RAILROAD COMMISSION OF TEXAS
Discharge of Oil and Gas
Waste
Tiffany Humberson
Environmental Permits and Support
Disclaimer
 This presentation is a quick overview and not intended to
be a complete guide for filing discharge applications.
 Each application is reviewed by an analyst and
additional information may be required.
 Read the rules that are specific to your discharge and
contact Environmental Permits and Support should you
have any questions.
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Outline
 Laws and Rules
 Federal and State Jurisdiction
 EPA,TCEQ,TSWQS, and the RRC
 Define Surface Water
 Types of Discharges- Applications
 Hydrostatic Pressure Test Discharges
 Gas Plant Discharges
 Produced Water Discharges
 Testing
 Storm Water Discharges/ On-Site Septic
 Question and Answer Session
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Laws and Rules
 Clean Water Act (CWA)- primary federal law in the U.S
governing water pollution.(NPDES program)
 Texas Surface Water Quality Standards(TSWQS) from
Texas Commission of Environmental Quality (TCEQ) are
in Texas Administrative Code (TAC), Title 30, Chapter
307.
 Section 26.131(b) of the Texas Water Code prohibits the
Railroad Commission from issuing a permit for a
discharge that will cause a violation of the Texas Surface
Water Quality Standards adopted by the Texas
Commission on Environmental Quality (TCEQ).
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Federal and State Jurisdiction
 The EPA has not
authorized the RRC to
implement a National
Pollutant Discharge
Elimination System
(NPDES) permit program.
 RRC regulates the
disposal of all oil and gas
wastes.
 Discharges to surface
water must be permitted
by both EPA and RRC.
Texas Surface Water Quality Standards
Texas Surface Water Quality
Standards
 Establish explicit goals for
the quality of streams, rivers,
lakes, and bays throughout
the state
 Permit restrictions based on
water quality and dilution of
the receiving body
 Receiving bodies organized
into segments
http://www.tceq.texas.gov/assets/public/waterquality/standards/tswqs_2014/TSWQ2014Rule.pdf
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Define Surface Water
 Defined by Rule §3.8(a)(29)
 Navigable or non-navigable waters, (unlike CWA)and
includes beds and banks of all water courses and
bodies of water.
 Surface water refers to water on ground surface or
water collection areas including lakes, ponds,
wetlands, intermittent streams, drainage ditches,
canals, fresh or salt water, etc., but excluding artificial
water containment where storm water runoff cannot
enter.
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Types of Discharges
Three major categories of discharges to surface waters:
 Hydrostatic Test Water (HT); most common
 Gas Plant Effluent(GPE);
 Produced Water
 Inland
 Offshore
Hydrostatic Test (HT)
Discharges
 Hydrostatic tests are preformed to pressure test
pipelines and tanks.
 Authorized by a minor permit issued from the Austin
office and is valid for 60 days. Must file two copies of
the applications and attachments.
 Currently, a person may be required to obtain a
federal permit and a state permit to discharge oil and
gas wastes to surface water in the state. You may
contact EPA Region 6 for more information.
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HT Permit Not Required
 A permit is not required if all the following conditions are
met:
 The pipeline is a gathering line.
 The pipe is new.
 The test water is a good quality water source.
 The volume of test water discharges is 10,000
gallons or less.
 The test water is kept on the pipeline right-of-way and
the landowner(s) has been notified and not objected.
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Type of Pipeline to be Tested
 Transmission line means a pipeline, other than a gathering
line, that: (1) Transports gas from a gathering line or storage
facility to a distribution center, storage facility, or large volume
customer that is not down-stream from a distribution center;
(2) operates at a hoop stress of 20 percent or more of SMYS
(Specified Minimum Yield Strength); or (3) transports gas
within a storage field.
 Gathering line means a pipeline that transports gas from a
current production facility to a transmission line or main.
 Distribution line means a pipeline other than a gathering or
transmission line.
Application for HT Minor
Permit
1. Operator information
2. Description of pipeline or tank
to be tested
3. H2S > 100 ppm?
4. Source of water
5. Chemicals, concentrations,
and MSDS
6. Dates of test and discharge
7. Volume and rate of discharge
8. Location of discharge
(Latitude/Longitude)
9. Map that shows fill point and
discharge point
10. Filtration system, erosion
control devices
11. Frac tanks?
12. Landowner notification
13. Cleaning information(used)
14. Application fee for discharge to
surface waters($750)
15. Signature and certification
16. File two copies of the
application, including all
attachments with Technical
Permitting in Austin
http://new.rrc.state.tx.us/oil-gas/applications-and-permits/environmental-permit-types-information/hydrostatic-test-dischargesminor-and-other-permits/hydrostatictestwater1change/
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HT Permit Typical Testing
Requirements
Frac tanks used?
New pipe and
discharge volume
< 100,000 gal
Yes
No
Tanks used after test?
No
No
Test beginning,
midpoint, and end for:
Yes
Discharge to surface
No testing
required
(gathering line)
Yes
Test each
tank for:
Discharge to surface water
Parameter
Limitation
Parameter
Limitation
Benzene
0.5 mg/l
Benzene
0.05 mg/l
O&G
15 mg/l
O&G
15 mg/l
COD
Report
COD
Report
Conductivity
Report
Conductivity
Report
TSS
Report
TSS
Report
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Gas Plant Effluent
Discharges (GPE)
 Common waste streams include:
 Cooling tower blowdown
 RO reject stream
 Compressor condensation
 Individual EPA permit
 May not cause a violation of the Texas Surface Water
Quality Standards
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Application for Gas Plant
Effluent Discharge Permit
1.
2.
3.
4.
5.
6.
7.
8.
9.
Identify the plant by operator
10.
information
Indicate the operations carried out at
the plant include the type of gas plant
and waste stream(s)
11.
Drawing and description of any
treatments
12.
Pits? Form H-11 required
13.
Identify any chemicals, provide
concentration, and MSDS
Complete Water Analysis
Latitude and Longitude
County Highway Map
Plat drawn to scale with tract
boundaries and discharge point
Provide notice to waterfront surface
owners from the point of discharge to
½ mile downstream (If to discharge is
to watercourse)
Permission from flood control owner
(if to a ditch or canal)
Application fee($750)
Signature and certification
http://new.rrc.state.tx.us/oil-gas/applications-and-permits/environmental-permit-typesinformation/discharges/gasplanteffluent/
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Gas Plant Effluent Required
Testing and Limitations
 pH: 6.0 to 9.0
 Biochemical oxygen demand (BOD)
 Daily max: 30 mg/l
 Monthly average: 20 mg/l
 Additional testing parameters and limitations may be
added based on results of Water Analysis or chemicals
added to discharge.
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Produced Water Discharges
West of 98th
meridian
3 nautical
miles
East of
98th
meridian
Not to scale
9 nautical miles
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Produced Water Discharged
West of 98th Meridian
 Not covered by an EPA general
permit; but under effluent
guidelines in 40 CFR Part 435,
Subpart E
 Individual EPA Permit
 Produced water must be
beneficially used for agricultural
or wildlife use when discharged
into navigable waters.
 May not cause a violation of the
Texas Surface Water Quality
Standards
http://www.epa.gov/region6/6en/w/offshore/effluentguidelines-dec-16-1996.pdf
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Produced Water Discharged
East of 98th Meridian
 EPA General Permit TXG 330000.
(existing facilities in the Stripper
Subcategory).
 Produced water must be from
Carrizo/Wilcox, Reklaw, or Bartosh
formations.
 Discharges into impaired waters
may require an individual permit.
 May not cause a violation of the
Texas Surface Water Quality
Standards
http://www.epa.gov/region6/water/npdes/genpermit/txg330000/txg330000permit.pdf
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Application for a Permit to Discharge
Produced Water to Inland Waters
1.
2.
Operator Information
Indicate county, field, lease
identification, well numbers for the
produced discharge
3. Include the average and maximum
water production rates, well-by-well.
4. Drawing and description of any
treatments
5. Pits? Form H-11 required
6. Identify any chemicals, provide
concentration, and MSDS
7. Complete Water Analysis
8. Latitude and Longitude
9. County Highway Map
10. Provide notice to waterfront surface
11.
12.
13.
14.
owners from the point of discharge to
½ mile downstream (If to discharge is
to watercourse)
Permission from flood control owner
(if to ditch or canal)
Application fee($750)
Is the water for agricultural or wildlife
use?
Signature and certification
http://new.rrc.state.tx.us/oil-gas/applications-and-permits/environmental-permit-typesinformation/discharges/producedtoinland/
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Produced Water Required Testing
and Limitations
 Oil and Grease
 Daily max: 35 mg/l
 Monthly average: 25 mg/l
 Total Dissolved Solids (TDS) < 3,000 mg/l (Produced water E.
of 98th meridian only)
 24-hour acute WET test required for E. of 98th meridian
 Additional testing parameters and limitations may be added
based results of Water Analysis or chemicals in the discharge
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Produced Water Discharged to
the Territorial Seas
 Covered by EPA General Permit
TXG260000
 Authorized discharge of produced
water
 RRC and EPA require the
discharge to pass Whole Effluent
Toxicity (WET) tests
 Toxicity testing results must pass
both acute and chronic limits prior
to any discharge
 May not cause a violation of the
Texas Surface Water Quality
Standards
http://www.epa.gov/region6/water/npdes/genpermit/txg260000/txg260000_2012_finalpermit.pdf
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Coastal Management
Program
 Discharges must not
adversely affect any critical
area
 Examples of critical areas
are a coastal wetland, oyster
reefs, hard substrate reefs,
submerged aquatic
vegetation, or tidal sands or
mud flats
 Discharge of produced water
to bays, estuaries, and tidal
areas with the exception of
the Gulf of Mexico, is no
longer permitted
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Produced Water Discharged to
the Outer Continental Shelf
 Covered by EPA General Permit
GMG290000
 Authorized discharges for
drilling fluids, drill cuttings, and
produced water
 RRC and EPA require the
discharge to pass Whole
Effluent Toxicity (WET) test (7day chronic)
 May not cause a violation of the
Texas Surface Water Quality
Standards
http://www.epa.gov/region6/water/npdes/genpermit/gmg290000final/gmg290000finalpermit2012.pdf
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Application for a Permit to Discharge
Produced Water to Gulf of Mexico
1.
2.
3.
4.
5.
6.
7.
8.
9.
Operator Information
10. Signature and certification
Indicate county, field, lease
identification, well numbers for the
produced discharge
Include the average and maximum
water production rates, well-by-well
Depth at which the discharge occurs
Drawing and description of any
treatments
Identify any chemicals, provide
concentration, and MSDS
Complete Water Analysis
Latitude and Longitude
Application fee($750)
http://new.rrc.state.tx.us/oil-gas/applications-and-permits/environmental-permit-types-information/discharges/producedwater-to-gom/
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Offshore Produced Water
Required Testing and Limitations
 Oil and Grease
 Daily max: 42 mg/l
 Monthly average: 29 mg/l
 7-day chronic WET test
 24-hour acute WET test (Territorial Seas only)
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Water Analysis
General Parameters
Parameter MAL(mg/l)
Parameter MAL(mg/l)
Temperature (oF)
Calcium
Aluminum
0.03
Mercury*
0.0002
pH (standard units)
Magnesium
Arsenic*
0.01
Nickel
0.01
Dissolved Oxygen
Sodium
Barium*
0.01
Selenium*
0.01
Hardness (mg/l as CaCO3) Potassium
Benzene
0.01
Silver*
0.002
Total Suspended Solids
Iron
Cadmium* 0.001
Zinc
0.005
Total Dissolved Solids
Manganese
Chromium* 0.01
Chlorides
Oil & Grease
Hexavalent*
0.01
Chromium
Sulfates
Total Organic Carbon
Copper
0.01
Sulfides
Phenols
Cyanide
0.02
Ammonia Nitrogen
Naphthalene
Lead*
0.005
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Whole Effluent Toxicity
 Whole Effluent Toxicity (WET) refers to the aggregate
toxic effect to aquatic organisms from all pollutants
contained in a facility's wastewater (effluent).
 In a WET test, aquatic organisms from fresh or saline
water are placed in a mixture of the receiving water
diluted with the discharged effluent.
 WET tests determine the acute and chronic effects on
the aquatic organisms.
 A WET test is passed by recording No Observable
Effect Concentration at the calculated critical dilution
concentration.
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WET Test for Offshore
Discharge
 The critical dilution used in the chronic 7-day WET test
for Territorial Seas and Outer Continental Shelf
discharges can be determined from tables in their
respective general permits based on:
 The highest monthly average discharge rate over the
three months prior to the sample,
 Discharge pipe diameter, and
 Depth between the base of the discharge pipe and
sea floor.
 The critical dilution for the acute 24-hour LC50 test at
100 percent concentration.
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Storm Water Discharges
Permits will distinguish between contact storm water and noncontact storm water.
 Non-contaminated storm water may be discharged without a
permit from RRC. A permit from EPA may be required.
 Best Management Practices (BMPs) should be followed when
managing non-contact storm water.
 Contact storm water is considered oil and gas waste and must
be managed, stored and contained separate from non-contact
storm water and disposed of in an authorized manner.
 Discharge of contact storm water is prohibited.
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On-Site Sewage Facility
(OSSF)
 On-Site Sewage Facilities (OSSFs) are under the jurisdiction of the
Texas Commission on Environmental Quality (TCEQ).
 Unless the OSSF is located at a well site under the jurisdiction of
RRC or a RRC-permitted facility.
 Do not need a permit if;
 The waste is not commingled with any other waste stream;
 designed by a professional engineer or sewage system installer;
 the construction, operation, and maintenance of the OSSF
complies with all applicable local, county, and state
requirements.
Additional Comments
 Storm water should not be commingled with the effluent
prior to the discharge point.
 Septic and gray water should not be commingled with
the effluent prior to the discharge point.
 Technical Permitting does not allow any additives that
contain chromium or zinc to be discharged.
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Summary
 Roles of the RRC, EPA, and TCEQ
 Discharge types and applications
 common application problems
 Water quality testing and parameters.
 WET testing
 Unauthorized discharges
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Contact Information
Environmental Permits & Support
512-463-3840 (Main)
Tiffany Humberson
tiffany.humberson@rrc.state.tx.us
(512) 463-4990(Direct)
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