Underground Injection Control (UIC) Permitting, Testing and - - PowerPoint PPT Presentation

▶
underground injection control uic permitting testing and
SMART_READER_LITE
LIVE PREVIEW

Underground Injection Control (UIC) Permitting, Testing and - - PowerPoint PPT Presentation

Nov 01, 2022 214 likes •1.01k views

Underground Injection Control (UIC) Permitting, Testing and Monitoring Injection-Storage Permits Unit February, 2019 1 Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide) Session Overview Overview: UIC Online

slide-1
SLIDE 1

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Underground Injection Control (UIC) Permitting, Testing and Monitoring

Injection-Storage Permits Unit February, 2019

1

slide-2
SLIDE 2

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Session Overview

Overview:

  • UIC Online Manual
  • Safe Drinking Water Act & Primacy
  • Application requirements
  • Permit Details

– Forms and Attachments – Administrative Review – Technical review

  • Contact Information

2

slide-3
SLIDE 3

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

UIC ONLINE MANUAL

Where is it?

3

slide-4
SLIDE 4

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Permitting UIC Manual

http://www.rrc.texas.gov/

4

slide-5
SLIDE 5

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Find Permitting Manual

Place cursor over Oil & Gas, then click Publications and Notices.

5

slide-6
SLIDE 6

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Find Permitting Manual - 1

Click Injection/Disposal Well Permitting, Testing and Monitoring Manual

6

slide-7
SLIDE 7

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Find Permitting Manual - 2

7

slide-8
SLIDE 8

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

SAFE DRINKING WATER ACT & PRIMACY

Where does RRC get their authority? What does RRC have authority

  • ver?

8

slide-9
SLIDE 9

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Safe Drinking Water Act

  • Safe Drinking Water Act – 1974
  • To protect human health and drinking water
  • Underground Injection Control (UIC)

– Prohibits contamination of USDWs

  • Underground Sources of Drinking Water

(USDW)

  • Enforcement Primacy

– RRC: April 1982

9

slide-10
SLIDE 10

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Water Quality Terms & Uses

  • USDW < 10,000 ppm Total Dissolved Solids

(TDS)

– SDWA protects

  • Usable-Quality Water < 3,000 ppm TDS

– RRC standard for casing

  • Freshwater / Superior Water < 1,000 ppm TDS

– RRC may recognize and require additional protection

10

slide-11
SLIDE 11

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Jurisdiction in Texas

Who has State Jurisdiction in Texas For Injection Wells (Primacy)?

  • Oil and Gas Related Activities: Railroad

Commission of Texas (RRC)

  • Other Injection Activities: Texas Commission
  • n Environmental Quality (TCEQ)

11

slide-12
SLIDE 12

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Injection Classes

  • Class I: industrial and municipal wastes
  • Class II: oil and gas injection, disposal,

storage

  • Class III: solution mining (brine mining)
  • Class IV: shallow injection (not used anymore)
  • Class V: shallow injection, non-hazardous,

remediation, pilot projects

  • Class VI: CO2 capture and storage

12

slide-13
SLIDE 13

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

INJECTION / DISPOSAL PERMITTING FORMS H-1/H-1A AND W-14

13

slide-14
SLIDE 14

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Injection Well Permitting

There are > 35,000 Active Class II Wells in Texas.

Permit Procedures for Class II Wells:

  • Administrative Review
  • Technical Review
  • Manager Review
  • Hearing (protested or UIC denied)

14

slide-15
SLIDE 15

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Forms H-1 / H-1A and Form W-14

Form W-14:

  • To apply for Disposal into a Non-Productive

Formation

  • Statewide Rule 9

Form H1 and H1A:

  • To apply for Injection /Disposal into a Productive

Formation

  • Statewide Rule 46
  • Multiple Zones: If a mix of Productive and Non-

Productive

15

slide-16
SLIDE 16

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Filing UIC Permit Applications

Do I file Forms H-1 & H-1A or Form W-14?

  • Is the injection formation productive or non-

productive?

  • Which form is determined by current or past

production within 2 miles radius.

  • File original application to RRC Technical

Permitting – UIC department in Austin.

  • Mail a copy of the application forms to the

district office.

16

slide-17
SLIDE 17

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Permit Application Filing Fees

  • Form W-14: $250 per wellbore
  • Forms H-1 & H-1A: $500 per wellbore
  • Exception Requests: $375 (additional) each

request

  • These fees include surcharges and are non-

refundable

  • Check or Credit (Central Records)
  • Applications will not begin processing until paid

17

slide-18
SLIDE 18

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Injection Form at a Glance - 1

  • Who? (P-5 information)

– Must have active P-5 – Operator name, number and address

  • Where? (P-4 information)

– Must have active P-4 (or be new drill) – Lease name and number – Field name and number

18

slide-19
SLIDE 19

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Injection Form at a Glance - 2

19

slide-20
SLIDE 20

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Determine the Field Name

H-1/H-1A Field Name:

  • is correlative to injection/disposal formation
  • use deepest if more than one formation, or keep

current Field Name if the well is on proration schedule in one of the proposed formations. W-14 Field Name:

  • may be correlative by formation name more than

2 miles away, or correlative to the formation that is the source of disposal fluids

20

slide-21
SLIDE 21

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Injection Form at a Glance - 3

  • Where? (Reservoir)

– Formation, Lithology, Permeability, etc.

  • Why?

– Purpose of Injection – Waterflood, Disposal, etc.

  • What?

– What will be injected – Salt Water, Natural Gas, etc.

21

slide-22
SLIDE 22

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Injection Form at a Glance - 4

22

slide-23
SLIDE 23

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Injection Form at a Glance - 5

  • How? (Well Data)

– Specific location

  • Legal description & coordinates

– Well construction

  • Casing, tubing, packer description

– Injection interval – Injection volumes & pressures

  • Sign

– Email address for quicker communication – Re-date so we can track the newest submission

23

slide-24
SLIDE 24

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Injection Form at a Glance - 6

24

slide-25
SLIDE 25

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Measured Depth / Total Vertical Depth

Total Vertical Depth (TVD)

  • Injection Interval

Measured Depth (MD)

  • Packer Depth
  • Perforation Depths
  • Put both on the form if deviated or horizontal!

25

slide-26
SLIDE 26

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Injection Form at a Glance - 7

johnsmith@xyz-operating.com

26

slide-27
SLIDE 27

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Email Address on Form

Including your email address on the application form:

  • Helps quick process of your application
  • Quick communication for missing information
  • No mail lag-time to receive permit
  • Write the email address near the signature

box (bottom of the application form)

27

slide-28
SLIDE 28

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

INJECTION / DISPOSAL PERMITTING ADMINISTRATIVE REVIEW

28

slide-29
SLIDE 29

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Administrative Permitting Staff

UIC General UIC Tel number (512)463-6792 Jason Lockie - Lead Jason.Lockie@rrc.texas.gov (512)463-4032 Darlene Cottle Darlene.Cottle@rrc.texas.gov (512)463-7330 Meghan Riley Meghan.Riley@rrc.texas.gov (512)463-6816 Vacant To be hired (512)463-3576

29

slide-30
SLIDE 30

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Administrative Review - 1

  • Fees are paid
  • Form is complete
  • Application includes all necessary attachments
  • Data entry into tracking system

30

slide-31
SLIDE 31

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Administrative Review - 2

Check Organization Report (Form P-5):

  • Check for current P-5 on file
  • Check corporation franchise taxes are paid

Check Certificate of Compliance (Form P-4):

  • Verify that applicant is operator of lease
  • For a new lease, file Form P-4 with completion report

Check UIC Well Inventory:

  • Is this application for a new or amended permit?

31

slide-32
SLIDE 32

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Dual Authorities

  • Only one permit may be valid on an

injection/disposal well at any given time

  • Amended permit supersedes the original permit
  • Plan re-permitting to coincide with workover
  • Whenever a dual authority is discovered, the
  • lder permit is cancelled

32

slide-33
SLIDE 33

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Administrative denial

  • Applications will be administratively denied if

lease is under severance or seal-in.

  • This does not apply to permit amendment

applications that return well to compliance.

33

slide-34
SLIDE 34

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

INJECTION / DISPOSAL PERMITTING ADMIN REVIEW - FORM ATTACHMENTS

34

slide-35
SLIDE 35

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Notice

Mail or deliver a copy of front and back of the application forms W-14 or H1/H-1A (letter may be included) to the following parties:

  • the surface owner of record (county deed)
  • adjacent surface owners of record if application is for

a commercial disposal well

  • operators of wells within a ½ - mile radius of the

proposed injection/disposal well

  • county clerk
  • city clerk if well is located within corporate city limits

35

slide-36
SLIDE 36

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Notice attachments - 1

  • Map showing the location of wells within ½-mile
  • f proposed injection/disposal well

– operators of wells must be notified unless the well is plugged and abandoned

  • For a commercial disposal well, provide a plat

showing the surface tract boundaries and all adjacent tract boundaries.

36

slide-37
SLIDE 37

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Notice attachments - 2

  • List the names and addresses of:

– surface owner(s), operators of wells within ½-mile radius, county clerk, city clerk, and adjoining surface

  • wners if commercial
  • Signed statement indicating the date that a copy
  • f the application form(s), front and back, was

mailed or delivered to everyone on the list.

37

slide-38
SLIDE 38

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Adjacent Surface Owner Plat

38

slide-39
SLIDE 39

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Commercial Facilities

  • Injection well is commercial if:

–waste is partially or wholly trucked in and –a disposal fee or other compensation is charged and –it is your primary business purpose

  • Surface facility requirements: spill prevention and

containment, restricted access, and additional financial security if you have pits

39

slide-40
SLIDE 40

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Publication Guidelines - 1

  • Publish notice for one day in a newspaper with

general circulation in the county

  • Submit newspaper clipping with notarized affidavit of

publication

  • Publication and affidavit format available on RRC

website - Injection Permitting Manual

  • 15 day waiting period after notice and publication

40

slide-41
SLIDE 41

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Publication Guidelines - 2

  • Match the application and the notice for:

– direction and miles to nearest town – injection/disposal interval – for several wells publish the shallowest top and deepest bottom

  • Legal authority for permit
  • Opportunity/ instructions to protest
  • RRC contact information

41

slide-42
SLIDE 42

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Publication Guidelines - 3

  • State that the application is for a “commercial”

disposal well if applicable

  • State H2S will be injected if applicable
  • Provide affidavit that the newspaper is of general

circulation in the county for the proposed well, certified by Notary Public

42

slide-43
SLIDE 43

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Permit Amendments

  • File Form W-14 or H-1/H-1A with filing fee
  • Filing requirements vary with purpose of amendment
  • Zone amendments or permits pre-dating April 1982

– Well log – Groundwater letter – AOR map and table

43

slide-44
SLIDE 44

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Permit Amendment Guidelines

44

slide-45
SLIDE 45

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

INJECTION / DISPOSAL PERMITTING TECH REVIEW - FORM ATTACHMENTS

45

slide-46
SLIDE 46

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Electric Log

  • Complete electric log with header
  • Include proposed zone and overlying strata
  • If log is unavailable, submit a log from a

nearby well (include plat showing both locations)

  • If multiple wells are one Form H-1, only one

well log is required if the log is representative

  • f all wells

46

slide-47
SLIDE 47

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

GAU Letter

  • RRC Groundwater Advisory Unit (GAU) issues

the Groundwater Depth Letter

  • H-1/H-1A: Form GW-2 stating the depth to

which usable-quality water (UQW) and USDW must be protected

– GW-1 Purpose of Filing must be H-1

  • W-14: Submit GAU letter stating that the

proposed injection will/will not endanger UQW and USDW.

47

slide-48
SLIDE 48

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Area of Review (AOR)

  • Provide scaled map of wells within ¼-mile
  • Table of wells within AOR with:

– lease name and number – API and well numbers – total depth and date drilled – current status (producing, shut-in, P&A’d, etc) – plugged wells, include plug date and W-3

  • Confirm that wells are on the proration schedule,

have been properly plugged, or do not penetrate the injection zone

48

slide-49
SLIDE 49

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Create AOR Map – Public GIS Viewer

49

slide-50
SLIDE 50

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Create AOR Map - 1

50

slide-51
SLIDE 51

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Create AOR Map - 2

51

slide-52
SLIDE 52

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Create AOR Map - 3

List wells in the circle. Click radius icon and the circle

  • disappears. Click identify.

52

slide-53
SLIDE 53

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Create AOR Map - 4

Click Identify Tool. Then, click on the well of interest. See injection well on schedule.

53

slide-54
SLIDE 54

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

AOR Map Example

54

slide-55
SLIDE 55

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

AOR Well Listing Example

55

slide-56
SLIDE 56

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Unknown or Improperly Plugged Well

  • You may plug the well or enter the well to determine

status if unknown

  • Applicant may use a Pressure Front Calculation (PFC)

to show the actual affected radius is less than ¼-mile

  • PFC must be prepared by a Texas-Registered

Professional Engineer

56

slide-57
SLIDE 57

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Seismic Activity Amendments

  • Amendments to Rules 9 & 46 in 2014

– RRC may modify, suspend or terminate a permit if injection is likely to be contributing to seismic activity – Requires seismic information with disposal well applications

  • Include a survey of seismic events from the USGS

within 9.08 kilometers of the proposed well site

  • USGS Earth Archive Search – use following link:

(http://earthquake.usgs.gov/earthquakes/search/)

57

slide-58
SLIDE 58

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Seismic Event Survey - 1

  • Enter the following parameters in USGS Earth Archive

Search:

– DATE & TIME: 1973-01-01 00:00:00 – MAGNITUDE: Minimum: Enter 1 – Advanced Options:

  • CIRCLE: Center Latitude and Center Longitude
  • CIRCLE: Outer Radius; Enter 9.08
  • Include the map and the page depicting your inputs
  • The map should display details about each event,

including location, magnitude, and date

58

slide-59
SLIDE 59

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

USGS Earth Archive Search - 1

59

slide-60
SLIDE 60

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

USGS Earth Archive Search - 2

60

slide-61
SLIDE 61

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

USGS Earth Archive Search - 3

61

slide-62
SLIDE 62

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Fresh water injection for EOR

  • Fresh water questionnaire

– Search for “questionnaire”

  • Form H-7 (unless fresh water is purchased)

– plat of fresh water rights – chemical analysis of the fresh water

62

slide-63
SLIDE 63

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

INJECTION / DISPOSAL PERMITTING TECHNICAL REVIEW CONT’D

63

slide-64
SLIDE 64

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Surface Casing

  • Base of usable-quality water (BUQW) determined by

GAU

  • Commercial and new injection/disposal wells must set

and cement surface casing through the BUQW

  • Wells converted from production are reviewed on a

case-by-case basis. If permitted, additional requirements like: – annual mechanical integrity (MIT) testing vs 5 years – weekly tubing-casing annulus monitoring (TCAM)

64

slide-65
SLIDE 65

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Production Casing Cement

  • Cement must be adequate to confine fluids to the

injection zone

  • 600 feet of cement above injection interval if high

yield cement is used and Top Of Cement (TOC) is based on volume calculation.

  • 250 feet if TOC is based on temperature survey
  • 100 feet if TOC is based on cement bond log and

– At least 80% bond – No indication of channeling

65

slide-66
SLIDE 66

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Geological Requirements

  • SWR 9 disposal wells must have a “no harm” letter

from GAU

  • SWR 46 injection/disposal wells must be isolated

from usable-quality water by 250 total feet of low permeability strata and adequately separated from USDW

  • Pre-primacy wells without adequate separation, if

permitted, will have injection fluids limited to fluids produced from the same lease and formation

66

slide-67
SLIDE 67

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Packer setting depth

  • Rule 9: set within 100 feet of the permitted zone
  • Rule 46:

– 150 feet below base of usable-quality water and 200 feet below TOC – Should have cement behind casing and no permeable zones between the packer and the top of the injection interval to protect natural resources

67

slide-68
SLIDE 68

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Injection Pressures

  • Typical maximum is ½ psi per foot of depth
  • For coastal wells less than 2,000 feet, injection

above Barnett Shale, and injection into Delaware formations pressure may be limited to ¼ psi per foot

  • Fracture step-rate tests may justify a higher

pressure or be required if formation fracture pressure is known to be low

68

slide-69
SLIDE 69

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Injection Fluids

  • Limited to the injection of produced salt water unless
  • ther fluids are specified (see Item 45 on Form H-1)
  • Injection of Hydrogen Sulfide requires “well-specific”

authority (SWR 36) – Must go through a public hearing – Admin approval from the District Office H2S Coordinator if already been through public hearing

69

slide-70
SLIDE 70

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Application vs Construction

  • The well must be constructed and operated as

proposed and permitted

  • Significant changes will require permit amendment,
  • r may result in enforcement or permit cancellation
  • Permit-required remedial action must be done

before injection begins

70

slide-71
SLIDE 71

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Injection Initiation

  • Perform a Mechanical Integrity Test (MIT, Form H-5)

before injection

  • File completion report (Form W-2/G-1)

– Filing online greatly reduces processing time – Lease numbers for new leases are assigned after final processing/approval of completion report

  • File annual Form H-10 upon due date

– You will receive a letter indicating when H-10 is due – Filing online greatly reduces processing time

71

slide-72
SLIDE 72

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Protested Applications - 1

  • Staff may not administratively issue a permit if it has

a valid protest

  • Protests should be filed within 15 days of the date of

publication or the date the application is filed with UIC department, whichever is later.

  • However, protests received later than 15 days and

before a permit is issued are typically considered valid

72

slide-73
SLIDE 73

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Protested Applications - 2

  • Affected persons:

– Operators of wells within ½ mile – Surface owner of record – Adjoining surface owners for commercial well – Local government (such as city or water district)

  • Others if RRC determines it’s in the public interest:

– offset surface or mineral owners – other government agencies – members of the general public

73

slide-74
SLIDE 74

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Affected Persons

Affected Person: a person who has suffered or will suffer actual injury or economic damage

  • ther than as a member of the general public or

as a competitor, and includes surface owners of property on which the well is located and commission-designated operators of wells located within one-half mile of the proposed disposal well.

74

slide-75
SLIDE 75

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Affected Person Letters

  • In coordination with RRC Office of General Counsel,

UIC is reviewing application protests to determine if they may not be from an “affected person”

  • UIC may ask protestors to reply with an explanation
  • f their affected person status
  • UIC may issue a permit administratively if no affected

person protests an application

75

slide-76
SLIDE 76

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Protested Applications

Options for applicant:

  • Withdraw the application
  • Obtain a withdrawal letter from the protestant, or
  • Request a hearing

– The application must be administratively complete – Pre-hearing and/or hearing will be held – Protest is dismissed and remanded to UIC for administrative processing, or the Commission rules on the application

76

slide-77
SLIDE 77

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Permit Application Denials

  • If application remains incomplete after two

additional submittals, it is returned

  • Unsatisfactory completion or operating proposal

– Modify the application to allow for administrative approval, or – Request a hearing

77

slide-78
SLIDE 78

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Technical Review Staff

Sean Avitt Sean.Avitt@rrc.texas.gov (512) 463-3011 Robert Alford Robert.Alford@rrc.texas.gov New Cheryl Burns Cheryl.Burns@rrc.texas.gov (512) 463-6439 Will Labbe William.Labbe@rrc.texas.gov New Nagi Mabruk Nagi.Mabruk@rrc.texas.gov (512) 475-4655 Jim Moore Jim.Moore@rrc.texas.gov (512) 463-6443 Nicole Moore Nicole.Moore@rrc.texas.gov New Tony Rios Anthony.Rios@rrc.texas.gov (512) 463-2259 Scott Rosenquist Scott.Rosenquist@rrc.texas.gov (512) 475-2307

78

slide-79
SLIDE 79

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

The End

79