality standards
• States may have regulations ANYWAY!! – TX RRC would permit via EPA TXR120000 GP
Asset Management
Landowner Relations
Other Regulatory Reasons
Erosion Vs. Sedimentation • Erosion is a process that involves soil
detachment due to wind, water, ice, and gravity – Rills and Gullies, Headward Erosion
• Sedimentation is the settling out of transported soil particles
Best Management Practices 1. Site Management/ Planning 2. Erosion Controls 3. Sediment Controls 4. Runoff Controls 5. Good Housekeeping 6. Post Construction
Maintenance
Best Management Practices • Site Management/Planning
– Identify sensitive areas and protect with access controls
– Install controls before land disturbance takes place
– Limit area to be disturbed at one time
– Protect vegetation off of the ROW
• Erosion Controls – Soil Texturing – Mulch – Tracked Hay – Soil Binders – Erosion Control Blanket – Turf Reinforcement Mat – Vegetation – Rip Rap
Best Management Practices • Sediment Controls
– Fiber Rolls – Sediment Bags – Temporary Stream
Crossing – Sediment Basins – Silt Fence
Volume
Velocity
Sediment Load
Best Management Practices • Runoff Controls
– Rock Check Dam
– Diversions
– Inlet Protection
– Gabions
• Good Housekeeping – Material Storage &
Handling – Spill Response
• Post Construction Controls – Final stabilization, – Inspection & Maintenance
Common Problem Areas • Steep Slopes • Stream Crossings • Downstream Stock Tanks • Adjacent private roads, fences, etc. • Floodplains • Access roads with improper drainage structures • Missing or misunderstood BMPs
Stormwater: Questions & Answers
Spill Prevention, Control & Countermeasures Planning
Overview – Applicability & Exemptions – General Requirements – O&G Specific Requirements
SPCC: Applicability • Can “reasonably be expected to discharge
harmful amounts of oil into navigable waters of the United States or adjoining shorelines”;
• Has the capacity to store oil in volumes greater than or equal to 1,320-gallons total aggregate in above ground containers sized 55-gallons or larger each or;
• Has the capacity to store oil in volumes greater than or equal to 42,000-gallons in total completely buried storage containers.
Applicability SPCC applies only to “oil” Under the SPCC regulations, “oil” is defined as "oil of any kind or in any form including, but not limited to, petroleum, fuel oil, sludge, oil refuse and oil mixed with wastes other than dredged spoil and oily mixtures." This also includes non-petroleum oils, animal, and vegetable oils. Chemicals and hazardous materials are not necessarily considered “oil” under the SPCC regulations. Oils cause a sheen on water.
Applicability & Exemptions • Can not reasonably be expected to discharge harmful
amounts of oil into navigable waters of the United States or adjoining shorelines.
– Must be based upon consideration of the geographical and location aspects of the facility such as proximity “waters”
– May not consider man-made features such as dikes, equipment or other structures which may serve to restrain, hinder, contain or otherwise prevent a discharge.
Applicability & Exemptions • Transportation Related Facilities under the
jurisdiction of the US DOT – MOU dated 11-24-1971
Applicability & Exemptions • Facility under the jurisdiction of the US DOI
(MOU dated 11-8-1993) – EPA is responsible for non-transportation related
offshore facilities located landward of the coastline. – DOI is responsible for facilities, including pipelines,
located seaward of the coast line (except for deepwater ports and associated seaward pipelines – see DOT above).
– DOT is responsible for transportation related facilities, including pipelines, located landward of the coastline and deepwater ports and associated seaward pipelines.
SPCC Plan Options • Tier I Self-Certified Plans
• Tier II Self-Certified Plans
• Professional Engineered (PE) Certified Plans
Note: Self Certified Plans may not use “Environmental Equivalence Measures”
SPCC Plan Options • Tier I Self-Certified Plans
– Total above ground storage capacity of 10,000 US gallons or less
AND – No single above ground storage container with a
capacity greater than 5,000 US gallons AND – No single discharge exceeding 1,000 US gallons or
no two discharges each exceeding 42 US gallons within any 12 month period prior to the SPCC Plan certification date.
SPCC Plan Options • Tier II Self-Certified Plans
– Total above ground storage capacity of 10,000 US gallons or less
AND
– No single discharge exceeding 1,000 US gallons or no two discharges each exceeding 42 US gallons within any 12 month period prior to the SPCC Plan certification date.
SPCC Plan Options • P.E. Certified Plans
– P.E. must be licensed in the state for which the SPCC Plan is being developed
– The SPCC Plan must be reviewed and re-certified by a P.E. at least once every five years.
– Any technical amendments to the SPCC Plan will require re-certification by a P.E.
General Requirements 1. SPILL PREVENTION Achieved through installation of required equipment,
timely repair of malfunctioning systems, regular inspections, and good oil handling/fueling practices.
2. SPILL CONTROL Achieved through monitoring of leak detection systems and proper reporting, and ensuring containment systems are functional.
3. SPILL COUNTERMEASURES Achieved through quick spill response activities.
“Facility” • The owner or operator has discretion in
identifying which contiguous or non-contiguous buildings, properties, parcels, leases, structures, installations, pipes, or pipelines make up the “Facility”.
General Requirements (40 CFR 112.7) • The requirements of 112.7 are applicable to all SPCC
regulated facilities. • SPCC Plan must:
– Follow the outline of the rule (40 CFR Part 112) or provide a cross-reference to the rule
– Describe conformance and/or non-conformance to the rule – Include a facility diagram, including bulk storage containers,
piping, and appurtenances • Issues: mobile sources, buried (and unburied) piping, diversion
systems, oil-filled operational equipment
General Requirements • SPCC Plan must:
– Include spill reporting procedures (include State and/or other local requirements)
– Describe spill response procedures to be used in the event of a discharge
– Include a prediction of the direction, rate of flow, and total quantity of a potential oil discharge from each potential area of release
– Describe appropriate containment and/or diversionary structures or equipment in use at the facility to prevent a discharge
General Requirements • SPCC Plan must:
– Describe required inspections, tests, and recordkeeping (e.g., monthly/annual inspections; integrity testing, etc.)
• Records must be retained for a period of three years – Provide training criteria for all oil-handling personnel
• Training must be provided annually – Describe security controls in place at the facility to prevent
unauthorized access and/or to discourage vandalism
General Requirements • SPCC Plan must:
– Provide specific controls for a “loading/unloading rack”
– Provide specific controls for “field constructed aboveground containers”
– Include additional State rules that are applicable to oil storage and spill response that may be more stringent
– Provide specific controls for “oil-filled operational equipment”
Add’l Requirements by Facility • In addition to the General Requirements (112.7):
– Onshore, non-production facilities (112.8) – Onshore oil production facilities (112.9) – Onshore oil drilling and work over facilities (112.10) – Offshore oil drilling, production, or work over facilities
(112.11) – Animal Fats and Vegetable Oils (AFVO) (112.12)
Onshore oil production facilities (112.9) (excluding drilling & work over)
Oil Production Facilities include: – all structures (including but not limited to wells, platforms, or storage
facilities), – piping (including but not limited to flow lines or intra-facility gathering lines),
or – equipment (including but not limited to work over equipment, separation
equipment, or auxiliary non-transportation related equipment) used in the production, extraction, recovery, lifting, stabilization, separation
or treating of oil (including condensate), or associated storage or measurement, and is located in an oil or gas field, at a facility.
Examples: Tank batteries, upstream pipelines, storage locations on well pads, etc.
Onshore oil drilling and work over facilities (112.10)
Oil drilling and work over facilities include all equipment and appurtenances related thereto used in drilling operations for exploratory or development wells, but excluding any terminal facility, unit or process integrally associated with the handling or transferring of oil in bulk to or from a vessel.
Examples: Active drilling sites where wells are being installed or
worked over for improved production
Offshore oil drilling, production, or work over facilities (112.11)
Offshore includes facilities located in, on or under navigable waters of the U.S., however DOI re-delegates to EPA and DOT those waters not within “the line of ordinary low water along that portion of the coast which is in direct contact with the open sea and the line marking the seaward limit of inland waters”.
While DOI has jurisdiction over offshore facilities, 40 CFR 112
includes specific requirements for offshore oil drilling, production, or work over facilities.
Questions?
Fundamentals of Waste Management
Overview • Fundamentals of Waste Management
– Agency Jurisdiction – Waste Stream Evaluation – Transportation and Disposition
Agency Jurisdiction – Federal – Environmental Protection Agency
• Resource Conservation & Recovery Act (RCRA) • Comprehensive Environmental Response & Clean Up Act
(CERCLA) (a.k.a. Superfund) – State Regulations – Two Examples
• Texas Railroad Commission and/or Texas Commission on Environmental Quality (TCEQ)
• Oklahoma Corporation Commission and/or Department of Environmental Quality (DEQ)
RCRA Exclusions – RCRA Title 40 CFR Part 261
“Identification and Listing of Hazardous Waste – RCRA Exclusions: Part 261.4(b)(5) -
“The following solid wastes are not hazardous wastes: Drilling fluids, produced waters, and other wastes associated
with the exploration, development, or production of crude oil, natural gas, or geothermal energy.”
RCRA Exclusions – What? • Not required to register as a Generator of
Hazardous Waste – Manifest System – Waste Minimization Program – Accumulation area time and storage volume limits – Transportation packaging, labeling, placarding, etc. – Reporting and Recordkeeping
Other Waste Considerations – Wastes may have characteristics of a hazardous waste:
• Ignitability • Corrosivity • Reactivity • Toxicity
– Can still present a hazard in the environment – May require disposal in a non-O&G landfill
This is not the complete list… – And, not all wastes are excluded by RCRA:
• Asbestos Containing Materials (pipes) • Cleared vegetation • Buckets (detergents, grease, etc.) • Concrete (contaminated or not) • Empty barrels, drums, buckets • Empty fiberglass tanks, pipes, etc. • Mobile equipment maintenance wastes (used oil, filters, tires, etc.)
– These waste must be disposed of in accordance with Federal, State, and Local regulatory requirements
Waste Disposal Process • Step 1: Identify RCRA exclusion status of waste stream • Step 2: Evaluate appropriate disposition options of waste
material (e.g., recycling, land farm, underground injection, burial, landfill)
• Step 3: Consider State & Local Rules for Waste Transportation and Disposition
• Step 4: Document regulatory pathway for disposition choice
Some Basic Rules • Do not bury (even authorized) waste without
written consent from the landowner • Do not bury waste within the 1% annual
chance floodplain • Do not dispose of waste into surface water
(even through runoff)
Some Basic Rules • Plan and implement controls to mitigate impacts
from precipitation runoff • Do not land farm during saturated conditions • Do not land farm drill cuttings from oil based muds
(TEXAS) • Water based drilling fluids with <3,000 mg/L
Chlorides may be land farmed (TEXAS)
Some Best Management Practices • Consider geology, hydrology, and soil conditions in
each area where waste burial is proposed – Low relief topography preferred – Impervious soil/rock floor – Utilize a liner – Identify nearest well, depth to groundwater (drinking
and/or fresh) – Watch for sandy/silty zones during construction and
mitigate
