The Railroad Commission of Texas last month adopted revisions for Chapters 3 and 4 of its rules that govern commercial oilfield waste landfills and on-site disposal at drilling rigs. The new rule — a compendium of numerous new requirements — goes into effect on July 1 and covers waste streams that include drill cuttings, mud that oozes out of wells and the saline wastewater that comes to the surface during drilling.
The rule-making generated widespread interest. The commission, which regulates oil and gas drilling and waste, received over 650 public comments on the draft rule from individuals, companies and associations.
The final rule includes new provisions that watchdogs say will better protect property owners and the environment. For the first time companies will have to register the location of earthen waste pits that contain toxic drilling waste, known as reserve pits. But companies holding leases to drill on private property will still be able to bury this waste near the surface without notifying the landowner or, in most cases, lining the pit to prevent groundwater contamination. These pits were the subject of more than 400 public comments.
Some oil and gas companies had submitted comments in favor of easing provisions in the draft rule. Other companies had urged the commissioners to go further in requiring new reserve pit protections to bring Texas regulations in line with other states. In response to public comments on reserve pits, the Railroad Commission technical staff wrote that they attempted to “strike a balance between these interests.”
Commissioner Jim Wright, who spearheaded the rulemaking, reflected on the multi-year process during the December meeting.
“Today I believe the Railroad Commission and the state of Texas have taken a significant step forward to update our practices and procedures to better align with the considerable changes that have occurred in those 40 years,” he said.
Waste pit requirements
The waste rule, last updated in 1984 and previously housed in Chapter 8 of the RRC rules, covers a wide range of disposal sites for drilling wastes. Texas is now drilling record amounts of oil and gas. Waste streams have also changed as hydraulic fracturing, or fracking, overtook conventional drilling. Horizontal wells used for fracking can extend laterally up to four miles, which generates more waste.
“The volume of waste for every well that’s drilled is dramatically higher,” explained Gabriel Rio, the CEO of Milestone Environmental Services, an oilfield waste management company based in Houston.
Operators must dispose of the mud and cuttings that return to the surface when a well is drilled.
One horizontal well generates between 8,000 and 16,000 barrels of waste, equivalent to 336,000 to 672,000 gallons, according to Milestone’s comments on the draft.