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NMOCD PIT RULE. 19.15.17 NMAC Effective June 28, 2013. NMOCD Pit Rule. Case No. 14784 and 14785 Order No. R-13506-D This rule covers all pits , closed-loop systems, below-grade tanks and sumps . Facilities under WQCC Discharge Plans are not exempt. NMOCD Pit Rule. - PowerPoint PPT Presentation
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NMOCD PIT RULE
19.15.17 NMACEffective June 28, 2013
NMOCD Pit Rule
Case No. 14784 and 14785
Order No. R-13506-D
This rule covers all pits, closed-loop systems, below-grade tanks and sumps. Facilities under WQCC Discharge Plans are not exempt.
NMOCD Pit Rule
Major Changes 2009 – 2013 Below-grade tank now defined as > 5 bbl.
Capacity
Continuously flowing watercourse defined
Floodplain defined
New concept: “Life-form ratio” (re-vegetation)
More Changes2009 – 2013
New concept: “Low chloride fluids”
“Measurable” now defined
New concept: “Multi-well fluid management pit”
Definition of “significant watercourse” expanded and made more descriptive
Temporary pits may now be used for multiple wells
Still More Changes
Major Changes 2009 – 2013 Permit still required for pits, but below-grade tanks
are “registered” (district office)
Closed-loop systems require only notification of their use (district office)
Other than site-specific data may now be used to determine groundwater depth (modeling, cathodic well lithology)
Major Changes in the Pit Rule
Major Changes 2009 – 2013 Time limits for action on a permit now imposed on the
NMOCD
If using “low-chloride fluids” (<15,000 mg/L): A pit is now allowed where groundwater is at least 25
feet below the bottom of the pit Significant changes in setbacks
Below-grade tanks meeting standards now allowed where groundwater is at least 25 feet deep
Even More Major Changes
Major Changes 2009 – 2013 A temporary pit (on-lease) or burial trench (on lease)
may receive waste from another temporary pit (on-lease)
Soil beneath a BGT or drying pad shall be remediated to 600 mg/kg chlorides
Containments of only untreated fresh water are not temporary pits for the purposes of the rule
ALL PITS AND BELOW-GRADE TANKSSUMPS, CLOSED LOOP SYSTEMS
GENERAL REQUIREMENTS
NMOCD Pit Rule
19.15.17.9 Permit Application and Registration
Form C-144 is to be used to apply to the division for a permit to construct or use a pit or to register a below-grade tank May be filed by itself or included as an attachment to
a permit application for the facility where the pit or below-grade tank will be located
NMOCD Pit Rule
Pit construction requires a permit issued by the division. All pits must be lined.
The division may issue a single permit for all pits associated with a single APD.
Below-grade tanks installed after June 28, 2013 must be registered with the appropriate division office.
Closed-loop systems and sumps do not require a permit or registration, but the district office must be notified on the APD or C-103, or applicable BLM form of use of a closed-loop system.
NMOCD Pit Rule
Siting Requirements for Excavated Material Newly-excavated (non-contaminated) Distance from a continuously flowing, or significant
watercourse 100 feet or greater Distance from a lakebed, sinkhole or playa lake 200
feet or greater Distance from a wetland 100 feet or greater Outside a 100-year floodplain
19.15.17.11 Design and Construction Specs
General for pits, closed-loop systems, BGT’s, and sumps Must adequately contain liquids and solids
Topsoil must be stripped and stockpiled
Signs for pits and BGT’s must be present. Well signs are sufficient
Pits must be fenced to deter unauthorized access
Chain link (6 feet high) with barbed wire (2 strands) on top if pit located within 1,000 feet of an occupied permanent residence, school, hospital, institution or church
Permanent pits, MWFM pits, and open top tanks must be netted
NMOCD Pit Rule
19.15.17.12 Operational RequirementsGeneral
Prevent contamination of fresh water and protect public health and the environment
Recycle, reuse, reclaim or dispose of all drilling fluids according to division rules
No hazardous waste in a pit, closed-loop system, BGT or sump
Liner integrity compromised above the fluid level, repair or replace within 48 hours
Liner integrity compromised below the fluid level, remove all fluid above the leak within 48 hours and notify the district office in accordance with 19.15.29
NMOCD Pit Rule
Operational RequirementsGeneral (cont’d)
Inject or withdraw liquids in a manner that prevents damage
Prevent collection of surface water run-on
Maintain oil-absorbent boom to control unanticipated releases
NMOCD Pit Rule
19.15.17.14 Emergency Actions Permit not required
Emergency pits are to be constructed, to the extent possible given the emergency, in a manner consistent with the Pit Rule
Notify the district office ASAP
Emergency pits to be used only for the duration of the emergency
If longer than 48 hours, obtain district office approval
Close within 48 hours after use unless time period extended by district office
COLLECTION, RETENTION OR STORAGE OF PRODUCED WATER OR BRINE, AND NOT A
TEMPORARY PIT
PERMANENT PITS
NMOCD Pit Rule
Permanent Pit Used for collection, retention or storage of produced
water or brine
In use for a relatively longer period of time
Special construction requirements
Regulated by the Santa Fe office
Must be inspected on a regular basis
Siting Requirements for Permanent or MWFMP
Groundwater depth 50 feet or greater from bottom of pit
Distance from a continuously-flowing watercourse 300 feet or greater
Distance from any other significant watercourse 200 feet or greater
Distance from a permanent residence, school, hospital, institution or church 1,000 feet or greater
Siting Requirements for Permanent or MWFMP
Distance from a spring or fresh water well used for stock watering 500 feet or greater
Outside incorporated municipal boundaries unless municipality specifically approves
Outside defined municipal fresh water fields unless municipality specifically approves
Distance from a wetland 500 feet or greater
Outside an area overlying a subsurface mine
Outside an unstable area
Outside a 100-year floodplain
NMOCD Pit Rule
Temporary Pit Drilling or workover pit
May be used for one or more wells
Must be located at one of the associated drilling locations
Must be closed within six months from the date the operator releases the rig from the first well using the pit
INCLUDES DRILLING OR WORKOVER PITS, TO HOLD LIQUIDS AND MINERAL SOLIDS.
MAY BE USED FOR ONE OR MORE WELLS
TEMPORARY PITS
NMOCD Pit Rule
Temporary Pits (District office) Construction shall follow applicable liner mfg.
requirements
Permit application shall include: Operating/Maintenance procedures Closure plan Hydrogeologic data In the absence of groundwater data, operator can
provide a reasonable determination of groundwater depth approved by the appropriate district office
NMOCD Pit Rule
Temporary Pits (continued)
Operators may have standard pit designs approved by the OCD district office
These standard plans may then be incorporated, by reference, in multiple APD’s
Applications sent to the appropriate district office
Low vs. Non-Low Chloride Fluids
Temporary Pit Siting Requirements 19.15.17.10
Low-Chloride FluidsWater-based, <15,000 mg/L of
ChloridesNon-Low-Chloride Fluids
Groundwater must be greater than 25 feet below the bottom of the pit.
Groundwater must be greater than 50 feet below the bottom of the pit.
Must be located more than 100 feet from any continuously flowing watercourse, or any other significant watercourse.
Must be located more than 300 feet from any continuously flowing watercourse, or any other significant watercourse.
Must be located more than 300 feet from an occupied permanent residence, school, hospital, institution, or church.
Must be located more than 300 feet from an occupied permanent residence, school, hospital, institution, or church.
Must be located more than 200 feet from a spring or fresh water source.
Must be located more than 500 feet from a spring or fresh water source.
Low vs. Non-low Chloride Fluids
Temporary Pit Siting 19.15.17.10
Low-Chloride FluidsWater-based, <15,000 mg/L of
ChloridesNon-Low-Chloride Fluids
Must be located outside incorporated municipal boundaries, and outside of a defined municipal fresh water field unless agreed to by the municipality
Must be located outside incorporated municipal boundaries, and outside of a defined municipal fresh water field unless agreed to by the municipality
Must be located more than 100 feet from a wetland.
Must be located more than 300 feet from a wetland.
Must be located outside an area overlying a subsurface mine.
Must be located outside an area overlying a subsurface mine.
Must be located outside of an unstable area.
Must be located outside of an unstable area.
Must be located outside any 100-year floodplain.
Must be located outside any 100-year floodplain.
NMOCD Pit Rule
Design and Construction Specs – SpecificTemporary Pits
Must confine liquids and prevent releases
Foundations and interior slopes must be properly constructed
Must have a geomembrane liner, 20-mil LLDPE or equivalent
Minimize liner seams and orient them up and down, not across a slope
NMOCD Pit Rule
Design and Construction Specs – SpecificTemporary Pits (Cont’d)
Avoid excessive stress and strain
Geotextile underliner required where needed
Edges anchored in trench at least 18 inches deep
Protect from any fluid force or mechanical damage
Prevent run-on of surface water using berm, ditch proper sloping or other diversion
NMOCD Pit Rule
Design and Construction Specs – SpecificTemporary Pits (Cont’d)
Pit volume limited to 10 acre feet including freeboard (2 feet)
The part of a temporary pit used to vent or flare gas does not require a liner.
No free-standing liquids on the unlined portion
NMOCD Pit Rule
Operational RequirementsSpecific – Temporary Pits
To contain only drilling, completion or workover fluids and solids
No miscellaneous solid waste or debris
Remove any visible layer of oil from the surface immediately after cessation of drilling or workover operation
At least 2 feet of freeboard
NMOCD Pit Rule
Operational RequirementsSpecific – Temporary Pits (cont’d)
Daily inspection while the rig is on location
Weekly inspection thereafter, so long as liquids remain in the pit
Free liquids removed from a drilling or workover pit within 60 days after rig release
Free liquids removed from a pit used for cavitation within 48 hours after completing cavitation
(MWFMP)STORAGE, TREATMENT AND RECYCLING OF
STIMULATION FLUIDS AND FLOW-BACK WATER DURING DRILLING AND
COMPLETION OF MULTIPLE WELLS
MULTI-WELL FLUID MANAGEMENT PITS
Multi-Well Fluid Management Pit (MWFMP)
Storage, treatment and recycling of stimulation fluids and flow-back water during the drilling and completion of multiple wells
No waste disposal
May be located either on- or off- location
Remain in use until all wells associated with the permit are completed
Applications include a list of wells to be associated with the MWFMP
Requests for additional wells will go to hearing
NMOCD Pit Rule
Multi-Well Fluid Management Pits (District Office) Construction shall follow applicable liner mfg. requirements
Permit application (Form C-144) shall include: Operating and maintenance procedures A list of wells, with approved applications to drill, that will be
associated with the pit Closure plan Hydrogeologic data In the absence of groundwater data, operator can provide a
reasonable (district-approved) determination of groundwater depth
NMOCD Pit Rule
Multi-Well Fluid Management Pits (continued)
Standard designs may be used and incorporated by reference
Applications sent to the appropriate district office
NMOCD Pit Rule
Design and Construction Specs – SpecificMulti-Well Fluid Management Pits
Designed to confine liquids and prevent releases
Properly constructed foundation
Slopes no steeper than 2H:1V
Levee’s outside grade no steeper than 3H:1V
Anchor trench for liners required
Double-lined (60-mil HDPE, or 30-mil PVC) with leak detection
NMOCD Pit Rule
Design and Construction Specs – SpecificMulti-Well Fluid Management Pits
Orient thermally-sealed seams up and down, not across slopes
Leak detection system as specified in 19.15.17.11.J (8) or a division-approved alternative (district office)
Surface water run-on to be prevented
Multi-Well Fluid Management Pits
Operational Requirements
Contains only stimulation fluids, produced water used for stimulation and drilling, and flow back from multiple wells
No visible layer of oil (see definitions)
At least 3 feet of freeboard
Weekly inspections to include leak detection system
Remove all fluids within 60 days from cessation of stimulation operations associated with the MWFMP
(BGT)
BELOW-GRADE TANKS
NMOCD Pit Rule
Below-Grade Tanks Registered with the OCD district office Form C-144 Registration shall include:
Operating and maintenance procedures Closure plan Hydrogeologic data Reasonable (district-approved) determination of
groundwater depth Standard designs may be submitted and incorporated
by reference
Siting Requirements for a Below-Grade Tank
Distance from a continuously flowing or significant watercourse, lakebed, sinkhole, wetland or playa lake greater than 100 feet
Distance from a spring or fresh water well used for public or livestock consumption greater than 200 feet
Groundwater depth greater than 25 feet below the bottom of the excavation containing the BGT
NMOCD Pit Rule
Design and Construction Specs – SpecificBelow-Grade Tanks
Made of a material that is resistant to the tanks contents and to damage from sunlight
Properly constructed foundation Level base Free of rocks, sharp edges, or irregularities
Constructed to prevent surface water run-on and overflow
NMOCD Pit Rule
Design and Construction Specs – SpecificBelow-Grade Tanks (cont’d)
Options(a) Double-walled construction not required if the tank’s side
walls are visible and the bottom of the tank is elevated a minimum of 6 inches and the underlying ground is lined and sloped toward a location that is visible
(b) If side walls are not visible, double-walled with leak detection required
(c) A division-approved alternative (district office)
NMOCD Pit Rule
Design and Construction Specs – SpecificBelow-Grade Tanks (cont’d)
No retrofit required for single-walled BGT’s, that have visible sidewalls, existing prior to June 16, 2008 so long as they demonstrate integrity
Single-walled BGT’s existing prior to June 16, 2008, whose sidewalls are not visible, must be retrofitted or closed
NMOCD Pit Rule
Operational RequirementsSpecific – Below-Grade Tanks
No fluid run-on or run-off No measurable layer of oil Monthly inspections Document integrity annually Freeboard adequate to prevent overtopping Repair or close if integrity is lost Inspect for contamination under a BGT during work
required for compliance with this rule
NMOCD Pit Rule
Operational RequirementsSpecific – Sumps
Visually inspect annually Promptly repair or replace if necessary Maintain records of inspections See sump definition
BURIAL & RECLAMATION
CLOSURE
Closure, In-Place or Trench Burial
Groundwater depth 25 feet or greater below the bottom of the pit (must meet standards set forth in Table II)
Distance from a continuously flowing watercourse 100 feet or greater
Distance from any other significant watercourse, lakebed, sinkhole or playa lake 200 feet or greater
Distance from an occupied permanent residence, school, hospital, institution or church 300 feet or greater
Distance from a spring or water well used for stock watering 300 feet or greater
Siting for Closure, In-Place or Trench Burial
Outside incorporated municipal boundaries and outside of a defined municipal fresh water field unless the municipality specifically approves
Distance from a wetland 300 feet or greater
Outside the area overlying a subsurface mine
Outside an unstable area
Outside a 100-year floodplain
Table I and Table II Closure Criteria
Table I lists criteria for soils beneath Below-Grade Tanks, Drying Pads Associated with Closed-Loop Systems and Pits where contents are removed.
Table II lists closure criteria for burial trenches and waste left in place in Temporary Pits Depth to protectable water Chloride, TPH, BTEX, Benzene analyses
Table I Closure Criteria
Table II Closure Criteria
NMOCD Pit Rule
Design and Construction Specs – SpecificBurial Trenches
Properly constructed foundation
Geotextile under the liner if needed
Geomembrane liner, 20-mil LLDPE or equivalent
Orient seams up and down, not across, slopes
Secure the outer edges
NMOCD Pit Rule
19.15.17.13 Closure and Site Reclamation
Where wastes are destined for off-site facilities
Must have approved closure plan in place
Remove all contents, including liners
Test soils beneath the liner 5-point composite sample Additional delineation may be required if sample analysis exceeds
Table I of 19.15.17.13 NMAC If sample analysis does not exceed these parameters, backfilling may
commence
Closure and Site Reclamation
Burial in place or temporary pit/lined trench burial Must have approved closure plan in place
Remove and dispose of all free liquids
Remaining pit contents must be stabilized or solidified
Mixing ratio maximum is 3:1 clean soil to contents
5-point composite sample of contents, after stabilization
If concentration of contaminants does not exceed Table II of 19.15.17.13 NMAC, operator may continue with closure
If concentration exceeds Table II parameters, closure must proceed in accordance with 19.15.17.13.C (dig and haul)
NMOCD Pit Rule
Closure and Site Reclamation Burial in place or temporary pit/lined trench burial
Fold outer edges of the liner to overlap the waste
Install a geomembrane (20-mil LLDPE) cover on top
Cover this with a 4-foot uncontaminated soil cover as described in 19.15.17.13.H(3)
Re-vegetate the location in accordance with 19.15.17.13.H(5)
Closure and Site Reclamation
Burial in place or temporary pit/lined trench burial
If the operator has transferred the wastes and the liner to a burial trench or another temporary pit, a 5-point composite sample must be taken under the original temporary pit
Sample must be analyzed for the constituents shown in Table I of 19.15.17.13 NMAC
Additional delineation may be required by the district office if levels are exceeded
If contaminant levels are not exceeded, operator may begin backfilling
NMOCD Pit Rule
Closure Notice Surface owner notification is required for any in-place or
trench burial
Notify surface owner at least 72 hours, but not more than one week, prior to closure operation
Include well name, API number and location
Certified mail, return receipt requested
Retain this proof of notification
NMOCD Pit Rule
Closure Notice The appropriate district office must be notified of any
in-place or trench burial closure
Notify verbally, and in writing at least 72 hours, but not more than one week prior to closure operation
The NMOCD Santa Fe office (Environmental Bureau) must be notified of any cessation of operations at a permanent pit at least 60 days prior to cessation and a proposed schedule for closure must be provided
NMOCD Pit Rule
Closure Notice
Onsite burial on private land requires a deed notice to be filed with the appropriate county clerk
NMOCD Pit Rule
Closure Report and Burial Identification
Document all closure activities on a C-144
Due within 60 days of closure completion
Plat showing the location of the temporary pit used for closure, or the location of an onsite burial to be included on C-105
Steel marker to be placed at the center of an onsite burial
Closure Timing
Permanent pit – within 60 days of cessation of operations
Temporary pit – within 6 months from the date of rig release from the first well using the pit
Drying pad – within 6 months from the date of rig release
Below-Grade Tanks – liquids removed and disposed of within 60 days of cessation of operations – closure within 6 months
MWFMP – within 6 months of cessation of stimulation operations on all associated wells
Reclamation
Pits, trenches, drying pads, below-grade tanks, areas associated with a closed-loop system
Reclaim to a safe and stable condition
So that former location blends with the surrounding area
Restore to the condition that existed prior to oil and gas operations
Contouring and re-vegetation per 19.15.17.13.H(5)
Alternatives to the contouring and re-vegetation requirements must be approved by the district office and the surface owner.
Reclamation
Soil covers for closures shall be the background thickness of topsoil or one foot whichever is greater
Chloride level for the soil beneath a BGT or drying pad shall be less than 600 mg/kg per EPA method 300.0
Chloride level for the soil cover for burial in place or trench burial shall be at least 4 feet of uncontaminated soil with chloride concentration less than 600 mg/kg per EPA method 300.0
Soil covers shall be contoured to prevent erosion
Reclamation and Re-vegetation
Reclaimed as nearly as practicable to their original condition
Contour topsoil and subsoil to achieve erosion control
Re-seed in the first favorable growing season
Reclamation complete when life-form ratio of 50%, and total plant cover of 70% of pre-disturbance levels is achieved excluding noxious weeds
These requirements shall be superseded by other federal or tribal agencies if those requirements equal or exceed those specified in this rule
EXCEPTION HANDLED BY SANTA FEVARIANCE HANDLED BY DISTRICT OFFICE
EXCEPTIONS & VARIANCES
NMOCD Pit Rule
19.15.17.15 Exceptions and Variances “Exception” means authorization from the
division’s Santa Fe office to depart from the requirements of 19.15.17 NMAC.
“Variance” means authorization from the appropriate division district office to depart from the requirements of 19.15.17 NMAC. A variance may not be obtained where exceptions are required specifically by a provision of 19.15.17 NMAC.
NMOCD Pit Rule
Exceptions and Variances The Commission made a conscious effort to specify, in
the rule, whether a particular departure from the rule was an exception or a variance
Generally: Any departure from a requirement concerning permanent pits must be approved by the Santa Fe office
Generally: Any departure from any other requirement can be approved by the appropriate OCD district office
NMOCD Pit Rule
Exceptions and Variances In the few instances where the rule does not specify, it
is safe to assume that a departure is a variance, and can be handled by the district office
The district office may deem such a departure to be significant enough that it requires an exception
Specific procedures listed in rule to apply for exception or variance
NMOCD Pit Rule
19.15.17.16 Permit Approvals, Conditions, Denials, Revocations, Suspensions, Modifications or Transfers Division shall determine an application
administratively complete or provide written notice as to deficiencies within 30 days of receipt
If no written notice is received, operator may assume application is administratively complete. This does not mean the permit is approved.
NMOCD Pit Rule
19.15.17.16 Permit Approvals, Conditions, Denials, Revocations, Suspensions, Modifications or Transfers The division has a total of 60 days to approve, deny or
approve with conditions the application
If no action is taken by the division within 60 days, application is deemed denied
Operator may apply for a hearing
NMOCD Pit Rule
19.15.17.16 Permit Approvals, Conditions, Denials, Revocations, Suspensions, Modifications or Transfers The division may impose conditions for approval
The division must notify the operator in writing if application is denied
The operator may apply for a modification of a permit
NMOCD Pit Rule
19.15.17.16 Permit Approvals, Conditions, Denials, Revocations, Suspensions, Modifications or Transfers The division may revoke, suspend or impose additional
conditions upon discovery that the operator is in material breach of any applicable statutes or rules
Operator to be notified by certified mail, return receipt requested of any intended revocation, suspension or imposition of additional conditions
Operator may request a hearing on this matter within 10 days after receipt of such notification
NMOCD Pit Rule
19.15.17.16 Permit Approvals, Conditions, Denials, Revocations, Suspensions, Modifications or Transfers Permits shall not be transferred without division
approval
Division approvals shall be by written statement
Written statements include e-mail
NMOCD Pit Rule
Thank you for your time and attentionIf you have questions:
Hobbs District Office: 575-393-6161 Artesia District Office: 575-748-1283 Aztec District Office: 505-334-6178 Ed Martin: 505-476-3470