Subject: TRC Spill Cleanup Guidelines/GLO Oil Spill Penalties
From: [email-masked]
To: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
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Date: Thu, 27 Jul 2000 10:14:00 -0700 (PDT)

The Texas RailRoad Commission (TRC)  has sent a guideline for cleanup of 
condensate spills to its District Offices for implementation on July 1, 
2000.  Attached is the guideline which is titled,  

Field Guide for the Assessment and Cleanup of Soil and Groundwater 
Contaminated with Condensate From a Spill Incident (Statewide Rules 8, 20, 
and 91)

The introduction to the guideline states that it establishes bench marks and 
protocols that, when met and followed, will demonstrate that condensate 
spills have been addressed in a manner that complies with Statewide Rules 8, 
20, and 91.

Some comments related to this guideline from an industry association meeting 
in mid-July are listed below:

There appeared to be a wide variation in response of the districts to this 
guideline.

The TRC is receiving landowner compliants.  The TRC has gone out and found 
spills not cleaned up, where closure reports have been submitted.  

Parts of the guideline are not clear and the groundwater classification is 
not consistent with TRRP.  A revised guideline might be issued by TRC.

This condensate guideline is temporary until RBCA guidelines are available.  
TRC is working on a software model projected by the end of this year.

Also attached is another guideline that the TRC issued at the same time, 
which is titled:

Field Guide for Reportable Surface Releases of Crude Oil in Non-sensitive 
Areas (Statewide Rules 8, 20, and 91).

In a somewhat related item, the General Land Office on June 23, 2000 issued 
revised penalty guidelines (attached) effective August 1st for oil spills in 
Texas coastal waters.  Spills of less than a gallon will have fines of $250.  
The fines for larger spills will depend on factors such as the size of the 
spills, the number of unauthorized discharges in the past twelve-month 
period, and whether a Sound Management Practice or like program is in place.