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USEPA Region 6 Update TCEQ UIC Symposium May 17, 2017
Brian Graves UIC Land Ban Coordinator
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Image is an Organization Chart of the US Environmental Protection Agency Region 6.
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Water Division 5/25/2019 William K. (Bill) Honker Director
United States Environmental Protection Agency · Region 6 · Dallas, TX Water Division Phone · Fax William K. (Bill) Honker Director (6WQ) Image is an Organization Chart of the Water Division of the Environmental Protection Agency in Region 6 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) Karen McCormick Section Chief, Marine, Coastal & Analysis Section (6WQ-EC) Patricia A. Taylor Team Leader, Surface Water Team (6WQ-EC) Maria Martinez Section Chief Wetlands Section (6WQ-EM) Richard Wooster, Section Chief, Assessment, Listing and TMDL Section (6WQ-PT) Brent E. Larsen Section Chief, Permitting Section (6WQ-PP) James R. Brown, Assoc. Director, Safe Drinking Water Branch (6WQ-S) Kim Ngo, Section Chief, Drinking Water Section, 6WQ-SD Philip Dellinger, Section Chief, Groundwater and UIC Section (6WQ-SG) David F. Garcia Deputy Director (6WQ) Stacey Dwyer Associate Director (6WQ-P) Angela Restivo, Acting Section Chief, NPDES Mgmt. Section, (6WQ-PO) VACANT, Section Chief, Community Infra- structure Section XXXX (6WQ-AP) Philip Crocker Section Chief, Watershed Management Section (6WQ-EW) Curry Jones, Section Chief, State/Tribal Program Sect. (6WQ-AT) 5/25/2019
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Philip Dellinger, Geologist
Chief FAX Ground Water Center Ground Water UIC/Section 6WQ-SG US Environmental Protection Agency Region 6 1445 Ross Avenue Dallas, TX Michael Overbay, Geologist Coordinator Nancy Dorsey, Geologist Special Projects UIC Land Ban UIC State Programs Brian Graves, Engineer Omar Martinez, Env. Scientist Sole Source Aquifers Arnold Bierschenk, Geologist Mike Frazier, Geologist UIC Direct Implementation on Indian Lands Bill Hurlbut, Geologist Permits Railroad Commission of Texas (RRC) AR & Reporting Jana Harvill, Engineer LA José Torres, Engineer Texas Commission on Environmental Quality (TCEQ) Lauren Ray, Geologist Oklahoma Department of Environmental Quality (ODEQ) Oklahoma Corporation Commission (OCC) Lisa Pham, Engineer NM & Aquifer Exemptions Ken Johnson, Engineer Chris Tingey, Geologist Image is an organization chart of the Ground Water/UIC Section of the Environmental Protection Agency Region 6
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Image is a screenshot of the EPA UIC webpage for Region 6
Image is a screenshot of the EPA UIC webpage for Region 6 Link to the EPA UIC Webpage
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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
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Image is a chart showing the number of petitions per state for Class I Injection Well No Migration Petitions
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Image is a screenshot of the webpage.
Link to the EPA Guidelines for Completing Class I Petition webpage Image is a screenshot of the webpage.
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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
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Image is a screen shot of an application
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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.
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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
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Image is a screen shot of EPA Region 6 modeling strategy for UIC No Migration Petitions.
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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.
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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
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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.
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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
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Active No Migration Petitions Chart
Image is a Pie chart of Petitions per region EPA Region
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Region 6 Workload Status (3 new petitions and 14 reissuances)
Image is a pie chart of petition and reissuance work load in region 6.
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Image is a graph of petitions by date that are received and expiring
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Technical Assistance Region 6 continues to provide assistance to EPA HQ, other Regions and States. Falloff test review for various well classes Step-rate test review for various well classes Input on no migration petition reviews Radioactive tracer and temperature survey reviews Image group is a graphic of a computer, and 3 different graphic chart representations.
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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.
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