Consider and/or act upon protest of R360 Environmental Solutions, LLC’s

Staff Report & Agenda Item Details

Consider and/or act upon protest of R360 Environmental Solutions, LLC’s request to the RRC to build a Solid Waste Disposal Facility in Northern Pecos County 2 miles south of the Pecos River on Hwy 18. General Manager Ty Edwards gave the following brief background: This is a solid waste disposal facility located 2 miles south of the Pecos River on Highway 18 on Schuyler Wight's property composed of a 300 acre lease. R360 Environmental Solutions (R360) filed their application for a Commercial Oil & Gas Waste Treatment & Disposal Facility with the Texas Rail Road Commission (RRC) in early 2017. MPGCD protested the application, and R360 withdrew their application. R360 re-filed their application and MPGCD protested it. Currently R360's application is administratively complete and is awaiting a hearing date to be set at the RRC. R360 has asked MPGCD to withdraw the protest, and is the reason they are here today. One of the main reasons that we protested it is the close proximity to the Pecos River and Santa Rosa Spring. The groundwater depth is around 35 feet in that area, and with the pits being 25 feet deep, there is very little separation. Luke Bross with R360 presented a power point presentation to the Board. R360 is an oil and gas waste disposal recycling company. They are a wholly owned subsidiary of Water Connections, Inc. and is the nation’s largest E&P waste disposal company with over 40 facilities, and 22 land-fills. This facility is designed for 30-year lifespan, and will also depend on the industry and market. Middle Pecos GCD Minutes for May 21, 2019 Page 7 As Oil and Gas companies drill a deep well to say 20,000 feet, they have drill cuttings, mud, fluids that they add, and drilling waste. This is trucked to us and we treat and dispose of it. The leachate collection pond will have a duplicate in case one fills up. The leachate is siphoned off and trucked to a disposal well. There is a 50-acre- landfill with a berm around it. This cell is an engineered cell and is triple lined with a geo-synthetic liner. A 60 mil liner is on top of that, and then there is the leak detection system and a leachate collection system, and underneath that there is another 60 mil liner, and underneath that is another geo-synthetic liner. The landfill area will serve as the treatment staging area, and where we will dry the waste before it goes into the landfill cell. This cell is roughly 10° or 15” deep. Once the cell is closed — it will be covered up, and then the cell will be expanded and operations will continue. We continuously hau! off and keep our leachate levels low. There is groundwater monitoring wells surrounding each one of our facilities to monitor the groundwater. Each well will be sampled quarterly for the following RRC required parameters: Benzene, Total Petroleum Hydrocarbons, Total Dissolved Solids, Chloride, Bromide, Sulfate, Nitrate, Carbonate, Calcium, Magnesium, Sodium, and Potassium. There will be a total of 7 monitor wells. One up gradient well, and six down gradient wells across the permitted unit. There were initially going to be 5 monitor wells, and 2 more monitor wells have been added at the request of MPGCD. Base line water quality analysis samples will be pulled once the wells are drilled, and then sampling will be done quarterly and only includes the facility parameter. All 7 monitor wells will be sampled quarterly, and the results are submitted to the RRC and to MPGCD. Sampling will continue for 5 years after the facility is closed. Surface water that does not touch the waste is collected in surface water ponds. The rainfall and surface water that does come in contact with the waste collection is collected in the leachate ponds and is disposed down a well. Rainfall on the solid waste pits goes through a drainage system, then to a holding pit, and then gets hauled off continuously. We do not plan on drilling any water wells. We plan to haul water in, and haul water off. We do not have plans on putting

This motion is scored as RESTRAINS_GOVERNMENT (Impact Weight: 4.3/10). Under the Bastiat Liberty Watchdog Index, voting YES on measures that cap or reduce ad valorem tax burdens, expand taxpayer exemptions, retire debt early, enforce competitive bidding caps, or remove regulatory/zoning barriers to private property rights earns a positive Pro-Liberty score.