API E5.pdf

Environmental Guidance Document: Waste Management in Exploration and Production Operations

API E5 SECOND EDITION, FEBRUARY 1997

Strategies for Today’s Environmental Partnership

American Petroleum Institute

Copyright American Petroleum Institute Provided by IHS under license with API

Not for ResaleNo reproduction or networking permitted without license from IHS

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One of the most significant long-term trends affecting the future vitality of the petroleum industry is the public’s concerns about the environment. Recognizing this trend, API member companies have developed a positive, forward looking strategy called STEP: Strategies for Today’s Environmental Partnership. This program aims to address public concerns by improving industry’s environmental, health and safety performance; documenting performance improvements; and communicating them to the public. The foundation of STEP is the API Environmental Mission and Guiding Environmental Principles. API standards, by promoting the use of sound engineering and operational practices, are an important means of implementing API’s STEP program.

API ENVIRONMENTAL MISSION AND GUIDING ENVIRONMENTAL PRINCIPLES

The members of the American Petroleum Institute are dedicated to continuous efforts to improve the compatibility of our operations with the environment while economically developing energy resources and supplying high quality products and services to consumers. The members recognize the importance of efficiently meeting society’s needs and our responsibility to work with the public, the government, and others to develop and to use natural resources in an environmentally sound manner while protecting the health and safety of our employees and the public. To meet these responsibilities, API members pledge to manage our businesses according to these principles:

0 To recognize and to respond to community concerns about our raw materials, products and operations.

o To operate our plants and facilities, and to handle our raw materials and products in a manner that protects the environment, and the safety and health of our employees and the public.

o To make safety, health and environmental considerations a priority in our planning, and our development of new products and processes.

o To advise promptly appropriate officials, employees, customers and the public of information on significant industry-related safety, health and environmental hazards, and to recommend protective measures.

o To counsel customers, transporters and others in the safe use, transportation and disposal of our raw materials, products and waste materials.

o To economically develop and produce natural resources and to conserve those resources by using energy efficiently.

o To extend knowledge by conducting or supporting research on the safety, health and environmental effects of our raw materials, products, processes and waste materials.

0 To commit to reduce overall emissions and waste generation.

o To work with others to resolve problems created by handling and disposal of hazardous substances from our operations.

o To participate with government and others in creating responsible laws, regulations and standards to safeguard the community, workplace and environment.

0 To promote these principles and practices by sharing experiences and offering assistance to others who produce, handle, use, transport or dispose of similar raw materials, petroleum products and wastes.



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Environmental Guidance Document: Waste Management in Exploration and Production Operations

Exploration and Production Department

API E5 SECOND EDITION, FEBRUARY 1997

American Petroleum Institute



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SPECIAL NOTES

API publications necessarily address problems of a general nature. With respect to particular circumstances, local, state, and federal laws and regulations should be reviewed.

API is not undertaking to meet the duties of employers, manufacturers, or suppliers to warn and properly train and equip their employees, and others exposed, concerning health and safety risks and precautions, nor undertaking their obligations under local, state, or federal laws.

Information concerning safety and health risks and proper precautions with respect to particular materials and conditions should be obtained from the employer, the manufacturer or supplier of that material, or the material safety data sheet.

Nothing contained in any API publication is to be construed as granting any right, by implication or otherwise, for the manufacture, sale, or use of any method, apparatus, or product covered by letters patent. Neither should anything contained in the publication be construed as insuring anyone against liability for infringement of letters patent.

Generally, API guidance documents are reviewed and revised, reaffirmed, or withdrawn at least every five years. Sometimes a one-time extension of up to two years will be added to this review cycle. This publication will no longer be in effect five years after its publication date as an operative API guidance document or, where an extension has been granted, upon republication. Status of the publication can be ascertained from the API Authoring De- partment [telephone (202) 682-8000]. A catalog of API publications and materials is published annually and updated quarterly by API, 1220 L Street, N.W., Washington, D.C. 20005.

All rights reserved. No part of this work may be reproduced, stored in a retrieval system, or transmitted by any means, electronic, mechanical, photocopying, recording or other-

wise, without prior written permission from the publishel: Contact the Publishel; API Publishing Services, 1220 L Street, N. W , Washington, D. C. 20005.

Copyright O 1997 American Petroleum Institute



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FOREWORD This document reflects our industry’s continuing commitment to environmental protec-

tion. It provides guidance for minimizing the direct and indirect environmental impacts of solid wastes originating from typical exploration and production (E&P) activities, which include exploration, drilling, well completions and workovers, field production, and gas plant operation.

This manual was prepared by the API Production Waste Issues Group, under the jurisdiction of the API Exploration and Production Department Executive Committee on Envi- ronmental Conservation.

The oil and gas industry must operate where oil and gas deposits are found. This means that the exploration and production activities listed above will be conducted in a variety of ecosystems, whose sensitivity to the activities of man will vary widely. The oil and gas industry must be environmental stewards in two critical ways:

a. It must use environmentally sound operating practices to manage materials, land, and the waste generated from exploration and production activities. b. It must produce oil and gas reserves as efficiently and prudently as possible in order to prevent squandering critical natural resources.

API publications may be used by anyone desiring to do so. Every effort has been made by the institute to assure the accuracy and reliability of the data contained in them; however, the institute makes no representation, warranty, or guarantee in connection with this publication an hereby expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal regulation with which this publication may conflict.

Suggested revisions are invited and should be submitted to the director of the Exploration and Production Department, American Petroleum Institute, 1220 L Street, N.W., Washing- ton, D.C. 20005.



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1 1.1 1.2 1.3 1.4 1.5

2 2.1 2.2 2.3 2.4 2.5

3

3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8

4 4.1 4.2 4.3 4.4 4.5 4.6 4.7

4.8 4.9

CONTENTS

page

POLLUTION PREVENTION Introduction ................................................................................................................ 1 API’s Management Practice for Pollution Prevention ................................................ 1 Media ......................................................................................................................... 1 Understanding Operational Impacts ........................................................................... 3 Pollution Prevention and waste Minimization ........................................................... 3

WASTE MANAGEMENT SYSTEM Introduction ................................................................................................................ 4 Summary of a Ten-Step Plan for Waste Management ................................................ 4 Training ...................................................................................................................... 4 Waste Tracking ........................................................................................................... 5 Auditing ...................................................................................................................... 5

WASTE GENERATION IN EXPLORATION AND PRODUCTION OPERATIONS Introduction ................................................................................................................ 6 Exploration ................................................................................................................. 6 Drilling ....................................................................................................................... 7 Completion and Workover ......................................................................................... 9 Field Production ....................................................................................................... 10 Gas Plant Operations ................................................................................................ 14 Transportation Pipelines ........................................................................................... 16 Offshore Operations ................................................................................................. 17

ENVIRONMENTAL LEGISLATION AND REGULATIONS Introduction .............................................................................................................. 17 The Resource Conservation and Recovery Act (RCRA) ......................................... 17 The Safe Drinking Water Act (SDWA) .................................................................... 22 The Clean Water Act (CWA) .................................................................................... 23 The Clean Air Act (CAA) ........................................................................................ 25 The Toxic Substances Control Act (TSCA) ............................................................. 25 The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) .......................................................................................... 25 The Oil Pollution Act of 1990 (OPA 90) ................................................................. 27 Other Federal Acts .................................................................................................. 27

4.10 Other Regulations and Agreements ......................................................................... 29

5 5.1 5.2 5.3 5.4 5.5

6 6.1 6.2 6.3 6.4

WASTE MANAGEMENT METHODS Introduction .............................................................................................................. 29 Source Reduction .................................................................................................... 29 Recycling and Reclaiming ........................................................................................ 30 Treatment .................................................................................................................. 30 Disposal .................................................................................................................... 30

IDENTIFYING MANAGEMENT OPTIONS FOR SPECIFIC WASTES Introduction .............................................................................................................. 38 Produced Water ........................................................................................................ 39 Drilling Wastes ......................................................................................................... 39 Workover and Completion Wastes ........................................................................... 41

V



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6.5 Tank Bottoms. Emulsions. Heavy Hydrocarbons. and Produced Solids .................. 42 6.6 Contaminated Soil .................................................................................................... 43 6.7 Used Oils and Solvents ............................................................................................. 43 6.8 Dehydration and Sweetening Waste ......................................................................... 44 6.9 Oily Debris and Filter Media ................................................................................... 44 6.10 Gas Plant Process and Sulfur Recovery Waste ......................................................... 45 6.1 1 Cooling Tower Blowdown. Boiler Water. Scrubber Liquids. and

Steam Generator Wastes ........................................................................................... 45 6.12 Downhole and Equipment Scale .............................................................................. 45 6.13 StormwaterRigwash ................................................................................................ 45 6.14 Unused Treatment Chemicals .................................................................................. 46 6.15 Asbestos .................................................................................................................. 46 6.16 Used Batteries .......................................................................................................... 46 6.17 PCB Transformer Oil ............................................................................................... 46 6.18 NonPCB Transformer Oil ........................................................................................ 46 6.19 Empty Oil and Chemical Drums ............................................................................. 47 6.20 Naturally Occurring Radioactive Material ............................................................... 47 6.21 Geological and Geophysical Operation Wastes ....................................................... 47 6.22 Recompression and Facility Utility Wastes .............................................................. 47

APPENDIX A-Guidelines for Developing Area-Specific Waste

APPENDIX B-Waste Management Planning Aids ........................................................ 55

APPENDIX D-Summary of Environmental Legislation and Regulations ..................... 61 APPENDIX E-Acronyms ............................................................................................... 63

APPENDIX G-EPA Publication: (EPA 530-K-95-003), May 1995- Crude Oil and

Management Plans ................................................................................ 49

APPENDIX C-Summary Waste Table ........................................................................... 57

APPENDIX F-Reference Materials ............................................................................... 67

Natural Gas Exploration and Production Wastes: Exemption from RCRA Subtitle C Regulation ................................................................ 69

Figures 1-Media Pathways ......................................................................................................... 2

Tables 1-Ten-Step Plan Summary ............................................................................................ 5 2-Overview of Waste Management Methods .............................................................. 30 3-API Metals Guidance: Maximum Soil Concentrations ........................................... 33 &Example of E&P Waste. Disposal Technique. and

Applicable Constituent Criteria ............................................................................... 34 A- 1-Ten-Step Plan for Preparing a Waste Management Plan .................................... 49 B-1-Iron Sulfide Scale and Iron Sponge ..................................................................... 56

D-1”Summq of Key Legislation and Regulations ................................................... 61 C- I-Summary Waste Table ......................................................................................... 57

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Waste Management in Exploration and Production Operations

1 Pollution Prevention

1.1 INTRODUCTION

Pollution prevention is the practice of reducing or eliminating pollutant discharges to air, water, or land. It includes the development of more environmentally acceptable products, changes in processes and practices, source reduction, beneficial use, environmentally sound recycling, waste minimization, proper waste handling, waste treatment, and proper disposal practices. This section presents an overview of media, operational impacts, and waste minimization methods, including the EPA hierarchy of waste management. These basic concepts are critical in achieving pollution prevention goals.

Pollution prevention requires continuous improvement in operating practices. Industry should review its use of materials, processes, practices, and products in order to identify ways to reduce or eliminate pollution. A practical approach encourages the use or production of environmentally acceptable products while working toward source reduction on the following waste management hierarchy:

source reduction (most preferred)

recyclinglreuse

treatment, and/or

land disposal (least preferred) I

Details are presented in 1.3.2.

The API Pollution Prevention Management Practices for API’s Strategies for Today’s Environmental Partnerships (STEP) program embody the petroleum industry’s practical commitment to pollution prevention. They provide specific guidelines for compliance with these Guiding Environmental Principles, which are as follows:

a. To recognize and to respond to community concerns about our raw materials, products, and operations. b. To operate our plants and facilities, and to handle our raw materials and products in a manner that protects the environment and the safety and health of our employees and the public. c. To make safety, health, and environmental considerations a priority in our planning, use, and development of new products and processes. d. To advise promptly appropriate officials, employees, customers, and the public of information on significant industry- related safety, health, and environmental hazards and to recommend protective measures. e. To counsel customers, transporters, and others in the safe use, transportation, and disposal of our raw materials, products, and waste materials.

f. To develop and produce natural resources economically and to conserve those resources by using energy efficiently. g. To extend knowledge by conducting or supporting research on the safety, health, and environmental effects of our raw materials, products, processes, and waste materials. h. To commit to reduce overall emissions and waste generation. i. To work with others to resolve problems created by handling and disposal of hazardous substances from our operations. j . To participate with government and others in creating responsible laws, regulations, and standards to safeguard the community, workplace, and environment. k. To promote these principles and practices by sharing experiences and offering assistance to others who produce, handle, use, transport, or dispose of similar raw materials, petroleum products, and wastes.

1.2 API’S MANAGEMENT PRACTICE FOR POLLUTION PREVENTION

Both management commitment and comprehensive planning are critical to a successful pollution prevention program. Steps to consider in developing and operating such a program include the following:

a. Providing management support for ongoing pollution prevention activities through appropriate policies, actions, communications, and resource commitments. b. Developing and implementing a program to improve prevention and early detection and reduce impacts of spills of crude oil and petroleum products and other accidental releases from operations. c. Developing an inventory of significant releases to air, water, and land; identifying their sources; and evaluating their impact on human health and the environment. d. Periodically reviewing and identifying pollution prevention options and opportunities, developing approaches for reducing releases, and setting goals and schedules for reducing releases and measuring progress; consider the issues of community concerns, technology and economics, and impact on human health and the environment. e. Including pollution prevention objectives in research efforts and in the design of new or modified operations, processes, and products. f. Supporting an outreach program to promote pollution prevention opportunities within the industry, including sharing of industry experiences and accomplishments.

1.3 MEDIA

Proper management of wastes is important to the protection of human health and the environment. Waste can be transported via three natural carriers-water, soil, and air.

1



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All three media may provide pathways by which potentially polluting materials can migrate from their original source. Thus, materials used and wastes generated in exploration and production operations should be managed by considering risk to human health and the environment via media pathways (see Figure 1).

1.3.1 Water

Fresh water for human consumption, domestic needs, recreation, stock water, irrigation of crops, and industry comes from underground aquifers, lakes, streams, and reservoirs.

Materials from spills or improper waste disposal may con- taminate aquifers. Of major concern are those aquifers that contain water suitable for drinking. Also important are aquifers used for agricultural purposes. Pollutants found in water are measured in concentrations of parts per billion (ppb); some of these pollutants may cause that water to fail drinking water standards.

The quality of aquifer waters can be degraded by pollutants to such a degree that it is not practical to restore the aquifer to drinking water standards.

1.3.2 Soil

Most fresh water is stored in underground reservoirs Spills can adversely affect the capacity of soil to support called aquifers. Aquifers are part of a large water-recycling agricultural, industrial, human, and recreational uses. Soil system as illustrated in Figure 1. These porous formations or acts to retain spilled, improperly stored, or disposed materi- sediments can store and transport groundwater from rain, als; however, once in the soil, pollutants can migrate to air leakage of stream beds, and other sources. and water and be picked up by plants and animals. Contam-

Evaporation and transpiration from

bgd = billion gallons per day

Figure 1-Basic Media of Soil, Air, and Water Can Transport Pollutants Away From Their Original Source



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WASTE MANAGEMENT IN EXPLORATION AND PRODUCTION OPERATIONS 3

inants can evaporate into the atmosphere, be carried by rain- generated by the general public and can be managed simi- water to a lake, creek, or other surface water, and be leached larly. Most of the waste generated by the oil and gas industry downward into groundwater. consists of naturally occurring materials brought to the sur-

1.3.3 Air Due to large increases in costs of waste management, in- face in association with extracted oil and gas.

Gaseous waste released to the air can potentially affect hu- mans, animals, and plant life through inhalation or dermal contact. Indirectly, gaseous wastes may alter the chemical balance in the atmosphere. Acid rain is a known result of al- tering the chemical makeup of the atmosphere. Ozone depletion and global warming are thought by some to be the result of human impact on the atmosphere.

1.3.4 Summary

A properly implemented pollution prevention program can reduce or eliminate pollutant discharges to air, water, or land. API supports cooperative efforts to research and develop scientifically based standards and promotes technical advancements for the evaluation and implementation of measures to address environmental impacts.

1.4 UNDERSTANDING OPERATIONAL IMPACTS

Because exploration and production (E&P) operations can affect all environmental media, API suggests the use of sound science to identify adverse impacts and the means to mitigate, reduce, or eliminate them. Science is also critical to developing cost-effective strategies that address environmental risks. Science provides the foundation for identifying methods to prevent or reduce pollution, for expanding waste management options to reduce risk, and for developing and improving pollution control technologies.

Sound science is the key to determining which environmental problems pose the greatest risk to human health, ecosystems, and the economy. Without sound scientific information, high profile but low risk problems may possibly be targeted, while more significant threats remain ignored.

A sound scientific understanding of environmental risks to populations and ecosystems will help create a more effective allocation of resources-resources which can be targeted towards hazards that pose the greatest environmental risk.

1.5 POLLUTION PREVENTION AND WASTE MINIMIZATION

Waste minimization is a major component of pollution prevention. The goals of a waste minimization plan are to reduce the total volume or quantity of waste generated and to reduce the toxicity of waste.

Hydrocarbon recovery, an extractive procedure, inherently generates wastes. Some of these wastes are similar to those

creasing complexity of waste management regulations, and efforts to reduce potential environmental liabilities, many API member companies have implemented in-house waste minimization programs.

These programs go beyond traditional approaches to waste management and incorporate pollution prevention concepts.

1.5.1 Solid Waste Definition

According to federal regulations, a solid waste is any material that is discarded or intended to be discarded. Solid wastes may be either solid, semi-solid, liquid, or contained gaseous material. Point source water discharges, subject to federal permits under the Clean Water Act, are not considered solid wastes.

1.5.2 EPA Hierarchy of Methods

EPA has developed the following hierarchy of waste management methods to guide generations toward waste minimization. The four waste management hierarchy steps, in decreasing order of preference are as follows:

a. Source Reduction-reduce the amount of waste at the source through the following:

material elimination inventory control and management material substitution process modification improved housekeeping return of unused material to supplier

b. Recycling/Reuse-reuse and recycle material for the original or some other purpose, such as materials recovery or energy production; this may occur onsite or offsite, through the following methods:

reuse reprocess reclaim use as fuel underground injection for enhanced recovery roadspreading

c. Treatment-destroy, detoxify, and neutralize wastes into less harmful substances through the following methods:

filtration chemical treatment biological treatment thermal treatment extraction



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chemical stabilization incineration landfarming landspreading

d. Disposal-dispose of wastes through the following methods:

landfills NPDES discharge solidification burial underground injection for disposal

1.5.3 Summary

By incorporating waste minimization practices into the waste management program, the generator may further efforts to

a. Protect public health and worker health and safety. b. Protect the environment. c. Meet company, state, and/or national waste minimization goals. d. Save money by reducing waste treatment and disposal costs and other operating costs. e. Reduce potential environmental liabilities.

2 Waste Management System

2.1 INTRODUCTION

In order to achieve pollution prevention and waste minimization goals, waste management needs to be viewed as an integrated system. A good waste management system should include the following key elements:

a. A system for maintaining knowledge of pertinent laws and regulations. b. A system for pollution preventiodwaste minimization. c. A health and safety program. d. An incident response preparedness program. e. A training program. f. A system for proper waste identification. g. A transportation program. h. A proper waste storage and disposal program. i. A system for waste tracking, inventories, and recordkeeping. j. A waste management auditing program.

This section introduces the concept of a waste management plan-the tool for implementing these key elements at the field level, where actual waste management decisions should be made.

The key elements of training, waste tracking, and auditing are also discussed.

2.2 SUMMARY OF A TEN-STEP PLAN FOR WASTE MANAGEMENT

A waste management plan should

a. Offer a solid waste plan that is area-specific. b. Provide proper management guidance for each waste generated in E&P operations. c. Be written for field operations. d. Be used to ensure regulatory compliance and environmentally sound management of wastes. e. Form a basis for training, evaluation, monitoring, and pollution prevention programs. f. Be periodically reviewed and updated as new practices and options are discovered.

API suggests the ten-step waste management plan shown in Table 1 for integrating the waste management system into operations. This plan is described in detail in Appendix A. It has proven successful for a number of member companies. Appendix B includes planning aids to help in preparing the waste management plan.

Both technology and regulatory requirements in the environmental field are changing constantly. For these reasons, open communication among field operations personnel, environmental and legal specialists, and management is crucial to conducting environmentally sound operations.

2.3 TRAINING

Training in the proper identification and handling of waste material is vital in any exploration or production operation. Field personnel and management should be trained in environmentally sound and safe waste management practices. In- struction in waste management should include the following:

a. General environmental awareness. b. Health and safety concerns related to waste handling. c. Benefits of proper waste management, including risk reduction for future liabilities. d. Review of internal environmental policies and other documentation of management support. e. Environmental laws and regulations. f. Legal liability, both corporate and personal, associated with improper handling of waste. g. The applicable facility waste management program.

In addition, a company may consider scheduling periodic training to cover updates of procedures, review of incidents, and feedback from field personnel.

Federal agencies also mandate personnel training as follows:

a. The U.S. Occupational Safety and Health Administration (OSHA) requires specific, detailed training for certain operations that may be associated with waste management. b. Emergency response to a release of hazardous chemicals



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(including crude oil) and the following cleanup operations may require certified and trained personnel (HAZWOPER-29 Code of Federal Regulations Part 1910.120). c. OSHA also has training and information requirements for personnel who might be exposed to hazardous chemicals (HAZCOM-29 Code of Federal Regulations Part 1910.1200). d. The EPA requires annual training for certain hazardous waste generators (40 Code of Federal Regulations Part 262.34). e. State agencies may have additional health, safety, and waste management requirements. f. The U.S. Department of Transportation (DOT) and some state agencies have transportation requirements for certain wastes. Specific training is required for employees handling hazardous materials (49 Code of Federal Regulations Part 172.702).

Training can be done in-house or through enrollment in schools, workshops, seminars, and conferences available to industry and the general public. Many training opportunities are available through academic institutions or private companies.

2.4 WASTE TRACKING

To ensure proper waste disposal and to minimize individual company liability for the cleanup of improperly disposed waste, it is important to know the types and amounts of waste generated, as well as the ultimate disposition of that waste.

This should be documented by using a company waste tracking system.

Sound waste management techniques should include tracking for both onsite and offsite disposal.

Identification of types and amounts of waste generated ben-

efits operations by allowing identification of waste minimization opportunities. Tracking wastes offsite helps prevent significant costs associated with improper waste disposal.

2.5 AUDITING

Companies should consider developing audit programs for their own facilities as well as third-party facilities that may accept their wastes.

2.5.1 Company Facilities

An onsite waste management auditing program assesses the compliance status of a company’s facilities and programs for waste management. An auditing program’s goal is to help companies achieve higher levels of environmental performance.

Penalties for noncompliance are harsh. Failure to comply with laws and regulations regarding waste management can subject a company to loss of business opportunities, as well as to civil and criminal penalties. Noncompliance can also subject directors, officers, and employees to fines, criminal penalties, and imprisonment.

One of the benefits of a waste management audit program is that company management is provided with information on waste management practices. Other potential benefits include the following:

a. Improved compliance records and reduction of fines, legal actions, and incidents or accidents. b. Improved communication between all levels of company management. c. Improved financial planning efficiency by reducing civil and criminal exposure, enhancing evidence of insurability, im-

Table 1-Ten-Step Plan Summary

Step I .

Step 2.

Step 3.

Step 4.

Step 5.

Step 6.

Step 7.

Step 8.

Step 9.

Step 10.

Management approvd-obtain management approval and support.

Area definitiondefine operating area such as oil field, unit. lease, or state.

Waste identification-identify each waste generated within Step 2 area and briefly describe each waste.

Regulatory analysis-complete reviews of relevant federal, state, and local laws on waste types for which requirements exist; also review lease agreements and landowner agreements.

Waste classification-categorize each identified waste; determine whether it is “exempt” or “nonexempt” and “nonhazardous” or “hazardous.”

Waste minimization-review processes that generate the waste and execute procedures to reduce waste generation.

List and evaluate waste management and disposal options-list the potential options for each waste and rank their desirability.

Select preferred waste management practice(s)-select a waste management option for each waste and the best practice for each operation location.

Prepare and implement an area-specific waste management plan-develop and implement this by compiling a11 options into a plan. Summarize in documents.

Review and update waste management plan-Define a review and update procedure.



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proving public relations, and reducing barriers to successful Decision criteria that will rate a commercial facility as ei- acquisitions and merger negotiations. ther acceptable or unacceptable, based on the collected site in-

Refer to the API document Envimnmental Audit Guideline Protocol and Checklist for help in designing an environmental audit format customized to meet the specific criteria of your facility or compliance program. This guideline was developed by API specifically for the oil and gas E&P industry.

2.5.2 Offsite Noncompany Facilities

An integral part of a waste management program should be a system or process to assess whether commercial waste disposal facilities-including reclaiming and recycling facilities to which wastes are sent-operate in an environmentally and financially sound manner. It is imperative to select commercial facilities that manage wastes properly, inclusive of recycling, treatment or neutralization, and disposal. Companies should consider auditing commercial facilities to limit potential exposure to future environmental liability that might result from improper management by the commercial facility.

Commercial disposal site audits should consider the following:

a. The regulatory aspects of a facility, including: l . Proper permits. 2. Compliance with permits. 3. Relationship with regulatory agencies. 4. History of violations. 5 . Remediation projects in progress. 6. Closure plans. 7. Insurance or other surety bonds. S. Manifesting records and procedures.

b. The operational aspects of a facility, including: l . Adequacy of onsite waste treatment equipment. 2. Adequacy of disposal or recycling processes. 3. Location of the disposal of secondary waste streams that the facility is permitted to manage. 4. Site security. 5. Adequacy of lab analysis. 6. Incoming waste testing and verification procedures. 7. Secondary containment and spill prevention. S. Adequate waste storage prior to disposal. 9. Housekeeping. 10. Adequate contingency plans and training. 1 l . Environmental expertise and financial standing.

c. Physical aspects, including: l . Depth to groundwater. 2. Monitoring well data. 3. Soil data. 4. Geology. 5. Hydrogeology. 6. Remoteness of site location and public exposure potential.

formation, should be established.

or recycling.

that acceptable sites continue to operate acceptably.

Unacceptable sites should not be utilized for waste disposal

Site reevaluation on a periodic basis is critical to ensuring

3 Waste Generation in Exploration and Production Operations

3.1 INTRODUCTION

Wastes are generated in each phase of E&P operations. This section summarizes wastes generated in each phase and the associated environmental impact considerations. The work phases are as follows:

a. Exploration. b. Drilling. c. Completion and workover. d. Field production. e. Gas plant operations. f. Transportation. g. Offshore operations.

See Appendix C for a summary of E&P waste sources.

3.2 EXPLORATION

Exploration operations identify locations that contain potential oil and gas deposits. These operations may begin with remote sensing and aerial geomagnetic surveys to identify underground geologic structures where oil and gas may have accumulated. Seismic surveys and related geologic field work are conducted on potential locations.

3.2.1 Seismic Surveys

Prior to drilling an exploratory well, seismic surveys and related geologic field work are the primary exploration activities that generate appreciable amounts of waste. Three basic field work activities contribute to waste generation:

a. Access to the area of interest. b. Construction of seismic lines. c. Construction and maintenance of a base camp or camp sites.

The environmental impact of each of these efforts should be considered.

3.2.1.1 Accessing Areas of Potential Deposits

Gaining access to an area of potential oil and gas deposits often requires construction of roads or footpaths into remote areas. Construction may involve clearing trees and brush and



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temporary displacement of topsoil'. Good management processes include the following:

a. Using cleared foliage in soil conservation and control. b. Retaining and replacing topsoil. c. Encouraging revegetation by native flora.

3.2.1.2 Seismic Line Construction

Seismic lines are constructed by clearing a 3- to 6-foot- wide footpath. The root stock and topsoil should be left in place. Shallow holes are typically drilled along the seismic line and explosives are placed in them to be detonäted. Any unused shot holes and/or craters caused by explosions should be backfilled to reduce the chance of subsequent erosion. An alternative is to use vehicle-mounted, nonexplosive energy sources.

Wastes generated during this operation include explosives residue, used oil and filters, line stakes or markers, and domestic waste. In general, the volume and toxicity of these wastes are minimal; however, steps should be taken to assure that all nonrecyclable material is either (a) incinerated or buried onsite when allowed by applicable regulations; (b) collected and carried out by the seismic crew once operations cease; or (c) otherwise appropriately managed.

3.2.1.3 Base Camp

Seismic exploration and geologic field work may require a large workforce. In remote areas, a base camp to accommodate personnel and equipment is sometimes necessary. Base camp operations may generate many different wastes.

Base camps are typically self-contained. They will usually consist of personnel accommodations, dining facilities, vehicle/aircraft fueling facilities, and maintenancelparking areas for vehicles and helicopters. Wastes generated include sewage effluent, domestic refuse, used oil and filters, empty petroleum hydrocarbon storage containers, and building material wastes. Disposal of these wastes can be a common problem for base camps in areas where water treatment and waste disposal facilities do not exist. In such cases, provisions must be made for proper treatment or disposal. Specific steps to treatment and disposal include the following:

a. All food wastes and other putrefiable material should be collected and properly disposed. b. Solid and hydrocarbon wastes should be evaluated for recycling whenever possible. c. Residue from burned or incinerated wastes should be buried or transported offsite. d. A system for the collection of sewage and water effluents should be constructed and designed to flow through a soak- away system of permeable, earth-covered beds in such a way as to not impact potable water supplies. e. Wastes requiring special handling such as used oil and filters should be kept segregated and disposed in a manner

that prevents surface water or groundwater contamination. f. All material, equipment, and man-made structures (such as buildings, bridges, helipads, and so forth) should be dis- mantled and removed from the area when work is completed, unless otherwise agreed upon by the landowner and the operators.

The disposal of solid and liquid wastes is controlled by regulation. Landowner consent and/or permits from appropriate authorities may be required before waste disposal methods such as incineration or construction of effluent field can be utilized.

3.2.2 Waste Summary

A list of the major waste categories that may be generated during exploration operations is shown below. See Appendix C for a more complete listing of wastes generated by E&P.

Exploration Operations Wastes

Absorbent material

Antifreeze

Batteries

Domestic refuse

Domestic wastewater

Filters First-aid waste

Hydraulic fluid Incineration ash

Mudkuttings from shot holes

Paint related materials

Rags, oily

Sanitary wastewater

Scrap metal

Soil, contaminated

Solvents, petroleum naphtha

Stormwater

Tires

Unused materials, discarded

Used oil Vegetation

Washdown water (rigwash)

Water, noncontact (for example, cooling or fire water)

Wood

3.3 DRILLING

Drilling operations are conducted to locate the oil and gas (that is, exploratory drilling), to delineate a discovered reserve or to develop a reservoir for production. The drilling operation has two key components, the drilling rig and the circulation system, which are discussed below.

3.3.1 Drilling Rig

3.3.1.1 Introduction

The drilling rig provides the power and equipment (including safety equipment and systems such as blowout pre- venters) necessary to drill the wellbore. Its key systems and their uses areas follows:

3.3.1.2 Hoisting System

The hoisting system lifts drill pipe in and out of the well and controls weight on the drill bit as it penetrates rock and



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sand formations. It also handles drill pipe when it is out of the wellbore and is used to run casing into the wellbore.

3.3.1.3 Rotating System

The rotating system turns the drill bit so that it can penetrate underground rock and sand formations.

3.3.1.4 Casing

Casing serves the following functions:

a. It protects the integrity of the wellbore during drilling. b. It provides a conduit for fluid movement both up and down the wellbore. c. It keeps drilling fluids from leaving the wellbore and seeping into the formation. d. It allows fluids to flow to the surface for processing after well completion. e. It provides protection for underground sources of drinking water.

Wastes generated by the drilling rig result primarily from the operation and maintenance of rig equipment. These wastes include washwater (rigwash), used lubricating oils and filters, solvents, hydraulic fluids, gaskets, used drill bits and pipe, discarded thread protectors, cut drill line, empty grease and pipe dope containers, absorbent materials (such as clay and pads), worn brake pads, and similar materials.

kgwash, or water used to wash down the rig floor, may contain minor amounts of the detergents that are used to clean the rig and provide a safe work area. The system used to collect rigwash may also collect rainwater.

3.3.2 Circulating System


The circulating system is the lifeblood of the drilling operation. In this phase, the drilling fluid (that is, mud) is formulated and maintained; circulated downhole to cool the drill bit and flush drilled cuttings from the bottom of the wellbore; used to transport cuttings to the surface where they are mechanically removed from the mud system; and then returned to tanks where the process starts again.

3.3.2.2 Drilling Mud

The drilling mud, mostly water-based clays and inert weighting materials, is formulated using various additives, depending on expected well conditions. Additives help cool the drill bit, lubricate the drill string, and remove the drilled cuttings from the wellbore; they also add the necessary weight to prevent formation fluids from entering the wellbore and support and prevent damage to the underground formations being drilled. In certain geographic regions, spe-

cial drilling fluids such as oil- or saltwater-based muds are used when drilling deep, high-temperature, high-pressure, water-sensitive reservoirs, or high-angle wells.

Wastes generated during drilling mud formulation typically include empty additive containers (such as bags and pails) and unused or contaminated additives.

After formulation, drilling mud is stored in tanks before it is pumped down the drill string. As mud exits the drill bit nozzles, it cools the bit and flushes away any drilled cuttings and solids at the wellbore bottom. The mud then carries these drilled solids to the surface where they are removed using cleaners (such as hydrocyclones or desilters, centrifuges, and shale shakers). These wastes are typically collected in a reserve pit adjacent to the drilling rig.

Wastes generated during drilling operations may include the following:

a. Drilling fluids (muds) and solids. b. Cement returns. c. Saltwater. d. Oil. e. Formation cuttings (such as shale, lime, salt, and dolomite).

The waste volumes generated will vary greatly, depending on the well's diameter, depth, type of mud system, and other operating factors.

3.3.2.3 Reserve Pits

Unlined or lined reserve pits store supplies of water, waste drilling fluids, formation cuttings, rigwash, and stormwater runoff from the drilling location. Unlined pits are normally used for freshwater mud systems; lined pits are normally used for oil- or saltwater-based mud systems, or in areas of shallow groundwater, or in those adjacent to fresh surface waters.

Liners may not be necessary for some oil- or saltwater- based mud systems, such as where soil and hydrogeological conditions preclude any adverse impact, or soil, waste mud, and cuttings may be managed to ensure protection of soil and groundwater (for example, treated to fix or solidify contaminants). Conversely, liners may be required in areas that are hy- drogeologically or otherwise sensitive. In specific cases, closed-loop drilling mud systems may be required to protect environmentally sensitive areas. These systems do not require reserve pits.

Regulations apply as follows:

a. State regulations usually require pit construction to comply with specified land use standards. b. State regulations normally restrict reserve pit usage to the drilling operation and require that pits be closed shortly after cessation of drilling operations (normally within 6-12 months). c. Certain reserve pits may remain open for extended periods because multiple wells may be drilled from a single well pad. Special regulations, including compliance with applicable wa-



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WASTE MANAGEMENT I N EXPLORATION AND PRODUCTION OPERATIONS 9

ter quality standards for reserve pit contents, may be required in environmentally sensitive areas.

3.3.3 Other Drilling Rig Operations

Support equipment located adjacent to the drilling rig is essential to the drilling operation. Equipment includes fuel tanks, electric power generators, pipe racks, and equipment used to support the maintenance of personnel quarters.

Wastes can include the following:

a. Used oil and filters. b. Contaminated fuel and spillage. c. Domestic waste and sanitary sewage. d. Solid waste (including paper sacks, cans, and drums). e. Quarters, garbage, and other materials.

3.3.4 Waste Summary

A list of the major waste categories that may be generated during drilling operations is shown below. See Appendix C for a more complete listing of wastes generated by E&P.

Drilling Operations Waste

Absorbent material Antifreeze Batteries

Blasting sandmaterial

Cement returns CompletionlW.O./well

treatment fluids Constructioddemolition debris

Domestic refuse Domestic wastewater

Drill cuttings

Drilling fluids

Filters first-aid waste

Hydraulic test (BOP) fluids


Insulation material

Mud sacks

Paint-related materials

Pallets

Polychlorinated biphenyls (PCBs) Produced sand

Produced water Radioactive waste, LSA [low

specific activity (for example, tracer materials)]

Rags, oily

Sanitary wastewater

Scrap metal

Soil, contaminated Solvents

Spill cleanup waste. hydrocarbon (for example, crude)

Stormwater

Thread protectors Tires


Used oil Vegetation



Wood

3.4 COMPLETION AND WORKOVER

Once drilling operations are finished, newly drilled wells must be completed before being put into production. There are many methods of completing or preparing a well for

production or injection.

a. Generally, the well casing must be'perforated to allow fluid flow. h. Downhole equipment may also be installed to facilitate production or injection. c. The producing formation may also be acidized or frac- tured to enhance production or injection capacity.

Workover rigs are typically used for completion activities; in some cases, drilling rigs are also used. The latter is not normal practice, due to the higher operating cost of a drilling rig as compared to a workover rig. When using a drilling rig, larger quantities of waste may be generated due to the rig's increased size.

In addition, existing production and injection wells require periodic maintenance utilizing workover rigs. Workover operations include installing tubing and packer, acidizing or fracturing stimulations, replacing tubing or pumping equipment, recompleting to new reservoirs, or plugging and aban- doning of wellbores. The amount and type of waste generated from completion, well treatment, and workover operations can range from virtually none for chemical treatments and logging operations to large volumes similar to those encountered during drilling operations.

Wastes generated from the workover rig itself include hydraulic fluids, used oils and filters, and other maintenance wastes. Other wastes include spent completion and workover fluids and filters (for example, diatomaceous earth), produced water, produced sand and other solids, spent acids, inhibitors, and solvents.

Spent or used fluids are normally produced through flow- lines to production facilities or trucked to operator-owned production facilities for further processing. Workover fluids are also disposed of at commercial facilities when operators are unable to process them in their own production facilities.

A list of the major waste categories that may be generated during completion and workover operations is shown below. See Appendix C for a more complete listing of wastes generated by E&P.

Completions and Workover Operations Waste

Absorbent material

Antifreeze

Batteries

Blasting sandhaterial

Cement returns

CompletionlW.O./well treatment fluids

Constructioddemolition debris

Pipdequipment hydrates

Pipe/equipment scale

Pit sludges

Polychlorinated biphenyls (PCBs)

Produced sand

Produced water

Radioactive waste, LSA (low specific activity [for example, tracer materials])



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~

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Crude oilkondensate, waste

Domestic refuse

Domestic wastewater

Drill cuttings

Drilling fluids

Filters

First-aid waste

Hydraulic test (BOP) fluids

Hydraulic fluid

Incineration ash

Insulation material

Naturally occumng radioactive material (NORM)

Packing fluids

Paint-related materials

Pallets

Parafin

Rags, oily

Sanitary wastewater

Scrap metal

Soil. contaminated

Solvents

Source sand

Source water

Spill cleanup waste, hydrocarbon (for example, crude)

Stormwater

Tires


Used oil

Vegetation


Water, noncontact (for example, cooling or fire water

Wood

3.5 FIELD PRODUCTION

3.5.1 Introduction

After a well is drilled and completed, field facilities collect oil and/or gas from the well and prepare it for sale. Well fluids are often a complex mixture of liquid hydrocarbons, gas, water, and solids. The objective of the production process is to separate constituents of the mixture, remove those that are nonsaleable, and sell the liquid hydrocarbons and gas. Purchasers have contract standards for the oil and gas they will accept. For example, oil purchasers typically limit the amount of basic sediment and water (BS&W) to less than 1 percent. Gas purchasers set similar limits on water, water vapor, hydrogen sulfide (H2S), carbon dioxide (CO,), and BTU content.

The field production facility can be grouped into the following areas:

a. Wells and gathering systems. b. Oil and produced water treatment systems. c. Dehydration and sweetening. d. Injection operations. e. Oil storage and sales. f. Compression and gas sales. g. Other field production facilities and operations.

The following sections describe each field facility area and the wastes that may be generated from it in the production process.

3.5.2 Wells and Gathering Systems


Wastes generated at the well site include paraffin, oil and produced water contaminated soils, and used gear box lubrication oil. These wastes are more commonly found at oil wells than at gas wells.

3.5.2.2 Paraffin Removal

Paraffin precipitates within tubing and piping when oil containing parafin is produced up a wellbore and pressures and temperatures are reduced. Paraffin solvents or dispersants, heating, or mechanical cutting remove it from the tubing and piping. Paraffin solvents, dispersants, and hot treatment fluids are normally handled and treated as part of the crude stream in the field processing facilities. However, paraffin cut with downhole tools is generated at the wellhead.

3.5.2.3 Stuffing Box

Oil and produced water contaminated soils and debris may result from leaks in the stuffing box of a pumping unit or from minor amounts of spillage during well chemical treatment, workover, or servicing operations. The stuffing box on a pumping well is the mechanical seal between the tubing and polished rod. The fluid (for example, crude oil) being pumped acts as the seal lubricant. Because of the continuous wearing action of the polished rod, the stuffing box packing requires periodic adjustment to minimize leakage.

Pumping unit gear box lubricating oil must be replaced occasionally, either because of gear box malfunction or for pre- ventive maintenance.

3.5.2.4 Flow Lines

Flow lines gather produced fluids from wells for transport to field facilities for processing. Periodically, flow lines gathering crude production can plug from a buildup of paraffin and scale. When this occurs, either pipeline pigs are run through the flow lines or hot oil is pumped through them to remove or dissolve the plugging material.

Plugging material that is not dissolved back into the crude oil is recovered at a pig trap at the facility inlet. Recovered paraffin solids can be heated and returned to the production system or hauled to a storage site for future reclaiming or disposal. Scale material is also collected for disposal.

Flow line ruptures or leaks generate crude oil and/or produced water-contaminated soil. Depending on the severity and location of the release, contaminated soils may either be managed in situ or removed for treatment or disposal, either onsite or offsite.



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3.5.2.5 Chemical Treating

Treating chemicals such as corrosion inhibitors are sometimes injected into the well or flowline to provide protection. Chemical injection pumps typically dispense chemicals from 55-gallon drums or bulk containers. Leaks from this process may result in chemical-contaminated soils; spills should be minimized via drip pans. Any spill should be managed as described in the preceding paragraph, provided it is also in accordance with applicable state and RCRA regulations (see Section 4).

3.5.3 Oil and Produced Water Treatment Systems


When produced fluids and solids reach the field facilities, they enter the treatment system. There the gas, crude, water, and solids are separated into individual streams. Each stream is then further treated in preparation for sale or disposal, as applicable.

3.5.3.2 Free-Water Knockout

Typically, the free-water knockout (FWKO) is the first vessel to receive produced fluids. The FWKO separates free water (that is, water not linked to oil in an emulsion) from other produced fluids and solids. Separated produced water then flows into the water treatment system for either disposal or reinjection. Periodically, solids and bottom sludges are removed from the FWKO for reclamation, treatment, or disposal.

3.5.3.3 Separators

Two-phase separators isolate produced liquids from gases as they flow from the wells. Three-phase separators, which have additional float mechanisms, also separate produced water from produced fluids. The gas, oil or condensate, and water are then further processed prior to sale or disposal. The primary waste generated by the separator consists of produced sand, scale, and bottom sludges recovered during cleanout operations.

3.5.3.4 Heater TreaterdElectrostatic Treaters

Heater treaters and/or electrostatic treaters separate emul- sified oil and water. Occasionally, emulsions (that is, bad oil) that cannot be treated successfully in a single pass through the treatment system must be placed in a standby oil tank for recycling and further treatment. Produced water separated in the treaters goes to a disposal or injection system. As is the case with the FWKO and other production vessels, these treaters are occasionally drained to remove solids and bottom sludges. Treaters that use hay or excelsior sections to absorb minute amounts of oil must be cleaned out periodically, and the absorption material must be replaced.

3.5.3.5 Desanders

Where produced water carries excessive solids (produced sand), desanders may be utilized to remove these solids. Typ- ically, much of the produced sand is also removed in other treating vessels.

3.5.3.6 Produced Water Treating Equipment

Several types of produced water treating equipment are used to prepare the water for discharge, injection, or other options. Skim tanks, gun barrels, and corrugated plate interceptors (CPIs) rely on gravity and residence time to remove residual free oil and solids from produced water. Recovered oil may be returned to the oil treating system or recycled offsite.

Another type of treatment system utilizes gas flotation. These units are used to remove small concentrations of insol- uble oil and grease from produced water. The units agitate the water by injecting a gas, usually natural gas or air, through the liquid stream. This action flocculates the suspended oil, grease, and dirt. The flocculated materials then rise to the surface, where they are skimmed off. This material may also be recovered as oil (for example, returned to the oil treating system).

3.5.3.7 Produced Water Tanks

Produced water tanks may be required to provide storage and additional settling time for sandsolids removal prior to discharge, injection, or other disposal. These tanks must be cleaned occasionally to remove bottoms, including oily sand and solids.

3.5.3.8 Produced Water Discharges to Surface Water

Produced water that is separated from oil and gas may be of sufficient quality to discharge after the above treatment. However, in certain instances, pits or additional tanks are used to separate additional solids and oil from the produced water prior to discharge. Bottoms or sludges are generated if solids are recovered from the settling pit or tank.

3.5.4 Dehydration and Sweetening

Field dehydration and sweetening units perform the same function as that described in greater detail for gas plants in 3.5.2 and 3.5.3. Wastes may include iron sponge, spent glycol, spent amine, spent caustic, and filters and filter media, depending on the type of system operated.

3.5.5 Injection Operations


Injection operations at field production facilities are used to either dispose of produced water or to enhance recovery of crude oil from the reservoir.



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3.5.5.2 Disposal

After initial treatment of produced water, as described above, filtering is frequently used to improve water quality before injection. Filter media must be replaced on a periodic basis; if they are permanent, they must be backwashed.

Replaceable filters include sock, cartridge, or canister units. Permanent filters may use diatomaceous earth or gran- ular media such as sand or coal. Permanent filters are periodically backwashed with fresh or produced water, which sometimes contains a small amount of surfactant.

Backwash should be circulated to a solids treatment and disposal system. There, backwash liquid should be returned to the production facilities for reprocessing.

After filtering, produced water can be injected into the disposal well. An electric motor or gas engine usually drives the injection pump, pressurizing produced water into the injection well. Waste lubricating oil and filters are typically generated at these facilities.

3.5.5.3 Enhanced Recovery

Enhanced recovery is used to maintain pressures in the reservoir and to improve recovery of crude oil from reservoir formations. Several methods of enhanced recovery may be used; these include produced water injection, source water injection, seawater injection, steam flooding, or CO, flooding. Although these methods are most common, other methods are also available. The method selected will be dictated by the formation type and method feasibility.

As with injection disposal, water utilized for enhanced recovery must be treated prior to injection. In general, the types of equipment used and the wastes generated are the same as described above.

3.5.5.4 TEOR Steam Generators

In heavy oil operations, steam is sometimes injected into reservoirs to reduce oil viscosity and to enhance fluid production. Traditionally, oilfield operators have generated steam using conventionally fired heaters known as thermally enhanced oil recovery (TEOR) steam generators. The steam these generators make is injected into geological formations containing heavy crude oil; it heats the oil for easier recovery. Injected steam also drives (or pushes) the oil toward producing wells.

TEOR steam generators are fueled by either crude oil, fuel oil, or natural gas. Steam generators fired by crude or fuel oil may have sulfur dioxide air pollution scrubbers associated with them. Steam is also generated and used in some field production facilities and gas plants by burning natural gas.

When burning crude, fly ash impinges on the steam generator convection tubes. To increase thermal efficiency of the generators, fly ash is removed by washing the tubes with water. The resulting effluent is referred to as stack wash water.

Other wastes from steam generators can include fuel oil filters, spent water softening resin, refractory waste, and flue duct ash. Water softening resin is typically used when a central water plant is not available.

3.5.5.5 TEOR Cogeneration Units

Recently, TEOR cogeneration steam generators have replaced some TEOR conventional steam generators. Typi- cally, a TEOR cogeneration steam generator consists of a turbine and its associated heat recovery boilers (steam generators). Cogeneration of electricity and steam can significantly increase the energy efficiency of the process.

TEOR steam generators use soft water (that is, water with low concentrations of dissolved calcium and magnesium). Soft water is used as steam generator feed water to prevent scaling. The water softening process creates a waste fluid identified as regeneration brine. Surplus soft water for disposal (that is, soft water blowdown) is also generated during startup and shutdown of both conventional and cogeneration steam generators.

Waste fluids typically generated at TEOR facilities consist of water softener generation brine, surplus soft water (for example, soft water blowdown), excess deionized water, backwash water from the deionization process, scrubber waste (that is, sulfur dioxide liquor), and stack wash.

A typical waste generated at facilities using steam is boiler blowdown water.

3.5.5.6 Air Pollution Control Scrubbers

Air pollution control scrubbers may be required to control sulfur dioxide and particulate matter emissions from exhaust gases of oil-fired TEOR steam generators. The process bubbles exhaust gas through a basic aqueous solution (usually NaOH or Na2C0,) which reduces SO, to NaHSO,, Na,SO,, and Na2S04. The scrubber liquor waste typically has a neu- tral pH and low concentration of heavy metals.

3.5.5.7 Deionization

Two other fluids associated only with TEOR cogeneration plants are deionized water and backwash produced from the water purification process. The deionization process involves removing additional dissolved minerals present in water. Deionized water is injected into the turbine combustion chamber to reduce nitrogen oxide emissions. Raw water used in the deionization process is either soft water or fresh water.

Excess deionization water, as well as backwash from this water purification process, may be commingled with excess produced water, regeneration brine, and soft water blowdown prior to disposal.



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3.5.6 Oil Storage and Sales

Treated oil that leaves the treatment system goes to oil stock tanks and is ready for sale. Solids and water continue to separate by gravity and accumulate in stock tanks. These tank bottom materials may require periodic removal.

Oil in stock tanks is transported offsite for further processing or refining via pipeline, tank truck, or barge. Wastes generated from onsite transfer operations include lubrication oils, filters, and drips and leaks from pumps and transfer lines. When shipping by tank truck or barge, drainage from transfer hoses can be returned to the system for reprocessing.

3.5.7 Compression and Gas Sales


Produced gas and fuel scrubbers are used where necessary to separate fluids from gas. After scrubbing, recovered fluids may include condensate, oil, and/or produced waters; these should be returned to the system for reprocessing.

3.5.7.2 Hydrate Prevention

Pressure and temperature decrease as gas is produced from a reservoir. If sufficient water or water vapor exists in the gas stream, hydrates (that is, ice) may form and block flow lines. Methanol is sometimes injected or line heaters are sometimes used to prevent hydrate formation. Methanol is typically used in low concentrations; the concentrations are dictated by field conditions.

The primary waste generated onsite from methanol injection is empty methanol containers. Wastes generated from line heaters include spent thermal fluids (such as glycol, oil, or salt mixtures) used to transfer heat from heat sources to the gas stream.

3.5.7.3 Compressors

Compressors are used to boost the gas pressure to sales line pressure and/or gas lift pressure, inject gas back into the reservoir for pressure maintenance, permit vapor recovery, or allow flow into central facilities. Compressors may be driven by electric motors or by internal combustion or turbine engines.

Wastes generated from compressor operation are identical to those wastes generated by gas plant compressors (see 3.6.2 and 3.6.6). These include engine cooling water containing glycol and used lubrication oil and filters.

3.5.8 Other Field Production Facilities and Operations

Heat exchangers, glycol systems, absorption oil systems, storage tanks, and the like must be cleaned to remove hydrocarbons, salts, scale, and other solids that have built up and reduced field production efficiency.

Internal cleaning of tanks, treating and process vessels, and other equipment is also an operation that can generate wastes.

Wastes generated during cleaning include mixtures of spent cleaning solutions (for example, acids, caustics, solvents, and detergents) and removed solids and/or hydrocarbons.

Other field production facilities or operations that may generate waste include the following:

a. Warehousing. b. Equipment maintenance. c. Domestic and sanitary waste handling and treating. d. Construction and demolition. e. Laboratory testing. f. Office, transportation, and maintenance facilities.

3.5.9 Waste Summary

A list of major categories of waste that can be generated during field production operations is shown below. (Note that some of these wastes may be contaminated with naturally occurring radioactive material (NORM) and require special handling.) See Appendix C for a more complete listing of wastes generated by E&P.

Field Production Operations Waste

Absorbent material Antifreeze

Batteries Blasting sand/material Boiler blowdown

Catalyst Cleaning wastes, process

equipment

fluids Completion/W.O./well treatment

Constructioddemolition debris Cooling tower blowdown

Crude oikondensate, waste Deionized water, excess

Domestic refuse Domestic wastewater

Filters Flue dust ash (fly ash) first-aid waste


Insulation material Lab waste, sample wastes, and

residues Mercury, metallic liquid Mercury, solids Naturally occurring radioactive

material (NORM)

Pipe/equipment scale Pit sludges Polychlorinated biphenyls (PCBs) Produced sand Produced water

Rags, oily Refractory waste

Saltbath heater salt

Sanitary wastewater

Scrap metal Scrubber liquid, hydrogen sulfide

Soft water, excess

Soil, contaminated Solvents Source sand

Source water

Spill cleanup waste, hydrocarbon

Storm water Sulfur dioxide liquor Sweeteningldehydration liquids Sweetening/dehydration solids

(for example, crude)

Tank bottoms

Tires Unused materials, discarded



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Packing fluids Used oil Paint-Elated materials Vegetation Pallets Washdown water (rigwash) Paraffin Water, noncontact (for example,

Pigging wastes from gathering Water softener regeneration brine

cooling or fire water)

lines

Pigging wastes from DOT Water softening resin, spent

F’ipdequipment hydrates Wood

3.6 GAS PLANT OPERATIONS

3.6.1 Introduction

pipelines

Natural gas plants often provide dehydration and compression facilities; sometimes sweetening facilities are provided as well. These plants process natural gas into a marketable condition; they also extract natural gas liquids such as ethane, propane, and butane for separate sale. Natu- ral gas streams entering gas processing plants vary in composition. Methane is the predominant component, but smaller amounts of ethane, propane, butane, pentane, and heavier hydrocarbons are also present. The inlet gas may contain compounds such as carbon dioxide, hydrogen sulfide, mercaptans, other sulfur compounds, water, and certain solid impurities. These can be removed by gas plant treating facilities. Treated gas then enters an extraction facility that removes the heavier natural gas liquids (NGLs) such as ethane, propane, and butane.

Gas plant treating and extraction processes include inlet separation and compression, dehydration, sweeteninghlfur recovery, natural gas liquids recovery, and recompression and plant utilities. Warehousing, product storage, equipment maintenance, domestic and sanitary waste handling and treating, construction and demolition, product shipping, and office facilities are other activities that can occur at a gas plant and generate wastes.

3.6.2 Inlet Separation and Compression

Gas can enter the facility in either an untreated or treated condition. Field production facilities can provide initial treatment; all subsequent treatment, however, is conducted at the gas plant. Produced fluids such as water and liquid hydrocarbons are usually separated at the plant inlet. If necessary, gas will be compressed to a sufficient pressure to allow the plant to operate.

Wastes typically associated with inlet separation include produced water that may contain methanol or other treating chemicals; pigging materials; inlet filter media; fluids from corrosion treatments; and small amounts of solid material (such as, pipe scale, rust, and reservoir formation material).

Wastes generated from plant inlet compressor operations are like wastes generated in field compressor operations.

These include engine cooling water containing glycol and used lubrication oil and filters.

Inlet separators are designed to send produced water and hydrocarbons to process vessels for additional treatment. There, hydrocarbons can be recovered for sale and produced water can be separated for disposal.

Small amounts of pigging materials can also be recovered at the pig receiving traps at the plant inlet.

For safety reasons, inlet separators are equipped with relief valves that vent to emergency containment facilities, that are usually pits. This protects the facility if a fluid slug (for example, produced water) that exceeds separator capacity should reach the plant or if gas pressure exceeds design capacity.

Emergency pits are not disposal facilities; they provide control of emergency releases. Vented fluids should be recovered in accordance with state requirements or operating procedures. The pits should be constructed and operated to prevent groundwater contamination.

3.6.3 Dehydration

All natural gas contains water vapor. Typically, this water content must be reduced to meet sales pipeline specifications. Dehydration is the process of extracting water vapor to make the gas marketable. Processes used at gas plants are like those used at field production facilities where centralized dehydration is unavailable.

Natural gas is dehydrated by contact with either liquid or solid desiccants.

Liquid desiccants such as ethylene glycol, diethylene glycol, or triethylene glycol absorb the water. Heat regeneration evaporates the water, and glycol is recovered for reuse.

In solid desiccant dehydration, natural gas flows through tower vessels filled with alumina, silica-gel, silica-alumina beads, or a molecular sieve to absorb water vapor.

Wastes generated during the dehydration process consist of glycol-based fluids, glycol filters, condensed water, and spent solid desiccants. These fluids and solids may in some circumstances contain trace levels of hydrocarbons and treating chemicals.

3.6.4 SweeteningBulfur Recovery


Some natural gas contains hydrogen sulfide, carbon dioxide, or other impurities that must be removed either for field use or to meet the sales pipeline specifications. The sweetening process may be conducted using units identical in operation to those used at field production facilities where centralized sweetening facilities are not available. It may also be conducted in dedicated sulfur recovery or carbon dioxide (CO,) removal facilities where high hydrogen sulfide (H2S) and carbon dioxide concentrations exist.



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Sweetening primarily lowers the hydrogen sulfide and carbon dioxide content of natural gas. Hydrogen sulfide is removed from natural gas by contact with amines, sulfinol, iron sponge, iron chelate reduction, caustic solutions, and other sulfur-converting chemicals. Heat regenerates amine and sulfinol for reuse.

In the iron chelate oxidation-reduction process, oxidation (that is, having air as the oxygen source) is used to regener- ate the solution. Iron sponge, caustic solutions, and other sulfur-converting chemicals are spent in the process and are not regenerated.

3.6.4.2 Amine Sweetening

Amine treating of natural gas for removal of hydrogen sulfide and carbon dioxide is the process that is probably most widely used in the industry. This process is based on the reaction between aliphatic alkanolamines and acid gases at moderate temperatures. Amines are then regenerated by el- evating the temperature to release acid gases.

Wastes generated in amine sweetening include degraded or spent amine; used filter media; and acid gas, which must be flared, incinerated, or sent to a sulfur recovery facility.

3.6.4.3 Sulfinol Sweetening

The sulfinol treating process utilizes an aqueous mixture of an aliphatic alkanolamine (that is, either di-iso- propanolamine or methyl diethanolamine) and a physical solvent (that is, Sulfolane). This process involves the chemical reaction of an alkanolamine with hydrogen sulfide and carbon dioxide, and the physical absorption of these acid gases and other sulfur-containing compounds such as car- bonyl sulfide (COS), carbon disulfide (CS,), and mercaptans (RSH) at feed gas pressure and temperature. The acid gases and absorbed gases are released at near atmospheric pressure and somewhat higher temperatures.

Wastes generated in sulfinol sweetening include degraded amine and used filter cartridges or bags. The resulting acid gas waste stream may be flared, incinerated, or sent to a sulfur recovery facility.

3.6.4.4 Iron Chelate Oxidation-Reduction Sweetening

This desulfurization process uses an iron-chelating solution to selectively remove hydrogen sulfide from gas streams through a reduction reaction. When sour gas is contacted with a water solution of chelated iron, the H2S is converted to elemental sulfur in an iron reduction reaction.

The solution is regenerated by oxidation, normally carried out using air as the oxygen source.

This process uses a nontoxic solution and creates little or no H,S or SO, emissions. The solid waste generated by this sweetening process is a nontoxic wastewater stream.

3.6.4.5 Iron Sponge Sweetening

In the iron sponge treating process, iron oxide reacts with hydrogen sulfide to form iron sulfide. Iron sponge is com- posed of finely divided iron oxide, coated on a carrier such as wood shavings.

The iron sponge process is generally used for treating gas at pressures less than 50 psig with total hydrogen sulfide content under 100 grains per 100 standard cubic feet.

The waste generated in the iron sponge process is the iron sulfide and wood shavings combination.

3.6.4.6 Caustic Sweetening

Small volumes of hydrogen sulfide may be removed from natural gas and NGLs by contact with a caustic solution, which is reused until spent. Most caustic treaters utilize a 10- to 20-percent by weight sodium hydroxide solution. In it, the caustic consumption is approximately 2.4 pounds per pound of hydrogen sulfide removed, and 1.9 pounds per pound of carbon dioxide removed. Most caustic treaters consist of a simple vessel holding the caustic solution through which gas is allowed to bubble.

The primary waste from caustic treating is spent caustic solution.

3.6.4.7 Other Sulfur-Converting Compounds

Other sulfur-converting compounds such as Sulfa-check are employed in one-step processes to remove low levels of hydrogen sulfide. Here, a direct conversion using a single contact vessel occurs at ambient temperature. Natural gas bubbles through the vessel until the sulfur-converting com- pound is spent.

The primary waste is a nonhazardous slurry of sulfur and salts.

3.6.4.8 Claus Process Sweetening

The Claus process utilizes amine or sulfinol solutions to remove hydrogen sulfide from sour natural gas.

As part of the regeneration process, hydrogen sulfide is driven out of solution. The hydrogen sulfide is then burned in the presence of oxygen to produce sulfur dioxide. Hydrogen sulfide and sulfur dioxide are then mixed and exposed to a heated catalyst to form elemental sulfur.

The Claus process utilizes pelletized, inert aluminum oxide as a catalyst. The aluminum oxide does not react in the sulfur-making process but merely provides a greater surface area to speed and assist the process.

The primary waste generated is spent catalyst.

3.6.4.9 Molecular Sieve Sweetening

Molecular sieve absorbents are used to remove hydrogen sulfide, mercaptans, and heavier sulfur compounds from



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gases and NGLs. They are also used to remove water vapor. Thus, simultaneous sweetening and dehydration may be accomplished in the same unit. Molecular sieve sweetening is a batch-type regenerative operation requiring at least two beds for continuous processing. As one bed is sweetening, the other is regenerating.

The primary waste generated is spent molecular sieve.

3.6.5 Natural Gas Liquids Recovery

NGL recovery is the process by which hydrocarbons heavier than methane, which exist as liquids at moderate pressures, are extracted from natural gas. NGL extraction may use compression and cooling processes, absorption processes, or cryogenic processes. These processes either (a) absorb heavier molecular compounds from the process stream with an absorption oil that is recycled or (b) use temperature and pressure to separate fractions with different boiling points.

Wastes generated include lubrication oils; spent or degraded absorption oil, wastewaters, cooling tower water, and boiler blowdown water.

3.6.6 ReCompression and Plant Utilities

Plant compression and utility systems (including fuel, electrical generators, steam equipment, pumps, and sump systems) are necessary to operate the gas plant and to raise the pressure of the plant outlet gas to match the sales gas pipeline pressure.

Compressors are driven by electric motors, internal combustion, or turbine engines. These engines, compressors, and utility systems generate used lubrication oils; cooling waters; wastewaters; spent solvents such as petroleum naphtha used for cleaning equipment; and oily debris such as rags, sorbents, and filters.

Steam equipment wastes are the same as those described in the field operations in 3.5.5.4.

3.6.7 Other Gas Plant Facilities and Operations

Process cleaning wastes identical to those generated at field production facilities are generated at gas plants. Wastes generated during the cleaning process include mixtures of spent cleaning solutions (such as, acids, caustics, solvents, and detergents) and solids andlor hydrocarbons removed from the system.

Other activities that generate waste are warehousing, product storage, maintenance activities, domestic sanitary waste handling and treating, construction and demolition, product shipping, laboratory testing, and office operations.

3.6.8 Waste Summary

A list of major categories of waste that may be generated at gas plants is shown below. (Note that certain equipment, valves, piping, and so forth may be contaminated with de-

~~~

posits of naturally occurring radioactive material (NORM) and should be handled accordingly when removed from service.) See Appendix C for a more complete listing of wastes generated by E&P.

Gas Plant Waste

Absorbent material

Antifreeze

Batteries

Blasting sand/material

Boiler blowdown

Catalyst

Cleaning wastes, process equipment

Constructioddemolition debris

Cooling tower blowdown

Crude oilkondensate, waste

Deionized water, excess

Domestic refuse

Domestic wastewater

Filters

Flue dust ash (fly ash)

first-aid waste

Hydraulic fluid

Incineration ash

Insulation material

Lab waste, sample wastes, and residues

Mercury, metallic liquid

Mercury, solids

Naturally occurring radioactive material (NORM)

Paint-related material

Pallets

Pigging wastes from DOT

Pipe/equipment hydrates

Pipelequipment scale

pipelines

Pit sludges

Polychlorinated biphenyls (PCBs)

Produced sand

Produced water

Rags, oily

Refractory waste

Saltbath heater salt

Sanitary wastewater

Scrap metal

Scrubber liquid, hydrogen sulfide

Soft water, excess

Soil, contaminated

Solvents

Spill cleanup waste, hydrocarbon (for example, crude)

Storm water

Sulfur dioxide liquor

Sweeteningldehydration liquids

Sweeteningldehydration solids

Tank bottoms

Tires

Unused materials, discarded Used oil

Vegetation



Water softener regeneration brine

Water softening resin, spent

Wood

3.7 TRANSPORTATION PIPELINES

When the processing of crude oil and natural gas has been completed at field production facilities or gas plants, the oil and gas are metered and sold. Transportation pipelines transport crude oil or natural gas and associated liquids to the market for sale or refining. These pipelines are'usually referred to as transmission lines by the Department of Trans- portation (DOT).



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These facilities and operations are no longer considered uniquely E&P.

3.8 OFFSHORE OPERATIONS

Since many wastes generated at offshore operations are identical to those generated onshore, a separate offshore discussion is not included in this document. From a waste handling and disposal standpoint, offshore operations are unique in that they may have the option to discharge in accordance with their NPDES (National Pollutant Discharge Elimination System) permit. If the waste stream is not permitted for over- board discharge, it must be hauled to shore. Once onshore, the wastes are handled and disposed in much the same manner as those wastes generated at onshore operations.

4 Environmental Legislation and Regulations

4.1 INTRODUCTION

This section summarizes key federal environmental laws and regulations that affect E&P waste management and disposal practices. They impose responsibility and liability for the protection of human health and the environment from harmful waste management practices or discharges.

Users are cautioned, however, that interpretation of regulations varies. Readers should contact appropriate legal counsel for assistance and advice. Information in this document is not all-inclusive and may not be applicable in all situations. State and local requirements vary. Federal, state, and local regulations are constantly evolving and should be compared with the information in this document to ensure consistency. References to specific regulations appear italicized and in brackets. An example of a reference or citation is the definition of solid waste, which is located in 40 CFR P 261.2. This refers to Title 40 of the Code of Federal Regula- tions, Part 261, Section 2.

Environmental violations may subject corporations, man- agers, employees, and shareholders to varying degrees of liability. Liability has now been extended to include personnel who know or should know if a particular action is illegal. Actions cover the gambit from improper recordkeeping to willful violations of appropriate regulations. Individuals may no longer claim ignorance as a defense against prosecution and the subsequent civil and criminal penalties, including imprisonment.

Civil penalties may become quite costly through court and administrative agency involvement. In addition to remediation expenses, fines of $25,000 per day per violation are no longer uncommon and may also be assessed.

Similarly, the transfer of land may present economic risks from environmental concerns. A careful evaluation of properties should be made to identify these liabilities prior to

transfer. A good record of property condition prior to transfer can be very beneficial in dealing with claims from subsequent owners and government agencies.

4.2 THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)

4.2.1 Overview

Enacted in 1976, RCRA required EPA to establish procedures for identifying solid wastes as either hazardous or nonhazardous and promulgate requirements for managing both.

EPA established four different criteria or characteristics to determine whether a waste is hazardous: (a) ignitability, (b) corrosivity, (c) reactivity, and (d) toxicity.

EPA also listed certain specific wastes (including known poisons and carcinogens) as innately hazardous. Thus, hazardous waste$ are described as either characteristically hazardous or as listed hazardous wastes.

Hazardous waste management is stringently regulated under RCRA Subtitle C. Nonhazardous waste disposal is regulated under RCRA Subtitle D and depends primarily on state controls. To date, EPA has established criteria aimed at ensuring that nonhazardous waste management facilities operate as sanitary landfills rather than open dumps.

States are required to submit Solid Waste Management Plans for EPA approval and funding. EPA activity and RCRA amendments after 1988 increased the emphasis on Subtitle D wastes and established additional minimum standards that state programs must include for Subtitle D waste management.

4.2.1.1 1980 RCRA Amendment

When RCRA was amended in 1980, the United States Congress recognized the special nature, high volume, and low toxicity of wastes generated by oil and gas exploration and production operations (as well as by mining, geothermal operations, electric utilities, and cement kilns). The U.S. Congress deemed that these wastes required special consideration. Therefore, it exempted oil and gas industry exploration and production wastes from regulation under RCRA hazardous waste provisions (Subtitle C). In addition, the U.S. Congress directed EPA to study such wastes and recommend appropriate regulatory action.

The EPA study was to include analysis of the following:

a. Sources and volume of waste. b. Current disposal practices. c. Dangers to human health and the environment, including documented cases. d. Alternatives to current disposal methods. e. Costs of alternative disposal methods. f. Impact of alternative disposal methods on exploration and production.



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4.2.1.2 June 30,1988 EPA Regulatory Determination

EPA conducted the study on E&P wastes and submitted a report to the U.S. Congress on December 28, 1987. Based on that study, the Agency made public its Regulatory Determi- nation on June 30, 1988; it stated:

“The Agency has decided not to promulgate regulations under Subtitle C (for E&P wastes).

Existing State and Federal regulations are generally adequate . . . certain regulatory gaps do exist, however, and enforcement of existing regulations in some States is inadequate.”

EPA listed examples of waste treatment methods and general field practices that, in specific instances, had not been used in an environmentally sound manner. The practices themselves were not at issue; rather, the problem was the lack of state regulations for their oversight. These treatment methods/practices include the following:

a. Land farming. b. Road spreading. c. Pit construction. d. Surface water discharge. e. Central disposal and treatment facility management. f. Abandonment of existing and previously abandoned wells. g. Arctic operations (in general). h. Associated wastes management.

EPA also stated:

“Existing Federal standards under Subtitle D of RCRA. . . do not fully address the specific concerns posed by oil and gas wastes. Nevertheless, EPA has authority under Subtitle D to promulgate more tailored criteria. In addition, the authorities available under the Clean Water Act or Safe Drinking Water Act can be more broadly utilized, and efforts are already under- way to fill gaps under these programs.”

In the June 30, 1988, Regulatory Determination, EPA further stated that its plans were as follows:

“The Agency plans a three-pronged approach toward filling gaps in existing State and Federal regulatory programs by:

a. Improving Federal programs under existing authorities in Subtitle D of RCRA, the Clean Water Act, and Safe Drinking Water Act; b. Working with States to encourage changes in their regulations and enforcement to improve some programs; and c. Working with the Congress to develop any additional statutory authority that may be required.”

4.2.1.3 1990 IOGCC State Regulatory Guidelines

In 1989, the Interstate Oil Compact Commission (currently IOGCC-Interstate Oil and Gas Compact Commis- sion) formed a Council on Regulatory Needs to assist EPA with its approach to E&P wastes. In 1990, the council produced a study report that represents the IOCC’s initial effort to assist EPA and the states in improving E&P waste management programs. The report outlines goals and criteria for state programs to use in regulating these wastes. In 1994, the IOCCC published an update titled IOGCC Environmen- tal Guidelines for state oil and gas regulatory programs. IOGCC maintains an ongoing effort to peer review state regulatory programs using these guidelines. This effort demonstrates that there is no need to increase federal regulation of E&P wastes.

4.2.2 Definition of Solid Waste (40 Code of Federal Regulations Part 261.2)

In simplest terms, a solid waste is any material that is discarded or intended to be discarded. According to RCRA, solid wastes may be the following:

a. Solid. b. Semi-solid. c. Liquid. d. Contained gaseous materials.

Specifically excluded from the solid waste definition are certain point source discharges subject to National Pollutant Discharge Elimination System (NPDES) permits under the Clean Water Act. Commercial products-including residues from spill cleanup-are not regulated as wastes unless, and until, they are intended to be discarded. Commercial products may be regulated under other statutes, including:

a. Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). b. Toxic Substances Control Act (TSCA). c. Comprehensive Environmental Response Compensation and Liabilities Act (CERCLA). d. Superfund Amendments and Reauthorization Act (SARA).

Each of these will be discussed later in this section. Enhanced recovery describes all efforts to increase ulti-

mate production of oil and gas from a reservoir. EPA has determined that produced water injected for en-

hanced recovery is not a waste for purposes of RCRA Sub- title C or D. This is because produced water used in enhanced recovery is beneficially recycled and is an integral part of some crude oil and natural gas production processes. Also, as stated in 4.2, this practice is regulated under the Safe Drinking Water Act’s Underground Injection Control (UIC) Program.



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4.2.3 Hazardous Waste Criteria Determination city. These characteristics are described in the following sec-

Under RCRA, a solid waste may be designated as a haz- tions.

ardous waste either by being specifically listed or by exhibiting one of the characteristics identified in the regulations. 4.2.3.2.1 lgnitability

Although considered to be a solid waste, as discussed A solid waste is ignitable if above, wastes that are uniquely E&P have been specifically exempted from being considered hazardous [40 Code of Federal Regulations Part 261.4(b)(5)]. See 4.2.6 and 4.2.7 for wastes that have been identified as exempt and 4.2.8 for those identified as nonexempt.

Other wastes are also considered exempt from Subtitle C under other provisions of RCRA (e.g., 40 Code of Federal Regulations Part 261.4). These include certain reclaimed materials and point source discharges subject to Section 402 of the Clean Water Act. Thus, a waste considered nonexempt per the E&P exemption may still be considered exempt from regulation as a hazardous waste, provided it meets one of the other exemption categories.

In this document, exempt means an E&P exemption from Subtitle RCRA C regulation only. This is not intended to im- ply that the waste is exempt from regulation under other statutesfiaws.

4.2.3.1 Listed Hazardous Waste (40 Code of Federal Regulations Part 261, Subpart D)

EPA has listed numerous types or classes of solid wastes as hazardous because they

a. Typically exhibit one or more of the characteristics of hazardous waste (see below). b. Have been shown to meet certain human toxicity criteria. c. Contain any one of the chemical compounds or substances listed as hazardous constituents.

The regulations contain four lists of hazardous wastes:

a. Hazardous waste from nonspecific sources (F-listed). b. Hazardous waste from specific sources (K-listed). c. Commercial chemical products considered acutely hazardous when disposed (P-listed). d. Commercial chemical products considered toxic when disposed (U-listed). Chemical containers that are not empty by EPA's definition also are hazardous wastes.

4.2.3.2 Characteristically Hazardous Waste (40 Code of Federal Regulations Part 261, Subpart C)

The EPA has developed four tests for use in determining when a solid waste not listed as a hazardous waste, or specifically excluded from regulation as a hazardous waste, must be managed as hazardous. EPA considers any nonexempt waste to be a hazardous waste if it exhibits any one of the characteristics of ignitability, corrosivity, reactivity, or toxi-

a. It is a liquid and has a flash point less than 60°C (140°F). b. It is not a liquid and is capable of causing fire through friction, absorption of moisture, or spontaneous chemical changes and, when ignited, burns so vigorously and persis- tently that it creates a hazard. c. It is an ignitable compressed gas. d. It is an oxidizer.

4.2.3.2.2 Corrosivity

A solid waste is a corrosive if

a. It is aqueous and has a pH less than or equal to 2 or greater than or equal to 12.5. b. It is a liquid and corrodes steel at a rate greater than 0.25 inches per year.

4.2.3.2.3 Reactivity

A solid waste is reactive if

a. It is normally unstable and readily undergoes violent change without detonating. b. It reacts violently with water. c. It forms potentially explosive mixtures with water. d. When mixed with water, it generates toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment. e. It is a cyanide- or sulfide-bearing waste which, when exposed to pH concentrations between 2 and 12.5, can generate toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment. f. It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under con- finement. g. It is readily capable of detonation or explosive decompo- sition under normal conditions (standard temperature and pressure). h. It is a forbidden Class A, or Class B explosive as defined by the U. S . Department of Transportation.

4.2.3.2.4 Toxicity

A solid waste is toxic if the extract from a representative sample of the waste contains any of the contaminants specifically listed in 40 Code of Federal Regulations Part 261.24 at a concentration equal to or greater than the respective value for each contaminant, thereby failing the Toxicity Characteristic Leaching Procedure Test (TCLP).



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Contaminant levels have been established for heavy metals such as chromium, lead, and mercury; for organics such as benzene and toluene; and for pesticides.

The addition of organics to the TCLP list in 1990 expanded the potential universe of nonexempt E&P wastes that might be characteristically hazardous. In particular, some wastes previously characterized as nonhazardous may now fail the TCLP test for benzene.

4.2.4 EPA’s Mixture Rule (40 Code of Federal Regulations Part 261.3)

RCRA regulations contain a so-called mixture rule that provides that the commingling of any acutely hazardous or toxic listed hazardous waste with a nonhazardous waste stream renders the entire mixture a hazardous waste. [The validity of the mixture rule has been overturned in court (U.S. v. Shell Oil Co., 950 E2D 751, CA DC, December 6,. 1991). EPA has begun rulemaking that may replace or greatly alter the mixture rule.] The intent of this rule is to prevent avoidance of hazardous waste regulations through dilution.

Commingling a characteristically hazardous waste with a nonhazardous waste may also render the entire waste stream as hazardous if the resultant combined waste stream displays hazardous characteristics.

Because of the mixture rule, operators should segregate the following items for separate management:

a. Unused U-listed and P-listed chemicals and their containers. b. Other listed hazardous wastes from other wastes.

To prevent creating characteristic hazardous waste, operators should segregate characteristic hazardous waste from other wastes. Also, because some exempt wastes may have hazardous waste characteristics (such as benzene concentrations), operators should avoid commingling exempt and nonexempt waste streams unless they have determined that the exempt waste does not have hazardous waste characteristics.

4.2.5 Quantity Determination (40 Code of Federal Regulations Parts 261.5 and 262)

EPA requirements for hazardous waste generators vary. These requirements depend on the quantity of hazardous waste generated and/or accumulated at a facility in a given calendar month.

a. Large quantity generators (that is, generators of 1000 kg [2200 lbs] or greater per month) of hazardous waste have the most restrictions. Only a few E&P facilities fall under these requirements. b. Small quantity generators (SQGs) are those facilities that generate greater than 100 kg (220 lbs), but less than 1000 kg (2200 lbs), per month.

c. Conditionally exempt small quantity generators (CESQGs) are those facilities that generate 100 kg (220 lbs) or less per month. Most E&P facilities would probably fall under this category.

A facility may be subject to small generator requirements one month and large quantity generator requirements the next month, depending on the volume of hazardous waste generated.

Hazardous waste generated by a conditionally exempt small quantity generator is typically not subject to hazardous waste regulations (except for the identification requirements). Reference 40 Code of Federal Regulations Part 261.5 for the special requirements for hazardous waste generated by conditionally exempt small quantity generators. For the other generator categories, requirements are identified in 40 Code of Federal Regulations Part 262.

4.2.6 EPA’s List of Exempt E&P Wastes

The following wastes are listed as exempt in EPA’s June 1988 Regulatory Determination:

a. Produced water. b. Drilling fluids. c. Drill cuttings. d. Rigwash. e. Drilling fluids and cuttings from offshore operations disposed of onshore. f. Well completion, treatment, and stimulation fluids. g. Basic sediment and water and other tank bottoms from storage facilities that hold product and exempt waste. h. Accumulated materials such as hydrocarbons, solids, sand, and emulsion from production separators, fluid treating vessels, and production impoundments. i. Pit sludges and contaminated bottoms from storage or disposal of exempt wastes. j . Workover wastes. k. Gas plant dehydration wastes, including glycol-based compounds, glycol filters, filter media, backwash, and molecular sieves. 1. Gas plant sweetening wastes for sulfur removal, including amines, amine filters, amine filter media, backwash, precipitated amine sludge, iron sponge, and hydrogen sulfide scrubber liquid and sludge. m. Cooling tower blowdown. n. Spent filters, filter media, and backwash (assuming the filter itself is not hazardous and the residue in it is from an exempt waste stream). o. Packing fluids. p. Produced sand. q. Pipe scale, hydrocarbon solids, hydrates, and other deposits generated and removed from piping and equipment prior to transportation. r. Hydrocarbon-bearing soil.



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s. Pigging wastes from gathering lines. t. Wastes from subsurface gas storage and retrieval, except for the nonexempt wastes listed afterward. u. Constituents removed from produced water before it is injected or otherwise disposed of. v. Liquid hydrocarbons removed from the production stream but not from oil refining. W. Gases removed from the production stream, such as hydrogen sulfide, carbon dioxide, and volatilized hydrocarbons. x. Materials ejected from a producing well during the process known as blowdown. y. Waste crude oil from primary field operations and production. z. Light organics volatilized from exempt wastes in reserve pits or impoundments or production equipment.

4.2.7 Additional Exempt Wastes

EPA’s lists of exempt and nonexempt wastes are not all-inclusive; determinations need to be made on several other incidental wastes. In deciding which wastes are exempt, i t appears that EPA focused on wastes necessary to conduct so- called primary field operations (including centralized facilities and gas plants). Using this approach, the following wastes, although not specifically listed as exempt by EPA, clearly meet the definition:

a. Excess cement slurries and cement cuttings. b. Sulfur-contaminated soil or sulfur waste from sulfur recovery units. c. Gas plant sweetening unit catalyst. d. Produced water-contaminated soil. e. Wastes from the reclamation of tank bottoms and emulsions when generated at a production location. f. Production facility sweetening and dehydration wastes. g. Pigging wastes from producer operated gathering lines. h. Production line hydrotesUpreserving fluids utilizing produced water. i. Iron sulfide.

4.2.8 EPA’s List of Nonexempt E&P Wastes

EPA’s Regulatory Determination for E&P wastes lists the wastes enumerated below as nonexempt. It appears that the EPA concluded that waste materials from maintenance of production equipment, as well as transportation-related (pipeline and trucking) wastes, were nonexempt.

While the following wastes are nonexempt, they are not necessarily hazardous. Nonexempt wastes should be managed as described under 4.2.9. The nonexempt wastes are as follows:

a. Unused fracturing fluids or acids. b. Gas plant cooling tower cleaning wastes. c. Painting wastes. d. Oil and gas service company wastes, such as empty

drums, drum rinsate, vacuum truck rinsate, sandblast media, painting wastes, spent solvents, spilled chemicals, and waste acids. e. Vacuum truck and drum rinsate from trucks and drums transporting or containing nonexempt waste. f. Refinery wastes. g. Liquid and solid wastes generated by crude oil and tank bottom reclaimers. h. Used equipment lubrication oils. i. Waste compressor oil, filters, and blowdown. j. Used hydraulic fluids. k. Waste solvents. 1. Waste in transportation pipeline-related pits. m. Caustic or acid cleaners. n. Boiler cleaning wastes. o. Boiler refractory bricks. p. Boiler scrubber fluids, sludges, and ash. q. Incinerator ash. r. Laboratory wastes. s. Sanitary wastes. t. Pesticide wastes. u. Radioactive tracer wastes. v. Drums, insulation, and miscellaneous solids.

EPA did not specifically address in its Regulatory Deter- mination the status of hydrocarbon-bearing material that is recycled or reclaimed by reinjection into a crude stream (used oils, hydraulic fluids, and solvents). However, under existing EPA regulations, used oils, even if otherwise hazardous, may be reintroduced into the crude stream for recycling, if the used oils are from normal operations and are to be refined along with normal process streams at a petroleum refinery facility (see 40 Code of Federal Regula- tions Part 279).

The above sections on exempt and nonexempt wastes only address those wastes generated by E&P that are exempted by EPA as hazardous under 40 Code of Federal Regulations Part 261.4(b)(5) (that is, the E&P exemption). These sections do not address any other wastes that may also be exempted from Subtitle C under other provisions of RCRA (for example, 40 Code of Federal Regulations Part 261.4), including certain reclaimed materials and point source discharges subject to Section 402 of the Clean Water Act (that is, NPDES discharges).

4.2.9 Requirements for Nonexempt Wastes

Unless a waste’s characteristics are known through process knowledge or previous experience, operators should consider testing nonexempt wastes whenever there is reason to believe they may exhibit one or more of the hazardous waste characteristics. Although there is no regulatory requirement for testing, civil and criminal penalties may be imposed if the waste is not managed according to regulations.

It is important to segregate nonexempt wastes from ex-



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empt wastes. One possible implication from the commingling of a nonexempt waste with an exempt waste is that the entire waste stream could lose its exempt status and perhaps have to be managed as a hazardous waste.

If the nonexempt waste is a listed hazardous waste, EPA's mixture rule (see 4.2.4) would make the entire commingled waste stream subject to stringent RCR4 Subtitle C requirements, including the requirement that it be disposed of at a hazardous waste facility. Therefore, it is usually in the best interest of an operator to routinely segregate nonexempt wastes from exempt wastes.

When segregation is not practical, the nonexempt waste should be examined closely to ensure that it is not a hazardous waste.

Some states have hazardous waste regulations that differ from those the EPA has promulgated. These state rules are at least as stringent as the federal regulations and may be more stringent.

Certain wastes (such as asbestos, NORM, and PCBs) are regulated by laws other than RCRA. For example, the Clean Air Act, Occupational Safety and Health Act, Toxic Sub- stances Control Act, and some state laws can also regulate management of E&P wastes.

4.3 THE SAFE DRINKING WATER ACT (SDWA)

4.3.1 Introduction

The SDWA was passed in 1974. Legislation was subsequently passed for regulation of underground injection wells under the Underground Injection Control (UIC) program. Drinking water standards were also established by the SDWA.

4.3.2 UIC Program (40 Code of Federal Regulations Part 146, Subpart C)

To implement technological control, EPA divides well injection activities into five classes. Each class groups wells with similar functions, construction, and operating features so that technical requirements can be applied to the entire class. The following descriptions of injection well classes are taken from Part 146, Subpart A of the UIC regulations:

a. Class I: Wells used to inject industrial, hazardous, and municipal wastes beneath the deepest formation containing an underground source of drinking water. b. Class II: Wells used to dispose of fluids that are brought to the surface in connection with oil and gas production and treatment; to inject fluids for enhanced recovery of oil and natural gas; or for the storage of hydrocarbons that are liquid at standard temperature and pressure. c. Class III: Wells that inject fluids for the extraction of min-

erals, including mining of sulfur by the Frasch process, in situ production of uranium or other metals from unmined ore bodies, and solution mining of salts or potash. d. Class IV Wells used to dispose of hazardous wastes or radioactive wastes into or above (within one-quarter mile) a formation that contains an underground source of drinking water, and those wells that might inject hazardous wastes into exempted aquifers. e. Class V Injection wells not included in Classes I to IV, such as geothermal, subsidence control, groundwater heat pump wells, and cesspools.

The UIC program established a special class (Class 11) of injection wells for oil- and gas-related fluids, as described above. EPA regulations generally provide that fluids approved for Class II wells include the following:

a. Fluids brought to the surface in oil and gas production. b. Co-mingled wastewaters from gas plants (if not hazardous at the time of injection). c. Fluids injected for enhanced recovery.

These regulations recognize the statutory requirement that regulation of Class II wells should not interfere with or im- pede oil and gas production, unless essential to preventing the endangerment of underground sources of drinking water (USDWs).

A USDW is an aquifer that supplies drinking water for any public water system; or that contains a sufficient quantity of groundwater to supply a public water system; and currently supplies drinking water for human consumption; or contains less than 10,OOO mgniter total dissolved solids; and is not exempted.

Certain aquifers may be exempted from the definition of a USDW as discussed in 40 Code ofFederal Regulations Part 146.4(b). An aquifer that contains minerals or hydrocarbons that are commercially producible or is situated at a depth or location that makes the recovery of water for drinking water purposes economically or technologically practical may be exempted.

Class II regulatory programs are either directly adminis- tered by the states (primacy states), or by the EPA, where states do not administer the programs (direct implementation also known as DI states).

Primacy states have negotiated primacy agreements with EPA. In return, they receive funding for program implementation conditional on meeting minimum EPA-specified standards. Primacy agreements, which may be amended with approval from EPA, dictate what can be injected in Class II injection wells. EPA determines what can be injected in Class II injection wells in DI states.

The most significant minimum requirements that Class II wells must meet are as follows:



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a. Only approved E&P fluids may be injected. b. No well may endanger USDWs. c. Unless permitted by rule, all wells must be permitted before construction. d. All wells must periodically demonstrate mechanical integrity. EPA defines mechanical integrity as no significant leak in the casing, tubing, and packer and no significant fluid movement into a USDW through vertical channels adjacent to the injection wellbore.

4.3.3 Drinking Water Standards (40 Code of Federal Regulations Part 41, Subpart B)

Drinking water standards were promulgated for public water systems serving at least 25 people daily. Public water systems include private well distribution and storage facilities serving large E&P facilities of 25 or more people, such as drilling locations, production camps, and gas plants. States and Indian tribes may have jurisdiction over the program.

The following standards were established to ensure the provision of safe drinking water:

a. Maximum primary contaminant levels were set for organic contaminants such as benzene; inorganic contaminants such as fluoride; and microbiological contaminants such as total coliform, viruses, and giardia lamblia. b. Maximum secondary contaminant levels were established for contaminants such as chloride, iron, total dissolved solids (TDS), as well as for color and odor. c. Water systems are to be lead free.

Since some E&P facility water systems must meet these provisions, awareness of water system standards is another factor to consider when designing and operating E&P operations and E&P waste management facilities.

4.4 THE CLEAN WATER ACT (CWA)

4.4.1 Introduction

The CWA was enacted in 1972 primarily to control point source discharges into waters of the United States. All point source discharges require National Pollutant Discharge Elim- ination System (NPDES) and/or state equivalent permits.

Under Section 3 1 1 of the CWA, discharge of a reportable quantity of oil (causes a sheen) into waters of the United States must be reported to the Coast Guard National Re- sponse Center in Washington D.C. Operators are subject to fines and penalties if spills are not reported as required under the Act.

EPA promulgated Oil Pollution Prevention Regulations (40 Code of Federal Regulations Part 112) in 1973 to mitigate the impacts of accidental spill discharges onto surface waters.

Point source discharge categories for E&P operations covered under 40 Code of Federal Regulations Part 435, such as

discharges to coastal areas, discharges for beneficial use, and stripper well discharges, are discussed further in 5.5.8.

4.4.2 NPDES Point Sources (40 Code of Federal Regulations Part 435)

NPDES permits are required for point source discharges of pollutants into the waters of the United States.

Point sources are very broadly defined as any conveyances including, but not limited to, ditches and pipes that convey discharges of pollutants to waters of the U.S.

Waters of the U.S. are very broadly defined and include, but are not limited to, lakes, streams, dry stream beds, wetlands, marshes, and playa lakes. See the EPA Wetlands Guidance Document for wetlands delineation criteria.

Discharges of cooling water or hydrostatic test water through a pipe or other conveyance to a water of the U.S. are examples of point source discharges, as are discharges of produced water and drilling mud into offshore waters. Permit conditions usually require periodic monitoring and reporting of technology-based or water-quality-based effluent limitations. Onshore discharges of produced water are specifically prohibited unless the exemptions in Title 40 Code of Federal Regulations Part 435, Subparts C and E, are applicable.

4.4.3 EPA and State Permits

A discharge permit is required from EPA or a state with jurisdiction over the NPDES program before discharging any pollutants. Permit coverage can be obtained with an individual permit or, where available, a general permit.

NPDES permits are required for some E&P facilities and waste management operations. Wastewater treatment and produced water point discharges into waters of the U.S. are examples of activities requiring permits.

A general permit is issued where effluent standards or limitations are set for a particular industry. An applicant may apply to be included under the particular general permit specific to the industry and area of the facility. General permits are common in some states and on the Outer Continental Shelf (OCS) and near-shore coastal waters.

Permitted discharges of produced water, muds, cuttings, and other categories of discharge with effluent limitations are common on the OCS and near-shore coastal waters.

Under some conditions, waste treatment at an E&P operation may change. If the volume or characteristics of the waste being treated or the technology used to treat a waste changes significantly, it may be necessary to revise an existing permit.

Permits require strict adherence to the standards prescribed and monitoring of the discharge and reporting to the EPA and/or state.

Permits may take months or even years to apply for and receive. Thus, the need for permits should be addressed early in any E&P waste management operation.



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4.4.4 Storm Water Permits (40 Code of Federal Regulations Part 122.26)

Storm water regulations were issued by EPA in November 1990 as part of the NPDES program.

These regulations require facilities that discharge storm water associated with industrial activity to obtain an Individ- ual, Group, or General Storm Water Permit.

E&P activities are generally exempt from storm water permit requirements unless the particular facility has had a release of a reportable quantity (RQ) of oil (oil sheen on water) or other hazardous substance in storm water anytime since November 16, 1987, or unless storm water discharges contribute to a violation of water quality standards. EPA’s current interpretation of the release of an RQ is that the release must occur into storm water, presumably during a storm event.

The deadline for E&P Group Permit applications has expired. Those facilities that have not applied for Group Permits will need to either apply for an Individual Permit or file a Notice of Intent to be covered under one of the General Permits.

Storm water associated with industrial activity means the discharge from any conveyance used for collecting and con- veying storm water that is directly related to manufacturing, processing, or raw materials storage areas at an industrial plant. Storm water includes storm water runoff, snow melt runoff, surface runoff, and drainage. Storm water is regulated when it is associated with industrial activities and is discharged via a point source either directly or indirectly into the waters of the United States.

Construction activities are identified as a special category that requires regulatory attention. A Storm Water Permit is required for construction activities that impact 5 or more acres of total land area.

Locations, such as those in the coastal or offshore areas, that have NPDES permits that authorize the discharge of deck drainage would generally be covered for storm water discharge under that category. Specific review of the applicable NPDES permit should be made to determine if storm water is included.

4.4.5 Spill Prevention Control and Countermeasure Plans (40 Code of Federal Regulations Part 1 12.7)

Operators are required to prepare Spill Prevention Control and Countermeasure (SPCC) plans for nontransportation-related facilities located in state waters and onshore in areas where spills can potentially enter waters of the United States. This includes drilling rigs, workover units, or fixed platfoms.

SPCC plans are required for facilities that have oil storage capacities of more than 660 gallons in a single tank, 1320 gallons or more collectively aboveground, or 42,000 gallons or more underground. The SPCC program sets minimum standards for certain aspects of facility design and operation.

The SPCC plan must be certified by a registered profes-

sional engineer and reviewed every 3 years. Finally, the regulations require that an SPCC plan be pre-

pared within 6 months of commencement of facility operation and implemented within 1 year after commencement of operations.

The guidelines for preparing and implementing an SPCC plan are found at 40 Code of Federal Regulations Part 112.7 for prevention and control of an oil spill. If installation of the equipment called for in the guidelines is not practicable, a strong contingency plan must be prepared following the provisions in 40 Code of Federal Regulations Part 109.

4.4.6 Dredge and Fill (33 Code of Federal Regulations Parts 323 and 325)

The Army Corps of Engineers (COE) administers the Clean Water Act’s Section 404 dredge and fill permit program. Permits are required for some E&€’ activities such as the construction of artificial islands; construction of canals or facilities in wetlands; installations on the OCS; construction of fishing reefs (such as abandoned rigs or rig into reef programs); construction of a submerged pipeline across a navigable water of the U.S.; and discharge of dredged or fill material into the waters of the U.S.

The COE and EPA will determine whether the proposed discharge will violate any water quality requirements. Either agency may place conditions on the permit to ensure compliance with applicable water quality requirements. If the imposition of conditions cannot ensure such compliance, the permit will be denied.

Coastal Zone Management (CZM) consistency may also be applicable if the activity is to take place in a state operating under an approved CZM program. Permits will also be reviewed for any potential impact on threatened or endangered species under Section 7 of the Endangered Species Act (ESA), and an Environmental Impact Statement (EIS) may be required.

Not all activities have to be permitted individually. COE and EPA also permit activities under general permits.

a. Regional permits, a type of general permit, may be issued for individual activities in those categories authorized by such regional permits, or an individual permit may be required as deemed by the issuing authority. Regional permits are generally issued for up to 5 years. Individual permits generally take the form of a standard permit or a letter of permission for a project of short duration, such as some construction projects. b. Nationwide and other general type permits are also available. Permits for structures are generally of an indefinite duration with no expiration indicated.

Many E&P waste management activities, such as siting of new or expansion of older treatment facilities, landfarming and landspreading operations, production platforms, explo-



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ration drill pads, and other activities fall under the above permits requirements. They should be included in the waste management strategy.

4.5 THE CLEAN AIR ACT (CAA)

The Clean Air Act, enacted in 1970, was most recently amended i n 1990. This recent amendment, commonly known as the Clean Air Act Amendments of 1990, contains important attainment provisions for air quality standards, permits and enforcement, hazardous air pollutants (HAP), acid deposition, stratospheric ozone protection, and motor vehicles and fuels.

All areas of the nation are classified as attainment or nonattainment areas, depending on whether they achieve the national ambient air quality standard for ozone or four of six criteria pollutants.

Two criteria pollutants, volatile organic compounds (VOCs) and nitrogen oxides (NO,), are regulated as ozone precursors. The others are carbon monoxide (CO), particulates (PM-lo), sulfur oxides (SO,), and lead.

Areas with more severe pollution problems are given additional time to achieve air quality standards but must comply with stricter and more numerous control measures.

4.6 THE TOXIC SUBSTANCES CONTROL ACT CrSCA)

TSCA, effective January 1, 1977, applies to all chemical substances and mixtures that are manufactured, imported, processed, distributed, or used for commercial purposes in the United States. Only those chemical substances and mixtures that are on the TSCA inventory may be manufactured, imported, processed, distributed, or used for commercial purposes in the United States.

TSCA was established to fill the regulatory gaps left by other laws [for example, the Federal Food, Drug, and Cos- metic Act (FFDCA) and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)]. Therefore, substances regulated under these other laws are not subject to TSCA. These non-TSCA regulated substances include food additives regulated under the FFDCA and products such as biocides, in- secticides, and herbicides regulated under FIFRA.

TSCA was one of Congress’ responses to the dangers of human and environmental exposure to chemical substances and mixtures. TSCA imposes broad regulatory control over all chemicals produced in the U.S. These controls include testing, recordkeeping, reporting, and notice requirements.

TSCA empowers EPA to evaluate and regulate chemical substances and mixtures that may have an adverse impact on human health and the environment. TSCA recognizes that adequate data must exist to evaluate the chemical substances and mixtures. If required data is insufficient or unavailable,

additional data must be developed to make informed decisions. If it is determined that an unreasonable risk exists, this risk

may be reduced by banning or restricting a substance in some or all aspects of its manufacture, use, distribution, or disposal, or by imposing labeling requirements. TSCA also allows EPA to recommend product substitution.

All E&P facilities or locations are subject to TSCA. For example, TSCA regulates identification and management of certain chemicals, such as polychlorinated bypheryls (PCBs).

Because E&P is an extractive rather than manufacturing industry, few other TSCA programs have routine impact. However, EPA can request jnformation or testing for a specific chemical substance or mixture manufactured, imported, or processed by E&P; or for the manufacture, importation, or processing of a new substance not already on the TSCA inventory.

TSCA Section 8(c) requires chemical producers and manufacturers to provide information periodically on production volumes for TSCA inventory updates. E&P operations are excluded but gas processing plants are not.

4.7 THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT (CERCLA)

4.7.1 Introduction

CERCLA, commonly known as Superfund, was enacted in December 1980 and established a program to:

a. Identify sites from which releases of hazardous substances into the environment might occur or have occurred. b. Ensure that they are cleaned up by responsible parties or the government. c. Evaluate damages to natural resources. d. Create a claims procedure for parties who have cleaned up sites or spent money to restore natural resources.

Under CERCLA, EPA has broad enforcement authority to require potentially responsible parties (PRPs) to undertake cleanup operations (Section 106) or to recover costs incurred in conducting remedial actions from PRPs (Section 107).

Courts have interpreted the statute to be retroactive in its application. This provides for strict liability without regard to fault and, in appropriate circumstances, for the imposition of joint and several liability.

CERCLA provides operators with a significant economic incentive to properly manage disposition of solid wastes at both onsite and offsite locations, in order to avoid liability for expensive cleanup activities. Care should be taken in handling CERCLA hazardous substances at E&P sites, in order to avoid contaminating exempt E&P wastes with those substances.



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4.7.1.1 Petroleum Exclusion

CERCLA provides for the exclusion of petroleum, including crude oil or any fraction thereof, from the definition of hazardous substance, pollutant, or contaminant.

EPA has interpreted the petroleum exclusion to include, in their entirety, pure petroleum and pure petroleum fractions, even though they contain substances otherwise listed as hazardous.

Thus, EPA interprets the term petroleum to encompass crude oil, crude oil fractions, and refined products (for example, gasoline, including indigenous hazardous substances).

4.7.1.2 E&P Waste Exclusion

The CERCLA definition of hazardous substance in Sec- tion 101 (14) includes RCRA hazardous wastes and excludes any waste the regulation of which under the Solid Waste Dis- posal Act has been suspended by Act of Congress. Under RCRA, drilling fluids, produced water, and other wastes associated with the exploration, development, or production of crude oil or natural gas (E&P wastes) are exempt from regulation as Subtitle C hazardous waste. A list of both exempt and nonexempt E&P wastes are contained in Appendix B. In legislative history clarifying the definition of hazardous substances, Congress stated that the exclusion for E&P wastes applies, “notwithstanding the presence in such substance of any hazardous or toxic chemical.” Thus, drilling muds and brines that have been excluded by regulation are not hazardous substances, [S.Rep. No. 848, 96th Congress, 2d Ses- sion 28 (1980)l. The Environmental Protection Agency has not always treated RCRA-exempt production waste as excluded from the definition of CERCLA hazardous substance. Users of this guide should seek legal counsel on the issue of reporting releases of hazardous constituents of exempt E&P wastes.

4.7.1.3 Reporting SpilldReleases

CERCLA also requires reporting releases of reportabIe quantities (RQ) of regulated hazardous substances to the environment (that is, air, land, or water). Any spill or release into the environment equal to or greater than the applicable RQ in a 24-hour period must be reported to the Coast Guard National Response Center. In addition, the appropriate state and local agencies may also require notification.

CERCLA defines a release to mean: any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment (including the abandonment or discarding of barrels, containers, and other closed receptacles containing any hazardous substance or pollutant or contaminant). An exception is if the hazardous substance is nonvolatile and the release is into a contained area (that is, not land, water, or air)

such as a concrete pad, which is not considered a spill or release to the environment, providing that the material is recovered. In addition, federal permitted releases or discharges are exempt from this reporting requirement.

4.7.2 The Superfund Amendments and Reauthorization Act (SARA)

Title III of the Superfund Amendments and Reauthoriza- tion Act of 1986 (SARA Title III), also known as the Emer- gency Planning and Community Right-to-Know Act (EPCRA), has six programs affecting or with the potential to affect E&P:

a. Section 302 requires any facility possessing any Ex- tremely Hazardous Substance (EHS) in excess of a specified Threshold Planning Quantity (TPQ) to inform the State Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC) that they are subject to the law. b. Section 303 requires such a facility to notify the LEPC of the name of the designated emergency coordinator who will work with the LEPC in developing the local emergency plans. Any changes at the facility that might affect the local emergency plan or the designation of the “emergency coordinator” must be reported to the LEPC. c. Section 304 requires immediate emergency notification and follow-up reports to the SERC and LEPC of any spill, leak, discharge, injection, leaching, or disposal into the environment of any CERCLA “hazardous substance” or SARA EHS that is in excess of the reportable quantity (RQ). This requirement is in addition to any reporting required by CERCLA Section 103. Emergency reporting under SARA and/or CERCLA does not necessarily satisfy any other federal or state release notification requirements (for example, TSCA 0 8(e)). d. Section 31 1 requires any facility that is required under OSHA rules to maintain Material Safety Data Sheets (MSDS) to submit them or chemical inventory lists to the SERC, LEPC, and local fire department. Revisions to this list must be reported within 90 days. e. Section 312 requires facilities to provide information annually on the quantity and location of those chemicals contained on their specific chemical inventory lists. SARA Title III also requires that any facility covered under Sections 31 1 and 312 allow access to the local fire department for the purpose of conducting an onsite inspection. f. Section 313 of SARA Title III does not currently apply to E&P operations. This section pertains to annual reporting requirements for releases and emissions of certain listed chemicals. Reporting is also required for onsite injection and offsite transfers of listed chemicals for treatment, recycling, or disposal. Source reduction and recycling activities are now required reporting under this section.



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4.8 THE OIL POLLUTION ACT OF 1990 (OPA 90)

The Oil Pollution Act of 1990 mandates national contingency planning, increases limits of liability, revises the measure of damage of natural resources, establishes a fund for cleanup costs, increases financial responsibility, addresses prevention and removal, and sets up a research and development program.

Emphasis on spill planning is indicated by the need for facilities to develop a plan to handle a worst-case discharge of oil that has the potential to reach navigable waters (see 4.4.5). This plan should encompass identification of environmentally sensitive areas, disposal of recovered oil, and training.

OPA 90 amends Section 31 1 of the Clean Water Act by revising the federal spill response system. The spill response system includes the following types of plans:

a. Private response plans. b. Generic response plans. c. Single company plans. d. Plans that address specific classes of facilities.

EPA has authority for nontransportation-related facilities, inclusive of onshore and offshore drilling and workover facilities, while the U.S. Coast Guard and DOT have authority for pipelines, terminals, and tankers, as appropriate.

4.9 OTHER FEDERAL ACTS

4.9.1 National Environmental Policy Act (NEPA)

The National Environmental Policy Act of 1969 (NEPA) requires detailed environmental review, in the form of an environmental assessment or environmental impact statement (EIS), for any major federal action undertaken or permitted by agencies of the federal government when the action may significantly affect the quality of the human environment.

Determining whether a particular permit or approval constitutes a major federal action is to be made early in the review process by the agency involved (40 Code of Federal Regulations Parts 1501.2 and 1501.4). This determination should consider both beneficial and adverse effects on the environment that would result from the implementation of the proposal. If the agency decides that an EIS will not be necessary, it is nevertheless required to prepare an environmental assessment to justify its decision (40 Code of Fed- eral Regulations Part 1501.3).

4.9.2 Federal Land Policy and Management Act (FLPMA)

The Federal Land Policy and Management Act of 1976 (FLPMA) (43 U.S.C. 1701 through 1782) establishes comprehensive land use guidelines for the Bureau of Land

Management (BLM) on how to manage public lands under its jurisdiction.

Section 603 of FLPMA (43 U.S.C. 1782) directs the Secretary of the Interior and the BLM to review all public land roadless areas of 5000 acres or more and roadless islands having wilderness characteristics; determine their suitability or unsuitability for wilderness designation; and report the suitability recommendations to the President of the United States no later than October 21, 1991.

4.9.3 Endangered Species Act (ESA)

The Endangered Species Act of 1973 was designed to protect endangered or threatened species or their critical habitat from proposed activities. The U.S. Fish and Wildlife Service (USFWS) or the National Marine Fish- eries Service (NMFS), under 50 Code of Federal Regula- tions Part 402, make determinations as to whether or not an E&P project (activity) will adversely impact a threatened or endangered species. This should be part of the project review and may become an integral part of the permitting process.

If there is no adverse impact posed by the project, a neg- ative declaration will be issued under Section 7 of the ESA.

If a species may be adversely impacted, a formal consul- tation under Section 10 of the ESA will proceed. The con- sultation will determine if the project can proceed, and if so, under what conditions.

Conditions may be imposed to mitigate the probable impacts of the project to the species of concern, such as mov- ing the project location, establishing restrictions, offsetting the impacts within a mitigation bank, and so forth.

Federal agencies are required by Section 7 of the Endan- gered Species Act (16 U.S.C. 1536) to ensure that such activities neither jeopardize endangered or threatened species nor destroy or modify the critical habitat of such species.

An endangered species is a species that is in danger of extinction throughout all or a significant portion of its range.

A threatened species is one that is likely to become endangered.

The authority to place species on the endangered or threatened list is vested in the Secretary of the Interior and the Secretary of Commerce. The listing process may be ini- tiated by the petition of any interested person requesting review, by the Secretary of the Interior, of the status of a species of wildlife or plant.

The inclusion, removal, or change of status of a species with regard to the protected species list follows formal rulemaking procedures.

The List of Endangered und Threatened Wildlife and Plants is published periodically in the Federal Register. Once listed, a species is subject to protection under the En- dangered Species Act (16 U.S.C. 1531 through 1543).



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No person is allowed to take protected fish, wildlife, or vegetation without an incidental-taking permit. A willful violation of this prohibition is subject to criminal punishment.

In addition, all federal agencies have the duty to ensure that federal actions will not significantly impair or jeopardize either the protected species or its critical habitat.

4.9.4 Federal Oil and Gas Royalty Management Act (FOGRMA)

The Federal Oil and Gas Royalty Management Act of 1982 (FOGRMA) (30 U.S.C. 1701 et seq.) was designed to:

a. Assure proper and timely revenue accountability for production from onshore federal and Indian oil and gas leases. b. Address OCS matters. c. Address lease reinstatement. d. Prescribe onshore field operations requirements for inspections and enforcement actions. e. Establish the basis for cooperation with states and Indian tribes for onshore federal leases. f. Establish duties of lessees, operators, and others involved in the production, storage, measurement, and transportation or sale of oil and gas from federal onshore and Indian leases.

FOGRMA regulations require oil and gas operators on federal lands to maintain site security and to construct and operate wells and the associated facilities in a manner that protects the environment and conserves the federal resource (30 Code of Federal Regulations Parts 201 et seq., 43 Code of Federal Regulations Parts 3100 et. seq., 25 Code of Fed- eral Regulations Part 226).

4.9.5 Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was originally enacted in 1947 and subsequently amended to its current form. FIFRA provides for the registration and use of pesticides and similar products intended to eliminate or control rodents, insects, weeds, microorganisms, and other living pests. Under this Act, EPA can control, ban, or restrict the use, import, or disposal of pesticides.

FIFRA has four main objectives including the following:

a. Evaluating the risks posed by pesticides using a registration system. b. Controlling exposure by classifying and certifying pesticides for specific uses. c. Suspending, cancelling, or restricting the use of pesticides that pose a risk to the environment. d. Enforcing requirements through inspections, labeling no- tices, and state authorities.

Since there may be a need to use pesticides or other pest control chemicals at a facility, it is to the operator’s advantage to use a licensed applicatorkontractor to perform these

services. This can help prevent the misuse of these chemicals or the potentially dangerous storage and disposal of unused products.

If the operator chooses to use or apply a regulated pesticide, it must be used and/or applied in accordance with its label requirements, including instructions for the proper handling and disposal of the empty container.

4.9.6 Hazardous Materials Transportation Act

The Hazardous Materials Transportation Act is the authority for the regulation of all shipments of regulated materials by highway (that is, public access roads and highways), rail, air, or water. Regulated materials or wastes shipped by E&P are typically subject to either Department of Transportation (DOT) or Coast Guard regulations.

A hazardous material is defined as a substance or material, including a hazardous substance, that has been determined by the Secretary of Transportation to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce and that has been so designated (49 Code of Federal Regulations Part 17 1.8). In general terms, a hazardous material is defined as any material deemed to be hazardous by the DOT.

The regulations also provide that hazardous wastes (as defined by RCRA in 40 Code of Federal Regulations Part 261) and hazardous substances (49 Code of Federal Regulations Part 172.101, Appendix A) are subject to DOT regulation when shipped.

Some E&P waste streams (for example, zinc bromide), although not subject to the hazardous waste regulations, would still be subject to the DOT regulations, since they are either listed as a hazardous material or contain a regulated quantity of a hazardous substance.

Shipments completely within a facility or lease are not subject to DOT regulation, provided the materials are not shipped on or across public access roads or highways, waterways, or railroads. Depending on the task(s) being performed or required to be performed in preparing a material for shipment, the regulations set out specific requirements and procedures that must be performed prior to the hazardous material being offered, accepted, or transported.

4.9.6.1 Shipper Responsibility

Most importantly, a person (for example, individual, cor- poration, and so forth) must first determine if the material being shipped is a hazardous material subject to regulation by the DOT, If the material is subject to regulation, that person must then determine which of the duties assigned by the regulations are required to be performed (that is, shipper, transporter, or both).

A specific definition of the slupper is not provided in the regulations; however, the shipper of a hazardous material for



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transportation is defined by the duties or tasks he is required to perform. These tasks include classifying the material or waste; selecting the packaging; marking and labeling the package; preparing the shipping paper; certifying that the shipment is in accordance with the DOT requirements; providing emergency response information; and providing placards when required.

Transfer of ownership has little bearing on the shipper responsibilities under the DOT regulations. Ownership of the hazardous material offered or accepted for transportation is only one of many factors that determine which party or parties perform, or has a duty to perform, any of the functions of the shipper.

4.9.6.2 Transporter Responsibilities

The DOT regulations also apply to each carrier who transports a hazardous material by air, highway, rail, or water. In general, the carrier or transporter is defined as the person engaged in the transportation of passengers or property by land, water, or as a common, contract, or private carrier. In certain instances, the operator may also be considered the carrier or transporter if the hazardous materials are transported on company owned or leased vehicles or vessels.

Transporter tasks include incident reporting, training, shipping paper or dangerous cargo manifest requirements, marking or placarding the vehicle, loading and unloading requirements, segregating materials, and emergency response for accidents.

4.10 OTHER REGULATIONS AND AGREEMENTS

All states have regulations to protect public health and the environment. E&P wastes and practices are subject to regulation by state agencies responsible for environmental protection. When more than one agency is involved, typically a Memorandum of Understanding (MOU) delineates the specific areas of authority for the agencies involved (for example, oil and gas agency and environmental agency).

Oil and gas E&P takes place in states with widely di- verse geological and environmental conditions. The resulting state regulations exhibit a variety of approaches to environmental protection because they have evolved relatively independently.

All oil and gas producing state statutes, rules, and regulations provide regulatory agencies the right of access to in- spect producing properties for regulatory compliance and to investigate complaints associated with environmental or other problems. Pending the outcome of an investigation, states have the authority to:

a. Issue cease and desist orders. b. Assess or seek administrative, civil, or criminal penalties. c. Order cleanups. d. Ban further operations and sever an operator’s pipeline connection.

4.1 0.1 Naturally Occurring Radioactive Materials (NORM)

There are currently no federal statutes or regulations specifically covering generation, storage, or disposal of oilfield NORM, other than regulations that apply generally to other radioactive materials. States are developing or have developed rules for the regulation of NORM.

4.10.2 Oil and Gas Lease Agreements

Lease agreements may impose obligations with respect to waste treatment, disposal, or reclamation and may be different or more stringent than regulatory requirements.

5 Waste Management Methods

5.1 INTRODUCTION

This section describes waste management practices for E&P wastes and their potential environmental impacts. When these practices are implemented onsite, they should be conducted in accordance with lease and landowner obligations and local, state, and federal regulations. Although special circumstances may warrant regulatory approval of other specific practices, the following criteria have been shown to be effective in the management of wastes.

Users are cautioned, however, that the information in this document is not all-inclusive and may not apply in all situations. State and local requirements vary and may be more stringent. Federal, state, and local regulations are constantly evolving; they should be reviewed to determine whether information in this document is consistent with current laws and regulations. Finally, the chemical nature of a particular waste and its impact on its surroundings may dictate taking a more lenient or more stringent approach to waste management.

Sound practices should be employed in all aspects of waste management. These sound practices not only serve to protect human health and the environment, they can help protect an operator from the long term liabilities of waste disposal. An overview of waste management methods and applications is presented in this section and summarized in Table 2. To encourage pollution prevention, Table 2 arranges available waste management options in a hierarchy.

5.2 SOURCE REDUCTION

Source reduction means eliminating or decreasing, to the extent practical, the volume or relative toxicity of wastes that are generated.

Opportunities to achieve significant volume reductions for some E&P wastes may not be practical and are limited by



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Table 2-Overview of Waste Management Methods

Method Applications

Source reduction-eliminate or reduce the quantity or relative toxicity of waste generated.

Recycling-reuse or reclaim valuable material from the waste generated.

Treatment”emp1oy techniques to reduce volume, relative toxicity, or other characteristics of waste.

hper disposal-utilize environmentally-sound methods to dispose of generated waste to minimize its impact, if any, and to protect human health.

Product substitution 100% product use (inventory

Process modification Improved process controls Good housekeeping

Reprocessing Burning for energy recovery Reuse in same process Reuse in a different process Return of unused product

Filtration Centrifugation Chemical precipitation Chemical flocculation Thermal treatment Extraction Biodegradation (landfming)

Landspreading Roadspreading or road surfacing Burial or landfilling Onsite pits Annular injection Underground injection wells Discharges to surface water Open burning and incineration Offsite commercial facilities

control)

Note: Check appropriate regulations prior to selecting waste management options.

the age or state of depletion of a producing property. For example, the volume of produced water typically increases as the field is depleted.

The volume of drilling muds generated is generally linked to the number of wells drilled and their depths. Nevertheless, cost-effective opportunities for source reduction exist and should be considered. Suggestions include the following:

a. Product and process substitution to reduce the volume and toxicity of the waste generated. b. Complete use of all commercial chemical products or return of unused commercial chemicals to vendors. First idfirst out inventory control should be practiced to ensure that chemicals do not exceed their expiration date. The number of chemicals used should be minimized to simplify tracking and recordkeeping. c. Process modification through more effective use of mechanical means. Improved drilling techniques, such as the use of more effective drill bits rather than chemical additions, can minimize waste. d. Improved controls to minimize mud changes, engine oil changes, or solvent usage. e. Good housekeeping to prevent spills to soils, accumula- tions of oily materials, or releases to waterways.

5.3 RECYCLING AND RECLAIMING

After reviewing all reduction options, the operator should consider recycling or reclaiming the waste material, either in process, onsite, or with outside contractors. Suggestions include the following:

a. Reprocessing into products; burning for energy recovery, where permissible; reuse in different processes; returning unused materials; and recovery for reuse in other industries. b. Use of chemical clearinghouses to find a customer for waste materials. c. Recycling hydrocarbons. Used oils, hydraulic fluids, and oily sump waters may be managed according to 6.7. Recov- ery of hydrocarbons from tank bottoms and separator sludges can be accomplished at onsite production facilities or offsite commercial facilities. d. Return of oil-based drilling mud to the vendor for reprocessing, where practical. State and local regulations should be consulted to ensure that any notification or recordkeeping and reporting requirements are met.

5.4 TREATMENT

After examining source reduction and recycling opportunities, potentially cost-effective treatment steps to minimize waste volume, toxicity, or other characteristics should be considered. Examples include the following:

a. Filtration, centrifugation, chemical precipitatiodfloccula- tion, thermal treatment (evaporation), and extraction may be used to reduce the volume of a waste. This volume reduction may produce lower disposal space requirements, or it may concentrate a constituent to a level where recovery is feasible. b. Chemical treatment, such as hydrogen peroxide oxidation of phenol to carbon dioxide and water, may be used to reduce or eliminate the toxicity of a chemical waste. c. Biodegradation of organic material may result in transfor- mation to less toxic compounds or in complete degradation. d. Thermal treatment can result in recovery or destruction of toxic organics. e. Chemical stabilization of toxic inorganic compounds may be used to reduce toxicity and mobility. f. Elementary neutralization may be applicable to the treatment of corrosives.

All treatment must be performed in accordance with applicable state or federal regulations as described in Section 4.

5.5 DISPOSAL

5.5.1 Evaluation Factors

Disposal is the final waste management alternative to be considered after incorporating all practical source reduction,



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recycling, and treatment options. The following factors should be considered when evaluating both onsite and offsite disposal facilities.

5.5.1.1 General Site Conditions

Area-wide topographical, hydrological, and geological features, as well as sources of usable water, should be reviewed. Also, current and probable future activities around the disposal site should be evaluated.

5.5.1.2 Hydrological Conditions

A hydrological review should identify the location, size, and direction of flow for existing surface water bodies and aquifers characterized as an Underground Source of Drink- ing Water (USDW).

5.5.1.3 Area Rainfall or Net Precipitation Conditions

Historical rainfall and distribution data should be evaluated to establish soil loading conditions for landspreading, speed of reserve pit drying, net evaporation rates, and pH overtopping potential.

5.5.1.4 Soil Conditions and Loading Considerations

Soil conditions should be checked since they will affect decisions on loading for landspreading and liners for pits. For example, in high clay content and permafrost areas, liners may be unnecessary for reserve pits. In other areas, liners may be appropriate.

5.5.1.5 Drainage Areas

Natural or existing drainage pattern should be determined. Drainage devices needed to control water flow into, onto, or from facility systems should be identified.

5.5.1.6 Presence of Special Conditions

Environmentally-sensitive conditions such as wetlands, historical or archaeological sites, protected habitants, or the presence of endangered species should be identified. Prox- imity to urban areas also affects disposal decisions.

5.5.1.7 Air Quality

The potential air quality impact of solid waste management facilities should be considered.

5.5.2 Landspreading

Landspreading is a method of treatment and disposal for RCRA Subtitle C-exempt, low-toxicity wastes. It promotes

reduction of organic and inorganic constituents by natural processes. Landspreading, a process of applying a waste to the upper soil zone, minimizes impacts to current and future land use. Characteristics and levels of the wastes are such that contamination of soil, groundwater, and runoff should not occur if landspreading is executed in a prescribed manner.

While initial loadings are designed to be protective, further reduction of organic and inorganic constituents generally occur by natural processes such as dilution, absorption, and biodegradation.

Landspreading should be practiced in accordance with local, state, and federal regulations and consistent with lease obligations.

Wastes are applied in a one-time loading as determined by the absolute salt concentration, hydrocarbon concentration, metals concentration, and/or pH level after mixing with the soil. This one-time loading is what differentiates landspreading from landfarming. Landfarming is a permitted biological treatment process consisting of multiple applications of waste to an area with managed additions of moisture and nutrients and repetitive disking.

5.5.2.1 Loading Limits

Based on soil and waste analysis, one constituent will be found to be controlling-that is, it will limit the amount of waste that can be applied to soil. Loading criteria for salts, hydrocarbons, and metals are discussed below. An example of the application of this procedure is given in Appendix F.

5.5.2.2 Salts

Studies have shown that landspreading, which results in wastehoil mixtures with soluble salt levels (that is, electrical conductivity) of less than 4 mmho/cm, exchangeable sodium percentage less than 15, and a sodium adsorption ratio less than 12, will not harm most agricultural crops or soil (based on one-time application). Higher values may be appropriate for some sites depending on (a) land use, (b) salt tolerance of native vegetation, and (c) background soil salinity. For a detailed description of these guidance values and their application, see API Publication 4527, Evaluation of Limiting Constituents Suggested for Land Disposai of EdiP Opera- tions, August, 1993.

5.5.2.3 Hydrocarbons

API Publication 4527 also supports and describes the landspreading of wastes that contain hydrocarbons. A waste/soil mix containing oil and grease (O&G) or total petroleum hydrocarbon (TPH) concentrations of up to 1 percent by weight has been found to be generally protective of water, plants, and soil microbes. Site specific conditions may accommodate initial waste/soil mixtures with higher



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TPH if they contain low levels of water soluble organic compounds. Enhanced techniques, such as repetitive disking and nutrient addition, may be used to increase the rate of biodegradation.

5.5.2.4 pH

According to the API Publication 4595, Criteria forpH in Onshore Solid Waste Management in Exploration and Pro- duction Operations, the pH of the waste/soil mixture is best maintained between 6 and 8 for upland landspreading but may be expanded to between 6 and 9 for wetland landspreading. This document describes methods for determining and controlling pH in the field.

5.5.2.5 Metals

Concentration of metals in the waste/soil mixture must also be controlled. The API document, Metals Criteria for Land Management of Explanation and Production Wastes, should be consulted. Table 3 presents API-recommended guidance values for metals in land disposed soiYwaste mixtures.

5.5.2.6 Example Land Loading Calculations for Oil and Grease and TDS

Problem:

An operator has 1,500 yd3 of waste with 12,000 ppm TDS, 10 percent oil (100,000 ppm), and a density of 93.6 Ib/ft3. The operator wishes to landspread the waste such that the maximum oil loading in the soil is 2 percent and the TDS content of the soil/waste mixture is not above 3,000 ppm.

Detailed below is the solution calculation for the land requirements for landspreading this waste based on (a) the oil content of the waste and (b) the TDS content.

It is assumed that the soil will be tilled to a depth of 6 in. and that 1 acre of soil 6 in. deep (1 acre-6 in.) weighs 2x106 lbs.

Solution:

a. Calculate the land requirement based on the oil content of the waste and a 2 percent O&G maximum loading (assume soil with no previous O&G exposure).

Convert the 2 percent O&G maximum loading into pounds of O&G per acre-6 in.:

Maximum lbs oivacre-6 in.= 0.02 - x 2 x IO6 lbs soil/acre.-6 in. lbs oil lbs sod

= 40,000 lbs oivacre-6 in.

From the oil concentration in the waste, calculate the corresponding maximum pounds of waste that can be tilled in:

Maximum waste-to-soil =40,000

=40,000 [ lb oil 1 ( 1 lb waste) acre6" 0.1 lb oil

Convert pounds of waste to volume:

Maximum waste volume loading = 4 x 16 lb waste [ S] [ A.&~;te]

= 4,274 - ft3 waste acred"

Determine the land required to spread 1,500 yd3 of waste:

b. Calculate the land requirement based on the TDS content of the waste and a maximum loading of 3,000 ppm TDS (including TDS in the native soil). Assume the native soil has 100 ppm TDS.

Convert maximum ppm TDS loading to lbs TDS/acre-6 in.:

Maximum lbs TDS I acre-6= 3.000 mg TDS g TDS [ ~ ] ( 1 . 0 0 0 m g T D S )

[ Ikgsoil ][ 1IbTDS ][454gsoil)[2x1061bssoil) 1 , m g soil' m ÏiEX acre-6

Note that the pounds of TDS per acre-6 in. (6,000) is twice the loading of TDS in ppm (3,000).

Calculate lbs TDS/acre-6 in. in the receiving soil:

lbs TDS I acre -6" in receiving soil = 'Oo lbs TDS ] [ x 'O6 lbs 'Oi1] [ IxlO0lbs soil acre-6"

=200 lbs TDS I acre-6''

Calculate the maximum pounds TDS to be applied:

Maximum TDS 10 apply = (Maximum lb TDS/acred') -lb TDS/acrcd' in receiving soil) = (6000 lb TDS/acre-6) - (200 lb TDS/acre-6) = 5,800 lb TDS/acre-6

Convert pounds TDS to volume of waste:

Maximum waste loading = (Maximum lbs T D S I acrs6") - [ lb TDS ] [ lb waste ]

= 5.164 - fi3 waste acre-6

Determine the land required to spread 1,500 yd3 of waste:



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Since the land requirement for oil loading is greater than for TDS loading, oil is the limiting constituent and 9.5 acres would be required to landspread this waste to achieve the de- sired loadings.

Wastes that do not meet the above guidelines may be safely landspread if additional management controls have been developed and proper approvals obtained.

5.5.3 Roadspreading

5.5.3.1 Oil Wastes

Exempt oily wastes such as tank bottoms, emulsions, heavy hydrocarbons, and crude oil-contaminated soil may be used for road oil, road mix, or asphalt. These wastes should be analyzed to ensure they are not ignitable (that is, flash point above 140"F), and that they have a mixed density and metals content consistent with approved road oils or mixes.

Application of oily wastes to private or public roads should be at loading rates that minimize the possibility of surface runoff.

Roadspreading should have the approval of landowners and should meet appropriate state and local regulatory requirements.

5.5.3.2 Produced Waters

It is generally recommended that produced waters used for roadspreading or dust suppression be within a pH range of 6 to 9 and below electrical conductivity 4 mmhokm. Produced waters with higher electrical conductivity may be used in lieu of road salting with state and local regulatory agency approval.

5.5.4 Burial or Landfill

It is suggested that operators limit burial or landfilling without a protective liner primarily to solid or semi-solid, low-salt and low-hydrocarbon content inert materials (for example, fresh water-based drilling muds, spent iron sponge, pipe scale, gas plant catalyst, and molecular sieve). Further- more, these techniques should be used only in areas where soil and hydrological conditions would preclude or minimize any threat of groundwater contamination. Also, special waste characteristics such as naturally occurring radioactive material (NORM) should be considered.

Recommended criteria for buried or landfilled wastes include the following:

a. Less than 4 mmho/cm electrical conductivity. b. Less than 1 percent O&G by weight. c. Free oil should not be buried.

Burial may reduce the rate or amount of natural biodegradation that occurs.

As described in 5.5.2, the presence of heavy metals should also be considered. When the waste exceeds the suggested

Table 3-API Metals Guidance: Maximum Soil Concentrations

Metal

Arsenic

Barium

Boron

Cadmium

Chromium

Copper

Lead

Mercury

Molybdenum

Nickel

Selenium

Zinc

Extraction Method

EPA Method 305P

LDNR True Total Bariumb

Hot Water Soluble (Carter, 1993)c

EPA Method 3050

EPA Method 3050

EPA Method 3050

EPA Method 3050

EPA Method 3050

EPA Method 3050

EPA Method 3050

EPA Method 3050

EPA Method 3050

Maximum Soil Concentration

(mg/kg)

41

180,OOO

2 m a d

26

1,500

750

300

17

;ee Note 1

210

iee Note 2

1.400

aEPA, Testing Methods for Evaluating Solid Waste, SW-846, Third Edition, 1986. bLouisiana Department of Natural Resources, Laboratory Procedures for Analysis of Oiljïeld Waste, Statewide Order No. 29-B, 1989.

'Carter, Soil Sampling and Methods of Analysis. Lewis Publishers, Boca Ra- ton, pp. 91-93, 1993. dGuidance for boron is based on the soluble concentration with units of mg/L rather than the total concentration (mgkg). Notes: 1. Molybdenum: On February 25, 1994 (59 FR 9050). EPA rescinded the risk-based maximum soil concentration for Mo of 9 mgkg due to technical errors and established a nonrisk-based interim ceiling limit of 37 mgkg. Under certain conditions this interim level may not be protective of grazing livestock. These conditions are alkaline soils under arid and semi-arid conditions with deficient levels of copper in the soil (see Discussion of Limiting Exposure Pathways).

2. Selenium: The limiting pathway concentration of 1 0 0 mgkg was generated by EPA using the risk-based multipathway analysis (see Table 3). How- ever, the potential for plant uptake of Se may be high in alkaline soils under arid and semi-arid conditions. Plants that accumulate Se in these soils may pose a threat to grazing animals. Therefore, if elevated levels of Se are found in the waste, the operator should consider site conditions that control its availability (see Discussion of Limiting Exposure Pathways).

criteria (see Table 4), a liner or encapsulation should be used, unless it can be shown that groundwater is either not present or is naturally protected from any significant threat of contamination.

Solidification, stabilization, and encapsulation are methods used to modify adverse properties of wastes to make them suitable for burial.

Operators should maintain complete records of analytical data, sites used, and types and quantities of waste disposed.



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5.5.5 Onsite Pits

Onsite pits include reserve pits for drilling operations and emergency, workover, basic sediment, percolation, NPDES skimming, and evaporation pits for production operations.

5.5.5.1 Reserve Pits

Construction, operation, and closure of reserve pits should adhere to the following guidelines.

5.5.5.1.1 Reserve Pit Construction

Reserve pits should be constructed using the following guidelines:

a. In areas where it is necessary to construct reserve pits adjacent to water bodies or on the side of hills or bluffs, special engineering considerations should be used to ensure integrity of the pit and to prevent overflow of the pit during heavy rains. Pit liners, barrier walls, or closed mud systems should be employed as required in environmentally sensitive areas. b. Reserve pits should be constructed so that the pit bottom does not penetrate usable groundwater. If in wetland areas, the pit contents should not significantly impact usable groundwater or surface waters. c. Pit dikes should be built to fully contain liquid volume and prevent seepage. Pits should be sized to ensure adequate storage during drilling operations; historical rainfall patterns should be considered, d. State and local regulations may allow freshwater-based muds, cuttings, and rigwash discharge to unlined reserve pits. These fluids should be directed via a pipe or trench to the pit. e. Reserve pits and associated trenches should be lined if the drilling fluids are saltwater or oil-based muds, unless soil and groundwater environments will not be significantly impacted. Solids separation equipment (for example, shale shakers, cyclones, and so forth) should discharge directly to the reserve pit.

Any areas subject to spillage or contact by these muds should be lined with impermeable material. Liners should be made of a natural clay or clay-like synthetic material that will withstand normal operating conditions. Liners should protect the sides and bottom of the pit and provide a sufficient barrier to any potential flow.

If materials will be encapsulated permanently, liners should exhibit a hydraulic conductivity less than 1 OE-7 cdsec . It should be noted that in permafrost areas lining of only dike walls may be sufficient where the permafrost is continuous and an effective permanent barrier to the downward movement of fluid is provided.

f. Reserve pits should be strategically sited on drilling locations to collect the appropriate wastes and, where practical and appropriate, storm water runoff from the drilling pad. The pad should be constructed with storm water runodrunoff controls in place to minimize nondrilling pad storm water entering the reserve pit.

5.5.5.1.2 Reserve Pit Operation

Reserve pits may be operated using the following guidelines:

a. Wastes stored in reserve pits should be restricted to drilling muds, cuttings, rigwash, excess cement, and certain completion fluids.

It is recommended that completion fluids with electrical conductivity greater than 4 mmhoskm, pH outside of the range 6 to 9, or hydrocarbons greater than 1 percent by weight should not be stored in unlined pits where groundwater requires protection. b. Should it become necessary to introduce hydrocarbons into drilling muds to handle unusual drilling problems or if salts are unexpectedly encountered when an unlined pit is in use, special efforts may be needed to isolate these muds and cuttings from those already in the reserve pit. In certain cases, remedial action may be needed. This action may include immediate removal of free hydrocarbons and special pit closure techniques, described below. c. Generally, produced water or liquid hydrocarbons should not be placed in unlined pits. Any hydrocarbons that inadver- tently enter a pit when drilling and completion operations stop should be skimmed off. d. Lined pits should be used with care. Operators must assure maintenance of liner integrity. The operation should include measures to avoid damage of the liner either physical (tearing or puncturing) or chemical (dissolving, permeating, reacting). e. Operators must maintain dikes and liquid levels to prevent overfilling, unpermitted discharges, and spills.

5.5.5.1.3 Reserve Pit Closure

Reserve pits should be closed using the following guidelines:

a. Operators should close reserve pits as soon as practical or within 12 months after stopping drilling operations to avoid the potential for becoming an illegal dumping site. b. Pit liquids should have their free oil removed and be sam- pled for conductivity prior to pit closure. Waste management plans may address whether, based on geological areas or mud system additives, additional sampling and analysis for metals or salts is necessary.



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Sampling for organics should also be considered in cases where the mud system could contain excessive concentrations of organics due to mud additives used in drilling or other contamination. Information should be applied in designing pit closure procedures that will ensure soil and groundwater protection of the drill site. c. Freshwater pit liquids can be managed by injection down the well annulus (see 5.5.6), evaporation in arid areas, landspreading, discharging under state/NPDES permits, injection into onsite Class II wells, or transportation to offsite facilities. For land application of fluids, fluid composition and loading rates should be considered. State, local, and federal regulations should be reviewed prior to selecting a management option. d. Freshwater pit solids should be land-disposed onsite in a manner protective of soil and groundwater environments and consistent with lease obligations and all regulations. Alterna- tively, they may be hauled to offsite disposal sites. e. Pit liquids with electrical conductivity greater than 4 mmhoskm should be removed from reserve pits as soon as possible or within 1 to 2 months after cessation of drilling operations. They may be injected down the well annulus or Class II injection wells or disposed using other options approved by local, state, and federal regulations. f. Residual pit solids with electrical conductivity greater than 4 mmhokm, oil and grease greater than 1 percent by weight, or significant levels of heavy metals should be buried or landspread onsite in a manner consistent with future land use and to prevent leaching of pollutants into usable groundwater. Landspreading or burial as described in previous sections may be viable options, or pit solids may be removed and hauled to permitted offsite disposal facilities. Under certain circumstances, solidification and stabilization may be practical for minimizing the mobility of specific constituents.

Salts may be removed by washing and then injecting the resulting salty washwater into a Class II injection well as defined in 4.3.2. The resulting low-salt solids can be managed like freshwater solids. When drilling deeper wells using both freshwater and saltwater-based muds, one should consider segregating the saltwater-based system to minimize the wastes that must be managed using special techniques. g. Oil-based mud liquids should generally be returned to vendors or reclaimed at permitted facilities. h. Oil-based mud solids may be taken to offsite disposal facilities capable of handling oily wastes or mixed with soil to less than 1 percent O&G content by weight during burial or landspreading onsite. It may be possible to reduce the oil content of some muds by washing mud solids to reach this criteria.

Burial of solids with O&G content in excess of 1 percent may be feasible when approved solidification techniques are

used in accordance with local and state regulations. When drilling wells using both freshwater and oil-based muds, segregating the oil-based system to minimize total volume of oily waste should be considered. i. Pit sites should be compacted, contoured, and revegetated where necessary to provide ground support stability and prevent erosion of the well location. Records should be kept of pit locations. j . Operators should keep records of type, volume, analytical data, destination, and hauler used for waste fluids and solids transported to offsite facilities.

5.5.5.2 Production Pits

Construction, operation, and closure of onsite pits should generally follow the same guidelines as those for reserve pits described above. Unlined onsite pits used for disposal of waste should be restricted to areas where soil conditions, hydrological factors, and rainfall prevent significant soil or groundwater contamination. The following guidelines should be used for various onsite production pits.

5.5.5.2.1 Blowdown and Emergency Pits

Blowdown and emergency pits (flare pits, pressure vessel relief pits, and fluid overflow pits) should not be used for storage or disposal. Fluids diverted to emergency pits should be removed as quickly as practical and in accordance with local, state, and federal regulations. Siting and construction should minimize the potential, if any, of surface or groundwater contamination.

5.5.5.2.2 Workover Pits

Workover pits used to contain workover fluids should be open only for the duration of the workover. Siting of these pits should consider the presence of groundwater and surface waters. If site-specific considerations indicate that these waters could be endangered, pits may be lined or tanks may be used.

5.5.5.2.3 Basic Sediment Pits

Basic sediment pits should be lined or replaced with tankage. Basic sediment pits are used for temporary storage of oily wastes such as paraffin and vessel bottoms. Their contents are periodically cleaned out or burned.

5.5.5.2.4 Percolation Pits

Percolation pits allow liquid contents to migrate through their bottom and sides into surrounding soils. Percolation pits should be used only for disposal of produced waters where permitted by regulatory agencies and where USDWs are not present or endangered.



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5.5.5.2.5 Unlined Skimming/Settling Pits

Unlined skimmindsettling pits contain discharges to provide additional retention time for the settling of solids. This allows more complete residual oil separation. Unlined skim- minghettling pits should be used only in conjunction with permitted state/NPDES discharges. They should not be used for produced water. Pit walls should be constructed to prevent seepage and provide adequate free-board above normal operating conditions for precipitation.

5.5.5.2.6 Produced Water Pits

Produced water pits have been used in lieu of tankage. Produced water pits may be lined and should be operated only as a substitute for process vessels with NPDES- or injection-well-regulated disposal of the produced water.

5.5.5.2.7 Evaporation Pits

In areas where small volumes of wastewaters are generated, evaporation pits are used. Disposal of wastewater by evaporation produces concentrations of salts and residual hydrocarbons. Surface evaporation pits may be lined where groundwater or usable soils may be endangered.

5.5.6 Annular Injection of Reserve Pit Fluids

Annular injection is a disposal method where reserve pit fluids are injected down a casinglcasing annulus of a drilling well into formations not containing an underground source of drinking water (USDW), unless exempted according to 40 Code of Federal Regulations Part 146.4 andlor specific one- time permission is granted by the state.

Maximum surface injection pressures are approved by the state and recorded in the injection permit. In addition, operators must protect underground sources of drinking water with sufficient casing and cement to prevent contamination due to injected reserve pit fluids.

5.5.7 Underground Injection

Injecting fluids into underground reservoirs is an activity permitted by state or federal agencies according to 40 Code of Federal Regulations Part 146"Underground Injection Control Program: Criteria and Standards.

Fluids injected for disposal or enhanced oil recovery are subject to state or federal underground injection control regulations. Injection well classifications are summarized in 4.3.2.

Underground injection wells associated with E&P activities are classified by EPA as Class II wells. Class II wells are to be used for exempt E&P waste fluids. However, state regulations should be consulted to evaluate specific require-

ments. EPA classified Class V wells should not be used for disposal of E&P wastes without specific regulatory agency approval.

Operators should design injection wells to prevent endangerment of nonexempt USDWs. Operators must demonstrate mechanical integrity according to current requirements by ensuring that there is no leak in the tubing, casing, or packer and that an injected fluid is confined within the injection zone through proper cementing. Properly constructed and monitored underground injection wells represent a safe environmental practice for disposal of produced water, facility waste fluids, and hydrocarbon-containing wastes.

5.5.8 NPDES Discharges

Point source discharges from oil and gas operations to navigable waters of the U.S. are regulated by the Clean Wa- ter Act's NPDES program (40 Code of Federal Regulations Part 435). This program sets conditions for discharges in different areas, recognizing their unique environmental aspects. E&P operations may discharge produced water, subject to appropriate permit limitations, in the following areas:

a. Outer Continental Shelf (OCS) waters. b. Territorial seas. c. Coastal areas that contain brackish waters not suitable for human usage. Current status should be evaluated before discharging.

Or if the following conditions are met:

a. Beneficial usage, which are discharges of low-salinity produced waters in and regions (west of the 98th meridian) where they may provide the only source of water for livestock and wildlife. These discharges occur primarily in Wyoming and California and are permitted by state or federal agencies. b. Stripper discharges that are allowed for marginal wells under the CWA.

5.5.9 Open Burning and Incineration

Open burning and incineration are typically used to dispose of nonhazardous materials with properties that make recycling unsuitable.

Burning should be restricted to materials such as oily sorbents, paraffin, landscape wastes, and board road material. Also, burning should be conducted during daytime hours and should not cause nuisance smoke and particulates.

Incineration should be performed only with approval of state and/or local air pollution regulatory agencies.



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5.5.10 Offsite Commercial Facilities

Offsite commercial facilities offer reclamation, Class I and Class II fluid injection, hazardous and nonhazardous treatment and disposal capabilities, and incineration services. Due to the potential for long-term liability, great care should be exercised by operators in using these sites. It is recommended that operators periodically review offsite commercial facilities as per 2.5.2.

6 Identifying Management Options For Speciflc Wastes

6.1 INTRODUCTION

The following major topics are covered in this section: Produced Water Drilling Wastes Workover and Completion Wastes Tank Bottoms, Emulsions, Heavy Hydrocarbons, and Produced Solids Contaminated Soils Used Oils and Solvents Dehydration and Sweetening Wastes Oily Debris and Filter Media Gas Plant Process and Sulfur Recovery Wastes Cooling Tower Blowdown, Boiler Water, Scrubber Liq-

Downhole and Equipment Scale Transportation Wastes Storm watermigwash Unused Treatment Chemicals Asbestos Used Batteries PCB Transformer Oil NonPCB Transformer Oil Empty Oil and Chemical Drums Naturally Occurring Radioactive Material (NORM) Geological and Geophysical Operation Wastes Recompression and Facility Utility Wastes

When E&P waste management practices are implemented onsite, operators should conduct them in accordance with lease and landowner obligations and federal, state, and local regulations, as described in Section 4. Wastes should be managed according to waste management guidance in this section and Section 5.

Operators are cautioned, however, that information in this document is not all-inclusive and may not apply in all situations. State and local requirements vary. Federal, state, and local regulations are constantly evolving; they should be reviewed against information in this document to ensure consistency with current laws and regulations. Waste management options must be selected based on site-specific

uids, and Steam Generator Wastes

circumstances. Because of the great diversity of geological and geograph-

ical conditions across the United States, it is recommended that oil and gas companies develop waste management plans that address their specific operations and operating areas.

Waste management plan development should include an evaluation of existing environmental conditions and current management practices, a review of all state and federal regulations, and a review and selection of appropriate waste management options (see Sections 4 and 5). Other considerations should include the safety, availability, and practicality (for example, cost and technology) of the waste management options.

The following guidelines are suggested for determining waste management options:

a. Pollution prevention options should be evaluated using the waste management hierarchy, namely:

l. Source reduction. 2. Recycling. 3. Treatment. 4. Disposal.

The options selected must be economically and techni- cally practicable. b. The probable long term fate of the waste and its constituents should be considered. c. All applicable regulations (federal, state, and local) and lease provisions should be checked. d. Waste type, volume, and location records for wastes that have been disposed onsite should be maintained. e. When wastes are disposed in offsite commercial facilities, records should be kept that document the type and quantity of the waste, method of disposal, location of disposal, date of disposal, and any other pertinent information that could prove useful in subsequent investigations to assess liability.

Waste management practices are identified in Section 5. Where appropriate, each of the following discussions is or- ganized according to the waste management hierarchy.

It should be noted that certain source reduction options such as improved housekeeping, operating practices, and facility design; spill prevention and minimization; product substitution or elimination; waste stream segregation; and purchasing and inventory control procedures could be applicable to each of the following wastes or activities. Therefore, these general options are not repeated or discussed individually unless specific options are identified.

In addition, the options presented in this document are not intended to be all inclusive or applicable to each E&P location. A variety of considerations including federal, state, and local regulations, lease restrictions, environmental factors, and economic and technical feasibility, are all important when selecting a waste management option (see Appendix A).



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6.2 PRODUCED WATER

The primary environmental issue in managing produced water is the potential for contamination of soil and sources of usable water.

The quantity of water produced depends on the recovery method, the nature of the formation being produced, and the length of time the field has been producing. Generally, the ratio of produced water to oil or gas increases over time; it may exceed 90 percent of the total produced volume.

The total dissolved solids (TDS) in produced water ranges from several hundred parts per million to over 150,000 ppm. Seawater by contrast is typically about 35,000 ppm TDS.

Produced water may also contain trace quantities of petroleum hydrocarbons and naturally occurring metals. It can also contain trace amounts of additives necessary for the production process. These include coagulants, corrosion inhibitors, cleaners, dispersants, emulsion breakers, paraffin control agents, reverse emulsion breakers, and scale inhibitors.

As described in Section 4, produced water injected for enhanced recovery is not a waste, and produced waters des- tined for disposal are defined by the EPA as an exempt waste.

Source reduction options include the following:

a. Drilling and completing wells to minimize water production (for example, horizontal wells). b. Using downhole fluid separation techniques or water shut-off (blocking) techniques. c. Reperforating wells to minimize water production. d. Minimizing the volume and toxicity of the treatment chemicals that may end up in the produced water.

Probably the most common form of recycling for produced water is injection for enhanced recovery.

Most produced water is highly saline. However, levels of chlorides and other constituents in produced water can be low enough that certain regions allow the water to be used for beneficial purposes, such as crop irrigation, livestock or wildlife watering, and groundwater recharging.

Other recycling options include use for hydrotesting pipelines and equipmenthanks and desalination for other uses if water supplies are scarce and the process is cost effective.

Treatment options for produced water will vary by location and the ultimate disposition. Options include combina- tions of gravity and/or mechanical separation and chemical treatment. These are further discussed in Section 3.

The following practices may be used for managing produced water depending on its constituents; the presence of usable groundwater or surface waters; geography; and local, state, and federal regulations:

a. Underground injection. Underground injection is a uni- versally acceptable practice that returns produced waters to subsurface reservoirs that are isolated from Underground

Sources of Drinking Water (USDWs). This practice is regulated under the Class II injection well program of the UIC regulations as authorized by the Safe Drinking water Act. Most produced water is managed in this manner. b. Discharge to water. Discharge to surface water is allowed in certain circumstances. It is governed by the NPDES program of the Clean Water Act and/or individual state programs. All discharges must comply with these regulatory provisions. This option is rarely used onshore. c. Discharge to land. The use of percolation or evaporation is allowed in areas where freshwater is not present or is located such that contamination from produced waters cannot occur. This option is rarely used.

6.3 DRILLING WASTES

6.3.1 General

The largest volume of drilling-related wastes is used drilling fluids or muds. Composition of modern drilling fluids can be quite complex and varies widely, not only across geographical areas but also by depth of the well. Muds fall into three general categories:

a. Water-based muds, which can be made with fresh or saline water and are used for most types of drilling. b. Oil-based muds, which can be used when water-sensitive formations are drilled, high temperatures are encountered, differential pipe sticking occurs, or when it is necessary to protect against severe drill string corrosion. c. Synthetic muds, which may be used as substitutes for the above muds or in other specialty situations.

Drilling muds contain four essential parts:

a. Liquids-water, oil, synthetic materials, or varying com- binations. b. Active solids-the viscosity-building part of the system, often bentonite clays. c, Inert solids-the density-building part of the system, such as barite. d. Other additives to control the chemical, physical, and biological properties of the mud.

These basic components perform various functions. For example, clays increase viscosity and barium sulfate (barite) acts as a weighting agent to increase mud density. This helps control subsurface pressures. Lime and caustic soda increase alkalinity. Additional conditioning materials may include polymers, starches, lignitic material, and various other chemicals.

EPA considers used drilling muds to be RCRA-exempt waste.

Cuttings consist of inert rock fragments and other solid materials. They are produced from geologic formations encountered during the drilling process. They must be managed as part of the content of the waste drilling mud. Other



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materials, such as sodium chloride, are soluble in freshwater and must be considered during disposal of drilling muds and cuttings.

Drill cuttings are also considered RCRA-exempt waste. Efforts should be made to reduce the volume and toxicity

of drilling wastes. Reducing the amount of excess fluids in- troduced into a reserve pit will enable the use of smaller pits and minimize the amount of material to be managed.

Substituting less toxic products and additives (for example, elimination of hexavalent chrome and replacement of formaldehyde with less toxic compounds) when preparing the mud system will increase the likelihood that onsite closure and disposal techniques can be used. This practice will also increase the number of management options available. In certain instances, drilling mud mixed with slag can be used as a substitute for cement. With this practice, not only is the volume of mud requiring disposal minimized, but a by- product from another industry is used as feedstock in the process.

Segregation of waste streams is another important method of reducing the volume of waste generated. Nonexempt and potentially hazardous wastes (such as, paint, lube oils, and solvents) should not be placed in reserve pits. Their introduction in reserve pits is illegal.

Drilling personnel should gather these wastes and store them in labeled, leak-proof containers in accordance with applicable state and federal regulations. Time limits for storage

Where practical and appropriate, drilling pads should be designed and constructed to collect storm water runoff and rigwash from all areas impacted by the drilling operation. At a minimum, these waters should be drained to the reserve pit. Storm water from outside the drilling pad area should be directed away from the operational area.

Drilling operations should be designed so that lubricating oil and chemicals are segregated for disposal and do not enter the reserve pit, except in upset or emergency conditions. Any lubricants and product spills that do reach the reserve pit should be removed as soon as possible. Liners may be required to prevent hydrocarbon and salt contamination of soil and groundwater.

Where it is necessary or more appropriate to construct reserve pits above ground level (thereby making location drainage directly to the reserve pit unfeasible), a small sump pit should be constructed. Fluids accumulated in the sump pit should be removed periodically. The sump pit should be lined, if necessary, to protect groundwater from contamination due to oil- or saltwater-based muds.

General good housekeeping practices (for example, spill and leak prevention) can prevent andor reduce the volume and toxicity of the waste generated.

may apply.

Volume reduction options include the following:

a. Optimizing solids control equipment. b. Using closed systems in certain environmentally sensitive areas. c. Collecting blow-out preventer test fluids to prevent ground contamination and returning them to the system if uncontaminated. d. Using alternative mud types (for example, oil-based muds) to drill near gauge holes and thereby minimize the volume of cuttings generated. e. Using bulk and/or recyclable packagingkontainers. f. Returning unused chemicals, additives, and muds to the vendor or supplier. g. Minimizing water usage (for example, water additions to the mud system and washwater) and excess chemicals and additives.

Whenever practical, special drilling fluids such as oil- based muds or extremely high density brines should be recycled by saving them for use in other wells or returning them to service companies for reuse.

6.3.2 Reserve Pit Wastes

Reserve pit wastes should be collected and stored for proper disposal using the following general guidelines:

a. Wastes stored in reserve pits should be restricted to exempt wastes such as drilling muds and cuttings, rigwash, and spent completion fluids. Exempt and nonexempt materials should be segregated. b. Hydrocarbons and produced water encountered during drilling of a productive hydrocarbon reservoir or resulting from drill stem tests in unlined reserve pits should not be collected. Exceptions may be made in certain geographic areas, depending on location and quality of groundwater.

Temporary production equipment should be provided onsite to process these test fluids. Waste test fluids should be piped or hauled to production facilities for processing or hauled offsite to a disposal facility.

6.3.3 Drilling Rig Waste

Wastes generated from drilling rig operations include spent hydraulic fluids; used oils from engines; used oil filters; empty cement, drilling mud and other product sacks; and empty paint, pipe dope, or other product containers.

EPA does not consider waste necessary for maintenance or operation of drilling equipment, such as used oils, paint, and so forth, to be exempt wastes.

These wastes should be managed using the following guidelines:

a. Pumps and power generation equipment should have containment to collect spills, leaks, or drainage of oily fluids.

Fuel oil storage tanks should be diked to prevent spills



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and leaks from being discharged offsite. Catch basins should be provided in loading areas so that hydrocarbon spills and leaks can be properly managed.

Chemical storage areas should be surrounded with containment devices to prevent migration of spills or leaks offsite. Storm events should be considered. b. Rig equipment wastes such as used lubrication oils should be segregated from material going into reserve pits and recycled or disposed of at a permitted offsite facility. c. Efforts should be made to use pipe dope, paint, and any other chemicals or materials in their entirety. Excess quantities should remain with the rig for successive operations or be returned to the vendor. Empty buckets can be sent to a metal reclaimer or disposed of in a permitted landfill. d. Sanitary wastewater and sewage should be collected and treated prior to discharge or disposal to satisfy state and local effluent requirements. Options include using septic systems, packaged wastewater treatment units, or portable commercial containers, or hauling to a permitted sewage facility. In- jection may also be a disposal alternative.

Low-flow and low-water-use toilets, showers, and faucets can be used to minimize the volume of water to be treated. e. Domestic solid waste such as paper, garbage, and cans should be managed in accordance with state solid waste regulations and should be recycled where practicable. Hiring commercial household waste disposal companies for solid waste should be considered. f. Bulk containers should be substituted for drums and other containers when practical. If the drums cannot be returned to the vendor or a drum reclaimer and they contain a hazardous or suspected hazardous material, they should be triple rinsed, crushed, and recycled for scrap metal or sent to a permitted solid waste disposal facility.

Drum rinsate that cannot be used as originally intended or unidentified residual chemicals should be considered a nonexempt waste. Testing should be performed if necessary -

to determine the characteristics of the should be handled accordingly.

Unused chemicals should be used returned to the vendor, or treated as a cording to regulatory reauirements.

waste, and the material

at the next drilling site, waste and managed ac-

Y Y

g. Where practical, operators should ensure that well treatment equipment (pump trucks, frac tanks, and so forth) is strategically located on the drilling location so that large volume spills, leaks, and discharges may be directed to the reserve pit in emergencies. Otherwise, well treatment waste liquids should be segregated and separately contained for reuse at another well, returned to the vendor, or disposed of properly. h. Groundwater wells used in the operation must be properly abandoned to prevent groundwater contamination or con- veyed to the landowner (seek legal advice) at his request when drilling activities stop. Permits are required to drill groundwater wells in some areas.

< >

i. Paint wastes can be reduced in volume and toxicity by the following:

l. Painting less frequently. 2. Purchasing less toxic, less volatile paints and solvents. 3. Using water-based or high-solids coatings whenever possible. .4. Training operators to minimize unacceptable quality and paint waste by reducing overspray, using all of the paint mixed, keeping containers closed to prevent evaporation, ensuring that proper volumes are mixed, and minimizing solvent usage. 5. Using cleaning solvents as thinners when too contaminated for use as a cleaner. 6 . Using brushes instead of spraying for smaller jobs. 7. Ensuring that paint containers are emptied and dried prior to disposal.

Paint and solvent waste that is generated should be recycled onsite or offsite via distillation to reclaim the solvent. If this recycling option is not available, the waste can also be recycled by burning for energy recovery (for example, cement kiln or other industrial boiler or furnace). When burning for energy recovery, the waste stream is a substitute product for virgin fuels. j . The volume of filters (for example, oil and fuel) generated can be reduced by:

l . Using permanent filters that can be cleaned and reused. 2. Increasing the time between filter changes based on pressure drop, testing, and so forth rather than replacement on a routine basis. 3. Optimizing operation of equipment to minimize degradation and contamination of fluids.

The filters should be recycled and managed as discussed later under 6.9. +

6.4 WORKOVER AND COMPLETION WASTES

RCRA-exempt workover and completion wastes include well completion, treatment, and stimulation fluids; inert materials originating from downhole, such as produced sand, formation and pipe scale, and cement cuttings; and pieces of downhole equipment such as sealing elements and pumping equipment.

EPA does not consider materials necessary to maintain or operate the workover rig (such as used oils, hydraulic fluids, and paint) to be RCRA-exempt wastes.

Workover fluids are primarily freshwater- or saltwater- based fluids with additives for special purposes. Examples include acids to dissolve scale and increase permeability, biocides, surfactants to break downhole emulsions, paraffin solvents and dispersants to control formation of downhole paraffin, and propant media used in fracturing operations. Workover operations should be designed to ensure that the fluids and additives are completely spent when used.



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Waste handling considerations include the following:

a. Waste fluids generated during these operations should be collected in lined pits or tanks, unless soil or usable groundwater environments will not be adversely impacted by them. b. Exempt and nonexempt wastes should be segregated. Exempt solid waste such as produced sand, formation and pipe scale, cement cuttings, and pieces of inert downhole equipment should be collected after circulation through the rig fluid handling system to ensure that no free oil is present. c. Whenever practical, unusual or special completion fluids such as hydrocarbon-based materials or saturated brines should be handled in closed systems and recycled for future use. d. Wellbore fluids generated while pulling pipe and so forth should be properly contained and collected when possible in pits or tanks for proper storage and disposal. e. Whenever practical, waste fluids should be transported by flowline or truck to the operator’s production facilities for reprocessing with production streams. f. Workover or completion fluids should be segregated from unused commercial products or contaminated additives that would be considered nonexempt if disposed. g. The well surface location of all miscellaneous wastes should be cleaned at the end of the workover or completion operation. General good housekeeping practices can prevent and/or reduce the volume and toxicity of the waste generated.

Table 2 should be consulted for identification of other waste management options.

6.5 TANK BOTTOMS, EMULSIONS, HEAVY HYDROCARBONS, AND PRODUCED SOLIDS

Bottoms are basic sediment and water (BS&W) and other materials that collect in the bottom of treating and storage facilities. These facilities include production separators, fluid treating vessels, and production impoundments. Materials found in bottoms include accumulated heavy hydrocarbons, solids, sand, and emulsions. In the same category as tank bottoms are pit sludges, paraffin, and pigging wastes from gathering lines.

EPA considers these materials to be RCRA-exempt wastes. The main goal in managing tank bottoms, emulsions, and heavy hydrocarbons should be to maximize hydrocarbon recovery.

Source reduction techniques that should be investigated are as follows:

a. The addition of heat to liquefy heavy hydrocarbons and paraffins, allowing their recombination with crude oil sales

streams. b. The addition of heat and/or demulsifiers to separate emulsions into produced water and saleable crude. c. The addition of heat in combination with centrifuging and/or filtration to separate crude from BS&W. d. The modification of process, equipment, or piping to prevent or reduce the creation of emulsion problems and to keep solids in suspension. e. The improvement of downhole solids control techniques to reduce the volume of solids produced. f. The prohibition of oxygen from the system to prevent the formation of iron oxides. g. The surveying of the process to identify sources of solids and emulsions and then attempting to correct any problems.

The following are other considerations:

a. For those heavy hydrocarbons that cannot be managed onsite, a number of offsite recycling, treatment, or disposal options are available.

Reclamation should be investigated first. Offsite reclaimers range from companies that only collect tank bottoms until they have sufficient volumes to sell to a refinery to those that operate small refineries. Operators should consider site selection, practices, and contractual provisions to limit potential liabilities of offsite commercial reclamation and disposal of a reclaimer’s waste.

Recycling by burning for energy recovery (that is, substituting for virgin fuel) is another option that should be considered. For example, oily sludges could be used as an alternative fuel source for cement kilns. On the other hand, produced solids with little or no oil contamination may be used as a substitute raw material (that is, source of silica) in the manufacture of cement. b. For materials that cannot be reclaimed, roadspreading should be investigated; these materials may be used as a substitute for commercial road surfacing materials. Heavy hydrocarbon materials are a primary constituent of road oil or mix. These materials are similar but should be tested for flash point, metals content, and density. They should be com- parable to those for commercial road oil or mix. Some states require permits for roadspreading, while other states prohibit this practice.

Before roadspreading, it is prudent for operators to notify state and local agencies and the landowner, consistent with lease obligations and regulations, and to document these activities by retaining records. c. Landspreading of materials containing hydrocarbons should be practiced in accordance with Section 5 and consistent with lease obligations and regulatory requirements. d. Before disposal, these wastes should be stored with proper containment (for example, in tanks, lined pits, or



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diked and lined piles) to protect soil, groundwater, and surface water. e. Emulsions that are untreatable by reprocessing through production facilities may be disposed via Class II injection wells. This should be done only when reservoir characteristics, operational factors, and regulations make this alternative feasible.

6.6 CONTAMINATED SOIL

Disposal of soil that becomes contaminated with commercial chemical products may be subject to RCRA hazardous waste regulation and CERCLA reporting requirements. Soil must be managed under RCRA Subtitle C rules if it is contaminated with a listed chemical or tests to be a characteristic hazardous waste.

As discussed in Section 4, EPA lists hydrocarbon-bearing soil as a RCRA-exempt waste. Using EPA's logic, API believes sulfur- and produced-water-contaminated soils are also RCRA-exempt.

For contaminated soil, whether exempt or nonexempt, prevention of the contamination is especially important. Proper maintenance and inspection of equipment and piping can prevent the leaks and spills from occurring. This can include cathodic protection, replacement of equipment or piping, and general good housekeeping. Impervious secondary containment (for example, drip pans, double-walled tanks and containers, liners, and so forth), high-level alarms, and leak detection equipment are also used to prevent or minimize contamination. When spills or leaks do occur, appropriate measures to stop and contain the spill or leak should be taken.

Exempt or nonhazardous-material contaminated soil that must be reclaimed to allow revegetation may be managed by any combination of the following procedures:

a. Mixture with other soils. b. Disking to promote biodegradation. c. Irrigation to leach salts. d. Other onsite treatment.

The practice chosen should be dictated by the extent of contamination, potential.for groundwater contamination, and other environmental conditions. State, local, and/or landowner approval may be required prior to initiating treatment or disposal.

Soil that must be removed from a site should be taken to a nonhazardous waste disposal facility. In the collection process, every effort should be made to remove free hydrocarbons for recycling, sulfur, and produced water.

Landspreading or roadspreading may be feasible if conducted according to Section 5.5 and applicable regulations and lease restrictions.

6.7 USED OILS AND SOLVENTS

6.7.1 General

Used oils and solvents are generated when maintaining and lubricating production, drilling, workover, and gas plant equipment. The most environmentally sound practice for managing these wastes is recycling.

6.7.2 Used Oil

Current EPA regulations allow used oil to be recycled into the crude stream, However, the following source reduction options should also be considered:

a. Extending the life of the lubricating oil by changing the oil only when dictated by testing, instead of by a routine maintenance schedule. b. Installing mechanical solids removal systems (for example, centrifuges, permanent filters, or magnets) directly on equipmenuengines to extend the oil life. c. Optimizing the operation of equipment to minimize degradation and contamination of the oil. d. Following a regular inspection and maintenance program to minimize leaks.

Other acceptable management practices are recycling or disposal of used oils and solvents at an offsite commercial facility.

A potential exception to these practices is electrical oil contained in large electrical switches, capacitors, and trans- formers, which may contain PCBs. These oils are not exempt and must be managed under TSCA regulations if PCBs are present above specified levels (50 ppm or greater and even 2 ppm or greater when burned for energy recovery). TSCA specifies storage, transportation, disposal, and recordkeeping requirements for PCB-containing oils (see 40 Code of Fed- eral Regulations Part 761).

6.7.3 Solvents

Solvent usage should be eliminated or minimized to the extent possible. Solvents that are nonhazardous (for example, nonflammable solvents) or less toxic should be purchased to increase management options. If possible, petroleum-based solvents should be recycled onsite (for example, regenerated, recycled into crude oil, or used for paraffin dissolving or cutting); one should be aware, however, that some may be considered hazardous.

Segregated solvents may also be sent to a commercial recycling or disposal facility that is permitted to accept these materials. This may include regeneration, reuse, or burning for energy recovery in lieu of virgin fuels.



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6.8 DEHYDRATION AND SWEETENING WASTE

6.8.1 General

As described in Section 4, EPA lists dehydration and sweetening wastes generated in gas plants as exempt. API believes these same wastes are exempt when generated at field facilities.

It is important to properly maintain and operate (for example, flow rate, temperature, and io forth) the dehydration and sweetening units to minimize waste and emissions.

6.8.2 Liquid Wastes

Liquid dehydration and sweetening wastes may include glycol, amine, sulfinol, caustic, or other process solutions. These solutions may be contaminated with light hydrocarbons and salts.

a. The first preference is to recycle onsite if practical. Re- turning sweetening wastes to the original product vendor or a reclaimer for commercial regeneration is a feasible offsite alternative. b. Where there is no market or capability to recycle these liquids (such as with spent caustic), they may be taken to offsite nonhazardous waste disposal sites or disposed in Class II injection wells operated under state/federal UIC regulations and permitted for such wastes. c. Water from the dehydration process should be released as water vapor or, if it condenses, disposed of via Class II injection wells, NPDES discharge, or evaporation pits. Hydrocar- bon contamination of these waters may preclude some of these disposal or discharge options.

6.8.3 Solid Wastes

Solid wastes generated from dehydration and sweetening processes consist of filter media, spent iron sponge, spent molecular sieve, andor slumes of sulfur and sodium salts.

Iron sponge consists of iron-impregnated wood chips. These react with hydrogen sulfide in the sweetening process to form iron sulfide. After the iron is consumed, the waste iron sponge is removed and kept wet to avoid spontaneous combustion. The iron sponge is then allowed to undergo oxidation prior to burial onsite.

Burial must be consistent with lease provisions and applicable regulations or it must be taken to an offsite, nonhazardous disposal facility.

While incineration of spent iron sponge is possible, it is seldom done, since iron sponge is generated infrequently and in small quantities at sites where commercial incineration facilities are generally unavailable.

State regulations on management of spent iron sponge should be consulted prior to choosing an option.

Although typically regenerated onsite, the life of molecu-

lar sieve may be extended by installing activated carbon up- stream to remove potential contaminants (for example, corrosion inhibitors, amines, and glycols).

Spent molecular sieve and solid desiccants may be used as fill material as a substitute for virgin commercial materials, buried onsite as detailed in 5.5.4, or sent to offsite disposal facilities after being drained of all liquids.

Liquids should be captured and returned to treatment facilities for recycling and treatment. Usually, slurries of sulfur and sodium salts may be landspread in accordance with 5.5.2 or disposed of offsite at a nonhazardous waste facility.

6.9 OILY DEBRIS AND FILTER MEDIA

6.9.1 General

EPA lists the following oily debris and filter media waste as RCRA exempt: spent filters, filter media, and backwash (assuming the filter itself is not hazardous and the residue in it is from an exempt waste stream). Contamination of filter media with hazardous substances may lead to CERCLA exposure.

6.9.2 Liquids

Liquids from backwashing filter media normally consist of fresh or produced water, sometimes containing a surfactant to aid in oil removal.

The most environmentally sound practice is to return these liquids to treatment facilities where free oil can be recycled and the remaining liquids disposed of with produced waters.

6.9.3 Filter Media and Filters

Solid filter media such as gravel, coal, sand, and diatomaceous earth should be treated as previously described for tank bottoms, emulsions, heavy hydrocarbons, and produced solids.

Free hydrocarbons should be removed for recycling and the resulting solids roadspread, landspread, buried, or taken to offsite disposal sites as described in 6.5.

Spent sock, cartridge, and canister filters should be recycled by burning for energy recovery in lieu of virgin fuels and by sending the metal portions to a metal reclaimer.

If they cannot be managed onsite, the filters may be sent to municipal or commercial landfills, after being drained to remove free liquids. It should be noted that some states have recently banned used oil filters from municipal landfills.

Any recovered liquids should be returned to the treatment facilities for reprocessing and recycling.

Oily wastes such as hay and sorbents used in water treatment and produced fluid spill cleanup, may be burned for energy recovery or incinerated with state air control agency approval.



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6.10 GAS PLANT PROCESS AND SULFUR cess also generates wastewater. RECOVERY WASTE Sulfur dioxide concentrations in stack gases must be re-

Gas plants and production operations produce many of the same wastes. For similar wastes refer to the sections on dehydration and sweetening (6.8); used oils and solvents (6.7); and tank bottoms, emulsions, heavy hydrocarbons, and produced solids (6.5).

Generated wastes include the following:

a. Lubrication oils, which should be recycled and managed according to 6.7. b. Wastewaters, which should be recombined with produced waters (for example, injection for enhanced recovery or disposal). c. Spent or degraded absorption oil, which should be reclaimed where possible by sending it to a reclaimer or returning i t to the vendor. If no other outlet is available, it should be disposed of in a Class II injection well. d. Cooling tower and boiler blowdown water, which should be disposed of in Class II injection wells (for example, enhanced recovery or disposal), NPDES discharge, or evaporation pits.

RCRA-exempt liquid wastes should be collected in plant sump systems where washwaters, nonhazardous lubricating oils, cooling waters, and run-off are typically collected via a series of sumps into a central clarifier/classifier pit.

Sumps and clarifier/classifier pits are process vessels and should always be maintained in leak-free condition. These pits separate the hydrocarbons from produced water, which is disposed via Class II injection wells or NPDES discharge. Hydrocarbons should be managed according to 6.5.

Sumps and clarifier/classifier systems should be used wherever justified to minimize disposal of reclaimable hydrocarbons.

Other RCRA-exempt solid wastes such as filters, catalyst, and oily debris should be drained if necessary, returning fluids to a sump or clarifier/classifier pit and recycling solids, disposing of them onsite via landfill or burial consistent with regulations and landowner obligations, or sending them offsite to municipal or commercial landfills. Certain catalysts may be recycled to reclaim precious metals or may be used as a raw material in the manufacture of cement.

I 6.11 COOLING TOWER BLOWDOWN, BOILER

STEAM GENERATOR WASTES I WATER, SCRUBBER LIQUIDS, AND

Water used in boilers and cooling towers eventually becomes contaminated with salts and must be supplemented over time. These waters are blown down or bled off for disposal. In addition, some waters used in boilers and most water used in thermally enhanced oil recovery (TEOR) steam generators must be softened before use in the steam generation process to prevent scale formation. This softening pro-

- moved to reduce emissions in some areas of the country. These sulfur oxides are often scrubbed using a slightly caustic solution [flue gas scrubber waste is exempt by regulation-see 40 Code of Federal Regulations Part 261.4(b)(4)].

Last, in cogeneration TEOR steam generators, deionized water is used to reduce nitrogen dioxide in stack emissions. The production of deionized water generates two waste streams: excess deionized water and blowdown from the deionization process. (See Section 4 for additional details regarding TEOR steam generators and their associated air pollution and water softening equipment.)

All of the above waters may be (a) injected into Class II wells alone or commingled with produced water prior to injection for enhanced recovery or disposal; (b) placed into evaporation pits; (c) discharged under a state and/or federal NPDES Permit.

Whatever disposal method is used, it must be done in compliance with state and federal regulations and to protect sources of drinking water.

It should be noted that, as described in Section 4, EPA considers wastes generated from the operation and maintenance of facilities such as cleaning compounds, refractory bricks, and so forth to be nonexempt.

6.12 DOWNHOLE AND EQUIPMENT SCALE

During the production process, scales may form within wellbores and production equipment due to temperature and pressure changes. Scale usually consists of barium sulfate, iron sulfide, calcium carbonate, or other inert materials.

Scale formation can be prevented or minimized by not mixing incompatible, scale-producing waters and by using scale inhibitors.

a. As discussed in Section 4, scales that are formed on the process side within segments of tubing, piping, or heat exchangers containing wellbore fluids are the result of primary field operations and are exempt waste. b. Scale formed in production equipment on the nonprocess side, such as in boilers, should be considered nonexempt waste. c. Production scale (that is, from process equipment) should be checked for the presence of NORM (see 6.20).

Management practices for scale that does not contain NORM should include the recovery of any free oil and landspreading or burial as described in Section 5. Alternatively, if onsite disposal is precluded by lease or other restrictions, the waste should be sent to offsite landfills.

6.13 STORM WATEWRIGWASH

Facilities should be constructed to allow segregation of rigwash and storm water in areas impacted by the operation



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from uncontaminated storm water (that is, runoff from areas not impacted by the operation). Since storm water can become contaminated upon contact with leaks and spills, good housekeeping practices; spillfleak prevention, containment, and cleanup procedures; and proper management of storm water run-on are important to minimize contamination. Cov- ering the facilities or potential sources of contamination is another minimization option.

Where feasible, these waters should be collected for use or reuse (for example, equipment washing, makeup water for drilling or completion operations, and agricultural purposes).

6.14 UNUSED TREATMENT CHEMICALS

Efforts should be made to plan an operation in a way that minimizes the volume of unused chemicals.

a. The system should be tested to ensure that the chemical treatment is needed and is working. b. Operating and inventory control procedures should be established to ensure that only the proper amount of chemicals are purchased and then used in a timely fashion. c. Unused treatment chemicals should be returned to the supplier, stored, or used at another suitable site. d. They may also be sold to other companies or industries with appropriate applications.

6.15 ASBESTOS

Any activity involving asbestos materials must be conducted to minimize exposure to personnel and the public. Ef- forts should be made to identify and label, per OSHA regulations, all sources of asbestos within a given facility.

a. Asbestos is a hazard when it becomes friable. Therefore, efforts should be made to ensure that the asbestos does not become friable (that is, it should be kept covered or sealed so that it does not become a waste or a hazard). b. If it is impossible to prevent the asbestos from becoming friable, an individual trained and certified in both removal and disposal techniques should remove it. c. Asbestos is not a hazardous waste, but its disposal is subject to TSCA requirements. More specific state regulations can also apply.

6.16 USED BATTERIES

6.16.1 General

Rechargeable and recyclable batteries should be purchased whenever feasible, and used batteries should be returned to the manufacturer, to vendors for exchange, or to a reclaimer for recycling.

Batteries that are no longer needed, but are not spent, should be used at an operation where they are needed. Used

batteries should be stored in a manner that prevents any spillage of electrolyte.

6.16.2 Recyclable

Both lead-acid and nickel-cadmium batteries are examples of used batteries that are hazardous and can be recycled.

a. Generators of lead-acid batteries are specifically exempt from RCRA hazardous waste generation regulations, provided the batteries are recycled. b. Spent nickel-cadmium batteries, even if recycled, are still subject to hazardous waste regulations.

6.16.3 Nonrecyclable

Used alkalis and lithium batteries are examples of batteries that are typically not recycled. These batteries may be hazardous and must be disposed of properly according to applicable regulations. These batteries should be substituted with recyclable batteries, if feasible.

6.17 PCB TRANSFORMER OIL

PCB fluids are regulated under the Toxic Substances Con- trol Act in 40 Code of Federal Regulations Part 761. These regulations apply to the use, storage, servicing, disposal and recordkeeping for PCBs and items containing 50 ppm or more of PCBs. Equipment should be properly maintained and operated to prevent leaks. Depending on the level of PCBs, most PCB-containing equipment can remain in service unless leaking.

a. Waste oils containing PCBs in quantities of 50 ppm or greater must be disposed at a TSCA-permitted disposal facility. b. Spills of PCB-containing oils are subject to specific cleanup standards and should be reported to federal, state, and local agencies. c. Capacitors, electrical switches, and other equipment containing PCBs would similarly be subject to the above TSCA requirements.

6.18 NON-PCB TRANSFORMER OIL

Materials containing less than 50 ppm PCBs are excluded from the TSCA regulations if the following conditions are met: (a) The PCBs were legally manufactured, processed, or distributed in commerce or used before October 1, 1984, and (b) The less-than-50-ppm concentration is not the result of dilution or the cleanup of leaks and spills.

State and local agencies should be contacted regarding cleanup standards.

a. Use of waste oil with any detectable concentration of



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PCBs as a sealant, coating, or dust control agent is prohibited. In other words, this oil cannot be applied to the land. b. Recycling of used oil with any quantifiable level (that is, 2 ppm or greater) of PCBs must be in accordance with 40 Code of Federal Regulations Part 761.20(e), which may include recycling into the crude oil (with refinery approval). C. Used oil with less than 2 ppm PCBs should be recycled into the crude oil-also with refinery approval.

6.19 EMPTY OIL AND CHEMICAL DRUMS

Where practical, bulk containers that are reusable should be used in order to prevent unnecessary generation of empty drums. However, when drums are required, every attempt should be made to minimize the amount of residual material remaining in a drum. Attempts include the following:

a. Return of the drum to the original supplier is the preferred management option, followed by recycling at a drum recon- ditioner or as scrap metal. b. The drums should be well rinsed and washed (that is, with an appropriate material) before sending to a waste metal/plastic recycler or disposal site. c. Rinsate materials should be used as originally intended in the process or properly handled and disposed of.

6.20 NATURALLY OCCURRING RADIOACTIVE MATERIAL

Naturally occurring radioactive material (NORM) may be present in oil and gas operations at some locations. NORM may be found in downhole tubing, as well as in aboveground processing equipment; saltwater disposal/injection wells and associated equipment; soils contaminated as a result of well workovers, tank cleaning, and saltwater leaks; and pipe cleaning and other associated operations.

In production facilities, water-handling equipment exhibits the greatest NORM activity levels. The NORM activity level in pipe scale can range from background levels to thousands of picocuries/gram, while NORM activity in oilfield sludges ranges from background levels to several hundred picocuries/gram, depending on the location. Con- sult API Bulletin E2, Bulletin on Management of Nutu- rally Occurring Radioactive Materials (NORM) in Oil & Gas Production for more detailed guidance on NORM and its prevention, handling, storage, transportation, and disposal.

As of the publication date of this document, no federal regulations directly apply to the disposal of oilfield NORM. This is primarily a state issue. Some states (i.e., Texas, New Mexico, and Louisiana) have developed regulations for NORM disposal, some states are currently developing regulations, and others are prohibiting disposal until regulations

are adopted. It is recommended that operators consult applicable state

and local regulatory agencies, as well as lease or landowner agreements, before disposing of NORM. It is also recommended that operators maintain records of types, volumes, analytical data, destinations, and haulers of NORM wastes.

6.21 GEOLOGICAL AND GEOPHYSICAL OPERATION WASTES

Geological and geophysical operations associated with the exploration for oil and gas are conducted throughout the world in a variety of environments, some sensitive. There- fore, steps should be taken to minimize the direct and indirect impact of exploration operations on these areas. These include the following:

a. Reducing the amount of waste generated by such operations. b. Recycling those wastes that are generated. c. Properly handling and disposing of the waste once the operations have been completed.

Refer to the Environmental Guidelines for Worldwide Geophysical Operations by the International Association of Geophysical Contractors for more complete detail.

Remote sensing and aerial geomagnetic surveys can provide useful subsurface information for the interpretation of geologic structures without disturbing or harming the environment. Such methods are particularly appropriate over national parks and other protected areas where surface access may be restricted. Such nonintrusive methods should always be considered when designing an exploration program to minimize the environmental impact and amount of waste generated by exploration activities.

6.22 RECOMPRESSION AND FACILITY UTILITY WASTES

Liquid wastes should be disposed of via the facility sump system where washwaters, lubricating oils, cooling waters, and so forth are typically collected via a series of sumps. Fluids are usually collected from the sumps into a central oiYwater separator. There, water is removed for disposal in Class II injection wells (for example, enhanced recovery or disposal), NPDES discharge, or evaporation pits.

a. Hydrocarbons are recycled by returning them to sales streams. b. If sales streams are not available, the hydrocarbons should be sent to waste oil collection and reclamation facilities. c. Other solid wastes, including filters, should be recycled or disposed as described earlier in this section and in Section 5 .



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Appendix A-Guidelines For Developing Area-Specific Waste Management Plans

A.l INTRODUCTION A.2 A TEN-STEP PLAN FOR WASTE MANAGEMENT

While many processes can aid in shaping waste management decisions into action steps, area-specific waste man- A solid waste management plan is an area-specific docu- agement plans have worked for many API member ment identifying the appropriate waste management practice companies. (See Table A- 1 for the Ten-Step Plan for Prepar- for each type of waste generated in E&P operations within ing a Waste Management Plan and the summary in Section the company. (The formal plan could be expanded to include 2.) The following sections outline this approach. multiple companies operating within the same area or mul-

tiple divisions of the company working in the same area. It could even become a state plan for the specific area.)

~~

Table A-1-Ten-Step Plan for Preparing a Waste Management Plan ~

Stet, Action

l . Obtain Management Approval

2. Define Plan’s Area

3. Identify Wastes

4. Perform Regulatory Analysis

5 . Categorize Wastes Generated

6. Plan Waste Minimization Practices

Establish goals Develop a mission statement Define key personnel and resources

Choose area within one state (generally) Choose area with similar regulations Choose area within a certain type of operation

Determine all pertinent wastes generated within plan’s area Complete a brief description for each type of waste Determine volumes and frequencies of waste generation

Evaluate federal, state, and local laws and regulations Evaluate landownerflease agreement restrictions Define operating conditions and requirements

Exempt Nonexempt hazardous Nonexempt nonhazardous

Volume reductiodminimization analysis Toxicity reduction Recycle, reclaim, reuse Implement procedures to reduce waste generation

7. List and Evaluate Waste Management and Disposal Options List all allowed waste managernent and disposal options Determine which options have acceptable environmental consequences Consider other issues such as regulatory restrictions, engineering limitations,

operating feasibility, and economics

8. Select Preferred Waste Management Practices

9. Prepare and Implement Plan

IO. Review and Update Plan

Choose best practice for area’s operation & location Implement any new or modified practices Provide specific instructions for selected practice

Compile all preferred waste management and disposal options Write management summaries for each waste Implement the plan on a field level

Establish a procedure to periodically review plan Evaluate new or modified waste management practices Revise plan as necessary

Note: E&P exemption applies only to RCRA Subtitle C. Exempt wastes are subject to RCRA Subtitle D and may be subject to UIC, NPDES, CERCLA, and so forth. Many of these steps can be done concurrently (for example, Steps 3 & 4, Steps 6 & 7). As the wastes are identified, the particular laws and regulations that apply to each can be reviewed.

49



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The plan, which should be written from the field perspec- tive, defines specific guidance for handling each waste generated in the area. To develop it, an E&P facility or company should use the ten general steps outlined below. The acceptable waste management practices for each type of waste should be defined through this evaluation process. On execu- tion, the area-specific waste management plan can be used for the following purposes:

a. Ensuring ongoing regulatory compliance and continued protection of the environment. b. Conducting ongoing training of field personnel. c. Evaluating and monitoring waste management practices. d. Minimizing the volume and toxicity of waste produced (that is, waste minimization/pollution prevention).

The waste management plan should be an evergreen document, subject to periodic review and revision. For example, new waste management practices or options should be evaluated whenever they become available and the plan should be revised, as appropriate.

The following sections provide more detailed information on each step of the process.

Step l . Management Approval

Obtain management approval and support:

a. To develop an area-specific waste management plan, management approval and issues involving key personnel, other resources, and scheduling should be resolved so that management can support the timing and scope of the project. b. The overall project goal should be set, and measurable objectives should be established. If the company does not have an environmental mission statement, one should be considered. In any case, a mission statement should be developed for the Waste Management Plan.

output: Waste Management Plan mission statement, goals, and

objectives.

Example: Company X is committed to running its operations in an

environmentally sound manner. The company intends to have waste management plans developed for each of the areas in which it operates by January 1, 19XX.

Step 2. Area Definition

Describe the area for the plan:

a. The waste management plan is area-specific. The key to defining an area is consistency in both regulatory and environmental issues. Therefore, a relatively small area is recommended for the initial waste management plan (for example, an oil field, a unit, or a lease). Small operations may prefer to begin with a larger area such as a state or a district within a state.

b. Later, the plan for a small area may be expanded to cover a larger area by incorporating the different types of wastes generated in the larger area. Since application of regulations must be consistent within a given waste management plan, the area of coverage is generally within one state and, in some cases, even within one county/parish. Note: Although many types of E&P wastes are similar, individual waste management plans are not necessarily transferable, since regulations and/or the environment vary from one location to another.

output: Description of (a) the area, and (b) the E&P activities to

be controlled by the waste management plan.

Example: The plan is developed for the Sable Field in West Texas.

Step 3. Waste Identification

Identify each waste generated:

a. Field personnel should identify all wastes generated within the area defined for each E&P activity (that is, production, drilling, completion/workover, and gas plants). b. Complete a brief description for each waste (for example, source(s), percent oil and/or saltwater content, and approxi- mate volume).

output: List of wastes, with a brief description of each.

Example: Field Production:

Produced water [ 10,000 ppm Total Dissolved

Tank bottoms [8 percent hydrocarbons (HC)] Drilling Operations:

Mud and cuttings (water-based) Cement returns

Solids (TDS)]

CompletionsMrorkovers: Spent hydraulic fluids (from rig) Spent acid [ 15 percent hydrochloric acid (HCI)]

Gas Plants: Used filters (lean oil) Spent amine

Step 4. Regulatory Analysis

Complete regulatory analysis:

a. Review applicable federal, state, and local laws and regulations to determine the types of wastes (for example, produced water, drilling mud, etc.) for which waste management and disposal requirements are clearly defined. b. For a plan with a restricted focus, review lease provisions to determine what, if any, landowner restrictions and/or preferred waste management practices are specified that may re-



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strict options allowed by regulations. c. Identify any waste types for which the regulations do not adequately define management requirements. This analysis will identify the waste types that are not adequately addressed in the regulations and for which additional guidance is required.

output: List of wastes and their operating stipulations, conditions,

and requirements.

Example: msk PracticelReauirementS

Low chloride Landfarming,

Completiordworkover Burial onsite after waste Pit waste de-watered, injection, etc.

Cooling tower Discharge injection, etc.

drilling fluid burial onsite, etc.

blowdown

Step 5. Waste Classification

Categorize each identified waste:

a. Determine if each waste is classified as exempt or nonexempt under RCRA or regulated as a special waste under some other authorization (for example, regulated under TSCA, identified as NORM, etc.). b. For nonexempt wastes, determine if each is nonhazardous or hazardous. c. You may have to test periodically if the waste composition varies.

output: Categorized list of wastes with waste classification iden-

tified.

Example: Exempt:

Produced water Drill mud

Nonexempt: Hazardous

Unused fracturing fluids or acids Waste solvents

Nonhazardous Empty drums and chemical sacks Refuse

Unknown (Hazardous or nonhazardous -requires periodic testing)

Other Painting wastes Vacuum truckldrum rinsate from nonexempt wastes

Step 6. Waste Minimization

Review the waste generating processes and implement procedures to reduce waste generation:

a. In order to find source reduction alternatives, it is important to understand how and why each waste is generated. Re- view the waste generating processes and options. Identify potential opportunities to reduce or eliminate waste volumes through volume or toxicity reduction, recycling and reclaiming, andor treatment. Priority should be placed on reducing those waste streams that may pose the highest potential risk. b. When a potential waste minimization practice arises, perform a pilot test and evaluate. c. Implement any waste reduction practices identified and revise the waste management plan accordingly.

Output: Testing and evaluation of any potential waste minimiza-

tion practices. Implement practices, as appropriate.

Example: Reduce the volume of contaminated soil by increasing the

use and maintenance of drip pans under the valves that could leak oil.

Substitute a chemical product with lower environmental risk constituents to eliminate a waste that requires special handling.

Step 7. List and Evaluate Waste Management and Disposal Options

a. After reviewing the waste generating processes and taking advantage of source reduction opportunities, list potential waste management options for each waste. h. Determine each option’s acceptability for that area’s environment. c. For each waste with more than one waste management practice allowed by law or regulation, list the management and disposal options potentially available (see Section 6) . This evaluation should target only the options available and under consideration. d. Evaluation should include regulatory restrictions, environmental considerations, location, engineering limitations, operating feasibility, economics, and potential long term liability. e. The list of acceptable waste management practice options and desirability of each should be reviewed by appropriate operations personnel and management.

output: List and evaluation of environmentally acceptable waste

management practice options for review by field personnel and management.



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Example: Spent iron sponge disposal options: a. Burial onsite after complete oxidation.

Pros: Most cost effective Cons: Landowner concerns

Pros: Flexibility in selecting disposal location Cons: Future liability potential

b. Disposal at an offsite nonhazardous disposal facility.

Step 8. Select Preferred Waste Management Practice(s)

Select a waste management option for each waste:

a. From the evaluation of waste management and disposal options, select the best practice for that operation and location. Through this process, operations personnel may justify several of the current waste management practices. b. Implement any new or modified practices.

output: Implementation of these practices.

Example: Dispose spent iron sponge at the Keep Clean Landfill, a

nonhazardous disposal facility, in Small Town, Texas. Prior to removal from the site, ensure that the iron sponge is completely oxidized.

Step 9. Prepare and Implement An Area-Specific Waste Management Plan

Develop and implement the plan:

a. Compile the preferred waste management and disposal options (as developed in Step 8) for each waste found in a given operating area into one comprehensive, area-specific waste management plan. b. Summarize the recommended waste management practices in concise documents for use at the field level. Describe only those wastes generated by the operations in that specific area or within an operator’s responsibility. c. For each waste, describe the waste and the designated waste management and disposal practice.

These summaries will be used to define the waste management practices for which an individual operator will be accountable and as the basis of training programs.

output: An area-specific waste management plan. A summary list-

ing the designated waste management practice for each waste identified.

Example: Gas Plant Operator:

unit: To dispose of spent filters from the lean oil absorption

a. Backwash and return liquids to treatment facilities. b. Drain free liquids. c. Collect and store in clean, labeled, and covered drums. d. For final disposal, send to “Look Nice Commercial

e. Maintain file of shipping records. Landfill.”

Step 10. Review and Update Waste Management Plan

Define a review and update procedure for each waste management plan, ensuring that the plan is modified as appropriate:

a. Effective waste management is an ongoing process. New waste management practices or options should be evaluated whenever they become available, and the plan should be revised accordingly. Establish a procedure to review and update the waste management plan, as appropriate. (At a minimum, periodic review of the plan should have an established frequency.) b. The types of issues that may trigger a review of the plan are as follows:

l. New waste minimization techniques. 2. The availability of new technologies that can be applied to waste management practices. 3. Applicable information which will reduce the company’s future liability.~ 4. A change in the type, volume, or toxicity of the waste being generated.

c. Implement modified practices and revise the waste management plan as new or modified practices are defined. Through this ongoing process, your company will always strive for the best method of handling the wastes generated in each area.

output: Periodic review of the waste management plan and imple-

mentation of the revised designated practices.

Example: The best available technology for treating spent acids

from workover operations is neutralization, which will be implemented March 1 , 19XX.

Recently received information indicates that “Keep Clean Landfill” is currently under enforcement action by the state; therefore, to reduce the company’s potential liability, use the “Look Nice Commercial Landfill” for future disposal of nonhazardous wastes.

(See Appendixes B and D and reference materials for an example of a plan for a specific waste that can be used in developing waste management plans.)



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A.3 RESOURCES TO DEVELOP WASTE waste management practices. MANAGEMENT PLAN b. Environmental professionals should be available as advi-

The most effective waste management plan is developed with the ultimate end users-field personnel-in mind. However, a variety of personnel within the company will have valuable experience to contribute. It is suggested that the following personnel also be included:

a. Operations personnel. b. Operating environmental professionals. C. Engineering staff. d. Technical advisors from support staff.

These personnel bring numerous resources to the team:

a. Field or operations personnel (for example, production foreman, company man, or gas plant operator) are key to the development process. They know the operations, current waste generation sources, and handling practices at the site

I of interest and will be responsible for implementing any new

sor(s) and may act as facilitator(s) to the regulatory analysis and planning process to assure that specific regulatory requirements are met for each waste. c. Engineering staff, knowledgeable in the processes at a given location, can provide information, design/operational options, and additional data that may be important for evaluating the feasibility of the acceptable waste management options. (An onsite engineer or an engineer dedicated to that operation/area would provide the best insight.) d. Safety and environmental support staff and drilling and production operations groups can provide technical advice during the process of developing the plan. They can facilitate information transfer to other areas that are developing waste management plans. e. Outside consultants can be recruited to provide selected expertise or prepare the entire plan(s).



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Appendix B-Waste Management Planning Aids

The following is an example of a Waste Management Field Manual outline. It can be used as a model in developing a custom program for your company.

Waste Management Field Manual Table of Contents

1. Introduction Waste Management Program . . . . . . . . . . . . . . . . . l - 1 How to Use This Manual . . . . . . . . . . . . . . . . . . . .l-2

2. Waste Management Policy Environmental Policy ...................... .2- 1 Pollution Prevention ...................... .2-2 Health and Safety and Waste Management . . . . . .2-3

3. Waste Classifications Texas Waste Classifications . . . . . . . . . . . . . . . . . .3- 1 RCRA Exempt and Nonexempt Classifications . .3-3 Guidelines for Nonexempt Classifications . . . . . .3-4

4. Transportation Requirements Overview of DOT Requirements . . . . . . . . . . . . . .4-1 Materialmaste Documentation . . . . . . . . . . . . . . .4-3 Hazardous Materialmaste Manifesting . . . . . . . . .4-4 Nonhazardous Materialmaste Manifesting . . . . . .4-6 Shipping Orders .......................... .4-8 I

Inserts: I Hazardous Materials Warning Labels and Placards

Texas Water Commission (TWC) Uniform

Nonhazardous Waste Manifest Shipping

Hazardous Waste Manifest

5. Management and Disposal by Waste Material Overview Cross Reference Aerosol Cans

Asbestos Batteries, Lead-acid Blowdown, Swabbing, and Bailing Wastes Caustics Cement Chemical Toilet Waste Chemicals, Surplus Chemicals, Unusable Condensate Debris, Chemical Contaminated Debris, Crude Oil Soaked Debris, Crude Oil Stained Debris, Lube Oil Contaminated Debris, Uncontaminated Drilling FluiddCuttings

i Amines

DrumsiContainers, Containing Chemicals DrumsiContainers, Containing Lube Oil DrumsiContainers, Empty Filters, Lube Oil Filters, Process Glycol Hydraulic Fluids Iron Sulfide Scale and Iron Sponge Mercury, Liquid Metal, Scrap Methanol NORM Oil, Lube Oil, Slop Oil, Weathered Paint Paraffin PCBs Pesticides and Herbicides Pigging Wastes Pipe Dope Plastic Liners Produced Water Sandblast Material Soils, Chemical Contaminated Soils, Crude Oil Contaminated Soils, Lube Oil Contaminated Soils, Mercury Contaminated Soils, PCB Contaminated Solvents SulfachecWChemsweet Waste Tank Bottoms and Basic Sediment Thread Protectors Vacuum Truck Rinsate Well Completion, Treatment, and Stimulation Fluids,

Unused

Appendixes l . Violation Penalties Table 2. Health, Safety, and Environmental Contacts 3. EPA and State Generator ID Numbers 4. State-Permitted Transporters 5. State-Permitted Disposal or Recycle Facilities 6. Onsite Waste Storage

7. Analytical Laboratories 8. Terms

Insert: Drum Label for Hazardous Waste

Acronyms and Abbreviations Glossary

The following table is a sample excerpt from The Waste Management Field Manual:

55



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Table B-1-Iron Sulfide Scale and Iron Sponge

Description

Special Handling

Onsite ManagementIDisposal

Offsite ManagementDisposal

DOT Requirements

Recordkeeping

Iron sponge is used on a limited basis to remove hydrogen sulfide from the gas stream. Iron sponge is a coating of iron oxide on wood chips or other carriers. It reacts with hydrogen sulfide and sulfur. Iron sulfide may be present in tank bottoms and may be associated with well stream fluids and production systems.

WARNING: Dry iron sulfide and iron sponge will auto-ignite; in confined space, with adequate oxygen, it may explode.

WARNING: Contact with acid will release hydrogen sulfide.

Always keep it wet. Spread iron sponge out on bare ground in an open, fenced area. Allow a minimum of 1 week for material to oxidize and cool to air temperature before

Do not mix with acid or acidic water. transporting offsite.

No onsite disposal. For temporary storage on the ground, see Special Handling above

None required unless it auto-ignites; contact your compliance coordinator to determine appropriate DOT requirements.

Use Nonhazardous Waste Manifest; keep in permanent file in area office. Must record the following:

Volume/weight of waste Name of leaselsite

9 Leaselsite location (nearest town) Name of transporter Date of transport

9 Name of disposal/receiving/recycling facility 9 Date of receipt by facility

Disposal Alternatives Send to approved, state-permitted disposal facility

Waste Category RCRA: Exempt Texas: Class I Industrial Nonhazardous

State-Permitted Transporters Any transporter with RRC permit and MWA.

State-Permitted Disposal or Recycle Facilities Marashi’s Mud Disposal Services 1905 Marashi Boulevard Marashi, Oklahoma 37337 9501555-2744

Borgnas Disposal, Incorporated 2000 Borgnas Lane Medicine Bow, Wyoming 28746 9501555-2674

Waste Reduction Consider alterative methods of removing hydrogen sulfide from gas stream.

Treat production streams with biocide or scale inhibitor to reduce iron sulfide formation.



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APPENDIX >SUMMARY WASTE TABLE

L I I I

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Appendix D-Summary Of Environmental Legislation And Regulations

The following table summarizes key federal legislation

E&P operations are impacted by a number of federal,

Since the early 1970s, the number and magnitude of envi-

The federal laws summarized in this section are only those

In addition to these and other federal regulations, states

and regulations, described in detail in Section 4.

state, and local environmental laws and regulations.

ronmental requirements have increased significantly.

that have the greatest impact on E&P operations.

also have environmental requirements that will affect E&P sites.

Local governments, such as counties or cities, may also impose requirements.

Lease agreements, landowner agreements, or other con- tracts may impose additional requirements. Operators must be aware of the various levels of regulations and ensure that necessary permits and approvals are obtained before operations begin.

Table D-1-Summary of Key Legislation and Regulations

Statutes Purpose Date Enacted

Resource Conservation and Recovery Act (RCRA)

Safe Drinking Water Act (SDWA)

Clean Water Act (CWA)

Clean Air Act (CAA)

Toxic Substances Control Act (TSCA)

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) or Superfund

Superfund Amendments and Reauthorization Act (SARA)

Oil Pollution Act (OPA) of 1990

National Environmental Policy Act (NEPA)

Federal Land Policy and Management Act (FLPMA)

Endangered Species Act (ESA)

Federal O&G Royalty Management Act (FOGRMA)

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)

Hazardous Materials Transportation Act (HMTA)

Naturally Occumng Radioactive Materials (NORM)

Requires EPA to set up procedures for identifying solid wastes as hazardous or nonhazardous and issue requirements for their management.

Underground Injection Control Public water systems

Controls point source discharges into navigable waters of the U. S. Manages NPDES Point Source permits Includes stormwater permits Regulates Spill Prevention Control and Countermeasures Plans (SPCC) Covers dredge and fill permits Wetlands use

Regulates air quality standards, permits and enforcement, hazardous air pollutants, acid deposition, ozone protection, and motor vehicles and fuels

Regulates all chemical substances and mixtures in the US. Regulates the manufacture, processing, or distribution of chemical

substances, excluding pesticides, tobacco, and tobacco products, nuclear materials and by-products, and food, food additives, drugs and cosmetics

Grants EPA broad enforcement authority to require Potentially Responsible Parties (PRPs) to undertake cleanup of hazardous sites

Its six sections have inventorylrelease reporting requirements and emergency plans

Mandates contingency planning, increases liability limits and cleanup funds and other measures

Requires detailed environmental reviews of major actions permitted by federal agencies if there may be significant impact on human health and environment

Sets guidelines for land management by the Bureau of Land Management (BLM)

Protects endangered or threatened plant and animal species

Sets requirements for onshore and offshore wells and facilities

Provides for registration and proper management of pesticides, including disposal

Regulates hazardous material shipment (includes hazardous waste)

Only a few states have rules

61

1976 1980, Amendment HSWA Amendments TCLP amendments

1974

1972

I970 1990, Amendment

I977

1980

1986

I990

1969

1976

1973

1982

1947

1975

NA



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STD*API/PETRO ES-ENGL 1777 m 0732270 05b4734 380 m

AAC ACL API ARAR

BACT

BAF BAT

BATEA

BDAT BDT BIF

BLM BMP BOD BPT

BTU CAA

CAAA CAMU

CERCLA

CESQG

Appendix E-

Acceptable Ambient Concentration Alternate Concentration Limit American Petroleum Institute Applicable or Relevant and Appropriate Requirement (Under SARA) Best Available Control Technology-the standard for pollution control technology which must be met by major new or modified pollution emission sources in areas with above-standard air quality. Bioaccumulation Factor Best Available Technologydegree of treatment to be applied to all toxic pollutants and nonconventional pollutants based generally upon control technology which has been demonstrated as tech- nically and economically feasible but which may not yet have been applied in any facility. Best Available Technology Economically Achievable Best Demonstrated Available Technology Best Demonstrated Technology Boiler and Industrial Furnace (RCRA Regulations) Bureau of Land Management Best Management Practice Biochemical Oxygen Demand Best Practical Technology-degree of treatment to be applied to all industrial wastes by July 1, 1977, based generally upon the average pollution control performance achieved by the best existing plants. British Thermal Unit Clean Air Act-the 1970 Clean Air Act as amended in 1977. Clean Air Acts Amendments of 1990 Corrective Action Management Unit (RCRA) Comprehensive Environmental Response, Compensation, and Liability Act (commonly known as Superfund) of 1980. Pro- vides for liability, clean-up, and emergency response for hazardous substances released into the environment and the clean-up of inactive hazardous waste disposal sites. Amended by Superfund Amendments and Reauthorization Act of 1986 (SARA). Conditionally Exempt Small Quantity Generator

.Acronyms

CFR CN CO

COD COE CPIS CWA CZM

c02

bL V D Wastes

DMR DOC DOE DOI DOT DRE

EC ECHO EGD EHS

EIS

EOP

E&P EP

EPA

EPCRA

ESA “F” Wastes

FFDCA FIFRA

FLPMA FOGRMA

FOIA FWKO

Code of Federal Regulations Cyanide Carbon Monoxide Carbon Dioxide Chemical Oxygen Demand Army Corps of Engineers Corrugated Plate Interceptors Clean Water Act Coastal Zone Management Wastes considered hazardous by virtue of a characteristic: ignitability, corrosivity, reactivity, or toxicity Discharge Monitoring Reports Dissolved Organic Carbon Department of Energy Department of the Interior Department of Transportation Destruction and Removal Efficiency (incineration) Effective Concentration Expanded Characteristics Option (RCRA) API Environmental Guidance Document Extremely Hazardous Substances (Materi- als listed under SARA) Environmental Impact Statement-a logical analysis of the effects on the environment that will or may reasonably be expected to occur as a result of a proposed action. End-of-Pipe-Treatment-those processes that treat a combined plant wastestream for pollutant removal prior to discharge. Exploration and Production Extraction Procedure for determining toxicity characteristic United States Environmental Protection Agency Emergency Planning & Community Right-to-Know Act of 1986, also known as SARA Title III. Endangered Species Act Hazardous waste from nonspecific sources Federal Food, Drug, and Cosmetic Act Federal Insecticide, Fungicide, and Ro- denticide Act Federal Land Policy and Management Act Federal Oil and Gas Royalty Management Act Freedom of Information Act Free-Water Knockout

63



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64 API E5

FWPCA Federal Water Pollution Control Act of MDL Method Detection Level 1972-sets effluent control limits for all MEA Monoethanolamine industries discharging into waters of the MOU Memorandum of Understanding United States. MSDS Material Safety Data Sheet

GACT Generally Available Control Technol- MTR Minimum Technology Requirements ogy-level of control for area sources of [RCRA Sec 3004(0)] hazardous air pollutants. NCP National Contingency Plan-basic regula-

GAO General Accounting Office tions governing the cleanup of Superfund GCKD Gas ChromatographKonventional Detec- sites.

GC/MS Gas Chromatograph/Mass Spectrometer federal statute that established basic fed- HAP Hazardous Air Pollutant eral policy and procedures for review of HAZCOM Hazard Communications the impacts on the environment that HAZWOPER Hazardous Waste Operations and Emer- would result from a proposed project.

tor NEPA National Environmental Policy Act-a

HC HOC HON

HMTA HRS

HS

H2S HSWA

HWIR

ITP “K” Wastes LAER

LC LDAR

LDR LEPC LQG MACT

gency Response-lawlregulations requiring training for various waste manage ment and emergency response duties. Hydrocarbons Halogenated Organic Compounds Halogenated Organic NESHAP-”ACT rule for Synthetic Organic Chemical Man- ufacturing Industry (SOCMI) Hazardous Materials Transportation Act Hazard Ranking System-scoring system that determines whether a site will be added to the National Priority List (NPL) Hazardous Substances (Materials listed under CERCLA) Hydrogen Sulfide Hazardous and Solid Waste Amendments -1984 Amendments to RCRA Hazardous Waste Identification Rule (RCRA) Industrial Toxics Project Hazardous wastes from specific sources Lowest Achievable Emission Rate-control level required on new major sources of VOC missions in nonattainment areas. The most stringent control applied or required anywhere without consideration of cost or energy impact. Lethal Concentration Leak Detection and Repair Procedures for Fugitive Emissions Land Disposal Restrictions (RCRA) Local Emergency Planning Committee Large Quantity Generator Maximum Achievable Control Technol- ogy-level of control required for new and existing major sources of hazardous air pollutants under the reauthorized Clean Air Act.

MCWMCLG Maximum Containment LeveVMaximum Containment Level Goal

NESHAP

NGL NMFS NOAA

NOX

NORM NPDES

NPL

NRDA

NSPS

NSR OMB OPA

OSHA

osw OSWER

OTS

National Emission Standard for Haz- ardous Air Pollutants-emission limitations established by EPA for pollutants that the Agency judges to possess a significant potential for causing health problems, but for which no national air quality standards have been established. Natural Gas Liquids National Marine Fisheries Service National Oceanic & Atmospheric Admin istration Abbreviation for nitrogen oxides or oxides of nitrogen Naturally Occurring Radioactive Material National Pollutant Discharge Elimination System-the national permitting system authorized under Section 402 of the FWPCA. National Priorities List-list of sites to be cleaned up under the federal Superfund program. Natural Resource Damages Assessment (CERCLA, OPA) New Source Performance Standards-the levels and types of emission control imposed by EPA on various categories of new or modified sources of air pollution. New Source Review under CAA Office of Management and Budget Oil Pollution Act of 1990-addresses response, liability, and penalties for oil and chemical spills to navigable water. United States Occupational Safety and Health Administration

Office of Solid Waste (EPA) Office of Solid Waste and Emergency Re sponse (EPA) Office of Pesticides and Toxic Substances o=A)



--`,,-`-`,,`,,`,`,,`---


T ’ wastes

PAISI PAVE PCBs PH

PIC PM POTW PPA PPb PPm PRP

, PSD

PSES

PSNS

QA RACT

RCRA

REG NEG RF1 RVFS ROD RQ SARA

SARA 313

SDWA SERC SI SIC

Commercial chemical products consid ered acutely hazardous wastes if discarded off-specification, or spill cleanup residues Preliminary AssessmentJSite Investigation Program for Assessing Volatile Emissions Polychlorinated Biphenyls A measure of the acidity or alkalinity of material, liquid, or solid. Product of Incomplete Combustion Particulate Matter Publicly Owned Treatment Works Pollution Prevention Act of 1990 Part per billion Part per million Potentially Responsible Parties (CERCLA) Prevention of Significant Deterioration- -a policy implemented by regulations applying to attainment areas of the USA to protect these areas from any future significant deterioration. Pretreatment Standards for Existing Sources of indirect discharges under Sec- tion 307(d) of the Clean Water Act. Pretreatment Standards for New Sources of Indirect Discharges under Section 307(b) and (c) of the Clean Water Act. Quality Assurance Reasonably Available Control Technology ”applied to existing major sources in nonattainment areas. Resource Conservation and Recovery Act of 1974-establishes controls for the handling and disposal of solid wastes and hazardous wastes. Negotiating Rulemaking Remedial Facility Investigation Remedial InvestigationFeasibility Study Record of Decision Reportable Quantities (Superfund) Superfund Amendments and Reauthoriza- tion Act of 1986 Data collection under Section 313 of the Emergency Planning and Community Right to Know-Act of 1986 Safe Drinking Water Act State Emergency Response Commission Surface Impoundment Standard Industrial Classification-a nu- merical categorization scheme used by the U.S. Department of Commerce to denote segments of industry.

SIP

SOX SPCC

SQG SS STEP

Superfund

SWMU TC

TCLP

TDS TEOR THC TITLE III of SARA

TLV TPQ TRE TRI

TSCA TSDF

TSP TSS TUR “U” Wastes

UCR UIC USDW USGS VOC

VOL

State Implementation Plans-a body of regulations and emissions standards developed by the state and designed to reach the air quality goals of the state. Must be approved by EPA. Sulfur Oxides Spill Prevention Control and Counter- measure Small Quantity Generator Suspended Solids Strategies for Today’s Environmental Partnership Popular term applied to the Comprehen- sive Environmental Response, Com- pensation and Liability Act of 1980 and the Superfund Amendments and Reau- thorization Act of 1986. Solid Waste Management Unit (RCRA) Toxicity Characteristic-concentration levels for 39 compounds used as one way to define solid waste as hazardous. Toxicity Characteristic Leaching Proce- dure (RCRA) Total Dissolved Solids Thermally Enhanced Oil Recovery Total Hydrocarbons

Emergency Planning and Community Right-to-Know-Act of 1986 Threshold Limit Values Threshold Planning Quantity Toxicity Reduction Evaluation Toxic Release Inventory under S A R A Title III Toxic Substances Control Act Treatment, Storage, or Disposal Facility (RCRA) Total Suspended Particulates Total Suspended Solids Toxic Use Reduction Commercial chemical products considered toxic hazardous wastes when discarded, off-specification, or spilled Upper Confidence Range Underground Injection Control Underground Source of Drinking Water U.S. Geological Survey Volatile Organic Compounds-organic compounds that may be involved in photochemical reactions that produce ozone. Volatile Organic Liquid



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66 API E5

WETT Whole Effluent Toxicity Testing-program for testing the toxic effects on aquatic life of an effluent, or specified pollutants in an effluent.

centration of a pollutant, based upon the latest scientific knowledge concerning the effects of the pollutant on health and welfare.

WQC Water Quality Criteria-acceptable con-

WQS Water Quality Standard-a regulatory program for a particular segment of a receiving water which will normally be based upon applicable water quality criteria and other relevant characteristics of the receiving water segment and will include designated use or uses for the water Seg- ment, along with a plan of enforcement.



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STD-API/PETRO ES-ENGL L777 m 0732270 05b4738 T2b

Appendix F-Reference Materials

F.l REFERENCES 1 O. Criteria for pH in Onshore Solid Waste Management in

l . Credible Science, Credible Decisions, U.S. Environmen- Exploration and Production Operations, Publication 4595,

tal Protection Agency, March 1992. American Petroleum Institute, 1994.

2. Suggested Procedures for Development of Spill Preven- 1 l . Metals Criteria for Land Management of Exploration

tion, Control and Countermeasure Plans, Bulletin D16, and Production Wastes: Technical Support Document for

American Petroleum Institute, August 1, 1989. API Recommended Guidance Values, Publication 4600, American Petroleum Institute, 1994.

3. Bulletin on the Generic Hazardous Chemical Category

duction Industry, Bulletin E 1, American Petroleum Institute, 40 Code of Federal Regulations Parts 257, 403, and 503,

December 1, 1990. U.S. Environmental Protection Agency, 1993.

4. Bulletin on Management ofNaturally occurring 13. “Underground Injection Control Program: Criteria and

dioactive Materials (NORM) in Oil and Gas Production, Standards,” 40 Code of Federal Regulations Part 146, U.S. Bulletin E2, American Petroleum Institute, April 1, 1992. Environmental Protection Agency, 1992.

List and Inventory for the Oil a& Gas hploration and pro- 12. ‘‘StatKhds for the Use or Disposal of Sewage Sludge?”

5. Environmental Guidance Document on Well Abandon- ment and Inactive Well Practices for U.S. Exploration and Production, Bulletin E3, American Petroleum Institute, Jan- uary 1993.

6 . Environmental Guidance Document on Release Report- ing for the Oil and Gas Exploration and Production Industry as Required by the CWA, CERCLA and SARA lïtle III, Bul- letin E4, American Petroleum Institute, June l , 1993.

7. Regulatory Determination for Oil and Gas Geothermal Exploration, Development and Production Wastes, U.S. En- vironmental Protection Agency, July 6, 1988.

8. EPNIOCC Study of State Regulation of Oil and Gas Ex- ploration and Production Waste, Interstate Oil Compact Commission, December 1990.

9. Evaluation of Limiting Constituent Suggested for Land Disposal of Exploration and Production Wastes, Publication 4527, American Petroleum Institute, August 1993.

14. “Standards for the Use or Disposal of Sewage Sludge,” 40 Code of Federal Regulations Parts 257, 403, and 503, U.S. Environmental Protection Agency, 1993.

15. “Underground Injection Control Program: Criteria and Standards,” 40 Code of Federal Regulations Part 146, U.S. Environmental Protection Agency, 1992.

F.2 SOURCES FOR JUSTIFICATION AND ANALYTICAL METHODS IN TABLE 4

Electrical conductivity, sodium absorption ratio, exchangeable sodium percentage, and oil and grease guideline values are described in detail in API Publication 4527.

The pH values are detailed in API Publication 4595. Metals guidance is developed in API Publication 4600.

67



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Appendix G-REPRINT OF EPA PUBLICATION (EPA 530-1<-95-003), MAY 1995- Crude Oil and Natural Gas Exploration and Production Wastes: Exemption from RCRA

Subtitle C Regulation

INTRODUCTION

In the 1987 report to Congress entitled “Management of Wastes from the Exploration, Development and Production of Crude Oil, Natural Gas, and Geothermal Energy,” the U.S. Environmental Protection Agency (EPA) presented estimates on the amount of oil and gas drilling and production wastes generated in the United States. Those estimates were provided to the Agency by the American Petroleum Institute (API). Specifically, API estimated that 361 million barrels of drilling wastes and 20.9 billion barrels of produced water were generated in 1985 from exploration and production (E&P) operations. API later estimated that 1 1.8 million barrels of other wastes associated with E&P operations were generated that same year.

Drilling activity in the United States has declined significantly since 1985, which would result in a corresponding reduction in the generation of drilling wastes. According to the International Association of Drilling Contractors, the total footage drilled for all oil and gas wells dropped from 315.4 million feet in 1985 to 133.1 million feet in 1991; a decrease of 58 percent. It seems logical to assume that drilling waste volumes would have declined proportionately during this time. On the other hand, as hydrocarbons from producing wells deplete, produced water volumes typically increase. Because no attempts have been made to update the 1985 E&P waste volume data, it is uncertain what effect the downward trend in drilling activity has had on total E&P waste generation volumes.

Nevertheless, managing all these wastes in a manner that protects human health and the environment is essential for limiting the operators’ legal and financial liabilities and makes good business sense. The preferred option for preventing pollution is to avoid generating wastes whenever possible (source reduction). Examples include process mod- ifications to reduce waste volumes and materials substitution to reduce toxicity. Also, a determination should be made as to whether the waste is subject to hazardous waste regulations. At times this determination is misunderstood and may lead to improper waste management decisions. Prudent waste management decisions, even for nonhazardous wastes, should be based on the inherent nature of the waste. Not all waste management options are appropriate for every waste. Additionally, operators should be familiar with state and federal regulations governing the management of hazardous and nonhazardous wastes.

This publication was produced by EPA to provide an understanding of the exemption of certain oil and gas exploration and production (E&P) wastes from regulation as

~

hazardous wastes under Subtitle C of the Resource Conser- vation and Recovery Act (RCRA).

The information contained in this booklet is intended to furnish the reader with:

A basic background of the E&P exemption. Basic rules for determining the exempt or nonexempt

Examples of exempt and nonexempt wastes. Status of E&P waste mixtures. Clarifications of several misunderstandings about the

Answers to frequently asked questions. Recommendations for sensible waste management. Additional sources of information.

Understanding the procedures for determining the exempt or nonexempt status of a waste is a valuable tool, especially for operators who choose to develop voluntary waste management plans. When these procedures are used in conjunction with a knowledge of the nature of the waste, the operator will be better prepared to develop site-specific waste management plans and to manage E&P wastes in a manner that protects human health and the environment.

SCOPE OF EXEMPTION

status of wastes.

exemption.

In December 1978, EPA proposed hazardous waste management standards which included reduced requirements for several types of large volume wastes. Generally, EPA be- lieved these large volume “special wastes” are lower in toxicity than other wastes being regulated as hazardous wastes under RCRA. Subsequently, Congress exempted these wastes from the RCRA Subtitle C hazardous waste regulations pending a study and regulatory determination by EPA. In 1988, EPA issued a regulatory determination stating that control of E&P wastes under RCRA Subtitle C regulations is not warranted. Hence, E&P wastes have remained exempt from Subtitle C regulations. The RCRA Subtitle C exemption, however, did not preclude these wastes from control under state regulations, under the less stringent RCRA Subtitle D solid waste regulations, or under other federal regulations. In addition, although they are relieved from regulation as hazardous wastes, the exemption does not mean these wastes could not present a hazard to human health and the environment if managed improperly.

Among the wastes covered by the 1978 proposal were “gas and oil drilling muds and oil production brines.” The oil and gas exemption was expanded in the 1980 legislative amendments to RCRA to include “drilling fluids, produced

69



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70 API E5

water, and other wastes associated with the exploration, development, or production of crude oil or natural gas ...” (Geothermal energy wastes were also exempted but are not addressed by this publication.)

According to the legislative history, the term “other wastes associated” specifically includes waste materials intrinsically derived from primary field operations associated with the exploration, development, or production of crude oil and natural gas. The phrase “intrinsically derived from the primary field operations” is intended to distinguish exploration, development, and production operations from transportation and manufacturing operations.

With respect to crude oil, primary field operations include activities occurring at or near the wellhead and before the point where the oil is transferred from an individual field facility or a centrally located facility to a canier for transport to a refinery or a refiner.

With respect to natural gas, primary field operations are those activities occurring at or near the wellhead or at the gas plant but before the point where the gas is transferred from an individual field facility, a centrally located facility, or a gas plant to a carrier for transport to market. Examples of carriers include trucks, interstate pipelines, and some in- trastate pipelines.

Primary field operations include exploration, development and, the primary, secondary, and tertiary production of oil or gas. Crude oil processing such as water separation, de-emul- sifying, degassing, and storage at tank batteries associated with a specific well or wells are examples of primary field operations. Furthermore, because natural gas often requires processing to remove water and other impurities prior to en-

tering the sales line, gas plants are considered part of production operations regardless of their location with respect to the wellhead.

In general, the exempt status of an E&P waste depends on how the material was used or generated as waste, not necessarily whether the material is hazardous or toxic. For example, some exempt E&P wastes might be harmful to human health and the environment and many nonexempt wastes might not be as harmful. The following simple rule of thumb can be used to determine if an E&P waste is exempt or nonexempt from RCRA Subtitle C regulations:

Has the waste come from down-hole, i.e., was it brought to the surface during oil and gas E&P operations? Has the waste otherwise been generated by contact with the oil and gas production stream during the removal of produced water or other contaminants from the product?

If the answer to either question is yes, then the waste is most likely considered exempt from RCRA Subtitle C regulations.

EXEMPT AND NONEXEMPT WASTES

In its 1988 regulatory determination, EPA published the following lists of wastes that were determined to be either exempt or nonexempt. The lists are provided as examples of wastes regarded as exempt and nonexempt and should not be considered comprehensive. The exempt waste list applies only to those wastes generated by E&P operations. Similar wastes generated by activities other than E&P operations are not covered by the exemption.



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. o

.

. o

o

EXEMPT E&P WASTES

Produced water Drilling fluids Drill cuttings Rigwash Drilling fluids and cuttings from offshore operations disposed of onshore Geothermal production fluids Hydrogen sulfide abatement wastes from geothermal energy production Well completion, treatment, and stimulation fluids Basic sediment and water and other tank bottoms from storage facilities that hold product and exempt waste Accumulated materials such as hydrocarbons, solids, sands, and emulsion from production separators, fluid treating vessels, and production impoundments Pit sludges and contaminated bottoms from storage or disposal of exempt wastes Gas plant dehydration wastes, including glycol-based compounds, glycol filters, filter media, backwash, and molecular sieves Gas plant sweetening wastes for sulfur removal, including amines, amine filters, amine filter media, backwash, precipitated amine sludge, iron sponge, and hydrogen sulfide scrubber liquid and sludge Workover wastes

.

. o

.

Cooling tower blowdown Spent filters, filter media, and backwash (assuming the filter itself is not hazardous and the residue in it is from an exempt waste stream) Pipe scale, hydrocarbon solids, hydrates, and other deposits removed from piping and equipment prior to transportation Produced sand Packing fluids Hydrocarbon-bearing soil Pigging wastes from gathering lines Wastes from subsurface gas storage and retrieval, except for the nonexempt wastes listed below Constituents removed from produced water before it is injected or otherwise disposed of Liquid hydrocarbons removed from the production stream but not from oil refining Gases from the production stream such as hydrogen sulfide and carbon dioxide, and volatilized hydrocarbons Materials ejected from a producing well during the process known as blowdown Waste crude oil from primary field operations Light organics volatilized from exempt wastes in reserve pits or impoundments or production equipment

I NONEXEMPT E&P WASTES

o

. .

Unused fracturing fluids or acids Gas plant cooling tower cleaning wastes Painting wastes Waste solvents Oil and gas service company wastes such as empty drums, drum rinsate, sandblast media, painting wastes, spent solvents, spilled chemicals, and waste acids Vacuum truck and drum rinsate from trucks and drums transporting or containing nonexempt waste Refinery wastes Liquid and solid wastes generated by crude oil and tank bottom reclaimersl Used equipment lubricating oils Waste compressor oil, filters, and blowdown

Used hydraulic fluids

Waste in transportation pipeline related pits

Caustic or acid cleaners

Boiler cleaning wastes

Boiler refractory bricks

Boiler scrubber fluids, sludges and ash

Incinerator ash

Laboratory wastes

Sanitary wastes

Pesticide wastes

Radioactive tracer wastes

Drums, insulation, and miscellaneous solids

1 Although non-E&P wastes generated from crude oil and tank bottom rech- notice “Clarification of the Regulatory Determination for Wastes from the mation operations ( e g , waste equipment cleaning solvent) are nonexempt, Exploration, Development, and Production of Crude Oil, Natural Gas and residuals derived from exempt wastes (e.g., produced water separated from Geothermal Energy,” Federal Register, Volume 58, Pages I5284 to 15287, tank bottoms) are exempt. For a further discussion, see the Federal Register March 22, 1993.



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72 API E5

The following flowchart may be useful in determining whether a waste is exempt or nonexempt from RCRA Subtitle C regulation.

ExempVNonexempt Flowchart

Waste from Exploration,

Development, or Production?

Listed No >

Waste? > Yes Hazardous

Yes I

+- I

A No

Exempt from RCRA Subtitle C

(Subject to Subtitle D and

other State and Federal

statutes)

See Mixture

Flowchart

No

v Exhibit

Characteristic? Hazardous - Yes -

f Nonhazardous

Waste (Subject to

Subtitle D and other State and Federal

Statutes)

Hazardous Waste

Subject to

Subtitle C RCRA

4



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MIXING WASTES

Mixing wastes, particularly exempt and nonexempt wastes, creates additional considerations. Determining whether a mixture is an exempt or nonexempt waste requires an understanding of the nature of the wastes prior to mixing and, in some instances, might require a chemical analysis of the mixture. Whenever possible, avoid mixing nonexempt wastes with exempt wastes. If the nonexempt waste is a listed or characteristic hazardous waste, the resulting mixture may become a nonexempt waste and require management under RCRA Subtitle C regulation. Further- more, mixing a characteristic hazardous waste with a nonhazardous or exempt waste for the purpose of rendering the hazardous waste nonhazardous or less hazardous might be considered a treatment process subject to appropriate RCRA Subtitle C hazardous waste regulation and permitting re-

i quirements. Note: As this document was being prepared, the mixture rule was being re- examined by EPA as a result of a court challenge. Because the rule could be amended or clarified, the status of the rule should be determined prior to mixing any E&P wastes with hazardous wastes. For additional information, refer to the Federal Register notice, “Land Disposal Restrictions for Ig- nitable and Corrosive Characteristic Wastes Whose Treatment Standards Were Vacated; Interim Final Rule,’’ Federal Register Volume 58, Pages 29860 to 29887, May 24, 1993.

Below are some basic guidelines for determining if a mixture is an exempt or nonexempt waste under the present mixture rule.

A mixture of an exempt waste with another exempt I

waste remains exempt. Example: A mixture of stimulation fluid that returns from a well with produced water results in an exempt waste. , Mixing a nonhazardous waste (exempt or nonexempt) with an exempt waste results in a mixture that is also exempt. Example: If nonhazardous washwater from rinsing road dirt off equipment or vehicles is mixed with the contents of a reserve pit containing only exempt drilling waste, the wastes in the pit remain exempt regardless of the characteristics of the waste mixture in the pit.

If, after mixing a nonexempt characteristic hazardous waste with an exempt waste, the resulting mixture exhibits any of the same hazardous characteristics as the hazardous waste (ignitability, corrosivity, reactivity, or toxicity), the mixture is a nonexempt hazardous waste. Example: If, after mixing nonexempt caustic soda (NaOH) (corrosive) in a pit containing exempt waste, the mixture also exhibits the hazardous characteristic of corrosivity as determined from pH or steel corrosion tests, the entire mixture becomes a nonexempt hazardous waste.

Example: If, after mixing a nonexempt solvent containing benzene with an exempt waste also containing benzene, the mixture exhibits the hazardous characteristic for benzene, the entire mixture becomes a nonexempt hazardous waste.

If, after mixing a nonexempt characteristic hazardous waste with an exempt waste, the resulting <mixture does not exhibit any of the same characteristics as the hazardous waste, the mixture is exempt. Even if the mixture exhibits some other characteristic of a hazardous waste, it is still exempt. Example: If, after mixing nonexempt hydrochloric acid (HCI) that exhibits the corrosive characteristic only with an exempt waste, the mixture does not exhibit the hazardous characteristic of corrosivity, but does exhibit some other hazardous characteristic such as toxicity, the mixture is exempt. Example: If, after mixing a nonexempt waste exhibiting the hazardous characteristic for lead with an exempt waste exhibiting the characteristic for benzene, the mixture exhibits the characteristic for benzene but not for lead, the mixture is exempt.

Generally, if a listed hazardous waste’ is mixed with an exempt waste, regardless of the proportions, the mixture is a nonexempt hazardous waste. Example: If any amount of leaded tank bottoms from the petroleum refining industry (listed as waste code K052) is mixed with an exempt tank bottom waste, the mixture is considered a hazardous waste and is therefore nonexempt.

It is also important to emphasize that a mixture of an exempt waste with a listed hazardous waste generally becomes a nonexempt hazardous waste regardless of the relative volumes or concentrations of the wastes. Similarly, if a mixture of an exempt waste with a nonexempt characteristic hazardous waste exhibits any of the same hazardous characteristics as the hazardous waste, the mixture becomes a nonexempt hazardous waste regardless of the relative volumes or concentrations of the wastes. In other words, for both scenarios, the wastes could become nonexempt even if only one barrel of hazardous waste was mixed with 10,000 barrels of exempt waste. Note: Mixing a characteristic hazardous waste with a nonhazardous or exempt waste for the purpose of rendering the hazardous waste nonhazardous or less hazardous may be considered a treatment process subject to RCRA Subtitle C hazardous waste regulations and appropriate permitting requirements.

2 . Llsted hazardous wastes are those wastes listed as hazardous in the 40 Code of Federal Regulations Part 261, Subpart D.



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74 API E5

The following flowchart depicts the various possible mixtures and their exempt and nonexempt status.

Possible Waste Mixtures

Exempt

Exempt Exempt

Waste Exempt

Waste Waste Nonhazardous -

Waste Waste

W 4

-

Exempt Waste (See Note on

Previous Page)

No

Does Mixture Exhibit any

Nonexempt Characteristic

Hazardous Waste

Exempt Waste

Listed Hazardous

Waste

Exhibited by Nonexempt Waste?

Yes

J

Nonexempt

Hazardous Waste W Characteristic

Listed Hazardous Waste



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COMMON MISUNDERSTANDINGS

An incomplete understanding of the hazardous waste regulations can result in misinterpretations about the regulatory status of various wastes. The most common misunderstandings that arise with the RCRA Subtitle C exemption and hazardous waste determinations are presented here for clarification.

Misunderstanding: All wastes located at E&P sites are exempt.

Fact: All wastes located at E&P sites are not necessarily exempt. To be considered an exempt waste, the waste must have been generated from a material or process uniquely associated with the exploration, development, and production of crude oil and natural gas. For example, a solvent used to clean surface equipment or machinery is not exempt because it is not uniquely associated with exploration, development, or production operations. Conversely, if the same solvent were used in a well, it would be exempt because it was generated through a procedure that is uniquely associated with production operations.

Misunderstanding: All service company wastes are exempt.

Fact: Not all service company wastes are exempt. As with all oilfield wastes, only those wastes generated from a material or process uniquely associated with the exploration and production of oil and gas are considered exempt. The previous example of solvents used for cleaning equipment and machinery would also apply in this case-the solvent is not an exempt waste.

Misunderstanding: Unused products are exempt.

Fact: Unused products, if disposed of, are not exempt, regardless of their intended use, because they have not been used and therefore are not uniquely associated with the exploration or production of oil and gas. When unused products become waste (e.g., they are disposed of) they are subject to RCRA Subtitle C hazardous waste regulations if they are listed or exhibit a hazardous characteristic.

Misunderstanding: All exempt wastes are harmless to human health and the environment.

Fact: Certain exempt wastes, while excluded from RCRA Subtitle C hazardous waste control, might still be harmful to

human health and the environment if not properly managed. The exemption relieves wastes that are uniquely associated with the exploration and production of oil and gas from regulation as hazardous wastes under RCRA Subtitle C but does not indicate the hazard potential of the exempt waste. Addi- tionally, some of these wastes may still be subject to state hazardous or nonhazardous waste regulations or other federal regulations (e.g., hazardous materials transportation regulations, reserve pit regulations, and National Pollutants Discharge Elimination System (NPDES) or state discharge regulations) unless specifically excluded from regulation under those laws.

Misunderstanding: Any mixture of a nonexempt hazardous waste with an exempt waste becomes an exempt waste.

Fact: Not all mixtures of a nonexempt hazardous waste with an exempt waste become exempt wastes. Generally, a mixture of a listed hazardous waste with an exempt waste becomes a nonexempt hazardous waste. Also, a mixture of a hazardous waste that exhibits one of the characteristics of a hazardous waste (ignitability, corrosivity, reactivity, or toxicity) with an exempt waste, becomes a nonexempt characteristic hazardous waste if the mixture exhibits one of the same hazardous characteristics as the original hazardous waste. Conversely, if the mixture does not exhibit one of the same hazardous characteristics of the hazardous waste, the mixture becomes a nonhazardous exempt waste. As previously noted, mixing a nonexempt hazardous waste with an exempt waste for the purpose of rendering the hazardous waste nonhazardous or less hazardous may be considered a treatment process and must be conducted in accordance with applicable RCRA Subtitle C regulations and permitting requirements.

Misunderstanding: A waste exempt from RCRA Subtitle C regulation is also exempt from state and other federal waste management regulations.

Fact: The exemption applies only to the federal requirements of RCRA Subtitle C. A waste that is exempt from RCRA Subtitle C regulation may be subject to more stringent or broader state hazardous and nonhazardous waste regulations and other state and federal program regulations. For example, oil and gas exploration and production wastes are subject to regulation under the Clean Air Act (CAA), Clean Water Act (CWA), Safe Drinking Water Act (SDWA), and Oil Pollution Act of 1990 (OPA).



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FREQUENTLY ASKED QUESTIONS

EPA receives calls on a regular basis requesting answers to questions related to the E&P exemption. The most common questions and answers are listed below.

Q: Are RCRA-exempt wastes also exempt under other federal laws?

A: Not necessarily. Unless specifically excluded from regulation under other federal laws, RCRA-exempt wastes might still be subject to regulation under authorities other than RCRA.

Q: What is the benejìt of the RCRA exemption ifthe operator is still liable for deanups under RCRA?

A: Although the operator might still be liable for cleanup actions under RCRA for wastes that pose an imminent and substantial endangerment to human health and the environment, the RCRA exemption does allow the operator to choose a waste management and disposal option that is less stringent and possibly less costly than those required under RCRA Subtitle C. However, the operator should make every effort to choose the proper management and disposal procedures for the particular waste to avoid the need for later cleanup action.

Q: When is a waste considered “uniquely associated with ” exploration and production operations?

A: A waste is “uniquely associated with” exploration and production operations if it is generated from a material or procedure that is necessary to locate and produce crude oil or natural gas. Also, a waste is “uniquely associated with” exploration and production operations if it is generated from a material or procedure that only occurs during the exploration and production of crude oil or natural gas. A simple rule of thumb for identifying “uniquely associated wastes” is whether the waste came from downhole or otherwise was generated in contact with the oil or gas production stream for the purpose of removing water or other contaminants from the well or the product.

Q: Are wastes generated from a transportation pipeline considered exempt wastes under RCRA Subtitle C?

A: No. The RCRA Subtitle C exemption only applies to wastes generated from the exploration, development, and production (i.e., primary field operations) of crude oil or natural gas. Hence, wastes generated from the transportation of crude oil or natural gas are not RCRA-exempt.

Q: Do exempt wastes lose their exempt status if they undergo custody transfer and are transported ofssite for disposal?

A: No. Custody transfer is used to define the endpoint of production operations for crude oil and applies only to the change in ownership of the product (e.g., crude oil). Exempt wastes maintain their exempt status even if they undergo custody transfer and are transported offsite for disposal or treatment.

Q: Are all wastes generated at facilities that treat or reclaim exempt wastes also exempt?

A: No. The exemption applies only to those wastes derived from exempt wastes, not to additional wastes generated by the treatment or reclamation of exempt wastes. For example, if a treatment facility uses an acid in the treatment of an exempt waste, any waste derived from the exempt waste being treated is also exempt but the spent acid is not.

Q: When does transportation begin?

A: For crude oil, transportation begins at the point of custody transfer of the oil or, in the absence of custody transfer, after the end point of production separation and dehydration. Storage of crude oil in stock tanks at production facilities is considered part of the production separation process, not transportation, and is included in the exemption. For natural gas, transportation begins at the point where the gas leaves the facility after production separation and dehydration at the gas plant. Natural gas pipelines between the gas well and the gas plant are considered to be part of the production process, rather than transportation, and wastes that are uniquely associated with production that are generated along such a pipeline are exempt.

EPA periodically issues interpretive letters regarding the oil and gas exemption. One such letter was in response to a request for clarification of the exempt or nonexempt status of wastes generated at natural gas compressor stations. In some regions, such as the Appalachian states, natural gas does not require sweetening or extensive dehydration. Therefore the gas generally does not go to a gas plant but is canied from the wellhead to a main transmission line, and in some cases, directly to the customer. Compressor stations are located as needed along the pipelines that run between the wellhead and the main transmission line or the customer to maintain pressure in the lines. The Agency has taken the position that these compressor stations (in the absence of gas plants, and handling only local production) should be treated the same as gas plants, and that wastes generated by these compressor stations are exempt. On the other hand, compressor stations located along main gas transmission lines are considered to be part of the transportation process and any wastes generated by these compressor stations are nonexempt.



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SENSIBLE WASTE MANAGEMENT

Prudent operators will design E&P facilities and processes to minimize potential environmental threats and legal liabilities. EPA has been promoting sensible waste management practices through a number of joint efforts with organizations such as API and the Interstate Oil and Gas Compact Commission (IOGCC). The following waste management suggestions have been compiled from publications produced by these organizations as well as from literature available from industry trade associations, trade journals, and EPA.

Suggested E&P Waste Management Practices

Size reserve pits properly to avoid overflows.

Use closed loop mud systems when practical, particularly with oil based muds.

Review material safety data sheets (MSDS’s) of materials used, and select less toxic alternatives when possible.

Minimize waste generation, such as by designing systems with the smallest volumes possible (e.g., drilling mud systems).

Reduce the amount of excess fluids entering reserve and production pits.

Do not place nonexempt wastes in reserve or production pits .

Design the drilling pad to contain storm water and rigwash.

Recycle and reuse oil based muds and high density brines when practical.

Perform routine equipment inspections and maintenance to prevent leaks or emissions.

Reclaim oily debris and tank bottoms when practical.

Minimize the volume of materials stored at facilities.

Construct adequate berms around materials and waste storage areas to contain spills.

Perform routine inspections of materials and waste storage areas to locate damaged or leaking containers.

Train personnel to use sensible waste management practices.

SOURCES OF INFORMATION

Additional information regarding the exemption of E&P wastes from RCRA Subtitle C regulations can be obtained from the following publications and organizations.

Publications

Title: EPA Report to Congress: Management of Wastes from the Exploration, Development, and Production of Crude Oil, Natural Gas, and Geothermal Energy, NTIS Publication No. PB 88-146212, December 1987.

Available from: National Technical Information Services 5285 Port Royal Road Springfield, VA 22161 (703) 487-4650

Title: Regulatory Determination for Oil and Gas and Geothermal Exploration, Development, and Production Wastes, Federal Register Volume 53, Pages 25446 to 25459, July 6, 1988.

Available from: RCWSuperfund Hotline Washington, D.C. (800) 426-4791

Title: Clari’cation of the Regulatory Determination for Wastes from the Exploration, Development, and Production of Crude Oil, Natural Gas and Geothermal Energy, Federal Register Volume 58, Pages 15284 to 15287, March 22, 1993.

Available from: RCRNSuperfund Hotline Washington, D.C. (800) 426-479 1

Title: API Environmental Guidance Document: Onshore Solid Waste Management in Exploration and Production Opera- tions, January 1989.

Available from: American Petroleum Institute 1220 L Street, N.W. Washington, D.C. 20005 (202) 682-8375

Title: Oil and Gas Exploration and Production Field Personnel Pollution Prevention Training

Available from: National Environmental Training Association 2930 East Camelback Road, Suite 185 Phoenix, Arizona 85016-4412 (602) 956-6399



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OTHER SOURCES OF INFORMATION

U.S. Environmental Protection Agency Office of Solid Waste Oil and Gas Industry Section (5306W) 401 M Street, S.W. Washington, D.C. 20460 (703) 308-8424

RCWSuperfund Hotline Washington, D.C. (800) 424-9346

Safe Drinking Water Hotline Washington, D.C. (800) 426-479 1



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Additional copies available from API Publications and Distribution (202) 682-8375

Information about API Publications, Programs and Services is available on the World Wide Web at: http://www.api.org

American 1220 L Street, Northwest Petroleum Washington, D.C. 20005-4070 Institute 202-682-8000 Order No. GE5002



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Documents

API E5.pdf