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NMOCD PIT RULE

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.

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NMOCD PIT RULE

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  1. NMOCD PIT RULE 19.15.17 NMAC Effective June 28, 2013

  2. 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.

  3. 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)

  4. 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

  5. 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)

  6. 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

  7. 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

  8. GENERAL REQUIREMENTS All pits and below-grade tanks Sumps, closed loop systems

  9. 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

  10. 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.

  11. 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

  12. 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

  13. NMOCD Pit Rule • 19.15.17.12 Operational Requirements • General • 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

  14. NMOCD Pit Rule • Operational Requirements • General (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

  15. 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

  16. PERMANENT PITS COLLECTION, RETENTION OR STORAGE OF PRODUCED WATER OR BRINE, AND NOT A TEMPORARY PIT

  17. 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

  18. 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

  19. 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

  20. NMOCD Pit Rule • Temporary Pit • Drilling or workoverpit • 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

  21. TEMPORARY PITS INCLUDES DRILLING OR WORKOVER PITS, TO HOLD LIQUIDS AND MINERAL SOLIDS. MAY BE USED FOR ONE OR MORE WELLS

  22. 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

  23. 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

  24. Low vs. Non-Low Chloride Fluids Temporary Pit Siting Requirements 19.15.17.10

  25. Low vs. Non-low Chloride Fluids Temporary Pit Siting 19.15.17.10

  26. NMOCD Pit Rule • Design and Construction Specs – Specific • Temporary 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

  27. NMOCD Pit Rule • Design and Construction Specs – Specific • Temporary 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

  28. NMOCD Pit Rule • Design and Construction Specs – Specific • Temporary 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

  29. NMOCD Pit Rule • Operational Requirements • Specific – 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

  30. NMOCD Pit Rule • Operational Requirements • Specific – 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

  31. MULTI-WELL FLUID MANAGEMENT PITS (MWFMP) STORAGE, TREATMENT AND RECYCLING OF STIMULATION FLUIDS AND FLOW-BACK WATER DURING DRILLING AND COMPLETION OF MULTIPLE WELLS

  32. 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

  33. 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

  34. 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

  35. NMOCD Pit Rule • Design and Construction Specs – Specific • Multi-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

  36. NMOCD Pit Rule • Design and Construction Specs – Specific • Multi-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

  37. 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

  38. BELOW-GRADE TANKS (BGT)

  39. 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

  40. 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

  41. NMOCD Pit Rule • Design and Construction Specs – Specific • Below-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

  42. NMOCD Pit Rule • Design and Construction Specs – Specific • Below-Grade Tanks (cont’d) • Options • 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 • If side walls are not visible, double-walled with leak detection required • A division-approved alternative (district office)

  43. NMOCD Pit Rule • Design and Construction Specs – Specific • Below-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

  44. NMOCD Pit Rule • Operational Requirements • Specific – 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

  45. NMOCD Pit Rule • Operational Requirements • Specific – Sumps • Visually inspect annually • Promptly repair or replace if necessary • Maintain records of inspections • See sump definition

  46. CLOSURE BURIAL & RECLAMATION

  47. 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

  48. 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

  49. 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

  50. Table I Closure Criteria

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