USEPA Region 6 Update

Transcription

1 USEPA Region 6 Update TCEQ UIC Symposium May 17, 2017 Brian Graves UIC Land Ban Coordinator graves.brian@epa.gov

2 Image is an Organization Chart of the US Environmental Protection Agency Region 6.

3 Image is an Organization Chart of the Water Division of the Environmental Protection Agency in Region 6 United States Environmental Protection Agency Region 6 Dallas, TX Water Division Phone Fax William K. (Bill) Honker Director (6WQ) David F. Garcia Deputy Director (6WQ) Olivia Balandran, Team Leader, Outreach and Sustainability Team, (6WQ) Claudia Hosch, Assoc. Director, Assistance Program Branch (6WQ-A) Jane Watson, Assoc. Director, Ecosystem Protection Branch (6WQ-E) James R. Brown, Assoc. Director, Safe Drinking Water Branch (6WQ-S) Stacey Dwyer Associate Director (6WQ-P) VACANT, Section Chief, Community Infra- structure Section XXXX (6WQ-AP) Maria Martinez Section Chief Wetlands Section (6WQ-EM) Kim Ngo, Section Chief, Drinking Water Section, 6WQ-SD Angela Restivo, Acting Section Chief, NPDES Mgmt. Section, (6WQ-PO) Curry Jones, Section Chief, State/Tribal Program Sect (6WQ-AT) Philip Crocker Section Chief, Watershed Management Section (6WQ-EW) Philip Dellinger, Section Chief, Groundwater and UIC Section (6WQ-SG) Brent E. Larsen Section Chief, Permitting Section (6WQ-PP) 5/4/17 Karen McCormick Section Chief, Marine, Coastal & Analysis Section (6WQ-EC) Patricia A. Taylor Team Leader, Surface Water Team (6WQ-EC) Richard Wooster, Section Chief, Assessment, Listing and TMDL Section (6WQ-PT)

4 Ground Water UIC/Section 6WQ-SG US Environmental Protection Agency Region Ross Avenue Dallas, TX Image is an organization chart of the Ground Water/UIC Section of the Philip Dellinger, Geologist Environmental Protection Agency Region 6 Chief FAX Ground Water Center Michael Overbay, Geologist Coordinator UIC Land Ban Brian Graves, Engineer Coordinator UIC Direct Implementation on Indian Lands Bill Hurlbut, Geologist Permits UIC State Programs Mike Frazier, Geologist Coordinator Railroad Commission of Texas (RRC) Nancy Dorsey, Geologist Special Projects Omar Martinez, Env. Scientist Sole Source Aquifers Arnold Bierschenk, Geologist Nancy Dorsey, Geologist Mike Frazier, Geologist Jana Harvill, Engineer Chris Tingey, Geologist Permits Nancy Dorsey, Geologist Oklahoma Corporation Commission (OCC) Jana Harvill, Engineer LA Omar Martinez, Env. Scientist AR & Reporting Ken Johnson, Engineer Lisa Pham, Engineer NM & Aquifer Exemptions Lauren Ray, Geologist Lauren Ray, Geologist Oklahoma Department of Environmental Quality (ODEQ) Chris Tingey, Geologist José Torres, Engineer Texas Commission on Environmental Quality (TCEQ)

5 Image is a screenshot of the EPA UIC webpage for Region 6 Link to the EPA UIC Webpage

6 Image is a screenshot of the EPA UIC Impact of RCRA Land Disposal Restrictions webpage Link to the EPA UIC Impact of RCRA Land Disposal Restrictions webpage

7 Image is a chart showing the number of petitions per state for Class I Injection Well No Migration Petitions

8 Link to the EPA Guidelines for Completing Class I Petition webpage Image is a screenshot of the webpage.

9 Issue: QA/QC of petition documents Region 6 Actions to Address Developed UIC No Migration Petition Guidelines Stop review and send deficiencies identified to date Have a conference call just with operator to discuss the QA/QC issues Developed petition crosswalk to ensure all regulatorily required items are addressed and where they are addressed

10 Image is a screen shot of an application

11 Still having quality issues which delays the process Additional thoughts going forward: The crosswalk should be filled out by the preparer while the application is generated. The crosswalk should document how the information referenced satisfies the regulatory requirement. Don t just list a page number explain it briefly.

12 Other Streamlining Initiatives Region 6 Guidelines webpage Items contained on this webpage: UIC Petition Application Guideline UIC No Migration Petition Crosswalk Modeling Strategy for UIC No Migration Petitions Initial submittal should be a geologic interpretation and modeling strategy package

13 Image is a screen shot of EPA Region 6 modeling strategy for UIC No Migration Petitions.

14 Other suggestions and thoughts Have a face-to-face working meeting prior to beginning the petition work. Have a face-to-face working meeting if there are significant deficiencies. Region 6 legal has approved the transition to largely electronic submissions. This should help streamline the review process and when changes need to be made there won t be the replacement page process which can be time consuming and confusing. Keep the demonstration as simple as possible.

15 Reissuance requests include a summary upfront outlining changes from the previous approval to focus EPA review. Did the geologic interpretation change? Did the model parameters change? Did the pressure buildup/plume change? Identify new or changed condition artificial penetrations

16 Electronic Submittals Submit a disk/thumb drive with the whole petition/reissuance such that the whole disk/thumb drive is electronically searchable. Submit only hard copies of large documents (maps or cross sections), well logs and testing logs (radioactive tracer surveys, temperature logs, cement bond/evaluation logs etc.). Basically anything that is difficult to review on a computer screen/monitor.

17 Items of Focus for Petition Review* Local Geology (as related to the modeling setup) Model Input Parameters Injection History Pressure Buildup Models Cone of Influence Waste Plume Boundaries No Migration Demonstration Implementation and Compliance Section * Sections of the EPA Region 6 UIC Petition Application Guideline

18 Active No Migration Petitions Active No Migration Petitions Chart 2 4.5% 2 4.5% % Image is a Pie chart of Petitions per region EPA Region %

19 Region 6 Workload Status (3 new petitions and 14 reissuances) Image is a pie chart 6% of petition and reissuance work load in region % 2 12% % Waiting on Operator Waiting on EPA Under Review Circulating for Decision

20 Petition Cessation of Injection Date Image is a graph of petitions 10 by date that are received and expiring 6 "Expiring" Reissuance Received

21 Technical Assistance Region 6 continues to provide assistance to EPA HQ, other Regions and States. ü Falloff test review for various well classes ü Step-rate test review for various well classes ü Input on no migration petition reviews ü Radioactive tracer and temperature survey reviews

22 Technical Training Region 6 has instructed at the National UIC Inspector Training Course for the last 24 years. Image group is a cartoon inspector looking through a magnifying glass and a child raising his hand with a question.