Which Type of Facility Represents your Class I Injection Well Operations? Jan Bates, P.E. Underground Injection Control Permits Section Radioactive Materials Division Texas Commission on Environmental Quality TCEQ Trade Fair May 15, 2019

Facility Type Quandary Class I Injection Well Facility Type Facility Type Quandary

Types of Facility On-site Off-site Captured Non-commercial Commercial

Factors that determine Type of Facility Property boundaries Facility boundaries Who owns the facility Who operates the facility

Factors that determine Type of Facility (cont.) Location of waste generation Who generates the waste Location of waste management units Who uses the waste management units Who operates the waste management units

Definitions Related to Facility Class I Injection Well Facility Type Definitions Related to Facility

Facility §335.1(61) Includes all contiguous land Includes structures, appurtenances, improvements on the land used for storing, processing and disposing of waste May be different when implementing Corrective Action for SWMUs

On-site §331.2(81) Contiguous property May be divided by rights-of way if entrance and exit between the properties is at a cross-roads intersection Noncontiguous property owned by the same person if a right-of-way connects the properties, is controlled by the owner, and is not accessible to the public

Off-site §331.2(80) Property not characterized as on-site

Captured Facility §331.2(22) Manufacturing or production facility Generates waste that is routinely sorted, processed, or disposed of on a shared basis in an integrated waste management unit Located within a contiguous manufacturing complex

Non-commercial Well §331.2(77) Disposes wastes generated on-site Disposes waste generated at a captured facility Disposes waste generated at other facilities owned or effectively controlled by the owner/operator

Non-commercial Facility §331.2(75) Operates only non-commercial wells

Commercial Well §331.2(29) Disposes of wastes for a charge Except for a captured facility Except for a facility owned or effectively controlled by the owner/operator

Commercial Facility §331.2(27) Where one or more commercial wells are operated

Class I Injection Well Facility Type Case Studies

Facility Boundary & On-site/Off-site Case Study 1 Facility Boundary & On-site/Off-site

Facility Boundary, On-site/Off-site & Captured Facility Case Study 2 Facility Boundary, On-site/Off-site & Captured Facility

Case Study 3 On-site/Off-site

Case Study 4 Captured Facility

Case Study 5 Captured Facility

Case Study 6 Commercial Facility

Facility Type Summary Property & facility boundaries Owner & operator of the facility Location & generator of waste Location & user of waste management units Owner & operator of waste management units

UIC Program Contact Info Jan Bates, P.E. Underground Injection Control Permits Section Radioactive Materials Division (512) 239-6627 jan.bates@tceq.texas.gov (512) 239-6646 uic@tceq.texas.gov