Texas Oil Regulator Proposes Significant Overhaul of Waste Management Rules
by Andreas Exarheas
click here to read this article at Rigzone
*this article was not written by Roseland Oil & Gas
A statement posted on the Texas Railroad Commission (RRC) website revealed that the RRC is proposing a “significant overhaul of oil and gas waste management rules”.
“RRC commissioners voted to publish for public comment proposed amendments that are critical to updating the agency’s rules regulating waste management facilities,” the RRC statement noted, adding that “this is the first overhaul of RRC’s waste management rules in four decades”.
“Groundwater protection is a major factor in the rule amendments, and they also take into consideration the need for historical rules to adapt to technological advancements in the energy industry’s resource development in Texas,” the statement said.
The amendments relate to waste from oil and gas operations, as well as waste from other operations for which the legislature has given the RRC jurisdiction, the statement highlighted, noting that examples include geothermal, carbon sequestration, and brine mining wells.
“The proposed rule updates requirements on the design, construction, operation, monitoring, and closure of waste management units, and help[s] improve the commission’s ability to track and collect data on oilfield waste transported throughout Texas,” the RRC said in the statement.
“Many of the amendments codify informal guidance that the RRC has developed over the course of several decades and would give operators and the public certainty on how regulations of waste management facilities are carried out,” it added.
“The proposed rule also allows residents more time to protest waste management permit applications. Among the changes to the process is an extended time frame for a person to file a protest, from the current 15 days to 30 days,” it continued.
In the statement, RRC Chairman Christi Craddick said, “this proposed rule reflects the hard work and dedication of agency staff and stakeholders on this critical rule”.
“I am grateful to Commissioner Wright for his leadership on this important matter and look forward to reviewing public input as we work toward final adoption of our solid waste rule amendments,” Craddick added.
Commissioner Wayne Christian said in the statement, “the railroad commission continues to prove that a robust, responsible oil and gas industry can thrive while also ensuring a safe and clean environment for all”.
“Right next to oil and gas, water is becoming perhaps the most valuable natural resource in Texas. As an EPA commended agency for ground water protection, the commission takes safeguarding water extremely seriously, and this rule update makes certain that industry is taking every precaution possible toward protecting the public,” he added.
“I’m proud of the hard work by our commission staff and look forward to this rule continuing to bolster the RRC’s historic legacy as a world-class regulatory agency,” Christian continued.
RRC Commissioner Jim Wright said in the statement, “[this] draft rule represents an important step forward with respect to the railroad commission’s expectations regarding waste management practices”.
“It has been 40 years since the Commission last made significant updates to this rule, and … [this] proposal is an acknowledgment that considerable changes have occurred in terms of technology and industry practices now being utilized,” he added.
“I thank the railroad commission staff for their tireless work on behalf of our state and look forward to reviewing the public’s feedback on this important issue as we work towards final adoption,” Wright went on to state.
In a statement posted on its website last month, the RRC said its geologists and engineers will work with environmental experts from other states to analyze an important agency program that protects underground sources of drinking water.
“The RRC has requested the Groundwater Protection Council (GWPC), a respected organization of national groundwater experts, conduct an independent peer review of its Class II Underground Injection Control (UIC) program,” the RRC noted at the time, highlighting that Class II injection wells are used for oil and gas operations such as enhanced oil recovery, disposal of produced water, and underground hydrocarbon storage.
“The GWPC’s peer reviews include, but are not limited to, an evaluation of the state’s rules, permit application workflows, permit review criteria, protection of underground drinking water, well inspection practices, program funding, and data management,” the RRC outlined in the statement.
Paul Dubois, RRC Assistant Director of the Oil and Gas Division, pointed out in the statement that “the RRC has had success stories with our UIC program which began in 1982”.
“One example is the significant steps we took to help mitigate earthquakes in West Texas by setting injection limits for produced water disposal. We even leveraged artificial intelligence for that work,” he added.
GWPC peer reviews are in-depth, and the Texas UIC peer review could take between six months to a year to complete, the RRC said in the statement.
In a statement posted on its site back in June, the RRC stated that its commissioners approved the agency’s Fiscal Year 2025 Oil and Gas Monitoring and Enforcement Plan. That statement highlighted that this plan includes “added information to provide the public further insight on the agency’s work to protect the environment and Texans”.
The annual plans define the RRC’s strategic priorities for monitoring oil and gas activities and enforcing regulations across the state, the RRC pointed out in the statement, adding that they include the agency’s extensive field operations activities such as well inspections, orphaned well pluggings, and site remediations.
“We continue to utilize our staff’s expertise and the agency’s technological advancements to serve Texans and their communities,” Danny Sorrells, RRC Deputy Executive Director and Oil and Gas Director, said in the statement.
“The new monitoring and enforcement plan provides more information on how we plan to utilize those key resources for regulation as the Texas oil and gas industry continues to be a vital element of the state and U.S. economy,” he added.
In another statement posted on its site back in January, the RRC revealed that it had issued a framework for pilot programs that it said “could greatly enhance environmental protection in Texas with the potential to recycle produced water safely and economically”.
“The produced water recycling framework will provide a regulatory pathway for operators to assess the effectiveness and the suitability of applying treated produced water for beneficial purposes,” the RRC noted at the time.
“Operators will apply for authorization to conduct pilot studies, and RRC will issue a permit or letter of authorization if the application meets requirements. The operators would compile data of how treated produced water can be reused in certain activities that are safe and protective of human health and the environment,” it continued.
“Ultimately, the potential exists to reduce the amount of produced water that gets injected back into the ground, which can help reduce incidents of seismicity, as well as developing a potential water source for above ground use,” the RRC went on to state.
The RRC highlighted in that statement that the produced water recycling framework was a “starting point” and said it will evolve over time in collaboration with the work of others such as the academic community, consortia, industry, and community leaders.
“The information obtained by these pilot studies can be used to develop more focused regulation on produced water recycling and help guide future development,” the RRC said at the time.
In that statement, RRC Executive Director Wei Wang said, “this is another example of how we stay at the forefront of our critical mission of protecting public safety and the environment while we regulate an industry that is crucial to the state’s economy”.
“This framework opens up the potential to use treated produced water in ways that have never been seen before in Texas, which is a win-win for conserving water resources, and protecting the environment and Texans,” Wang added.
The RRC describes itself as the state agency with primary regulatory jurisdiction over the oil and natural gas industry, pipeline transporters, natural gas and hazardous liquid pipeline industry, natural gas utilities, the LP-gas industry, critical natural gas infrastructure, and coal and uranium surface mining operations.
The commission exists under provisions of the Texas Constitution and exercises its statutory responsibilities under state and federal laws for regulation and enforcement of the state’s energy industries, the RRC site states, adding that the Commission also has regulatory and enforcement responsibilities under federal law including the Surface Coal Mining Control and Reclamation Act, Safe Drinking Water Act, Pipeline Safety Acts, Resource Conservation Recovery Act, and Clean Water Act.
The RRC is the oldest regulatory agency in the state and one of the oldest in the country, RRC’s site notes, adding that the RRC was established in 1891 to regulate the rail industry of the 1800s.
by Andreas Exarheas
click here to read this article at Rigzone
*this article was not written by Roseland Oil & Gas