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API E5 SECOND EDITION, FEBRUARY 1997
Strategies for Today’s Environmental Partnership
American Petroleum Institute
COPYRIGHT American Petroleum Institute Licensed by Information Handling Services
One of the most significant long-term trends affecting the future vitality the petroleum of industry is the public’sconcerns 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:
To recognize and to respond to community concerns about our raw materials, products and operations. a manner that protects the environment, and the safety and health of our employees and the public.
o To operate our plants and facilities, and to handle our raw materials and products in
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 in-
formation 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 dis-
posal of our raw materials, products and waste materials.
o To economically develop and produce natural resources and to conserve those re-
sources 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.
To commit to reduce overall emissions and waste generation. ardous substances from our operations.
o To work with others to resolve problems created by handling and disposal of hazo To participate with government and others in creating responsible laws, regulations
and standards to safeguard the community, workplace and environment.
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.
COPYRIGHT American Petroleum Institute Licensed by Information Handling Services
S T D - A P I / P E T R O ES-ENGL L797 m 0 7 3 2 2 7 0 05b4b70 430 m
Environmental Guidance Document: Waste Management in Exploration and Production Operations
Exploration and Production Department
API E5 SECOND EDITION, FEBRUARY 1997
American Petroleum Institute
COPYRIGHT American Petroleum Institute Licensed by Information Handling Services
STD.API/PETRO ES-ENGL L997
0732290 0 5 b 4 b 7 L 377
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, orsuppliers to warn and properly train and equip their employees, and others exposed, concerninghealth and safety risks and precautions, nor undertakingtheir obligations under local, state, or federal laws. Information concerning safety and health risks and proper precautions with respect to particular materials and conditions should beobtained fromthe employer, the manufacturer or supplier of that material, or the material safety data sheet. Nothing contained in any API publication to be construed as granting any right,by imis plication or otherwise, for the manufacture, sale, or use any method, apparatus, product of or covered by letters patent. Neither should anything contained in the publication be construed as insuring anyone against liability for infringement of letters patent. are Generally, API guidance documents reviewed and revised, reaffirmed, or withdrawn at least every five years.Sometimes a one-time extension up to two years will be added of to this review cycle. This publication will no longer be in effect five years after its publication date as an operative API guidance document where an extensionhas been granted, or, upon republication.Status of the publication can ascertained from the API Authoring Debe 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 bereproduced, stored in a retrieval system, or transmitted by any means, electronic, mechanical, photocopying, recording or otherwise, 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
COPYRIGHT American Petroleum Institute Licensed by Information Handling Services
It provides guidancefor minimizing the direct and indirect environmental impacts of solid wastes originating from typical exploration and production (E&P) activities. It must use environmentally sound operating practices to manage materials. American Petroleum Institute. of the the institute makes no representation. or municipal regulation with which this publication mayconflict. whose sensitivity to the activities man will vary widely. land. 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. 20005. 1220 L Street.W.C. under the jurisdiction of the API Exploration and Production Department Executive Committee on Environmental Conservation. This manual was prepared by the API Production Waste Issues Group. field production. however. and the waste generated from exploration and production activities. which include exploration. well completions and workovers. state. Suggested revisions are invited and should be submitted director of the Exploration to the and Production Department.FOREWORD This document reflects our industry’s continuing commitment to environmental protection. N. and gas plant operation. API publications may be used by anyone desiring to do so. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Every effort has been made by the institute to assure the accuracy and reliability data contained in them. D. warranty. drilling. This means that the exploration and production activities listed above will beconducted in a variety of ecosystems. The oil and gas industry must operate where oil andgas deposits are found.. The oil and gas inof dustry must be environmental stewards two critical ways: in a. b. Washington. It must produce oil and gas reserves as efficiently and prudently as possible in order to prevent squandering critical natural resources.
...................................................1 6..4 4........4 3.....2 3..... 17 ENVIRONMENTAL LEGISLATION AND REGULATIONS Introduction ................................................................................ 16 Offshore Operations ..............5 6 6............................................................ 38 Produced Water..............................................................API/PETRO ES-ENGL L777 m 0 7 3 2 2 9 0 05b4b73 L4T CONTENTS page 1 1........................................4 5............................. 25 4.................................................................................. 7 Completion and Workover ................................................................................. 39 Workover and Completion Wastes .....................................................................................5 2 2........................................1 1..2 6..... ................................................ Understanding Operational Impacts Pollution Prevention and waste Minimization ..............................................6 3................................................3 3..........................................2 4.......................3 1...10 Other Regulations and Agreements ................5 4.......................5 3............................................................................................................. 4............................................................................... 30 IDENTIFYING MANAGEMENT OPTIONS FOR SPECIFIC WASTES Introduction .1 4....................8 The Oil Pollution Act of 1990 (OPA 90) ....................2 2................................................................. 17 The Resource Conservation Recovery Act (RCRA) ..............................................................2 5..............3 5.....................................................3 2........~~ STC...................... 25 Act The ComprehensiveEnvironmental Response..............................................................................................................................................................................................................................................................................4 1....... 25 The Toxic Substances Control (TSCA) ........and Liability Act (CERCLA) ..................................................................................................................................................................................4 WASTE MANAGEMENT METHODS Introduction .................... 27 27 4............................................................................................................................................................3 6....................................................................................................... Media .... and 17 The Safe Drinking Water Act (SDWA) ......................................... 41 V COPYRIGHT American Petroleum Institute Licensed by Information Handling Services ..............8 4 4.........................3 4............................................ Waste Tracking ..... 23 The Clean Air Act(CAA) ........................1 5...................7 POLLUTION PREVENTION Introduction ............. API’s Management Practice for Pollution Prevention........................................................ Summary of a Ten-Step Plan for Waste Management.................................. Training ................................ WASTE MANAGEMENT SYSTEM Introduction .5 3 3................................................... 9 Field Production ..................................................... 30 Treatment............................... 29 Source Reduction ...................................................................................................................................................................................................1 3.....9 Other Federal Acts.................................................................... 1 1 1 3 3 4 4 4 5 5 WASTE GENERATION IN EXPLORATION AND PRODUCTION OPERATIONS Introduction .................. 14 Transportation Pipelines .......... Auditing................................... 29 5 5...................6 4.................1 2................................ 39 Drilling Wastes .................................................................................... 6 Drilling ............................................ 29 Recycling andReclaiming..................................................... 10 Gas Plant Operations... Compensation...................................................................................................................4 2................... 6 Exploration .................................................2 1........................................ 30 Disposal ..................................................................................................7 3.... 22 The Clean Water Act (CWA) .............................
............................... APPENDIX D-Summary of Environmental Legislation and Regulations.........................9 Oily Debris and Filter Media .......................................................................... B-1-Iron Sulfide Scale and Iron Sponge...... D ............ 46 6........................ 46 6....... Soil &Example of E&P Waste.....................................................................................................7 Used Oils and Solvents................................................ May 1995............... Disposal Technique.............19 Empty Oil and Chemical Drums ...........................................................................................20 Naturally Occurring Radioactive Material 6......................... 46 6....................13 StormwaterRigwash .....................................................I-Summary Waste Table ........5 Tank Bottoms.. 47 APPENDIX A-Guidelines for Developing Area-Specific Waste Management Plans ............................................................................................. 46 6....................................................................................................................16 Used Batteries .... 3-API Metals Guidance: Maximum Concentrations .............12 Downhole and Equipment Scale .......................................................................................................... 2-Overview of Waste Management Methods ................................................................................................................................................................... and Steam Generator Wastes ............................. 42 6........................................................................ 45 6......................... 43 6...6 Contaminated Soil ...............1-Ten-Step Plan for Preparing a WasteManagement Plan ................................................ and Produced Solids ................ 43 6........... 47 6.....................................................8 Dehydration and Sweetening Waste ............................................17 PCB Transformer Oil ..........................Crude Oil and Natural Gas Exploration Production Wastes: Exemption from and RCRA Subtitle C Regulation ................Page 6....... C................................. APPENDIX F-Reference Materials ................................ APPENDIX B-Waste Management Planning Aids ................................................. 45 6. A.................. 44 6................................................. Figures 1-Media 49 55 57 61 63 67 69 Pathways .................................................. APPENDIX G-EPA Publication: (EPA 530-K-95-003)......................14 Unused Treatment Chemicals ...............................................................................1 ” S u m m q of Key Legislation and Regulations................. 45 6.............. 47 6...........................18 NonPCB Transformer Oil .................................................................................. 5 30 33 34 49 56 57 61 vi COPYRIGHT American Petroleum Institute Licensed by Information Handling Services ................10 Gas Plant Process and Sulfur Recovery Waste................. and Applicable Constituent Criteria ............... APPENDIX C-Summary Waste Table ...........................................................................22 Recompression and Facility Utility Wastes...... APPENDIX E-Acronyms ........................................................................................................................................... 44 6................ Heavy Hydrocarbons...............1 1 Cooling Tower Blowdown...............................................21 Geological and Geophysical OperationWastes ............. 46 6.............................. 47 .................................................... 45 6....................................................................15 Asbestos .............................. 2 Tables 1-Ten-Step Plan Summary .. Scrubber Liquids....................................................................................... Boiler Water........................ Emulsions...................
2. transporters. and environment. j. or dispose of similar raw materials. and impact on human health and the environment. To advise promptly appropriate officials. and settinggoals and schedules for reducing releases and measuring progress. and standards to safeguard the community. b. k. g. To promote these principles and practices by sharing experiences and offering assistance to others who produce. To recognize and to respond to community concerns about our raw materials.2 API’SMANAGEMENTPRACTICE FOR POLLUTION PREVENTION Both management commitment and comprehensive planning are critical to a successful pollution prevention program. products. and proper disposal practices.~~ ~ STD. identifying their sources. 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. 1. . communications. technology and economics. Developing an inventory of significant releases to air. source reduction. and wastes. This section presents an overview of media. c. e. To develop and produce natural resources economically and to conserve those resources by using energy efficiently. petroleum products. 1 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services f. (most preferred) (least preferred) I 1. developing approaches for reducing releases. Including pollution prevention objectives in research efforts and in the design of new or modified operations.3. and operations. Waste can be transported via three natural carriers-water. and waste materials. customers. use. consider the issues of community concerns. health. and environmental hazards and to recommend protective measures. proper waste handling. These basic concepts are critical in achieving pollution prevention goals. handle. and others in the safe use. To counsel customers. water.1 INTRODUCTION Pollution prevention is the practice of reducing or eliminating pollutant discharges to air. i. Industry should review its use of materials. health. and waste minimization methods. processes. and development of new products and processes. To commit to reduce overall emissions and waste generation. health. water. Supporting an outreach program to promote pollution prevention opportunities within the industry. including sharing of industry experiences and accomplishments. beneficial use. Steps to consider in developing and operating such a program include the following: a. and land.3 MEDIA Proper management of wastes is important to the protection of human health and the environment. To make safety. and the publicof information on significant industryrelated safety. and products in order to identify ways to reduce or eliminate pollution. and air. actions. h. It includes the development of more environmentally acceptable products. waste treatment. To extend knowledge by conducting or supporting research on the safety. Providing management supportfor ongoing pollution prevention activities through appropriate policies. transportation. They provide specific guidelines for compliance with these Guiding Environmental Principles. environmentally sound recycling. regulations. d. To participate with government and others in creating responsible laws. or land. employees. Pollution prevention requires continuous improvement in operating practices. e. and environmental effects of our raw materials. which are as follows: a. 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. workplace. c.API/PETRO ES-ENGL L777 m 0732270 05bVb75 T L 2 111 Waste Management in Exploration and ProductionOperations 1 Pollution Prevention 1. and/or land disposal Details are presented in 1. waste minimization. and disposal of our raw materials. f. To operate our plants and facilities. 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 recyclinglreuse treatment. transport. use. and products. practices. and to handleour raw materials and products in a manner that protects the environment and the safety and health of our employees and the public. products. Periodically reviewing and identifying pollution prevention options and opportunities. b. and evaluating their impact on human health and the environment. processes. d. changes in processes and practices. soil. operational impacts. and waste materials. and environmental considerations a priority in our planning. and resource commitments. processes. To work with others to resolve problems created by handling and disposal of hazardous substances from our operations. products. including the EPA hierarchy of waste management.
Pollutants found in water are measured in concentrations of parts per billion (ppb). Aquifers are part of a large water-recycling system as illustrated in Figure 1. domestic needs. or disposedmaterials. Materials fromspills or improper waste disposal may contaminate aquifers. and industry comes from underground aquifers. 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. and other sources. Contamby Evaporation and transpiration from bgd = billion gallons per day Figure 1-Basic Media of Soil. Also important are aquifers used for agricultural purposes.API/PETRO ES-ENGL L797 m 0732290 05b4b7b 957 W 2 API E5 All three media may provide pathways which potentially by polluting materials can migrate from their original source. Thus. pollutants can migrate to air and water and be picked up plants and animals. Air. Soil acts to retain spilled. stock water.STD. improperly stored. once in the soil.2 Soil Spills can adversely affect the capacity of soil to support agricultural. industrial. leakage of stream beds.3. These porous formations or sediments can store and transport groundwater from rain. streams. some of these pollutants may cause that water to fail drinking water standards. however. Most fresh water is stored in underground reservoirs called aquifers. recreation. lakes. irrigation of crops. Of major concern are those aquifers that contain water suitable for drinking. 1.3. human. and recreational uses. and reservoirs.1 Water Fresh water for human consumption. 1. and Water Can Transport Pollutants Away From Their Original Source COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . materials used and wastes generated exploration and in production operations should be managed by considering risk to human health and the environment via media pathways (see Figure 1).
Without sound scientific information. Air 1. many mans.2 EPA Hierarchy ofMethods EPA has developed the following hierarchy waste manof agement methods to guide generations toward waste minimization. reduce. while more significant threats remain ignored. this may occur onsite or offsite. Sound science is the to determining which environkey mental problems pose the greatest risk to human health. The goals of a waste minimization planare to reduce the total volume or quantity of waste generated and to reduce the toxicity of waste. 1. Solid wastes may be either solid. high profile but low risk problems may possibly be targeted. inherently generates wastes. water. 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.5. Some of these wastes are similar to those c.~ STD. Hydrocarbon recovery.4 Summary A properly implemented pollution prevention program can reduce or eliminate pollutant discharges to air. and the economy. or other surface water. and plant life through inhalation or dermal API member companies have implemented in-house waste contact. are not considered solid wastes. Acid rain is a known result of alThese programs go beyond traditional approaches to tering the chemical makeup of the atmosphere. Most of the wastegenerated by the oil andgas industry consists of naturally occurring materials brought to the surface in association with extracted oil and gas.3. gaseous wastes may alter the chemical minimization programs. Science is also critical to developing cost-effective strategies that address environmental risks. Recycling/Reuse-reuse and recycle material for the original or some other purpose. detoxify. and be leached downward into groundwater. liquid. increasing complexity of waste management regulations. API suggests the use of sound science to identify adverse impacts and the means to mitigate. of human impact on the atmosphere. be carried by rainwater to a lake. Treatment-destroy.an extractive procedure. and neutralize wastes into less harmful substances through the following methods: filtration chemical treatment biological treatment thermal treatment extraction COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . ecosystems. and for developing and improving pollution control technologies.5.3 Due to large increases in costs of waste management. creek. or contained gaseous material. inants can evaporate into the atmosphere.1SolidWasteDefinition According to federal regulations. semi-solid. animals. subject to federal permits under the Clean Water Act. and Gaseous waste released to the air can potentially affect huefforts to reduce potential environmental liabilities. a solid waste is any material that is discarded or intended to be discarded. Ozone deplewaste management and incorporate pollution prevention tion and global warming thought by some to be the result are concepts. API supports cooperative efforts to research and develop scientifically based standards and promotes technical advancements for the evaluation and implementation meaof sures to address environmental impacts. The four waste management hierarchy steps. for expanding waste management options reto duce risk. such as materials recovery or energy production.API/PETRO ES-ENGL 1777 I 0732270 U5b4b77 A 7 5 I WASTE MANAGEMENT IN EXPLORATION PRODUCTION AND OPERATIONS 3 generated by the general public and can be managed similarly. or eliminate them. in decreasing order of preference are as follows: a. 1. 1. Indirectly. 1. Science provides the foundationforidentifyingmethodstopreventorreduce pollution.5POLLUTIONPREVENTIONANDWASTE MINIMIZATION Waste minimization is a major component of pollution prevention. 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. Point source water discharges.4 UNDERSTANDING OPERATIONAL IMPACTS Because exploration and production (E&P) operations can affect all environmental media. balance in the atmosphere. or land.3. through the following methods: reuse reprocess reclaim use as fuel underground injection for enhanced recovery roadspreading 1.
the generator may further efforts to a. Field personnel and management shouldbe trained in environmentally sound and safe waste management practices. This section introduces the concept of a waste management plan-the tool for implementing these key elements at the field level. b. Health and safety concerns related to waste handling. The applicable facility waste management program. c. 2 Waste Management System 2. and recordkeeping. This plan is described in detail in Appendix A. both corporate and personal. associated with improper handlingof waste. It has proven successful for a number of member companies. and pollution prevention programs. state. and management is crucial to conducting environmentally sound operations. The key elements of training. e.1 INTRODUCTION In order to achieve pollution prevention and waste minimization goals. e. detailed training for certain operations that may be associated with waste management. 2. c. review of incidents. and feedback fromfield personnel. b. Appendix B includes planning aids to help in preparing the waste management plan. i. API suggests the ten-step waste management plan shown into in Table 1 for integrating the waste management system operations. c. A training program. d. Emergency response to a release of hazardous chemicals COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Be written for field operations. Environmental laws and regulations. Form a basis for training. In addition. b.S.3 Summary By incorporating waste minimization practices into the waste management program. Be periodically reviewed and updated as new practices and options are discovered. waste management needs be viewedas an to integrated system. Federal agencies also mandate personnel training as follows: a. Reduce potential environmental liabilities. The U.3 TRAINING Training in the proper identification and handling waste of material is vital in any exploration or production operation. a company may consider scheduling periodic training to cover updatesof procedures. evaluation. g. Meet company. f. A transportation program. Protect public health and worker health and safety. A waste management auditing program. waste tracking. inventories. A proper waste storage and disposal program.A good waste management system should include the following key elements: a. Occupational Safety and Health Administration (OSHA) requires specific. A system for waste tracking. A system for proper waste identification. Benefits of proper waste management. General environmentalawareness. Provide proper management guidance each waste genfor erated in E&P operations. includingrisk reduction for future liabilities. For these reasons. d. c. andauditing are also discussed. Both technology andregulatory requirements in the environmental field are changing constantly. open communication amongfield operations personnel. Review of internal environmental policies and other documentation of management support.4 API E5 chemical stabilization incineration landfarming landspreading d.2 SUMMARY OF A TEN-STEP PLAN FOR WASTE MANAGEMENT A waste management plan should a. Disposal-dispose of wastes through the following methods: landfills NPDES discharge solidification burial underground injection for disposal 2. e. and/or national waste minimization goals. g. A health and safety program. b. f. Instruction in waste management should include the following: a. h. environmental and legalspecialists. Save money by reducing waste treatment and disposal costs and other operating costs. 1. monitoring. j. Legal liability. Offer a solid waste plan that is area-specific. A system for pollution preventiodwaste minimization. A system for maintaining knowledge of pertinent laws and regulations. Protect the environment. e.5. b. d. Be used to ensure regulatory compliance and environmentally sound management of wastes. d. where actual waste management decisions should be made. f. An incident response preparedness program.
Improved compliance records and reductionof fines. Noncompliance can also subdustry andthe general public.subject a company toloss of business opportunities. OSHA also has training and information requirementsfor personnel who might be exposed to hazardous chemicals (HAZCOM-29 Code of Federal Regulations Part 1910. workshops. Select preferred waste management practice(s)-select location.1200). Other potential benefitsinclude company liability for the cleanup of improperly disposed the following: and waste. Improved communication between all levels of company tracking system. and imprisonment. Tracking wastes offsite helps prevent significant costs associated with improper waste disposal.management. and incidents or accidents. Step 6. or ties. Penalties for noncompliance are harsh. Step 4. as well as the ultimate disposition that waste. d. Sound waste management techniques should include track.34). and employees fines. Step 8. lease.STD. efits operations by allowing identification of waste minimization opportunities. it is important to know the types amounts of waste a. seminars.” Waste minimization-review processes that generate the waste and execute procedures to reduce waste generation. Step 7. Specific training is required for employees handling hazardous materials (49 Code of Federal Regulations Part 172. f. An auditing program’s goal is to help companies achieve higher levels of environmental performance. Waste identification-identify each waste generated within Step 2 area and briefly describe eachwaste. 2. Step 2. Many training opportunities are ject directors. officers. State agencies may have additional health. Area definitiondefine operating area such as oil field.S. One of the benefits of a waste management audit program 2. e.API/PETRO S-ENGL E 1777 m 0732270 0 5 b 4 b 7 7 b b 8 WASTE MANAGEMENT EXPLORATION AND IN PRODUCTION OPERATIONS 5 (including crude oil) and the following cleanup operations may require certified and trained personnel (HAZWOPER-29 Code of Federal Regulations Part 1910. Waste classification-categorize each identified waste. Summarize in documents. unit. 2.5 AUDITING Companies should consider developing audit programs for s may their own facilities a well as third-party facilities that accept their wastes. or state. Step 3. Management approvd-obtain management approval and support. of actions. and waste management requirements. and criminal exposure. Step 9. Step 10. List and evaluate waste management and disposal options-list the potential options for each waste and rank their desirability. and conferences available to in. c.702).5. and local laws on waste types for which requirements exist. safety. also review lease agreements and landowner agreements. imof Identification of types and amounts waste generated benof Table 1-Ten-Step Plan Summary Step I . Step 5. The U. The EPA requires annual training for certain hazardous waste generators (40 Code of Federal Regulations Part 262. Improved financial planning efficiency by reducing civil ing for both onsite and offsite disposal. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Review and update waste management plan-Define a review and update procedure. legal generated. criminal penalto available through academic institutions private companies.4 WASTE TRACKING is that company management provided with information on is To ensure proper waste disposal and to minimize individual waste management practices. state. as as to civil and criminal penalties. This should be documented by using a company waste b.1 Company Facilities An onsite waste management auditing program assesses the compliance status of a company’s facilities and programs for waste management. determine whether itis “exempt” or “nonexempt” and “nonhazardous” or “hazardous. Failure to comply with laws and regulations regarding waste management can Training can be done in-house or through enrollment in well schools. a waste management option for each waste and the best practice for each operation Prepare and implement an area-specific waste managementplan-develop and implement this by compiling a11 options into a plan. enhancing evidence insurability.120). c. Regulatory analysis-complete reviews of relevant federal. Department of Transportation (DOT) and some state agencies have transportation requirements for certain wastes.
See AppendixC for a summary of E&P waste sources. 2. a. Completion and workover.1 Accessing Areas of Potential Deposits Gaining access to an area of potential oil andgas deposits often requires construction of roads or footpaths into remote areas. 7. Construction may involve clearing trees and brush and COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Soil data. Remediation projects in progress. proper management by the commercial facility. Adequacy of onsite waste treatment equipment. Site reevaluation on a periodic basis is critical to ensuring that acceptable sites continue operate acceptably. Seismicsurveys and related geologic field work are conducted on potential locations. sure to future environmental liability that might result from im. The operational aspects of a facility.2 EXPLORATION Exploration operations identify locations that contain potential oil andgas deposits. This to which wastes are sent-operate in an environmentally and section summarizes wastes generatedeach phase and the in asfinancially sound manner.5. Monitoring well data. b. of phases are as follows: treatment or neutralization. 5 . Environmental expertise and financial standing. 7. 3. 5. Decision criteria that will rate a commercial facility eias ther acceptableor unacceptable. b. Construction and maintenance of a base camp or camp sites. Secondary containmentand spill prevention. Proper permits.b. 4. Manifesting records and procedures. 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.2. Offshore operations.d. Physical aspects. 2. Access to the area of interest. Unacceptable sites should be utilized for waste disposal not or recycling. Depth to groundwater. . Transportation. be The environmental impact of each of these efforts should considered. and reducing barriersto successful acquisitions and merger negotiations. S. 2. These operations may begin with to identify unremote sensing and aerial geomagnetic surveys derground geologic structures where oil and gas may have accumulated. ing: e.1. 3. Hydrogeology. 1l . Commercial disposal site audits should consider the follow.2. c. 6 . including: g. . Construction of seismic lines. This guideline was developed by API specifically for the oiland gasE&P industry. Three basic field of work activities contribute to waste generation: a. Remoteness of site location and public exposure potential. Location of the disposal of secondary waste streams that the facility is permittedto manage.Adequate contingency plans and training. shouldbe established. Adequacy of disposal or recycling processes. Drilling. 3. Housekeeping. Adequate waste storage prior to disposal. 10. Gas plant operations. including: l .a. S. Adequacy of lab analysis. Relationship with regulatory agencies. The work facilities that manage wastes properly. It is imperative to select commercial sociated environmental impact considerations. based on the collected insite formation. Companies should consider auditing commercial facilities to limit potential expo. History of violations. l . 6 . 3. 9. 4 Geology. 4 Site security. Field production. Insurance or other surety bonds. including: l . c. to 2. 6.1 INTRODUCTION a system or process to assess whether commercial waste disposal facilities-including reclaiming and recycling facilities Wastes are generated each phase of in E&P operations. seismic surveys and reare lated geologic field work the primary exploration activities that generate appreciable amounts waste. 3.1 Seismic Surveys Prior to drillingan exploratory well. The regulatory aspects of a facility. c. and disposal.6 API E5 proving public relations. Exploration. Compliance with permits. 3. Closure plans. inclusive recycling. Incoming waste testing and verification procedures. 5. f.2 OffsiteNoncompanyFacilities 3 Waste Generation in Exploration and Production Operations An integral partof a waste management program should be 3.
c. and domestic waste. Any unused shot holes and/or craters caused explosions should by be backfilledto reduce the chance subsequent erosion. oily Sanitary wastewater Scrap metal Soil. used oil and filters. The disposal of solid and liquid wastes is controlled by regulation.1. bridges. to delineate a discovered reserve or to develop a reservoir for production. vehicle/aircraft fueling facilities. which are discussed below.steps should be taken to assure that all nonrecyclable material is either (a) incinerated or buried onsite when allowed by applicable regulations. Disposal of these wastes can be a common problem for base campsin areas where water treatment and waste disposal facilities do not exist. Its keysystems and their uses areas follows: 3. Solid and hydrocarbon wastes should be evaluatedfor recycling whenever possible. Wastes generated include sewage effluent. noncontact (forexample. Base camp operations may generate many different wastes.1. discarded Used oil Vegetation Washdown water (rigwash) Water. cooling orfire water) Wood 3. nonexplosiveenergy sources. They will usually consist of personnel accommodations.2. Encouraging revegetation by native flora. Retaining and replacing topsoil. A system for the collection of sewage and watereffluents should be constructed and designed toflow through a soakaway systemof permeable. Good management processes includethe following: a. equipment.3 Base Camp Seismic exploration and geologic field work may require a large workforce.API/PETRO ES-ENGL L977 - ~ m 0732290 05b4b81 2Lb WASTE MANAGEMENT IN EXPLORATION AND PRODUCTION OPERATIONS 7 temporary displacement of topsoil'.3. Shallow holes are typically drilled along the seismic line and explosives are placed in them to be detonäted. the volume and toxicity of these wastes are minimal.2 Waste Summary A list of the major waste categories that may generated be during explorationoperations is shown below. petroleum naphtha Stormwater Tires Unused materials. and man-made structures (such as buildings.3. the drilling rig and the circulation system. provisions must be made proper treatmentor disposal.See Appendix C for a more complete listing of wastes generated by E&P. All material. empty petroleum hydrocarbon storage containers. helipads. An of alternative is to use vehicle-mounted. and building material wastes. exploratory drilling). Base camps are typically self-contained. e. earth-covered beds in suchway a as to not impact potable watersupplies. domestic refuse. Exploration Operations Wastes Absorbent material Antifreeze Batteries Domestic refuse Domestic wastewater Filters First-aid waste Hydraulic fluid Incineration ash Mudkuttings from shotholes Paint related materials Rags. unless otherwise agreedupon by the landowner and the operators. All food wastes and other putrefiable material should be collected and properly disposed. Wastes requiring special handling such as used oil and filters should be kept segregated and disposed a manner in 3.2 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 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Specific for steps to treatment and disposal include the following: a.2. b. The root stock and topsoil should be left in place.dining facilities. c.STD. In remote areas.3 DRILLING Drilling operations are conducted to locate the oil andgas (that is. (b) collected and carried out by the seismic crew once operations cease. The drilling operation has two key components. In general. 3. used oil and filters. or (c) otherwise appropriately managed. Using cleared foliage in soil conservation and control. that prevents surface water or groundwater contamination. and maintenancelparkingareas for vehicles and helicopters. Residue from burned or incinerated wastes should be buried or transported offsite. however. Wastes generatedduring this operation include explosives residue. line stakes or markers.1 Introduction The drilling rig provides the power and equipment (including safety equipment and systems such as blowout preventers) necessary to drill the wellbore. d. f. contaminated Solvents.1.2SeismicLineConstruction Seismic lines are constructed by clearing a 3. a base camp to accommodate personnel and equipment is sometimes necessary.1 Drilling Rig 3. and so forth) should be dismantled and removed from the area when work is completed. b. Landowner consent and/or permits from appropriate authorities may be required before waste disposal methods suchas incineration or construction of effluent field can be utilized.2.to 6-footwide footpath. 3. In such cases. 3.1.3.
Cement returns. It allows fluids to flow to the surface for processing after well completion.3 Reserve Pits Unlined or lined reserve pitsstore supplies of water. worn brake pads. Saltwater. salt. kgwash. used drill bits and pipe. hydraulic fluids. It protects the integrity of the wellbore duringdrilling.4 Casing Casing serves the following functions: a.3. State regulations usually require pit construction to comply with specified land use standards.3. Formation cuttings (such as shale. it cools the bit andflushes away any drilled cuttings and solids at the wellbore bottom. and dolomite). As mud exits the drill bit nozzles. rigwash. b. depth. or in areas of shallow groundwater. 3. solvents. or high-anglewells.or saltwaterbased mud systems.3. drilling mud is stored in tanks before it is pumped down the drill string. d. may contain minor amounts of the detergents that are used to clean the rig andprovide asafe work area. It keeps drilling fluids from leaving the wellbore and seeping into the formation. In specific cases. circulated downhole to coolthe drill bit and flush drilled cuttings fromthe bottom of the wellbore. closed-loop drilling mud systems maybe required to protect environmentally sensitive areas. lime. mostly water-based clays and inert weighting materials. Conversely. It also handles drill pipe when it is out of the wellbore and is used to run casing into the wellbore.1 Introduction The circulating system is the lifeblood of the drilling operation.2 Circulating System 3. In certain geographic regions. or soil.1.or saltwater-based muds are used when drilling deep. used lubricating oils and filters. d.2. high-temperature. These wastes include washwater (rigwash). used to transport cuttings to the surface where they are mechanically removed from the mud system. and remove the drilled cuttings from the wellbore. and similar materials. type of mud system. treated to fix or solidify contaminants). The mud then carries these drilled solids to the surface where they are removed using cleaners (such as hydrocyclones or desilters. Wastes generated during drilling mud formulation typically include empty additive containers (such as bags and pails) and unused or contaminated additives. they also add the necessary weight to prevent formationfluids from entering the wellbore and support and prevent damage to the underground formations being drilled. high-pressure. The systemused to collect rigwash may also collect rainwater.2 Drilling Mud The drilling mud. Unlined pits are normally used for freshwater mud systems. c. cut drill line. and stormwater runoff from the drilling location. and shale shakers). Wastes generated by the drilling rig result primarily from the operation and maintenance of rig equipment. discarded thread protectors. b. 3. These wastes are typically collected in a reserve pit adjacent to the drilling rig. Wastes generated during drilling operations may include the following: a. spe- COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . b.1. waste drilling fluids. centrifuges. mud) is formulated and maintained.3.3. 3.2. In this phase. depending on expected well conditions. Regulations applyas follows: a. API E5 3.3. and then returned to tanks wherethe process starts again. including compliance with applicable wa- 3. empty grease and pipe dope containers. Additives help cool the drill bit. After formulation. depending on the well's diameter. waste mud. c. The waste volumes generated will vary greatly. Drilling fluids (muds) and solids. e. Special regulations. gaskets. Liners may not be necessary for some oil. absorbent materials (such as clay and pads). lined pits are normally used for oil-or saltwater-based mud systems. Certain reserve pits may remain open for extended periods be because multiple wells may drilled froma single well pad. or water used to wash down the rig floor. e.2.3RotatingSystem The rotating system turns the drill bitso that it can penetrate underground rock and sandformations. is formulated using various additives. liners may be required in areas that are hydrogeologically or otherwise sensitive. It provides protection for underground sources of drinking water. and other operating factors. such as where soil and hydrogeological conditions preclude any adverse impact. State regulations normally restrict reserve pit usage to the drilling operation and require that pits be closed shortly after cessation of drillingoperations(normallywithin 6-12 months). water-sensitive reservoirs. It provides a conduit for fluid movement both up and down the wellbore. Oil. cial drilling fluids such as oil. c. and cuttings may be managed ensure protection of soil and to groundwater (for example. These systems not require do reserve pits. lubricate the drill string. the drilling fluid (that is.S T D * A P I / P E T R O ES-ENGL 1777 0732270 O5bllb82 1 5 2 m a sand formations. or in those adjacent to fresh surface waters. formation cuttings.
acidizing or fracturing stimulations. Other wastes include spent completion and workover fluids and filters example. There are many methods of completing or preparing a well for COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .3. See Appendix C for a more complete listing of wastes generated by E&P. cans. for in some cases. drilling rigs are also used. inhibitors. contaminated Solvents Spill cleanup waste. When using a drilling rig. replacing tubing or pumping equipment. A list of the major waste categories that may be generated during completion and workoveroperations is shown below./well treatment fluids Constructioddemolition debris Domestic refuse Domestic wastewater Drill cuttings Drilling fluids Filters first-aid waste Hydraulic test (BOP) fluids Hydraulic fluid Incineration ash Insulation material Mud sacks Paint-related materials Pallets 3. Completions and Workover Operations Waste Absorbent material Antifreeze Batteries Blasting sandhaterial Cement returns CompletionlW. Spent or used fluids are normally produced through flowlines to production facilities or trucked to operator-owned production facilities for further processing.STD. tracer materials]) 3.4COMPLETIONAND WORKOVER Once drilling operations are finished. production or injection. The producing formation may also be acidized or fractured to enhance production or injection capacity. Equipment includes fuel tanks. Wastes can include the following: a. Generally. hydrocarbon (for example. cooling or fire water) Wood Cement returns CompletionlW. c. and drums). garbage. h. LSA (low specific activity [for example. crude) Stormwater Thread protectors Tires Unused materials. Quarters. Drilling Operations Waste Absorbent material Antifreeze Batteries Blasting sandmaterial Polychlorinated biphenyls (PCBs) Produced sand Produced water Radioactive waste. Workover rigs are typically used completion activities. c. the well casing must be'perforated to allow fluid flow. See Appendix C for a more complete listing of wastes generated by E&P. and workover operations can range from virtually none for chemical treatments and logging operations to large volumes similar to those encountered during drilling operations. 3. newly drilled wells must be completed before being put into production. spent acids. b. produced sand and other solids. larger quantities of waste may be generated due to the rig's increased size. pipe racks. or plugging andabandoning of wellbores. In addition.may be required in environmentally sensitiveareas./welltreatment fluids Constructioddemolition debris Pipdequipment hydrates Pipe/equipment scale Pit sludges Polychlorinated biphenyls (PCBs) Produced sand Produced water Radioactive waste.API/PETRO ES-ENGL 1977 m 0 7 3 2 2 9 0 0 5 b 4 b 8 3 O77 WASTEMANAGEMENT EXPLORATION PRODUCTION IN AND OPERATIONS 9 ter quality standards for reserve pit contents. Solid waste (including paper sacks. produced (for water.O. Downhole equipment may also be installed to facilitate production or injection. d. recompleting to new reservoirs. e. and other maintenance wastes. The amount and type waste generated of from completion. LSA [low specific activity (for example. and other materials.4 Waste Summary A list of the major waste categories that may begenerated during drilling operations is shown below. Workover operations include installing tubing and packer. Contaminated fuel and spillage. Domestic waste and sanitary sewage. electric power generators.3OtherDrillingRigOperations Support equipment located adjacent to the drilling rig is essential to the drilling operation. The latter is not normal practice.3. and solvents.O. noncontact (for example. Used oil and filters. diatomaceousearth). Wastes generated fromthe workover rig itselfinclude hydraulic fluids. tracer materials)] Rags. well treatment. oily Sanitary wastewater Scrap metal Soil. used oils and filters. due to the higher operating cost of a drilling rig as compared to a workover rig. and equipment used to support the maintenance of personnel quarters. a. Workover fluids are also disposed of at commercial facilities when operators are unable to process them in their own production facilities. discarded Used oil Vegetation Washdown water (rigwash) Water. existing production and injection wells require periodic maintenance utilizing workover rigs.
The following sections describe each field facility area and the wastes that may begenerated from it in the production process. Oil and produced water contaminated soils and debris may result from leaks the stuffing box a pumping unit or from in of minor amounts of spillage during well chemical treatment.). d. 3. discarded Used oil Vegetation Washdown water (rigwash) Water. oil purchasers typically limit the amountof basic sediment and water (BS&W) less than to 1 percent. f. 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. 3.dispersants.5. flow lines gathering crude production can plug from a buildup of paraffin and scale. g. water vapor. noncontact (for example. Depending on the severity and be manlocation of the release. The stuffing box on a pumping well is the mechanical seal between the tubing and polished rod.1 Introduction After a well is drilled and completed. Gas purchasers set similar limits on water. Oil and produced water treatment systems. water. e. Pumping unit gear box lubricating oil mustbe replaced ocof casionally. hydrocarbon (for example. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .2 Paraffin Removal Paraffin precipitates within tubing and piping when oil containing parafin is produced up a wellbore and pressures and temperatures are reduced. hydrogen sulfide (H2S). Periodically. Recovered paraffin solids can be heated and returned to the production system or hauled to a storage site for future reclaimingdisor posal. gas. heating. For example.2.3 Stuffing Box 3. crude oil) being pumped acts as the seal lubricant. field facilities collect oil and/or gas from the well and prepare it for sale. either pipeline pigs are run through or the flow linesor hot oil is pumped through them to remove dissolve the plugging material. carbon dioxide (CO.5. crude) Stormwater Tires Unused materials.5. The objective of the production process is to separate constituents of the mixture. paraffin cut with downhole tools is generated at the wellhead.1 Introduction Wastes generated at the well site include paraffin. either because gear box malfunction or for preventive maintenance. Well fluids are often a complex mixture of liquid hydrocarbons.~ STD. b. cooling or fire water Wood 3. or servicing operations. Other field production facilities and operations.2. the stuffing box packingrequires periodic adjustment to minimize leakage. Becauseof the continuous wearing action of the polished rod.2. Flow line ruptures or leaks generate crude oil and/or produced water-contaminated soil. Injection operations. Scale material is also collected for disposal. or mechanical cutting remove it from the tubingandpiping.andhot treatment fluids are normally handled and treated as part of the crude stream in the field processing facilities.5. 3.4 Lines Flow Flow lines gather produced fluids from wells for transport to field facilitiesfor processing. Purchasers have contract standards for the oil and gas they will accept. Paraffin solvents or dispersants.5. and solids. contaminated Solvents Source sand Source water Spill cleanup waste.API/PETRO ES-ENGL L777 E 0732270 05b11684 T 2 5 10 API E5 Crude oilkondensate. The fluid (for example. When this occurs. These wastes are more commonly found at oil wells than at gas wells. c. contaminated soils may either aged in situ removed for treatment disposal. However. Compression and gas sales. remove those that are nonsaleable. oily Sanitary wastewater Scrap metal Soil. and BTU content. either onsite or or or offsite. workover. The field production facility can be grouped into the following areas: a.5 FIELD PRODUCTION 3. Paraffin solvents. and used gear boxlubrication oil. Plugging material thatis not dissolved back into the crude oil is recovered at apig trap at the facility inlet. Dehydration and sweetening.2WellsandGatheringSystems 3. Wells and gathering systems. and sell the liquid hydrocarbons and gas.2. oil and produced water contaminatedsoils.5. Oil storage and sales.
5. The (that is. Bottoms or sludges are generated if solids are recovered from the settling pit or tank. or other disposal. Produced water separated in the treaters goes to a disposal or injection system. The units agitate the water by injecting a gas.5. the free-water knockout (FWKO) is the first vesFWKO separates freewater sel to receive produced fluids.5. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . these treaters are occasionally drained to removesolids and bottom sludges.5.3 Oil and Produced Water Treatment Systems 3. much of the produced sand is also removed in other treating vessels.6ProducedWaterTreatingEquipment Several typesof produced water treating equipment are used to prepare the water discharge. Another type of treatment system utilizes gas flotation. This action flocculates the suspended oil.S T D . spent amine. Recovered may be oil returned to the oil treating system or recycled offsite. Three-phase separators. for Skim tanks. Field dehydration and sweetening units perform the same function as that described in greater detail for gas plants in 3.5. solids bottom sludges are removed from and the FWKO for reclamation. Leaks from this process may result in chemical-contaminated soils. grease.1 Introduction Injection operations at field production facilities are used to either dispose of produced wateror to enhance recovery of crude oil from the reservoir.including oily sand and solids. injection. depending on the type of system operated.5. Chemical injection pumps typically dispense chemicals from 55-gallon drums or bulk containers.5.5. Separated produced water then flows into the water treatment system for either disposal or reinjection.or other options. and water are then further processed prior to or disposal. returned to the oil treating system).4DehydrationandSweetening 3. Periodically.A P I / P E T R O ES-ENGL L777 m 0 7 3 2 2 9 l l 0 5 b 4 b A 5 9bL W m c WASTE MANAGEMENT EXPLORATION IN AND PRODUCTION OPERATIONS 11 3.8 3.4Heater TreaterdElectrostatic Treaters Heater treaters and/or electrostatic treaters separate emulsified oil and water. and dirt. oil or condensate. Produced Water Discharges to Surface Water Produced water that is separated from oil and gasmay be of sufficient quality to discharge after the above treatment. spent glycol.2 Free-Water Knockout Typically. 3.5 Chemical Treating Treating chemicals such as corrosion inhibitors are sometimes injected into the well orflowline to provide protection. emulsions (that is. and the absorption material must be replaced.3. injection. and bottom sludges recovered during cleanout operations.3. 3. There the gas.3.The sale primary waste generated by the separator consists of produced sand. scale. water not linked to oil an emulsion) from other proin duced fluids and solids.5. also separate produced water from produced fluids.5 Desanders Where produced water carries excessive solids (produced sand).5. Wastes may include iron sponge. spills should be as minimized via drip pans. gun barrels.5. Occasionally.2. These tanks must be cleaned occasionally to remove bottoms. provided it is also in accordance with applicable state and RCRAregulations (see Section 4). 3. bad oil) that cannot be treated successfully in a single pass through the treatment system must be placed in standby oil tank for a recycling and further treatment. These units are used to remove small concentrations of insoluble oil and grease from produced water. crude.3. or disposal. water. 3. The gas. pits or additional tanks are used to separate additional solids and oil from the produced water prior to discharge. and corrugated plate interceptors (CPIs) rely on gravity and residence time to remove residual free oiland solids from produced water. where they are skimmedoff.2 and 3. they enter the treatment system. 3. Typically.5.3. 3. in certain instances. However.5.3. through the liquid stream.5. 3. which have additional float mechanisms. Treaters that use hay or excelsior sections to absorb minute amounts of oil must be cleaned out periodically. treatment.5 Injection Operations 3. and solids are separated into individualstreams.7ProducedWaterTanks Produced water tanks may be required toprovide storage and additional settling time for sandsolids removal prior to discharge. Any spill should be managed described in the preceding paragraph. This material may also be recoveredas oil (for example.3 Separators Two-phase separators isolate produced liquids from gases as they flow from the wells.3.3. Each stream is then further treated in preparation for sale or disposal.3. usually natural gas or air.5. spent caustic.5. and filters and filter media. 3. The flocculated materials then rise to thesurface. as applicable. As is the case with the FWKO and other production vessels.1 Introduction When produced fluids and solids reach the field facilities. desanders may be utilized to remove these solids.
or CO. NaOH or Na2C0.backwash liquid should be returned to the production facilities for reprocessing. Water softening resin is typically used when cena tral water plant is not available.6 Air PollutionControl Scrubbers 3.STD. The resulting effluent is referred to as stack wash water. pressurizing produced water into the injection well. Filter media must be replaced on periodic a basis. Steam is also generated and used in some field production facilities and gas plants by burning natural gas. Other wastes from steam generators include fuel oil can filters. fly ash impingeson the steam generator convection tubes.7 Deionization Two other fluids associated only with TEOR cogeneration plants are deionized waterand backwash produced from the water purification process.) which reduces to NaHSO. soft water blowdown) isalso generated during startup and shutdownof both conventional andcogeneration steam generators. The method selected will be dictated by the formation type and method feasibility. flooding. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . soft water blowdown). Raw water used in the deionization process is either soft water or fresh water. and Na2S04.5. 3. As with injection disposal. steam flooding.5. Permanentfilters are periodically backwashed with fresh or produced water. Injected steam also drives pushes) the oil toward pro(or ducing wells. An electric motoror gas engine usually drives the injection pump.5.2 Disposal After initial treatment of producedwater. may be commingled with excess produced water. it heats the oil for easier recovery. regeneration brine. 3. filtering is frequently used to improve water quality before injection. Replaceable filters include sock. In general. if they are permanent.5. surplus soft water (for example.. spent water softening resin.5 TEOR CogenerationUnits 3.5. oilfield operators have generated steam using conventionally fired heaters known as thermally enhanced oil recovery (TEOR) steamgenerators. these include produced water injection. Several methods of enhanced recovery may be used. Waste fluids typically generated at TEOR facilities consist of water softener generation brine.Steam generators firedby crude orfuel oil may have sulfur dioxide air pollution scrubbers associated with them. water with low concentrations of dissolved calcium and magnesium). steam is sometimes injected into reservoirs to reduce oil viscosity and to enhance fluid production.5. cartridge. A typical waste generated facilities using steam is boiler at blowdown water. scrubber waste (that is. or canister units. andflue duct ash. as well as backwash from this water purification process. The water softening process creates a waste fluid identified as regeneration brine.5. The steam these generators make is injected into geological formations containing heavy crude oil.. source water injection. Soft water is used as steam generator feedwater to prevent scaling. Air pollution control scrubbers may be required control to sulfur dioxide and particulate matter emissions from exhaust gases of oil-fired TEOR steamgenerators. excess deionizedwater.5. deionization process involves The removing additional dissolved minerals present in water. Cogeneration of electricity and steam can significantly increase the energy efficiency of the process. a TEOR cogeneration steam generator consists of a turbine and its associated heat recovery boilers (steam generators).5. water utilizedfor enhanced recovery must be treated prior to injection. fuel oil. as described above. and stack wash. Surplus soft water for disposal (that is.5.To increase thermal efficiency of the generators. sulfur dioxide liquor). 3. TEOR steam generatorsare fueled by either crude oil.SO. After filtering. Recently. seawater injection. Waste lubricating oil and filters are typically generated at these facilities. other methods are also available.3 Enhanced Recovery Enhanced recovery is used to maintain pressures in the reservoir and to improve recovery crude oil from reservoir of formations.5. fly ash is removed by washing the tubes with water. produced water can be injected into the disposal well.4 TEOR SteamGenerators In heavy oil operations. The scrubber liquor waste typically has a neutral pH and low concentration of heavy metals. Na. refractory waste. the types of equipment used and the wastes generated are the same as described above. When burning crude. or natural gas. they must be backwashed.API/PETRO ES-ENGL L997 U 0732290 05b4bdb A T A 12 API E5 3. Backwash should be circulated to a solids treatment and disposal system. and soft water blowdown prior to disposal. Permanent filters may use diatomaceous earth or granular media suchas sand or coal.5. TEOR cogeneration steam generators have replaced some TEOR conventional steam generators. There. Traditionally. TEOR steam generators use soft water (that is. Typically. Deionized water is injected into the turbine combustion chamber to reduce nitrogen oxide emissions. which sometimes contains a small amountof surfactant. The process bubbles exhaust gas through abasic aqueous solution (usually SO. Excess deionization water. backwash water from the deionization process. Although these methods are most common.
excess Soil. or allow flowinto central facilities. oil. 3.8 Other Field Production Facilities and Operations Heat exchangers. hydrocarbon (for example. recovered fluids may include condensate. These include engine cooling water containing glycol and used lubrication oil and filters. treating and process vessels. f.2 Hydrate Prevention Pressure and temperature decrease as gas is produced from a reservoir.7CompressionandGasSales 3. or barge. waste Deionized water. filters. Wastes generated from onsite transfer operations include lubrication oils.) See Appendix C for a more complete listing of wastes generated by E&P. caustics. Laboratory testing.6. permit vapor recovery. e. Oil in stock tanks is transported offsite for further processing or refining via pipeline.5.2 and 3.7. solvents. storage tanks. salts. After scrubbing. sample wastes.7. Wastes generated from line heaters include spent thermal fluids (such as glycol. acids. solids Naturally occurring radioactive material (NORM) Pipe/equipment scale Pit sludges Polychlorinated biphenyls (PCBs) Produced sand Produced water Rags. Construction and demolition. Wastes generated from compressor operation are identical to those wastes generated by gas plant compressors (see 3.9 Waste Summary A list of major categories of waste that can be generated during field production operations is shown below.6 Oil Storage and Sales Treated oil that leaves the treatment system goes to oil stock tanks and is ready for sale. Other field production facilities or operations that may generate waste include the following: a.5.S T D .3 Compressors Compressors are used to boost the gas pressure to sales line pressure and/or gas lift pressure. Warehousing. hydrogen sulfide Soft water. Field Production Operations Waste Absorbent material Antifreeze Batteries Blasting sand/material Boiler blowdown Catalyst Cleaning wastes. contaminated Solvents Source sand Source water Spill cleanup waste. and other equipment is also an operation that can generate wastes. or salt mixtures) used to transfer heat from heat sources to the gas stream. process equipment Completion/W. 3. d. transportation. Wastes generated during cleaning include mixtures of spent cleaning solutions (for example. When shipping by tank truck or barge. The primary waste generated onsite from methanol injection is empty methanol containers. If sufficient water or water vapor exists in the gas stream. and maintenance facilities. oil. Domestic and sanitary waste handling and treating. Scrubber liquid. and/or produced waters.5. to Internal cleaning of tanks.5. Compressors may be driven by electric motors or by internal combustion or turbine engines. discarded COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . inject gas back into the reservoir for pressure maintenance.O.7. tank truck. b./welltreatment fluids Constructioddemolition debris Cooling tower blowdown Crude oikondensate. ice) may form and block flow lines. These tank bottom materials may require periodic removal. drainage from transfer hoses can be returned the system for reprocessing. metallic liquid Mercury. and residues Mercury.6). glycol systems. and drips and leaks from pumps and transfer lines. and detergents) and removed solids and/or hydrocarbons. excess Domestic refuse Domestic wastewater Filters Flue dust ash (fly ash) first-aid waste Hydraulic fluid Incineration ash Insulation material Lab waste. Methanol is sometimes injected or line heaters are sometimes used to prevent hydrate formation.5. absorption oil systems.6.1 Introduction Produced gas and fuel scrubbers are used where necessary to separate fluids from gas. c. these should be returned to the system for reprocessing. 3.5. the concentrations are dictated by field conditions. Office. crude) Storm water Sulfur dioxide liquor Sweeteningldehydration liquids Sweetening/dehydration solids 3. Tank bottoms Tires Unused materials. (Note that some of these wastes may be contaminated with naturally occurring radioactive material (NORM) and require special handling. oily Refractory waste Saltbath heater salt Sanitary wastewater Scrap metal 3. Solids and water continue to separate by gravity and accumulate in stock tanks. Methanol is typically used in low concentrations. Equipment maintenance.A P I / P E T R O ES-ENGL L997 0732290 0 5 b 4 b 8 7 734 m WASTE MANAGEMENT EXPLORATION IN AND PRODUCTION OPERATIONS 13 3.5. hydrates (that is. and other solids that have built up and reduced field production efficiency. scale. and the like must be cleaned to remove hydrocarbons.
The inlet gas may contain compounds such as carbon dioxide.STD. These can be removedby gas plant treating facilities. All natural gas contains water vapor.6GASPLANTOPERATIONS 3. The pits should be constructed and operated to prevent groundwater contamination.API/PETRO ES-ENGL L777 m 0732270 05bllbBB b70 m 14 API E5 Packing fluids Paint-Elated materials Pallets Paraffin Piggingwastes from gathering lines Pigging from wastes pipelines F’ipdequipment Wood hydrates Used oil Vegetation Washdown water (rigwash) Water.) removal facilities where high hydrogen sulfide (H2S) and carbon dioxide concentrations exist. condensed water. The sweetening processmay be conducted using units identical in operationto those used at field production facilities where centralized sweetening facilities are not available. These include engine cooling water containingglycol and used lubrication oil and filters.1 Introduction Some natural gas contains hydrogen sulfide. hydrocarbons can be recovered sale and produced for water can be separated for disposal. Wastes typically associated with inlet separation include produced water that may contain methanolor other treating chemicals. that to are usually pits. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . carbon dioxide. and office facilities are other activities that can occur at a gas plant and generate wastes. sometimes sweeteningfacilities are providedaswell. product shipping. diethylene glycol. 3. water. rust. pentane. If necessary.4.6. and butane for separate sale. pigging materials. It may also be conducted in dedicated sulfur recovery or carbon dioxide (CO. inlet separators are equipped with relief valves that vent emergency containment facilities.gas will be compressed toa sufficient pressureto allow the plant to operate. Dehydration is the process extracting water vapor of to make the gas marketable.6. and glycol is recovered reuse. 3. Natural gas streamsentering gas processingplants vary in composition. Gas plant treating and extraction processes include inlet separation and compression. propane. mercaptans. Small amountsof pigging materials can also be recovered at the pig receivingtraps at the plantinlet. and small amounts of solid material (such as.6. Liquid desiccants such as ethylene glycol. pipe scale. hydrogen sulfide. sweeteninghlfur recovery.2 Inlet Separation and Compression Gas can enter the facility in either an untreated or treated condition. For safety reasons. and heavier hydrocarbons are also present. natural gas liquids recovery.1 Introduction Natural gas plants often provide dehydration and compression facilities. for In solid desiccant dehydration. produced water) that exceeds separator capacity should reach the plant or if gas pressure exceeds designcapacity. they also extract natural gas liquids such as ethane. fluids from corrosion treatments. and certain solid impurities. cooling or fire water) Water softener regeneration brine Water softening spent resin. Emergency pits are not disposal facilities.Methane is thepredominantcomponent. Inlet separators are designed to send produced water and hydrocarbons to process vessels for additional treatment. Typically.Theseplantsprocessnaturalgasintoa marketable condition. silica-alumina beads. or other impurities that must be removedeither for field use or to meet the sales pipeline specifications. they provide control of emergency releases. Heat regeneration evaporates the water. or triethylene glycolabsorb the water.but smaller amounts of ethane. and reservoir formation material). silica-gel. noncontact (for example. propane. These fluids and solids may in some of circumstances contain trace levels hydrocarbons and treating chemicals. and butane. Treated gas then enters an extraction facility that removes the heavier natural gas liquids (NGLs) such as ethane. Wastes generated during the dehydration processconsist of glycol-based fluids. however. dehydration.6. and spent solid desiccants. domestic and sanitary waste handling and treating. There. glycol filters. natural gas flows through tower vessels filled with alumina.3 Dehydration 3.4 SweeteningBulfur Recovery 3. DOT 3. Warehousing. and recompression and plant utilities. Field production facilities can provide initial treatment. is conducted at the gas plant. all subsequent treatment. inlet filter media. This protects the facility if a fluid slug (for example. product storage. Vented fluids should be recovered in accordance with state requirements or operating procedures. construction and demolition. Wastes generated from plant inlet compressor operations are like wastes generated in field compressor operations. equipment maintenance. or a molecular sieve to absorb water vapor. Produced fluids such aswater and liquid hydrocarbons are usually separatedat the plant inlet. other sulfur compounds. Processes used at gas plants are like those used at field production facilities where centralized dehydration is unavailable. propane.6. butane. Natural gas is dehydrated by contact with either liquid or solid desiccants. this water content must be reducedto meet sales pipeline specifications.
The solid waste generated by this sweetening process is a nontoxic wastewater stream. or sent to a sulfur recovery facility. incinerated.4. iron chelate reduction.4.4. Sulfolane). Wastes generated in sulfinol sweetening include degraded amine and used filter cartridges or bags. iron sponge.6. The Claus process utilizes pelletized. 3. The primary waste generated is spent catalyst. Heat regenerates amine and sulfinol for reuse.4. coated on a carrier such as wood shavings. Natural gas bubbles through the vessel until the sulfur-converting compound is spent. The hydrogen sulfideis then burnedin the presence of oxygen to produce sulfur dioxide.4.6.6. and other sulfur-converting chemicals. As part of the regeneration process. Hydrogen sulfide is removed from natural gas by contact with amines.4.6. Amines are then regenerated by elevating the temperature to release acid gases.2 Amine Sweetening Amine treating of natural gasfor removal of hydrogen sulfide and carbon dioxide is the process that is probably most widely used in the industry. The primary waste is a nonhazardous slurry of sulfur and salts. and mercaptans (RSH) at feed gas pressure and temperature. 3.9MolecularSieveSweetening Molecular sieve absorbents are used to remove hydrogen sulfide. Wastes generated in amine sweetening include degraded or spent amine.3 Sulfinol Sweetening The sulfinol treating process utilizes an aqueous mixture of an aliphatic alkanolamine is. and 1.6.8ClausProcessSweetening The Claus process utilizes amine or sulfinol solutions to remove hydrogen sulfide from sour natural gas. caustic solutions. carbon disulfide (CS. This process involves the chemical reaction of an alkanolamine with hydrogen sulfide and carbon dioxide. 3. 3. The aluminum oxide does not react in the sulfur-making process but merely provides a greater surface area to speed and assist the process.4IronChelateOxidation-Reduction Sweetening This desulfurization process uses an iron-chelating solution to selectively remove hydrogen sulfide from gas streams through a reduction reaction.5IronSpongeSweetening In the iron sponge treating process. caustic solutions. This process is based on the reaction between aliphatic alkanolamines and acid gases at moderate temperatures.7OtherSulfur-ConvertingCompounds Other sulfur-converting compounds such as Sulfa-check are employed in one-step processes to remove low levels of hydrogen sulfide. When sour gas is contacted with a water solutionof chelated iron. emissions.9 pounds per pound of carbon dioxide removed.S or SO.WASTE MANAGEMENT ExPLoRnnoN AND P O U T N OPERATIONS IN R D CI O 15 Sweetening primarily lowers the hydrogen sulfide and carbon dioxide content of natural gas. a direct conversion using a single contact vessel occurs at ambient temperature. and acid gas. This process uses a nontoxic solution and creates little or no H. mercaptans. incinerated. oxidation (that is. 3. having air as the oxygen source) is used to regenerate the solution. Hydrogen sulfide and sulfur dioxide are then mixed and exposed to a heated catalyst to form elemental sulfur. The solution is regenerated by oxidation. sulfinol. and the physical absorption of these acid gases and other sulfur-containing compounds such as carbonyl sulfide (COS). and heavier sulfur compounds from COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .6. 3. In the iron chelate oxidation-reduction process. Here.6. the H2Sis converted to elemental sulfur in an iron reduction reaction. Most caustic treaters utilize a 10to 20-percent by weight sodium hydroxidesolution. In it. Ironsponge. inert aluminum oxide as a catalyst. Most caustic treaters consist of a simple vessel holding thecaustic solution through which gas is allowed to bubble. or sent to a sulfur recovery facility. The waste generated in the ironsponge process is the iron sulfide and wood shavings combination. iron oxide reacts with hydrogen sulfide to form iron sulfide.4 pounds per pound of hydrogen sulfide removed.6. normally carried out using air as the oxygen source.4. 3.4.6 Caustic Sweetening Small volumes of hydrogen sulfide may be removed from natural gas and NGLs by contact with a caustic solution. 3. The primary waste from caustic treating is spent caustic solution. Iron sponge is composed of finely divided iron oxide. hydrogen sulfide is driven outof solution. which is reused until spent. the caustic consumption is approximately 2. which must be flared. The resulting acid gas waste stream may be flared. 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. (that either di-isopropanolamine or methyl diethanolamine) and a physical solvent (that is. The acid gases and absorbed gases are released at nearatmospheric pressure and somewhat higher temperatures. and othersulfur-converting chemicals are spent in the process and are not regenerated. used filter media.).
5. 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. and filters. the oil and gas are metered andsold. They are also used to remove water vapor. Pigging wastesfrom DOT pipelines Pipe/equipment hydrates Pipelequipment scale 3.7 Other Gas Plant Facilities and Operations Process cleaning wastes identical to those generated at field production facilities are generated at gas plants.6. valves. noncontact (forexample. sorbents. hydrogen sulfide Soft water. which exist as liquids at moderate pressures.5. product shipping. internal combustion. spent or degraded absorption oil.6. electrical generators. 3. Wastes generated include lubrication oils.) See Appendix for a more completelisting of wastes C generated by E&P. andoily debris such as rags.6. and residues Mercury. simultaneous sweetening dehydration may be acand complished in the same unit. steam equipment. oily Refractory waste Saltbath heater salt 3. and office operations.7 TRANSPORTATION PIPELINES When the processing of crude oil and naturalgas has been completed at field production facilities or gas plants. product storage. or cryogenic processes. posits of naturally occurring radioactive material (NORM) and should be handled accordingly when removed fromservice. cooling or fire water) Water softener regeneration brine Water softening resin. Other activities that generate waste are warehousing. Transportation pipelines transport crude oil or natural gas and associated liquids to the market for sale or refining. Steam equipmentwastes are the same as those described in the field operations in 3. solvents. metallic liquid Mercury. As one bed is sweetening. cooling waters. piping. These pipelines are'usually referred to as transmission lines by the Department of Transportation (DOT).4.8 Waste Summary A list of major categories of waste that may be generated at gas plants is shown below. construction and demolition.~ ~~ S T D * A P I / P E T R O ES-ENGL L777 0732270 05b4b70 2 2 7 P 16 API ES gases and NGLs. domestic sanitary waste handling and treating. and detergents) and solids andlor hydrocarbons removed from the system. samplewastes. The primary waste generated is spent molecularsieve. NGL extraction may use compression and cooling processes. Compressors are driven by electric motors. spent Wood 3. acids. Thus. are extracted from natural gas. 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. wastewaters. caustics. absorption processes. process equipment Cooling tower blowdown Crude oilkondensate. laboratory testing. Molecular sieve sweetening is a batch-type regenerative operation requiring at least two beds for continuous processing.6. (Note that certain equipment. contaminated Solvents Spill cleanup waste. cooling tower water. wastewaters. Constructioddemolitiondebris Sanitary wastewater Scrap metal Scrubber liquid. and utility systems generate used lubrication oils. and so forth may be contaminated with de- COPYRIGHT American Petroleum Institute Licensed by Information Handling Services ~~~ . Wastes generated during the cleaning process include mixturesof spent cleaning solutions (such as. solids Pit sludges Polychlorinated biphenyls (PCBs) Produced sand Produced water Rags. Naturally occurring radioactive Vegetation material (NORM) Paint-related material Pallets Washdown water (rigwash) Water. Gas Plant Waste Absorbent material Antifreeze Batteries Blasting sand/material Boiler blowdown Catalyst Cleaning wastes. waste Deionized water. the other is regenerating. excess Soil.6ReCompressionandPlantUtilities Plant compression and utility systems (including fuel.5NaturalGasLiquidsRecovery NGL recovery is the process which hydrocarbons heavby ier than methane. hydrocarbon (for example. spent solvents such as petroleum naphtha used for cleaning equipment. compressors. maintenance activities.These engines. and boiler blowdown water. crude) Storm water Sulfur dioxide liquor Sweeteningldehydration liquids Sweeteningldehydration solids Tank bottoms Tires Unused materials. excess Domestic refuse Domestic wastewater Filters Flue dust ash (fly ash) first-aid waste Hydraulic fluid Incineration ash Insulation material Lab waste. pumps. or turbine engines. discarded Used oil 3.
Information in this document is not all-inclusive and may not be applicable in all situations.000 per day per violation are no longer uncommon and may also be assessed. including documented cases. that interpretation of regulations varies. Therefore. 3. (b) corrosivity. They impose responsibility and liability for the protection of human health and the environment from harmful waste management practices or discharges. Individuals may no longer claim ignorance as a defense against prosecution and the subsequent civil and criminal penalties. the wastes are handled and disposed in much thesame manner as those wastes generated at onshore operations. Liability has now been extended to include personnel who know or should know if a particular action is illegal. RCRA required EPA to establish procedures for identifying solid wastes as either hazardous or nonhazardous and promulgate requirements for managing both. hazardous waste$ are described as either characteristically hazardous or as listed hazardous wastes. and local regulations are constantly evolving andshould be compared with the information in this document to ensure consistency. An example of a reference or citation is the definition of solid waste. employees. however. Costs of alternative disposal methods. and shareholders to varying degrees of liability. Users are cautioned. and cement kilns). The EPA study was to include analysis of the following: a. Actions cover the gambit from improper recordkeeping to willful violations of appropriate regulations.S. References to specific regulations appear italicized and in brackets. Dangers to human health and the environment. This refers to Title 40 of the Code of Federal Regulations. for 4 EnvironmentalLegislationand Regulations INTRODUCTION 4. geothermal operations. Section 2. the U.8 OFFSHORE OPERATIONS Since many wastes generated at offshore operations are identical to those generated onshore. (c) reactivity. Environmental violations may subject corporations. b. Alternatives to current disposal methods. In addition to remediation expenses. Hazardous waste management is stringently regulated under RCRA Subtitle C. Current disposal practices. state. Congress deemed that these wastes required special consideration.S.1 Overview Enacted in 1976. d. Congress directed EPA to study such wastes and recommend appropriate regulatory action.1. Federal. State and localrequirements vary. States are required to submit Solid Waste Management Plans for EPA approval and funding.2. Sources and volume of waste. EPA activity and RCRA amendments after 1988 increased the emphasis on Subtitle D wastes and established additional minimum standards that state programs must include Subtitle D waste management. c.1 1980 RCRAAmendment When RCRA was amended in 1980. offshore operations are unique in that they may have the option to discharge in accordance with their NPDES (National Pollutant Discharge Elimination System) permit. the transfer of land may present economic risks from environmental concerns. it exempted oil and gas industry exploration and production wastes from regulation under RCRA hazardous waste provisions (Subtitle C). Similarly. the United States Congress recognized the special nature. which is located in 40 CFR P 261. electric utilities. From a waste handling and disposalstandpoint. A good recordof property conditionprior to transfer can be very beneficial in dealing with claims from subsequent owners and government agencies. 4. Once onshore. Readers should contact appropriate legal counsel for assistance and advice.2. To date. Impact of alternative disposal methods on exploration and production. transfer. In addition. a separate offshore discussion is not included in this document. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . high volume. Part 261. including imprisonment.2. Civil penalties may become quite costly through court and administrative agency involvement. f. EPA also listed certain specific wastes (including known poisons and carcinogens) as innately hazardous.2 THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) 4. managers. Nonhazardous waste disposal is regulated under RCRA Subtitle D and depends primarily on state controls. and low toxicity of wastes generated by oil and gas exploration and production operations (as well as by mining. fines of $25. EPA established four different criteria or characteristics to determine whether a waste is hazardous: (a) ignitability. The U. A careful evaluation of properties should be made to identify these liabilities prior to 4. it must be hauled to shore.1 This section summarizes key federal environmental laws and regulations that affect E&P waste management and disposal practices. Thus. If the waste stream is not permitted overfor board discharge. e. and (d) toxicity. EPA has established criteria aimed at ensuring that nonhazardous waste management facilities operate as sanitary landfills rather than open dumps.S T D * A P I / P E T R O ES-ENGL WASTE MANAGEMENT EXPLORATION PRODUCTION OPERATIONS IN AND 17 These facilities and operations are no longer considered uniquely E&P.
however. The practices themselves were not at issue. Toxic Substances Control Act (TSCA). Solid. In 1994. Enhanced recovery describes all efforts to increase ultimate productionof oil and gas from areservoir. Surface water discharge. h. in specific instances. d. rather.” In the June 30. d. certain regulatory gaps do exist. Liquid.S. Regulatory Determination. Superfund Amendments Reauthorization and Act (SARA). and until. Federal Insecticide. Land farming. c. Based on that study.1. Working with the Congress to develop any additional statutory authority that may be required. . EPA further stated that its plans wereas follows: “The Agency plans a three-pronged approach toward filling gaps in existing State and Federal regulatory programs by: a.2. and c. the problem was the lack of state regulations for their oversight. b. as stated in 4. the IOCCC published an update titled IOGCC Environmental Guidelines for state oil and gas regulatory programs.1. Contained gaseous materials. including: a. the authorities available under the Clean Water Act or Safe Drinking Water Act can be more broadly utilized. In addition. Improving Federal programs under existing authorities in Subtitle D of RCRA. a solid waste is any material that is discarded or intended to be discarded. Fungicide and Rodenticide Act (FIFRA). Associated wastes management. the Clean Water Act. Semi-solid. 4. This effort demonstrates that there is no need to increase federal regulation of E&P wastes. this practice is regulated under the Safe Drinking Water Act’s Underground Injection Control (UIC) Program.2. Congress on December 28. b.2 Definition of Solid Waste (40 Code of Federal RegulationsPart 261. Thereport outlines goals and criteria for state programs to use in regulating these wastes. the Agency madepublic its Regulatory Determination on June 30. This is because produced waterused in enhanced recovery is beneficially recycled and an integral is part of some crude oil and natural gas production processes.” 4. EPA has authority underSubtitle D to promulgate more tailored criteria. . the Interstate Oil Compact Commission (currently IOGCC-Interstate Oil and Gas Compact Commission) formed a Councilon Regulatory Needs to assist EPA with its approach to E&P wastes. Comprehensive Environmental Response Compensation and Liabilities Act (CERCLA).3 1990 IOGCC State Regulatory Guidelines In 1989.2.1988 EPA Regulatory Determination EPA conducted the study on E&P wastes and submitted a report to the U. Working with States to encourage changesin their regulations and enforcement to improve some programs. b. . Commercial products-including residues from spill cleanup-are not regulated aswastes unless.2) In simplest terms.2 June 30. and Safe Drinking Water Act. they are intended to be discarded. EPA also stated: “Existing Federal standards under Subtitle D of RCRA. These treatment methods/practices include the following: a. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .2. f.” EPA listed examplesof waste treatment methods and general field practices that. . had not been used in an environmentally sound manner. c. Arctic operations (in general). it stated: “The Agency has decided notto promulgate regulations under Subtitle C (for E&P wastes). Road spreading.18 API E5 4. solid wastes may be the following: a. Abandonment of existing and previously abandoned wells. Nevertheless. Commercial products may be regulated under other statutes. and efforts are already underway to fill gaps under these programs. Existing State and Federal regulations are generally adequate . IOGCC maintains an ongoing effort to peer review state regulatory programs using these guidelines. Central disposal and treatment facility management. c. Each of these will be discussed later in this section. 1987. do not fully address the specific concerns posed by oil and gas wastes. 1988. EPA has determinedthat produced waterinjected for enhanced recovery is not a waste for purposes of RCRA Subtitle C or D. Also. Pit construction. d. According to RCRA. b. g. Specifically excluded fromthe solid waste definition are certain point source dischargessubject to National Pollutant Discharge Elimination System (NPDES) permits under the Clean Water Act. the council produced a studyreport that represents the IOCC’s initial effort to assist EPA and the states in improving E&P waste management programs. In 1990. 1988. and enforcementof existing regulations in some States is inadequate. e.
3. SubpartD) EPA has listed numerous types or classes of solid wastes as hazardous because they a.3. It forms potentially explosive mixtures with water. It is a forbidden Class A. It is not a liquid and is capable of causing fire through friction.2.4). Commercial chemical products considered acutely hazardous when disposed (P-listed).2. burns so vigorously and persistently that it creates a hazard.This is not intendedto imply that the waste is exempt from regulation under other statutesfiaws. absorption of moisture. Contain any one of the chemical compounds or substances listed as hazardous constituents. can generate toxic gases. thereby failing the Toxicity Characteristic Leaching Procedure Test (TCLP). c. or fumes in a quantity sufficient to present a danger to human health or the environment. 4. d. exempt means an E&P exemption from Subtitle RCRA C regulation only.2.3. In this document.3 Hazardous Waste Criteria Determination Under RCRA. Althoughconsidered to beasolidwaste. d. EPA considers any nonexempt waste to be a hazardous waste if it exhibits any one of the characteristics of ignitability. The regulations contain four lists of hazardous wastes: a. 4. or toxi- 4. a waste considered nonexempt be per the E&P exemption may still considered exempt from regulation as a hazardous waste. It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated underconfinement. when ignited. b.3. It is aqueous and has a pH less than or equal to 2 or greater than or equal to 12. d.4(b)(5)]. it generates toxic gases.2. or Class B explosive as defined by the U.2. Hazardous waste from specific sources (K-listed)..25 inches per year. vapors. Other wastes are also considered exempt from Subtitle C under other provisions of RCRA (e. Hazardous waste from nonspecific sources (F-listed). These characteristics are described in the following sections. 4. Department of Transportation.5. b.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.2.3.2 Characteristically Hazardous Waste (40 Code of Federal RegulationsPart 261. or fumes in a quantity sufficient to present a danger to human health or the environment.2.8 for those identified as nonexempt. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .2. city. b.1 Listed Hazardous Waste (40 Code of Federal RegulationsPart 261. h. It is a liquid and has a flash point less than 60°C (140°F). e.3. 4. It is normally unstable and readily undergoes violent change without detonating.asdiscussedA above. c. Thus. It is readily capable of detonation or explosive decomposition under normal conditions (standard temperature and pressure).2 Corrosivity A solid waste is a corrosive if a.2.STD-API/PETRO E5-ENGL L797 0732290 O5b4b73 T38 m WASTE MANAGEMENT EXPLORATION AND PRODUCTION OPERATIONS IN 19 4. It is an oxidizer.g. See 4. When mixed with water.2.6 and 4. corrosivity. c. g. reactivity.or sulfide-bearing waste which. Have been shown tomeet certain human toxicity criteria. S .2. c. Chemical containers that are not empty by EPA's definition also are hazardous wastes. 4. provided it meets one the of other exemption categories.2.1 lgnitability solid waste is ignitable if a.5. Commercial chemical products considered toxic when disposed (U-listed).3 Reactivity A solid waste is reactive if a.2. f. must be managed as hazardous. a solid waste may be designated as a hazardous waste either by being specificallylisted or by exhibiting one of the characteristics identified in the regulations. or spontaneous chemical changes and. 40 Code of Federal Regulations Part 261. It is an ignitable compressed gas. It is a cyanide. b. These include certain reclaimed materials and point source discharges subject to Section 402 of the Clean Water Act.7 for wastes that have been identified as exempt and 4. wastes that are uniquely E&P have been specifically exempted from being considered hazardous [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 a hazardous waste. b. when exposed to pH concentrations between 2 and 12. It reacts violently with water. or specifas ically excluded from regulation as a hazardous waste. vapors. Typically exhibit one or more of the characteristics of hazardous waste (see below).2. It is a liquid and corrodes steel at a rate greater than 0.
Hazardous waste generated by a conditionally exempt small quantity generator is typically not subject to hazardous waste regulations (except for the identification requirements). Pit sludges and contaminated bottoms from storage or other wastes. 1991). Large quantity generators (that is. amine filter media. but less than 1000kg r. operators should avoid commingling exempt and k. per month. For the other generator categories. and hydrogen sulfide EPA requirements for hazardous waste generators vary. EPA has begun rulemaking that may replace or greatly alter the mixture rule. posits generated and removed from piping and equipment b. Packing fluids.S.lead.. A facility may besubject to small generator requirements one month and large quantity generator requirements the next month. and emulsion from production separators. The addition of organics to the TCLP list in 1990 expanded the potential universe nonexempt E&P wastes that of might be characteristically hazardous. Most E&Pfacilities would probably fall under this category. Small quantity generators (SQGs)are those facilities that prior to transportation. fluid treating To prevent creating characteristic hazardous waste. solids. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . and backwash (assuming the calendar month. Accumulated materials such as hydrocarbons.. depending on the volume of hazardous waste generated. and for pesticides.STD-API/PETRO ES-ENGL L997 9 0732290 05bYb9g 9 7 9 m 20 API E5 Contaminant levels have been established for heavy metals such as chromium. iron sponge. Only a few E&P facilities fall under these q. a. scrubber liquid and sludge. Produced sand. for organics such as benzene and toluene. backwash. These requirements depend on the quantity of hazardous m. operators should segregate the following itemsfor separate management: 4. Also.2. filter media. e. because some exempt wastes may have disposal of exempt wastes. hydrates.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. Produced water. d. Unused U-listed and P-listed chemicals and their g. storage facilities that hold product and exempt waste.] The intent of this rule is to prevent avoidance of hazardous waste regulations through dilution. glycol filters. requirements are identif fied in 40 Code o Federal RegulationsPart 262. filter media. and mercury. Cooling towerblowdown. treatment. f.2. Workover wastes. amine filters. In particular. Well completion. most restrictions. [2200 lbs] or greater per month) of hazardous waste have the p. opervessels. waste generated and/or accumulated at a facility in a given n. Conditionally c. Drill cuttings. including glycol-based nonexempt waste streams unless they have determined that compounds. Drilling fluids and cuttings from offshore operations disposed of onshore. hydrocarbon solids. filter itself is not hazardous and the residue in it is from an exempt waste stream). December6. h. sand. b. Gas plant sweetening wastes for sulfur removal. Commingling acharacteristically hazardous waste with a nonhazardous waste may also render the entire waste stream as hazardous if the resultant combined waste stream displays hazardous characteristics. including 4. and stimulation fluids. (2200 lbs). 1.6 EPA’s List of Exempt E&P Wastes The following wastes are listed as exempt in EPA’s June 1988 Regulatory Determination: a. tions). hazardous waste characteristics (such as benzene concentraj. Other listed hazardous wastes from other wastes. and the exempt waste does not have hazardous waste characteristics. Gas plant dehydration wastes.5 and 262) itated amine sludge.4 EPA’s Mixture Rule (40 Code o Federal f Regulations Part 261. and production impoundments. exempt quantity small generators (CESQGs) are those facilities that generate 100 kg (220 lbs) or less per month. backwash.5 for the special requirements for hazardous waste generated by conditionally exempt small quantity generators. molecular sieves. Basic sediment and water and other tank bottoms from containers.2. Spent filters.5 Quantity Determination (40 Code of amines. Pipe scale. Rigwash. b. precipFederal Regulations Parts 261. CA DC. ators should segregate characteristic hazardous waste from i. v. and other derequirements. Reference 40 Code of Federal Regulations Part 261. Drilling fluids. generators of 1000 kg o. a. generate greater than 100 kg (220 lbs). [The validity of the mixture rule has been overturned in court (U. 4. 950 E2D 751. some wastes previously characterized as nonhazardous may now fail the TCLP test for benzene. Because of the mixture rule. c. Shell Oil Co. 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 is init jected or otherwise disposed of. v. Liquidhydrocarbonsremoved 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. 4.2.7AdditionalExempt 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, it appears that EPA focused on wastes necessary to conduct socalled 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.
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. Refinerywastes. 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 Determination 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 arefrom normal operations and are to be refined along normal with process streams at a petroleum refinery facility (see 40 Code of Federal Regulations Part 279). The above sections on exempt and nonexempt wastes only address those wastesgenerated 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).
4.2.8 EPA’s List of Nonexempt E&P Wastes
EPA’s Regulatory Determination for E&Pwastes 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.
for Nonexempt Wastes
b. Gas plant cooling tower cleaning wastes. c. Painting wastes. d. Oil and gas service company wastes, such as empty
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 fortesting, 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 wastethat the is entire waste stream could its exempt status and perhaps lose have to be managed as a hazardous waste. If the nonexempt wasteis a listed hazardous waste, EPA's mixture rule (see 4.2.4) would make theentire commingled waste stream subject to stringent RCR4 Subtitle C requirements, includingthe 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 promulgated. These state rules are at has least as stringent as the federal regulations and may be more stringent. Certain wastes (such asbestos, NORM, and PCBs) are as regulated by laws other than RCRA. For example, the Clean Air Act, Occupational Safety and Health Act, Toxic Substances Control Act, and some state laws can also regulate management of E&P wastes.
erals, including mining of sulfur by the Frasch process, in situ production of uranium or other metals from unmined ore bodies, and solution mining ofsalts or potash. d. Class I Wells used to dispose of hazardous wastes or raV dioactive wastes into or above (within one-quarter mile) a formation that contains an underground sourceof 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 atthe 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 impede 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 waterfor any public water system; or that contains a sufficient quantity of groundwaterto supply a public watersystem; 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 at USDW as discussedin 40 Code ofFederal Regulations Pr 146.4(b). An aquifer that contains minerals or hydrocarbons or that are commercially producible or situated at a depth is location that makes the recovery of waterfor drinking water purposes economically or technologically practical may be exempted. Class II regulatory programs are either directly administered 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-specifiedstandards. 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:
4.3 THE SAFE DRINKING WATER ACT (SDWA) 4.3.1 Introduction
The SDWA was passed in 1974. Legislation was subsequently passedfor regulation of underground injection wells under the Underground Injection Control (UIC) program. Drinking water standards were also established by the SDWA.
UIC Program (40 Code o Federal f 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 tothe entire class. The following descriptionsof injection wellclasses are taken from Part 146, Subpart Aof 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 thatare liquid at standard temperatureand pressure. c. Class III: Wells that inject fluids the extraction of minfor
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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.
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. as Point sources are very broadly defined 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 water of theU.S. are a 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 produced water arespecifically of in prohibited unless the exemptions Title 40 Code of Federal Regulations Part 435,Subparts Cand E, are applicable.
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 includeprivate 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 contaminantssuch as benzene; inorganic contaminants such as fluoride; and microbiological contaminantssuch as total coliform, viruses, and giardia lamblia. b. Maximum secondary contaminant levels were established for contaminants such chloride, iron, total dissolved solids as (TDS), aswell as for color and odor. c. Water systems are to be lead free.
A discharge permit is required from or a state with EPA jurisdiction over the NPDES program before discharging any pollutants. Permit coverage canbe obtained with an individual permit or, where available,a general permit. Since some E&Pfacility water systems must meet these NPDES permits are required for some E&P facilities and provisions, awareness of water system standards is another waste management operations. Wastewater treatment and factor to consider when designing and operating E&Poperproduced water point discharges into waters of the U.S. are ations and E&P waste management facilities. examples of activities requiring permits. A general permit is issued where effluent standards or lim4.4 THE CLEAN WATER ACT (CWA) itations are set a particular industry.An applicant may apfor 4.4.1 Introduction ply to be included under the particular general permit specific to the industry and area of the facility. General permits are The CWA was enacted in 1972 primarily to control point common in some states and on the Outer ContinentalShelf source discharges into watersof the United States. All point source discharges require National Pollutant Discharge Elim- (OCS) and near-shorecoastal waters. Permitted dischargesof produced water, muds, cuttings, ination System (NPDES) and/or equivalent permits. state and other categories discharge with effluent limitations are of Under Section3 1 1 of the CWA,discharge of a reportable common on the OCS and near-shore coastal waters. quantity of oil (causes a sheen) into waters of the United Under someconditions, waste treatmentat an E&P operaStates must be reported to the Coast Guard National Retion maychange. If the volumeor characteristics of the waste sponse Center in Washington D.C. Operators are subject to a being treated or the technology used to treat waste changes fines and penalties spills are not reportedas required under if significantly, it may be necessary to revise an existing permit. the Act. Permits require strict adherence the standards prescribed to EPA promulgated Oil Pollution Prevention Regulations and monitoring of the discharge and reporting to the EPA (40 Code o Federal Regulations Part 112) in 1973 to mitif and/or state. gate the impacts of accidental spill discharges onto surface Permits may take months or even years to apply for and waters. receive. Thus, the need for permits shouldbe addressed early Point source discharge categories for operations covE&P in any E&P waste management operation. ered under40 Code o Federal RegulationsPart 435,such as f
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sional engineer and reviewed every 3 years. Finally, the regulations require that an SPCC plan be prepared within 6 months of commencement of facility operaStorm water regulations were issued EPA inNovember by tion and implemented within 1 year after commencement of 1990 aspart of the NPDES program. operations. These regulations require facilities that discharge storm The guidelines for preparing and implementing an SPCC water associated with industrial activity obtain an Individto plan are found at 40 Code of Federal RegulationsPart 112.7 ual, Group, or General Storm WaterPermit. for prevention and control of an oil spill. If installation of the E&P activities are generally exempt from storm water perequipment called for in the guidelines is not practicable, a mit requirements unless the particular facility has had a restrong contingency plan must prepared following the probe lease of a reportable quantity (RQ) oil (oil sheen on water) of visions in 40 Code of Federal RegulationsPart 109. or other hazardous substance in storm water anytimesince November 16, 1987, or unless storm water discharges con4.4.6 Dredge and Fill (33 Code of Federal EPA’s current tribute to a violation of water quality standards. Regulations Parts 323 and 325) interpretation of the releaseof an RQ is that therelease must The Army Corps of Engineers (COE) administers the occur into storm water, presumably during a storm event. Clean Water Act’s Section 404 dredge and fill permit proThe deadline for E&P Group Permit applications has expired. Those facilities that have not appliedfor Group Permitswill gram. Permits are required for some E&€’ activities such as need to either apply for an Individual Permit or file a Notice the constructionof artificial islands; construction canals or of of Intent to be covered underone of the General Permits. facilities in wetlands; installations on the OCS; construction Storm water associated withindustrial activity means the of fishing reefs (such as abandoned rigs or rig into reef prodischarge from any conveyance used collecting and confor grams); constructionof a submerged pipeline acrossa navigaveying storm water that is directly related to manufacturing, ble water of the U.S.; and discharge of dredged or fill material processing, or raw materials storage areas at an industrial into the waters of the U.S. plant. Storm water includes storm water runoff, snow melt The COE and EPA will determine whether the proposed runoff, surface runoff, and drainage. Storm water is regulated discharge will violate any water quality requirements. Either when it is associated with industrial activities and is disagency may place conditions on the permitto ensure complicharged via a point source either directly or indirectly into ance with applicable water quality requirements. the impoIf the waters of the United States. sition of conditions cannot ensure such compliance, the Construction activities are identified as a special category permit will bedenied. that requires regulatory attention. A Storm Water Permit is Coastal Zone Management (CZM) consistencymay also required for construction activities that impact 5 or more in be applicableif the activity is to take placea state operating acres of total land area. under an approved CZM program. Permits will also be reLocations, such as those in the coastal or offshore areas, or viewed for any potential impact on threatened endangered that have NPDES permits that authorize the discharge of species under Section 7 of the Endangered Species Act deck drainage would generally be covered for storm water be (ESA), andan Environmental Impact Statement (EIS) may discharge under that category. Specific review the applicaof required. ble NPDES permit shouldbe made todetermine if storm waNot all activities have to be permitted individually. COE ter is included. and EPA also permit activities under general permits.
Storm Water Permits (40 Code of Federal Regulations Part 122.26)
SpillPreventionControland Countermeasure Plans(40 Code of Federal Regulations Part 1 12.7)
Operators are requiredto prepare Spill Prevention Control and Countermeasure (SPCC) plansfor nontransportation-related facilities located in state waters and onshore in areas where spills can potentiallyenter waters of the United States. or fixed platfoms. This includes drilling rigs, workover units, SPCC plans are requiredfor facilities that have oilstorage capacities of more than660 gallons ina single tank, 1320 gallons or more collectively aboveground, or 42,000 gallons or more underground. The SPCCprogram sets minimum standards for certain aspects of facility design and operation. The SPCC plan must be certified by a registered profes-
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 the issuing authority. Regional permits by are generally issued for up to 5 years. Individual permits generally take the form a standard permitor a letter of perof mission for a project of short duration, such as some construction projects. b. Nationwide andother general type permits arealso available. Permits for structures are generally of an indefinite duration with no expiration indicated. Many E&P waste managementactivities, such as siting of new or expansion of older treatment facilities, landfarming and landspreading operations, production platforms, explo-
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4. TSCA was established to fill the regulatory gaps left by other laws [for example. or disposal. COMPENSATION. or processing of a new substance not already on the TSCA inventory. TSCA empowers EPA to evaluate and regulate chemical substances and mixtures that may havean adverse impact on human health and the environment.5 THE CLEAN AIR ACT (CAA) The Clean Air Act. Under CERCLA. in order to avoidcontaminating exempt E&P wastes withthose substances. or by imposing labeling requirements. EPA has broadenforcement 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). and motor vehicles and fuels. TSCA also allows EPA to recommend product substitution. permits and enforcement. If it is determined that unreasonable risk exists. EPA can request jnformation or testing for a specific chemical substance or mixture manufactured. Care should be taken in handling CERCLA hazardous substances at E&P sites. All E&P facilities or locations are subject to TSCA. All areas of the nation are classified as attainment or nonattainment areas. THE TOXIC SUBSTANCES CONTROL ACT CrSCA) 4. was most recently amended i n 1990.7.Thisrecentamendment. and other activities fall under the above permits requirements. TSCA recognizes that adequate data must exist to evaluate the chemical substances and mixtures. are regulated as ozone precursors. and Rodenticide Act (FIFRA)]. distribution. b. enacted in 1970. Evaluate damages to natural resources. Only those chemical substances and mixtures that are on the TSCA inventory may be manufactured. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Drug. importation. c. 4. in order to avoid liability for expensive cleanup activities. contains important attainment provisions for air quality standards.S. processed. and lead. CERCLA provides operators with a significant economic incentive to properly manage disposition of solid wastes at both onsite and offsite locations.commonly known as the Clean Air Act Amendments of 1990. This provides for strict liability without regard fault and. However. If required data is insufficient or unavailable. effective January 1. in appropriate circumstances. Two criteriapollutants. and Cosmetic Act (FFDCA) and the Federal Insecticide. reporting. AND LIABILITY ACT (CERCLA) 4. use. TSCA regulates identification and management of certain chemicals. The others are carbon monoxide (CO).). d. imported. and notice requirements. hazardous air pollutants (HAP). 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.7 THECOMPREHENSIVEENVIRONMENTAL RESPONSE.). this risk an may be reduced by banning or restricting a substance in some or all aspects of its manufacture. TSCA imposes broad regulatory control over all chemicals produced in the U. or used for commercial purposes in the United States. insecticides. They should be included in the waste management strategy. Fungicide. commonly known as Superfund. For example. Create a claims procedure for parties who have cleaned up sites or spent money to restore natural resources. imported. applies to all chemical substances and mixtures that are manufactured. TSCA was one of Congress’ responses to the dangers of human and environmental exposure to chemical substances and mixtures. particulates (PM-lo). for the imposition of joint and several liability. CERCLA. substances regulated under these other laws are not subject to TSCA. Ensure that they are cleaned up by responsible parties or the government. imported. distributed. processed.STD. Identify sites from which releases of hazardous substances into the environment might occur or have occurred.6 additional data must be developed to make informed decisions. depending on whether they achieve the national ambient air quality standard for ozone or four of six criteria pollutants. or for the manufacture. 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. as such polychlorinated bypheryls (PCBs). few other TSCA programs have routine impact. distributed. Courts have interpreted the statute to be retroactive in its to application.volatileorganiccompounds (VOCs) and nitrogen oxides (NO. These non-TSCA regulated substances include food additives regulated under the FFDCA and products such as biocides. Because E&P is an extractive rather than manufacturing industry. or processed by E&P. 1977.API/PETRO ES-ENGL 1997 m 0732290 O5bllb77 45b W WASTEMANAGEMENT EXPLORATION PRODUCTION IN AND OPERATIONS 25 ration drill pads. sulfur oxides (SO. the Federal Food. recordkeeping. These controls include testing. acid deposition. Therefore. stratospheric ozone protection.1 Introduction TSCA. or used for commercial purposes in the United States. and herbicides regulated under FIFRA. was enacted in December 1980 and established a program to: a.
also known as the Emergency Planning Community and Right-to-Know Act (EPCRA).1. in their entirety. pouring. Congress stated that the exclusion for E&P wastes c. Any changes at the facility that might affect the local B. pumping. 96th Congress. RCRA. Reporting is also required for onsite injection any hazardous substance or pollutant or contaminant). federal permitted releasesor discharges are exempt from this reporting requirement. 4. even though they contain substances otherwise listed as hazardous. pollutant. 4.Rep. or disposal. LEPC. Thus.7. not land. or disposing into the envito E&P operations. In addition. of der SARAand/or CERCLA doesnot necessarily satisfy any Users of this guide should seek legal counsel on the issue of other federal or state release notification requirements (for reporting releases of hazardous constituents of exempt E&P example. production of the name of the designated emergency coordinator who will crude oil or natural gas (E&P wastes) are exempt from regwork with the LEPC in developing the local emergency ulation as Subtitle C hazardouswaste. dumping. recyis exception is if the hazardous substance nonvolatile and the cling. In addition. which is not considered aspill or release to the environment. such as a concrete pad. gasoline. A list of both exempt plans. injectf. containers. discharge. d. produced water. Section 31 1 requires any facility that is required under OSHA rules to maintain Material Safety Data Sheets 4. water. providing that the material is recovered. purpose of conducting anonsite inspection. Section 303 requires such a facility to notify the LEPC of or sociated with the exploration. escaping. including indigenous hazardous substances). Section 312 requires facilities to provide informationanor into the environment equal to greater than the applicable nually on the quantity and location of those chemicals conRQ in a 24-hour period must be reported the Coast Guard to tained on their specific chemical inventory lists. crude oil fractions. drilling fluids. The EnvironmentalProtection Agency has (RQ).26 API E5 4. Section 304 requires immediate emergency notification applies.1 Petroleum Exclusion CERCLA provides for the exclusion petroleum. EPA interprets the term petroleum to encompass crude oil. 2d SesSARA EHS that is in excess of the reportable quantity sion 28 (1980)l.7. orar are now required reporting under this section. Any spill or release e. and other wastes asb. and refined products exam(for ple. “notwithstanding the presence in such substance of and follow-up reports to the SERC and LEPC of any spill.Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC) they are subthat posal Act has been suspended by Act of Congress. and other closed receptacles containing chemicals. the appropriate state III also requires that any facility covered underSections 31 1 and local agencies may also require notification. wastes. discharging. [S. includof ing crude oil or any fraction thereof.2 E&P WasteExclusion COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Section 313 of SARA Title III does not currently apply ing. or water). Revisions to this to quantities (RQ) of regulated hazardous substances the enlist must be reported within 90 days. 848. leaching. vironment (that is. This section pertains to annual reporting ronment(including the abandonment or discardingof requirements for releases and emissions of certainlisted barrels. An and offsite transfers of listed chemicals for treatment. stances. and local fire department. any hazardous or toxic chemical.” Thus. emitting.1. or contaminant. drilling muds and leak.2 The Superfund Amendments and Reauthorization Act (SARA) Title III of the Superfund Amendmentsand Reauthorization Act of 1986 (SARA Title III). Emergency reporting uncluded from the definition CERCLA hazardous substance. No. Under ject to the law. injection. leaking. Source reduction and recycling activities i) release is into a contained area (that is.1.3 Reporting SpilldReleases (MSDS) to submit them or chemical inventory lists to the CERCLA also requires reporting releases of reportabIe SERC. has six programs affecting or with the potential to affect E&P: a. and nonexemptE&P wastes are contained in Appendix In emergency plan or the designation of the “emergency coorlegislative historyclarifying the definitionof hazardous subdinator” must be reported to the LEPC.7. EPA has interpreted the petroleum exclusion to include. pure petroleum and pure petroleum fractions. TSCA 0 8(e)). emptying. development. Section 302 requires any facility possessing any Extremely Hazardous Substance (EHS) in excess of a specified The CERCLA definition of hazardous substance in SecThreshold Planning Quantity (TPQ) to inform the State tion 101 (14) includes RCRA hazardous wastes and excludes any waste the regulation of which under the Solid Waste Dis. from the definition of hazardous substance. or disposal into the enbrines that have been excluded by regulation are not hazvironment of any CERCLA “hazardous substance” or ardous substances. air. land. This requirement is in addition to any reporting renot always treated RCRA-exempt production waste asexquired by CERCLA Section 103. and 312 allow access to the local fire department for the CERCLA defines a release to mean: any spilling.7. leaching. SARA Title National ResponseCenter.
The inclusion. make determinations as to whether or not an E&P project (activity) will adversely impact a threatened or endangered species. in the form of an environmental assessment or environmental impact statement (EIS). and Federal agenciesare required by Section 7of the Endangered Species Act (16 U. increases limits of liability.9.S.3). revises the measure of damage of natural resources. and training. establishing restrictions. or change of status of a species with regard to the protected species list follows formal rulemaking procedures. as appropriate.C. Section 603 of FLPMA (43 U. 1991. offsetting the impacts within a mitigation bank. increases financial responsibility. by the Secretary of the Interior. Plans that address specific classes of facilities. d. The spill response system includesthe following types of plans: a. Single company plans. a negative declaration will be issued under Section 7of the ESA. 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. and if so.S. under 50 Code of Federal Regulations Part 402. If a species may be adversely impacted. terminals. The authority to place species on the endangered or threatened list is vested in the Secretary of the Interior and the Secretary of Commerce.2 and 1501.8 THE OIL POLLUTION ACT OF 1990 (OPA 90) The Oil Pollution Act of 1990 mandatesnational contingency planning. Once listed.S. If there is no adverse impact posed by the project.Coast Guard and DOT have authority for pipelines. This determination should consider both beneficial and adverse effects on the environment that would result from the implementation of the proposal. EPA has authority for nontransportation-related facilities.TheU. Determining whether a particular permit or approval constitutes a majorfederal action is to be made early in the review process by the agency involved(40 Code of Federal Regulations Parts 1501. Thelisting process may be initiated by the petition of any interested person requesting review. 4. addresses preventionand removal. Private response plans.1 National Environmental Policy Act(NEPA) The National Environmental Policy Act of 1969 (NEPA) requires detailed environmental review.4.S. The consultation will determine if the project can proceed. determine their suitability or unsuitability for wilderness designation. 4.Fishand Wildlife Service (USFWS) or the National Marine Fisheries Service (NMFS). a species is subject to protection under the Endangered SpeciesAct (16 U.A P I I P E T R O ES-ENGL L977 m 0 7 3 2 2 7 0 05b1170L 93'4 m 27 WASTE MANAGEMENT IN EXPLORATION PRODUCTION OPERATIONS AND 4. removal. establishes a fund for cleanup costs. it is nevertheless required to prepare an environmental assessment to justify its decision (40Code of Federal Regulations Part 1501. This plan should encompass identification of environmentally sensitive areas. Generic response plans.2 Federal Land Policy and Management Act (FLPMA) The Federal Land Policy and Management Act of 1976 (FLPMA) (43U. and sets up a research and development program.5).9. such as moving the project location. Conditions may be imposed to mitigate the probable impacts of the project to the species of concern. and report the suitability recommendations to the President of the United States no later than October 21. so forth. while the U. of OPA 90 amends Section 31 1 the Clean Water Act by revising the federal spill response system. under what conditions. aformal consultation under Section 10of the ESA will proceed.S.9.S.C. 1536) to ensure such acthat tivities neither jeopardize endangeredor threatened species nor destroy or modify the critical habitat of such species. 1531through 1543). b. The List of Endangered und Threatened Wildlife and Plants is published periodically in the Federal Register. inclusive of onshore and offshore drilling and workover facilities. of the status of a species of wildlife or plant.C.9 OTHER FEDERALACTS 4. An endangered species is a species that is in danger of extinction throughout all or a significant portion of its range. 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). 1701 through 1782) establishes comprehensive land use guidelines for the Bureau of Land COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . A threatened species is one that is likely to become endangered. Management (BLM)on how to manage public lands under its jurisdiction. c. 4. and tankers. This should be part of the project review and may become an integral part of the permitting process.3 Endangered Species Act (ESA) The Endangered Species Act of 1973 was designed to protect endangered or threatened speciesor their critical habitatfromproposedactivities. If the agency decides that an EIS will not be necessary.C.S T D . 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. disposal of recovered oil.
Appendix A) are subject to DOT regulation when shipped. or disposal of pesticides. and transportation or sale of oil and gas from federal onshore and Indian leases. individual. that person must then determinewhich of the duties assigned by the regulations are required to be performed (that is. it must be used and/or appliedin accordance withits label requirements.S T D = A P I / P E . would still be subject to the DOT regulations. a The regulations also provide thathazardous wastes ( sdef at fined by RCRA in 40 Code o Federal RegulationsP r 261) and hazardous substances(49 Code of Federal Regulations Part 172. Address lease reinstatement. the shipper a hazardous material for of COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . b. all federal agencies have the duty to ensure or jeopardize that federal actions will not significantly impair either the protected species or its critical habitat.) was designed to: a. Ifthe material is subject to regulation. provided the materials are not shipped onor across public access roads or highways. accepted. a hazardous material is defined as any material deemed to be hazardous by the DOT. and property when transported in commerce and that has been so designated (49 Code o Federal RegulationsP r 17 1.9. or water. d. In f at general terms. and Rodenticide Act (FIFRA) The Federal Insecticide. zinc bromide). Assure proper and timely revenue accountability for production fromonshore federal and Indian oil and gas leases. 4. shipper.although not subject to the hazardous waste regulations.T R O ES-ENGL L777 m 073ZZ7D 0 5 b q 7 0 2 870 9 L 28 API E5 No person is allowed to take protected fish. cancelling. Enforcing requirements through inspections. Fungicide.5 Federal Insecticide. rail. measurement. including a hazardoussubstance.6. or railroads. or both). 4. services. c. air. e. FIFRA providesfor the registration and use pesticides andsimilar products intendedto of eliminate or control rodents. EPA can control. waterways. import. 1701 et seq.8). Address OCS matters. and so forth) must first determine if the material being shipped is a hazardous material subject to regulation by the DOT.or restricting the use of pesticides that pose arisk to the environment. 43 Code of Federal RegulationsParts 3100 et. labeling notices. and others involved in the production. however. or restrict the use. 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 RegulationsParts 201 et seq. public access roadsand highways). ban. b. Establish the basis for cooperation with states and Indian tribes for onshorefederal leases.C.9. weeds. safety. that has been determined by the Secretary of Transportation to be capable of posing an unreasonable risk to health. A specific definition of the slupper is not provided in the regulations. the regulations set out specific requirements and procedures that must be performed prior tothe hazardous material being offered. This can help prevent the misuse these chemicals of or the potentially dangerous storage and disposal of unused products. since they are either listed as a hazardous material or contain a regulated quantity of a hazardoussubstance. and state authorities. as A hazardous material is defined a substance or material.101.. or transported.1 Shipper Responsibility Most importantly. In addition. d. seq.S. microorganisms. Fungicide.4 Federal Oil and Gas Royalty Management Act (FOGRMA) The Federal Oil and Gas Royalty Management Act of 1982 (FOGRMA) (30 U. storage. A willful violation of this prohibition is subject to criminal punishment. 4..6 Hazardous Materials Transportation Act 4.9. If the operator choosesto use or apply a regulated pesticide. a person (for example. Depending on the task(s) being performed or required to be performed in preparing a material for shipment. Suspending. and other living pests.9. Since there may be a need to use pesticides or other pest control chemicals at a facility. or vegetation without an incidental-taking permit. operators. Under this Act. c. Evaluating the risks posed by pesticides using a registration system. Shipments completely within a facility or lease are not subject to DOTregulation. 25 Code o Fedf eral Regulations Part 226). including instructions for the proper handling and disposal of the empty container. transporter. f. Regulated materials or wastes shipped by E&P are typically subject to either Department of Transportation (DOT) or Coast Guard regulations. and Rodenticide Act (FIFRA) was originally enacted in 1947 and subsequently amended to its current form. Controlling exposureby classifying and certifying pesticides for specific uses. FIFRA has four main objectives including the following: a. it is to the operator’s advantage to use a licensed applicatorkontractor to perform these The Hazardous Materials Transportation Act is the authority for the regulation of all shipments of regulated materials by highway (that is. wildlife. Some E&P waste streams(for example. Establish duties of lessees. Prescribe onshore field operations requirements for inspections and enforcement actions. insects. corporation.
Assess or seek administrative. b. and emergency response for accidents. shipping paper or dangerous cargo manifest requirements. d. or private carrier. The resulting state regulations exhibit a variety of approaches to environmental protection because they have evolved relatively independently. Although special circumstances may warrant regulatory approval of other specific practices. Issue cease and desist orders. the volume or relative toxicity of wastes that are generated. the carrier or transporter is defined as the person engaged in the transportation of passengers or property by land. oil and gas agency and environmental agency).10OTHERREGULATIONSANDAGREEMENTS All states have regulations to protect public health and the environment. and providing placards when required. 5 Waste Management Methods 5. States are developing have deor veloped rules for the regulation of NORM. marking or placarding the vehicle. To encourage pollution prevention. loading and unloading requirements. they should be reviewed to determine whetherinformation in this document is consistent with current laws and regulations. When thesepractices are implemented onsite. These sound practices not only serve to protect human health and the environment. or reclamation and may be different or more stringent than regulatory requirements. Users are cautioned. however.1 INTRODUCTION This section describes waste management practices for E&P wastes and their potential environmental impacts. State and local requirements vary and may be more stringent. When more than one agency is involved. Order cleanups. other than regulations that apply generally to other radioactivematerials. Transporter tasks include incident reporting. Sound practices should be employed all aspects of in waste management. 4. c. or as a common. training.10. Federal. or has a duty to perform. water. 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. the operator may also be considered the carrier ortransporter if the hazardous materials are transported on company owned or leased vehicles or vessels. the following criteria have been shown to be effective in themanagement of wastes.9. typically a Memorandum of Understanding (MOU)delineates the specific areas of authority for the agencies involved (for example.2 SOURCE REDUCTION Source reduction means eliminating or decreasing. or water. segregating materials. state. Ban further operations and sever an operator’s pipeline connection. or disposal of oilfield NORM. highway. E&Pwastes and practices are subject to regulation by state agencies responsible for environmental protection. These tasks include classifying the material waste. that the information in this document is not all-inclusive and may not apply in allsituations. disposal. Pending the outcome of an investigation. 4.2 Oil and Gas Lease Agreements Lease agreements may impose obligations withrespect to waste treatment. civil. they can help protect an operator from the long term liabilities of waste disposal. 5. states have the authority to: a. In general. or selecting the packaging. contract. or criminal penalties. rules.1 0. to the extent practical. Finally. rail.1 Naturally Occurring Radioactive Materials (NORM) There are currently no federal statutes or regulations specifically covering generation. and regulations provide regulatory agencies the right of access to inspect producing properties for regulatory compliance and to investigate complaints associated with environmental or other problems. Table 2 arranges available waste management optionsin a hierarchy. Ownership of the hazardous material offered or accepted for transportation is only one of many factors that determine which party or parof ties perform. certifying that the shipment is in accordance with the DOT requirements. providing emergency response information. storage.WASTE MANAGEMENT EXPLORATION AND IN P O U TO OPERATIONS R D CI N 29 transportation is defined the dutiesor tasks he is required to by perform. All oil and gas producing state statutes. they should be conducted in accordance with lease and landowner obligations and local. 4. preparing the shipping paper. any the functions of the shipper. 4. and federal regulations. state.6. Opportunities to achieve significant volume reductions for some E&P wastesmay not be practical and are limited by COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . marking and labeling the package. and local regulations are constantly evolving. In certain instances. Oil and gas E&P takes place in states with widely diverse geological and environmental conditions.2 Transporter Responsibilities The DOT regulations also apply to each carrier who transports a hazardousmaterial by air. Transfer of ownership has little bearing on the shipper responsibilities under the DOT regulations. An overview of waste management methods and applicationsis presented in this section and summarized in Table 2.
Nevertheless.7. e. c. or other characteristicsof waste.4 TREATMENT After examining source reduction recycling opportuand nities. Suggestions include the following: a. State and local regulations should be consulted to ensure that any notification recordkeeping or and reporting requirements are met. reuse different processes.1 Evaluation Factors Disposal is the final waste management alternative to be considered after incorporating all practical source reduction. and extraction maybe used to reducethe volume ofa waste. and to protect human health. the operator should consider recycling or reclaiming the waste material. Product and process substitution to reduce the volume and toxicity of the waste generated. cost-effective opportunities for source reduction exist and should be considered. d. and recovery for reuse in other industries. Biodegradation of organic material may result in transformation to less toxic compounds or in complete degradation. the volume of produced water typicallyincreases as the field is depleted.5 DISPOSAL 5. accumulations of oily materials. or solvent usage. relative toxicity. Examples includethe following: a. First idfirst out inventory control should be practiced to ensure that chemicals do exceed their not expiration date. hydraulic fluids. Good housekeeping to prevent spills to soils. onsite. Improved drilling techniques. Treatment”emp1oy techniques to reduce volume. Chemical treatment. where permissible. Product substitution 100% product use (inventory control) Process modification Improved process controls Good housekeeping Reprocessing Burning for energy recovery Reuse in same process Reuse in a differentprocess 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 injectionwells Discharges to surface water Open burning and incineration Offsite commercial facilities 5. may be used to reduce or eliminate the toxicity of a chemicalwaste. Recycling hydrocarbons. suchas hydrogen peroxide oxidation of phenol to carbon dioxide and water. such as the use of more effective drill bits rather than chemical additions. burning for energy recovery. b. Complete use of all commercial chemical products reor turn of unused commercial chemicals to vendors. Chemical stabilization of toxic inorganic compounds may be used to reducetoxicity and mobility. Suggestions include the following: a. or with outside contractors. or releases to waterways. potentially cost-effective treatment steps to minimize waste volume. the age orstate of depletion of a producing property. either in process. where practical. 5. The volume of drilling muds generatedis generally linked to the numberof wells drilled and their depths. b. Thermal treatment canresult in recovery or destruction of toxic organics. 5. b. e. All treatment must be performed in accordance with applicable state or federal regulationsas described in Section 4.E N G L L997 W 0732290 05b4704 b 4 3 m 30 API E5 Table 2-Overview of Waste Management Methods Method Source reduction-eliminate or reduce the quantity or relative toxicity of waste generated.A P I / P E T R O E S . Process modification through more effective use of mechanical means. Elementary neutralization may be applicable to the treatment of corrosives. Reprocessing into products. Recycling-reuse or reclaim valuable material from the waste generated.3 RECYCLINGANDRECLAIMING After reviewing all reductionoptions. or it may concentrate a constituent toa level where recovery is feasible. f. or other characteristics should be considered. d. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . can minimizewaste. The number of chemicals used should minimized to simplify trackbe ing and recordkeeping. Recovery of hydrocarbons from tank bottoms and separator sludges can be accomplishedat onsite production facilities or offsite commercial facilities. chemical precipitatiodflocculation. engine oil changes.S T D .5. centrifugation. Return of oil-based drilling mud to the vendor for reprocessing. d. Use of chemical clearinghouses to find a customer for waste materials. returning unin used materials. Improved controls to minimize mud changes. and oily sump watersmay be managed accordingto 6. hper disposal-utilize environmentally-sound methods to dispose ofgenerated waste to minimize its impact. This volume reduction may produce lower disposal space requirements. if any. Filtration.Used oils. Note: Check appropriate regulations prior to selecting waste management options. For example. c. toxicity. c. thermal treatment (evaporation).
and geological features. Characteristics and levels the wastes are such that of contamination of soil. liners may be unnecessaryfor reserve pits. This one-time loading is what differentiates landspreading from landfarming.1. 5. further reduction of organic and inorganic constituents generally occur by natural processes such as dilution. minimizes impacts current and future to land use. An example of the application of this procedure is given in Appendix F. Landfarmingis a permitted biological treatment process consisting of multiple applications of waste to an area with managed additions of moisture and nutrients and repetitive disking. reduction of organic and inorganic constituents by natural processes. August. should be reviewed. A waste/soil mix containing oil and grease (O&G) or total petroleum hydrocarbon (TPH) concentrations of up to 1 percent by weight hasbeen found to be generally protective of water. in high clay content and permafrost areas.5.1. and metals are discussed below.S T D . It promotes COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . 5. as well as sources of usable water. groundwater.1. speed of reserve pit drying. and a sodium adsorption ratio less than 12.1 General Conditions Site Area-wide topographical. For example. Loading criteria for salts.2 Landspreading Landspreading is a method of treatment and disposal for RCRA Subtitle C-exempt.4 Conditions Loading Soil and Considerations Soil conditions should be checked since they will affect decisions on loading for landspreading and liners for pits.5.5. protected habitants. 1993. one constituent will be found to be controlling-that is.In other areas. 5. size. and federal regulations and consistent with lease obligations. 5. will not harm most agricultural crops or soil (based on one-time application).1 Loading Limits 5. The following factors offsite should be considered when evaluating both onsite and disposal facilities.A P I / P E T R O ES-ENGL L997 WASTE MANAGEMENT ExPLownoN AND PRODUCTlON OPERATIONS IN 3 1 recycling.3 Hydrocarbons API Publication 4527 also supports and describes the landspreading of wastes that contain hydrocarbons. Higher values may be appropriate for some sites dependingon (a) land use. Also. Based on soil and waste analysis. liners may be appropriate. 5. exchangeable sodium percentage less than 15. electrical conductivity) of less than 4 mmho/cm. and/or pH level after mixing with the soil. a processof applying a waste to the upper soil zone.5. 5. 5.5. and(c) background soil salinity. or the presence of endangered species should be identified. Proximity to urban areas also affects disposal decisions. metals concentration. historical or archaeological sites.22.214.171.124.1. hydrological. 5. low-toxicity wastes. Sitespecific conditions may accommodate initial waste/soil mixtures with higher 5.2 Salts Studies have shown that landspreading.5. or from facility systems should be identified. 5. absorption. and soil microbes. onto.5. Evaluation of Limiting Constituents Suggested for Land Disposai of EdiP Operations. and treatment options. and biodegradation. and runoff should not occur if landspreading is executed in a prescribed manner.2. Drainage devicesneeded to control water flow into. Landspreading.1.7 Air Quality The potential air quality impact of solid waste management facilities should be considered.5. plants. Landspreading should be practiced in accordance with local.5 Drainage Areas Natural or existing drainage pattern should be determined. hydrocarbons.1. Wastes are applied ina one-time loadingas determined by the absolute salt concentration. state. net evaporation rates. and direction of flow for existing surface water bodies and aquifers characterized as an Underground Source of Drinking Water (USDW).3AreaRainfallorNetPrecipitation Conditions Historical rainfall and distribution data should be evaluated to establish soil loading conditions for landspreading. it will limit the amount of waste that can be applied to soil.2. Fora detailed description of these guidance values and their application.5. and pH overtopping potential. which results in wastehoil mixtures with soluble salt levels (thatis. see API Publication 4527.2 Hydrological Conditions A hydrological review should identify the location. While initial loadings are designed to be protective. hydrocarbon concentration. (b) salt tolerance of native vegetation. current and probable future activities around the disposal site should be evaluated.6 Presence of Special Conditions Environmentally-sensitive conditions such as wetlands.
500 yd3 of waste: 5. Assume the native soil has 100 ppm TDS.A P I / P E T R O ES-ENGL 1777 m 0732270 05b470b q1b 32 API E5 TPH if they contain low levelsof water soluble organic compounds.&~.2.500 yd3 of waste with 12. Enhanced techniques. and a density of 93.274 acred" [ [ Determine the land required to spread 1. It is assumed that the soil will be tilled a depth of 6 in.2 x IO6 lbs soil/acre. Metals Criteriafor Land Management of Explanation and Production Wastes. x lbs sod = 40. S] A. Solution: a. suchas repetitive disking and nutrient addition.800 lb TDS/acre-6 - Convert pounds TDS volume of waste: to Maximum waste loading = (Maximum lbs T D S I acrs6") [ lbTDS ] [lb ] waste fi3 waste = 5.2. (6.000 =40. The API document.-6 in. should be consulted. Calculate lbs TDS/acre-6 in. 10 percent oil (100. in the receiving soil: lbs TDS I acre -6" in receiving soil = 'Oo TDS lbs [IxlO0lbs soil ] [ x 'O6 lbs acre-6" 'Oi1] =200 lbs TDSI acre-6'' Calculate the maximum pounds TDS to be applied: Maximum TDS 10 apply = (Maximum lb TDS/acred') -lb TDS/acrcd' i receiving soil) n = (6000 lb TDS/acre-6) (200 lb TDS/acre-6) = 5. CriteriaforpH in Onshore Solid Waste Management inExploration and Production Operations.te] = 4.6 Problem: Example Land Loading Calculations for Oil and Grease and TDS [ [ Ikgsoil ][m 1IbTDS soil' ][454gsoil)[2x1061bssoil) ÏE i X acre-6 An operator has1.000mgTDS) 1.1 5.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 landfor spreading.) weighs 2x106 lbs.=0. 5.S T D .164 acre-6 Determine the land requiredto spread 1.02 . 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 3.2.6 Ib/ft3.000) is twice the loading of TDS in ppm (3.5.5.000 ppm TDS.000).000 lbs oivacre-6 in.000 ppm. deep (1 acre-6 in. may be used to increase the rate of biodegradation.5.000 ppm TDS (including TDS in the native soil).: lbs oil Maximum lbs oivacre-6 in. Convert maximum ppm TDS loading to lbs TDS/acre-6in.000 mg TDS g TDS ~](1. to and that 1 acre of soil 6 in. Calculate the land requirementbased on the TDS content of the waste anda maximum loading of 3.000 [ acre6"1 (1 lb waste) lb oil lb oil 0. Note that the pounds of TDS per acre-6 in. Calculatethe land requirement based on the oilcontent of the waste and a 2 percent O&G maximum loading (assume soil with no previous O&G exposure).000 ppm). Maximum waste-to-soil =40.mg Concentration of metals in the waste/soil mixture must also be controlled.4 pH Convert poundsof waste to volume: Maximum waste volume loading = 4 x 1 lb waste 6 ft3 waste According to the API Publication 4595.: Maximum lbs TDS I acre-6= 3. This document describes methods determining and controlling pH in the field. Table 3 presents API-recommended guidance values for metals in land disposedsoiYwaste mixtures.5 Metals b.500 yd3 of waste: From the oil concentration in the waste.calculate the corresponding maximum pounds of waste that can be tilled in: COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Convert the 2 percent O&G maximumloadinginto pounds of O&G per acre-6 in. Detailed below is the solutioncalculation for the land requirements for landspreading this waste based on(a) the oil content of the waste and(b) the TDS content.
5. 1993. and encapsulation are methods used to modify adverse properties of wastes to make them suitable for burial.4 Burial or Landfill It is suggested that operators limit burial or landfilling without a protective liner primarily to solid or semi-solid. b. As describedin 5. Wastes that do not meet the above guidelines may be safely landspread if additional management controls have been developed and properapprovals obtained. 91-93. 29-B. if elevated levels of Se are found in the waste. 2. or asphalt. spent iron sponge. Molybdenum: On February 25. These wastes should be analyzed to ensure they are not ignitable (that is. and molecular sieve). gas plant catalyst. and that they havea mixed density and metals contentconsistent with approved road oilsor mixes.5. emulsions. Selenium: The limitingpathway concentration of 1 0 0 mgkg was generated by EPA using the risk-based multipathway analysis (see Table 3).SW-846. Roadspreading should have the approval of landowners and should meet appropriate state and local regulatory requirements. Third Edition. Also. flash point above 140"F). Laboratory Procedures for Analysis o Oiljïeld Waste. Therefore. Statewide OrderNo. Soil Sampling and Methods o Analysis.1 Exempt oily wastes such as tank bottoms. Produced waters with higher electrical conductivity may be used lieu in of road salting withstate and local regulatory agency approval.5. 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 (mg/kg) 41 180. 1989. stabilization. Lewis Publishers. and types and quantities of waste disposed.ee Note 1 210 iee Note 2 1.3. f 'Carter. Solidification. Recommended criteria for buried or landfilled wastes include the following: a. and crude oil-contaminated soil may be used for road oil. waste characteristics such as naturallyoccurring radioactive material (NORM) should be considered. 5.5 acres would be required to landspread this waste achieve the deto sired loadings. Less than 1 percent O&G by weight. road mix.5.500 750 300 17 . 1986. Testing Methods for Evaluating Solid Waste.3. the operator should consider site conditions that control its availability (see Discussion of Limiting Exposure Pathways).WASTE MANAGEMENT EXPLORATION PRODUCTION OPERATIONS IN AND 33 Since the land requirement for oil loading is greater than for TDS loading. heavy hydrocarbons. Boca Raf ton. oil is thelimiting constituent and 9. bLouisiana Departmentof Natural Resources. Less than 4 mmho/cm electrical conductivity. low-salt and low-hydrocarbon content inert materials (for example. EPA rescinded the risk-based maximum soilconcentration for Mo of 9 mgkg due to technical errors and established a nonrisk-based interim ceiling limit of 37 mgkg. However.3 Roadspreading Oil Wastes Boron Cadmium Chromium Copper Lead Mercury Molybdenum Nickel Selenium Zinc 5. dGuidance for boron is based on the soluble concentration with units of mg/L rather than the total concentration (mgkg). sites used. Free oil should not be buried.400 5.2 Produced Waters aEPA.5. Burial may reduce the rate or amount of natural biodegradation that occurs.Plants that accumulateSe in these soilsmay pose a threat to grazing animals. the potential for plant uptake of Se may be high in alkaline soilsunder arid and semi-arid conditions. the presenceof heavy metals should also be considered.a liner or encapsulation should be used. Furthermore. these techniques should be used only in areas where soil and hydrological conditions would preclude or minispecial mize any threatof groundwater contamination. These conditions alkaline soils under arid and semi-arid conare ditions with deficient levels of copper in the soil (see Discussion of Limiting Exposure Pathways). Table 3-API Metals Guidance: Maximum Soil Concentrations Maximum Soil Concentration Metal Arsenic Barium Extraction Method EPA Method 305P LDNR True Total Bariumb Hot Water Soluble (Carter. 1994 (59 FR 9050).5. pp.OOO 2m a d 26 1. It is generally recommended that produced waters used for roadspreading or dust suppressionbe within a pH range of6 to 9 and below electrical conductivity 4 mmhokm. ) unless it can be shown that groundwater is either not present or is naturally protected from any significant threat of contamination. Application of oily wastes to private or public roads should be at loading rates that minimize the possibility of surface runoff. Operators shouldmaintain complete records analytical of data. Under certain conditions this interim level may not be protective of grazing livestock. pipe scale.2. fresh water-based drilling muds. When the waste exceeds the suggested criteria (see Table 4 . Notes: 1. c. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .
34 API E5 z d d d z z z Q Q d d z P Q z z d Q z Q z z Q z z Q z d d z z 4 P Q z Q P z z z Q Q Q Z 4 Z Q Q z z Q < z d z z S S z Q z P S Q P P 2 z 4 z P P P P P S Q Q z z P z Q " i 2 P P Q m - 2 P P 2 2 z Q P S * Q 2 2 z U z P z Q W c ? COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .
special engineering considerations should be used toensure integrity of the pit and to prevent overflow of the pit during heavy rains. Generally. Reserve pits should be constructed so that the pit bottom does not penetrate usable groundwater. Reserve pits should be strategically sited on drilling locations to collect the appropriate wastes and. The operation should include measures to avoid damage of the liner either physical (tearing or puncturing) or chemical (dissolving. Any areas subject to spillage or contact by these muds should be lined with impermeable material.1 Reserve Pits f.5. b. These fluids should be directed via a pipe or trench to the pit. unpermitted discharges. storm water runoff from the drilling pad. shale shakers. In certain cases. the pit contents should not significantly impact usable groundwater or surface waters. c. 5.1. If in wetland areas.1. and closure of reserve pits should adhere to the following guidelines. State and local regulations may allow freshwater-based muds. based on geological areas or mud system additives. historical rainfall patterns should be considered. Wastes stored in reserve pits should be restricted to drilling muds. Pit liners. cyclones. Solids separation equipment (for example. pH outside of the range 6 to 9. It is recommended that completion fluids with electrical conductivity greater than 4 mmhoskm. produced water or liquid hydrocarbons should not be placed in unlined pits. Operators must maintain dikes and liquid levels to prevent overfilling.2 Reserve Pit Operation Reserve pits may be operated using the following guidelines: a.STD*API/PETRO S-ENGL E 1777 9 0732270 05b4707 125 œ WASTE MANAGEMENT IN EXPLORATION AND PRODUCTION OPERATIONS 35 5. 5. and spills. Pit liquids should have their free oil removed and be sampled for conductivity prior to pitclosure. Liners should protectthesides and bottom of thepit and providea sufficient barrier to any potential flow. 5. and rigwash discharge to unlined reserve pits.5. If materials will be encapsulated permanently. This action may include immediate removal of free hydrocarbons and special pit closure techniques. d. barrier walls. remedial action may be needed. d. described below. rigwash. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . cuttings. permeating. additional sampling and analysis for metals or salts is necessary.5. basic sediment.5. Operators must assure maintenance of liner integrity. 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. e. cuttings. Waste management plans may address whether. reacting).5. Reserve pits andassociated trenches should be lined if the drilling fluids are saltwater or oil-based muds. e. NPDES skimming. Lined pits should be used with care. percolation.5 Onsite Pits Onsite pits include reserve pits for drilling operations and emergency. b.5. The pad should be constructed with storm water runodrunoff controls in place to minimize nondrilling pad storm water entering the reserve pit. special efforts may be needed to isolate these muds and cuttings from those already in the reserve pit. unless soil and groundwater environments will not be significantly impacted. where practical and appropriate. or closed mud systems should be employed as required in environmentally sensitive areas. In areas where it is necessary to construct reserve pits adjacent to water bodiesor on the side of hills or bluffs. b. workover.5.3 Reserve Pit Closure Reserve pits should be closed using the following guidelines: a. and certain completion fluids. It should be noted that in permafrost areas lining of only dike wallsmay be sufficient where the permafrost is continuous and an effective permanent barrier to the downward movementof fluid is provided.1 ReservePitConstruction Reserve pits should be constructed using the following guidelines: a.1. and evaporation pits for production operations. operation.5. 5. Liners should be made of a natural clay or clay-like synthetic material that will withstand normal operating conditions.5. Construction. liners shouldexhibit a hydraulicconductivitylessthan 1OE-7 c d s e c . 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. Pits should be sized to ensure adequate storage during drilling operations. or hydrocarbons greater than 1 percent by weight should not be storedin unlined pits wheregroundwater requires protection. Pit dikes should be built to fully contain liquid volume and preventseepage. excess cement. Any hydrocarbons that inadvertently enter a pit when drilling and completion operations stop should be skimmed off. c. and so forth) should discharge directly to the reserve pit.
5. Unlined onsite pits used for disposal of waste should be restricted areas where soilconditions. evaporation in arid areas.3BasicSedimentPits Basic sediment pits should be lined replaced with tankor age. Their contents are periodically cleaned outor burned. hyto drological factors. It may be possible to reduce the oil content of some muds by washing mud solids to reach this criteria. and closure of onsite pits should generally follow thesame guidelines as thosefor reserve pits described above. injection into onsite Class II wells. 5. landspreading. contoured.5. if any. analytical data. or pit solids may be removed and hauled to permitted offsite disposal facilities. discharging under state/NPDES permits. They may be injected down the well annulus or Class II injection wells or disposed using other options approved by local. d.2 Production Pits Construction. revegetated and where necessary to provide ground supportstability and prevent erosion of the well location. Residual pit solids with electrical conductivity greater than 4 mmhokm.5.5. Basic sediment pits are used for temporary storage of oily wastes such as paraffin and vessel bottoms. 5.5. they may be hauledto offsite disposal sites.2. operation.5. state.~~~ ~~ STD-API/PETRO ES-ENGL L997 m 0732290 05b97LO 997 36 API E5 Sampling for organics should alsobe considered in cases where the mud system could contain excessive concentrations of organics due to mud additives used in drilling or other contamination. or transportation to offsite facilities.2. and hauler used for waste fluids and solids transported to offsite facilities. and rainfall prevent significant soil or groundwatercontamination.5. Siting and construction should minimize the potential.2.1BlowdownandEmergencyPits Blowdown and emergency pits (flare pits. Pit sites should be compacted. Freshwater pit liquids can be managedby injection down the well annulus (see 5.5. 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 stateregulations. and federal regulations. f.6). Salts may be removed by washing and then injecting the resulting salty washwaterinto a Class II injection well as defined in 4. Under certain circumstances. 5. Alternatively.2. j. Theresulting low-salt solids can be managed like freshwater solids. or significant levelsof 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. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . and fluid overflow pits) should not be used for storage or disposal. 5. pits may be lined or tanks may be used. one should consider segregating the saltwater-based system to minimize the wastes that must be managed using special techniques. Oil-based mud solids may be taken to offsite disposal facilities capable of handling oily wastesor mixed with soilto less than 1 percent O&G content by weight during burial or landspreading onsite. of surface or groundwater contamination. When drilling wells using both freshwater and oil-based muds. c.5. pressure vessel relief pits.2. Records should be kept of pit locations. If site-specific considerations indicate that these waters could be endangered. Freshwater pit solids should be land-disposed onsite in a manner protectiveof soil and groundwater environments and consistent with lease obligations and all regulations. and federal regulations should be reviewedprior to selecting a management option. For land application of fluids.2 Workover Pits Workover pits used to contain workover fluids should be open only for the duration of the workover. solidification and stabilization may be practical for minimizing the mobility of specific constituents. Information shouldbe applied in designing pit closure procedures that will ensure soil and groundwater protection of the drill site. fluid composition and loading rates should be considered.5.5. local. destination. Landspreading or burial as described in previous sections may be viable options. volume. Siting of these pits should consider the presence groundwater and surface of waters. i. state. oil and grease greater than 1 percent by weight. e. h. segregating the oil-based system minimize total volume to of oily waste should be considered. Percolation pits should be used only for disposalof produced waters where permittedby regulatory agencies and where USDWs are not present or endangered. Oil-based mud liquids should generally be returned to vendors or reclaimed at permittedfacilities. When drilling deeper wells using both freshwater and saltwater-based muds. 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.4 Percolation Pits Percolation pits allow liquid contents to migrate through their bottom and sides into surrounding soils.3. Fluids diverted to emergency pits should be removed as quickly as practical and in accordance with local. Operators should keep records of type. and federal regulations.5. g.Thefollowingguidelines should be used for various onsite production pits. State.
are regulated by the Clean Water Act's NPDES program (40 Code of Federal Regulations Part 435). Burning should be restricted to materials such as oily sorbents. paraffin. Maximum surface injection pressures are approved by the state and recorded in the injection permit. facility waste fluids. Unlined skimminghettling pits should be used only in conjunction with permitted state/NPDES discharges. Territorial seas. recognizing their unique environmental aspects. They should not be used for produced water. burning should be conducted during daytime hours and should not cause nuisance smoke and particulates. 5. Class II wells are to be used for exempt E&P waste fluids. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . 5. c. in the following areas: a. and board road material.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 sourceof drinking water (USDW).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. In addition. b. Operators should design injection wells to prevent endangerment of nonexempt USDWs.5. Beneficial usage.S. Pit walls should be constructed to prevent seepage and provide adequate free-board above normal operating conditions for precipitation. landscape wastes. Properly constructed and monitored underground injection wells represent a safe environmental practice for disposal of produced water.5.2.5 UnlinedSkimming/SettlingPits Unlined skimmindsettling pits contain discharges to provide additional retention time for the settling of solids. 5. Current status should be evaluated before discharging.5. evaporation pits are used.or injection-well-regulated disposal of the produced water. state regulations should be consulted to evaluate specific require- 5.S T D * A P I / P E T R O ES-ENGL L777 0732270 05b47LL 883 m WASTE MANAGEMENT IN EXPLORATION AND PRODUCTION OPERATIONS 37 5. or packer and that an injected fluid is confined within the injection zone through proper cementing.6ProducedWaterPits Produced water pits have been used in lieu of tankage.7 Evaporation Pits In areas where small volumes of wastewaters are generated.2. and hydrocarbon-containing wastes. Stripper discharges that are allowed for marginal wells under the CWA. Injection well classifications are summarized in 4. unless exempted according to 40 Code of Federal Regulations Part 146. Or if the following conditions are met: a. Coastal areas that contain brackishwaters not suitable for human usage.5.This program sets conditions for discharges in different areas. ments. Outer Continental Shelf (OCS) waters.5. subject to appropriate permit limitations. operators must protect underground sources of drinking water with sufficient casing and cement to prevent contamination due to injected reserve pit fluids. b.8 NPDES Discharges Point source discharges from oil and gas operations to navigable waters of the U. This allows more complete residual oil separation. E&P operations may discharge produced water. 5. Underground injection wells associated with E&P activities are classified by EPA as Class II wells. Operators must demonstrate mechanical integrity according to current requirements by ensuring that there is no leak in thetubing. Fluids injected for disposal or enhanced oil recovery are subject to state or federal underground injection control regulations. Incineration should be performed only with approval of state and/or local air pollution regulatory agencies. These discharges occur primarily in Wyoming and California and are permitted by state or federal agencies.4 andlor specific onetime permission is granted by the state.5. casing.5. Surface evaporation pits may be lined where groundwater or usable soils may be endangered.3.9 Open Burning and Incineration Open burning and incineration are typically used to dispose of nonhazardous materials with properties that make recycling unsuitable. Produced water pits may be lined and should be operated only as a substitute for process vessels with NPDES. However. 5.2.2. Disposal of wastewater by evaporation produces concentrations of salts and residual hydrocarbons.5.5. Also. 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. EPA classified Class V wells should not be used for disposal of E&P wastes without specific regulatory agency approval.5.
and practicality (for example. operators should conduct them in accordance with lease and landowner obligations and federal. environmental factors. The options selected must be economically and technically practicable. state. Class I and Class II fluid injection. that information in this document is not all-inclusive and may not applyin all situations.5. Where appropriate. Federal. method of disposal. Waste management practices are identified in Section 5 . Because of the great diversity of geological and geographical conditions across the United States. they should bereviewed against information in this document to ensure consistency current and with laws regulations. Wastes should be managed according to waste management guidancein this section and Section 5 . as described in Section 4. and local regulations are constantly evolving. 6 Identifying Management Options For Speciflc Wastes 6. these general options are not repeated or discussed individually unless specific options are identified. state.~~ ~~~~ STD*API/PETRO E5-ENGL L997 c 0732290 OSb47L2 7 L T 38 API E5 5. State and local requirements vary. b. Other considerations should include the safety. Scrubber Liquids. and facility design. records shouldbe kept that document the type and quantity of the waste. state. Therefore. Disposal. 2. Heavy Hydrocarbons. of date disposal. It is recommended that operators periodically review offsite commercial facilities as per 2. e.2. great care should be exercised by operators in using these sites. 3. location of disposal. c. Source reduction. and economic and technical feasibility. spill prevention and minimization. d. Operators are cautioned. and local) and lease provisions should be checked. hazardous and nonhazardous treatment and disposal capabilities.1 INTRODUCTION The followingmajor topics are covered in this section: ProducedWater Drilling Wastes Workover and Completion Wastes Tank Bottoms. All applicable regulations (federal. and a review and selection of appropriate waste management options (see Sections 4 and 5). Waste management options must be selected based on site-specific circumstances. Emulsions. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . are all important when selecting a waste management option (see Appendix A). Boiler Water. Treatment. operating practices. 4. Due to the potential for long-term liability. and local regulations. a review of all state and federal regulations. cost and technology) of the waste management options. state. however. waste stream segregation.10 OffsiteCommercialFacilities Offsite commercial facilities offer reclamation. each of the following discussions is organized according to the waste management hierarchy. and any other pertinent information that could prove useful insubsequent investigations to assess liability. and local regulations. A variety of considerations including federal. In addition. It should be noted that certain source reduction options such as improved housekeeping. The probable long term fate of the waste and its constituents should be considered. availability. Pollution prevention options should be evaluated using the waste management hierarchy. Waste management plan development should includean evaluation of existing environmental conditions current and management practices. and location records for wastes that have been disposed onsite should be maintained. and Produced Solids Contaminated Soils Used Oils and Solvents Dehydration and Sweetening Wastes Oily Debris and Filter Media Gas Plant Process and SulfurRecovery Wastes Cooling Tower Blowdown. The following guidelines are suggested for determining waste management options: a. product substitution or elimination. and Steam GeneratorWastes 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 OperationWastes Recompression and Facility Utility Wastes When E&P waste management practices are implemented onsite. lease restrictions. it is recommended that oil and gas companies develop waste managementplans that address their specific operations and operating areas. and purchasing and inventorycontrol procedures could be applior cable to eachof the following wastes activities. volume. namely: l.5. the options presentedin this document are not intended to be all inclusive or applicable to each E&P location. When wastes are disposed in offsite commercial facilities. and incineration services. Recycling. Waste type.
such as barite. and various other chemicals. Source reduction options include the following: a. Discharge to land. or varying combinations. d. Water-based muds. and biological properties of the mud. Treatment options for produced water will vary by location and the ultimate disposition. and scale inhibitors. Underground injection. Most produced water is managed in this manner. b. emulsion breakers. These includecoagulants. physical. Lime and caustic soda increase alkalinity. high temperatures are encountered.STD. and federal regulations: a. They must be managed as part of the content of the waste drilling mud. reverse emulsion breakers. Additional conditioning materials may include polymers. 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. Other COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . b. starches. which can be made with fresh saline water and are used for most types of drilling. differential pipe sticking occurs. This option is rarely used onshore. Produced water may also contain trace quantities of petroleum hydrocarbons and naturally occurring metals. geography. Discharge to water. Reperforating wells to minimize water production. c. 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. and groundwater recharging.which may be usedas substitutes for the above muds or in other specialty situations. The quantity of water produced depends on the recovery method. oil. Using downhole fluid separation techniques or water shut-off (blocking) techniques. the presence of usable groundwater or surface waters. to Seawater by contrast is typically about 35. Cuttings consist of inert rock fragments and other solid materials. Liquids-water. Options include combinations of gravity and/or mechanicalseparation and chemical treatment. corrosion inhibitors.1 General The largest volume of drilling-related wastes is used drilling fluids or muds. It can also contain traceamounts of additives necessaryfor the production process. 6. However. Thispractice is regulated under the Class II injection well program of the UIC regulations as authorized by the Safe Drinking water Act. often bentonite clays. Muds fall into three general categories: or a. d. The following practices may be used for managing produced water depending on its constituents. 6 3 DRILLING WASTES . Drilling muds contain four essential parts: a. and the length of time the field has been producing. For These basic components perform various functions. Composition of modern drilling fluids can be quite complex and varies widely. c. Inert solids-the density-building part of the system. b. cleaners. dispersants. All discharges must comply with these regulatory provisions. c. c. the nature of the formation being produced. This option is rarely used. As described inSection 4. The total dissolvedsolids (TDS) in produced water ranges from several hundred parts per million over 150. state. It is governed by the NPDES program of the Clean Water Act and/or individual state programs. lignitic material. Most produced water is highly saline. Other additives to control the chemical. and local. Discharge tosurface water is allowed in certain circumstances. clays increase viscosity and barium sulfate (barite) acts as a weighting agent to increase mud density. not onlyacross geographical areas but also by depth of the well. paraffin control agents. Minimizing the volume and toxicity of the treatment chemicals that may end up in the produced water. it may exceed 90 percent of the total produced volume.API/PETRO ES-ENGL L977 0732270 05b4713 b 5 b m WASTE MANAGEMENT EXPLORATION PRODUCTION OPERATIONS IN AND 39 6. livestock or wildlife watering. example. horizontal wells). Generally. The use of percolation or evaporation is allowed in areas where freshwater is not present or is located suchthat contamination from produced waterscannot occur. and produced waters destined for disposal are defined by the EPA as an exempt waste.000 ppm TDS. or when it is necessary to protect against severe drill string corrosion. such as crop irrigation. which can be used when water-sensitive formations are drilled. b. EPA considers used drilling muds to be RCRA-exempt waste. Synthetic muds. Active solids-the viscosity-building part of the system. synthetic materials.2 PRODUCED WATER The primary environmental issue in managing produced water is the potential contamination of soil and sourcesof for usable water. They are produced from geologic formations encountered during the drilling process. produced water injected enfor hanced recovery is not a waste. the ratio of produced water to oil or gas increases over time.3.000ppm. Drilling and completing wells to minimize water production (for example. helps conThis trol subsurface pressures. Oil-based muds. Probably the most common form of recycling for produced water is injection for enhanced recovery. Underground injection is a universally acceptable practice that returns produced waters to subsurface reservoirs that are isolated from Underground Sources of Drinking Water (USDWs). These are further discussed in Section 3.
The sumppit should be and so forth. Liners may be re6. guidelines: General good housekeeping practices (for example. In certain instances. drilling mud mixed with slag can be used as a substitute for cement. leak-proof containers in accordance with ap. areas. Storm water fromoutside the drilling pad area should be directed away from the operational area. Fuel oil storage tanks should be diked to prevent spills COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . volume of cuttings generated. Time limits for storage spent completion fluids. if necessary. a minimum. a small sump EPA does not consider waste necessary for maintenance pit should be constructed. drainage directly to the reserve pit unfeasible). leaks. and plicable state and federal regulations. Returning unused chemicals. the mud system will increase the likelihood that onsite clog. paint. Optimizing solids control equipment.3 Drilling Rig Waste quired to prevent hydrocarbon and contaminationof soil salt Wastes generated from drilling rig operations include and groundwater. such as sodium chloride. With this practice.STD-APIIPETRO ES-ENGL L997 m 0732290 O 5 b 4 7 L 4 572 m ' 40 API E5 a. not only Whenever practical. special drilling fluids such as oilis the volume of mud requiring disposal minimized. At lected. Volume reduction options includethe following: a.2ReservePitWastes potentially hazardous wastes (suchas. Exempt and nonexempt materials should be segregated. lube oils. these waters should drained to the reserve pit.or saltwater-based muds. ple. ground contamination and returning them to the system if Efforts should be madeto reduce the volume and toxicity uncontaminated. may apply. of drilling wastes. used oils from engines. Collecting blow-out preventer test fluids to prevent Drill cuttings are also considered RCRA-exempt waste. a bybut based muds or extremely high density brines should be recyproduct from another industry is used as feedstock in the cled by saving them for use in other wells or returning them process. serve pits above ground level (thereby making location and empty paint. hauled offsite to a disposal facility. to protect groundwater from contaminaThese wastes should be managed using the following tion due to oil. and muds to the formaldehyde with less toxic compounds) when preparing vendor or supplier.Reserve pit wastes should be collected and stored for proper disposal using the following general guidelines: tion in reserve pits is illegal. Using bulk and/or recyclable packagingkontainers. are soluble in freshwater b. used oil filWhere it is necessary or more appropriate to construct reters. empty cement. and solvents) should not be placed in reserve pits. Wastes stored in reserve pits should be restricted to exthem in labeled. Waste test fluids should be oil and chemicals are segregated for disposal and do not enpiped or hauled to production facilities for processing or ter the reservepit. elimination of hexavalent chrome and replacement of f. to be exempt wastes. Minimizing water usage (for example. additives. spent hydraulic fluids. Substituting less toxic products and additives (for exame. rigwash. Nonexempt and 6. Exceptions may be made in certain geographic areas. to service companies for reuse. paint.3. or drainage of oily fluids. Temporary production equipment should be provided onso Drilling operations should be designed that lubricating site to process these test fluids. Pumps and power generation equipment should have containment to collect spills. Drilling personnel should gather these wastes and store a. pipedope. be depending on location andquality of groundwater. Segregation of waste streams is anotherimportant method of reducing the volume of waste generated. Fluids accumulated in the sump or operation of drilling equipment. drilling mud and other product sacks.3. Reducing theamount of excess fluids ind. pit should be removed periodically. such asused oils. oil-based troduced into a reserve pit willenable the use of smaller pits muds) to drill near gauge holes and thereby minimize the and minimize theamount of material to be managed.empt wastes suchas drilling muds andcuttings. c. Using alternative mud types (for example. materials. Using closed systemsin certain environmentally sensitive and must be considered during disposal of drilling muds and cuttings. additives. This practice will the mud system and washwater) and excess chemicals and also increase the number of management optionsavailable. spill and leak prevention) can prevent andor reduce the volume and toxicity of the waste generated. Hydrocarbons and produced water encountered during Where practical and appropriate. drilling pads should be drilling of a productive hydrocarbonreservoir or resulting designed and constructed to collect storm water runoff and from drill stem tests in unlined reserve pits should not be colrigwash from all areas impacted by the drilling operation. Any lubricants and product spills that do reach the reserve as pit should be removed soon as possible. or other product containers. Their introduc. lined. b. except in upset or emergency conditions. water additions to sure and disposal techniques can be used.
2. and the material should be handled accordingly. ensuring that proper volumes are mixed. Y Y < > COPYRIGHT American Petroleum Institute Licensed by Information Handling Services + and leaks from beingdischarged offsite. and discharges may be directed to the reserve pit in emergencies. returned to the vendor. Using permanent filters that can be cleaned and reused. . e. treatment. Storm events should be considered. d.or treated as a waste and managed according to regulatory reauirements. Permits are required to drill groundwater wells in some areas. Unused chemicals should be used at the next drilling site. Workover operations should be designed to ensure that the fluids and additives are completely spent when used. keeping containers closed to prevent evaporation. Injection may also be a disposal alternative. and faucets can be used to minimize the volume of water to be treated. Domestic solid waste such as paper. j. and so forth rather than replacement on a routine basis. Where practical. b. Training operators to minimize unacceptable quality and paint waste by reducing overspray. 6 . Hiring commercial household waste disposal companies for solid waste should be considered. testing. Optimizing operation of equipment to minimize degradation and contamination of fluids. Otherwise. Using brushes instead of spraying for smaller jobs. or disposed of properly. formation and pipe scale. such as produced sand. Increasing the time betweenfilter changes based on pressure drop. 5. Low-flow and low-water-use toilets. 7. cement kiln or other industrial boiler or furnace). surfactants to break downhole emulsions. and propant media used in fracturing operations. oil and fuel) generated can be reduced by: l . and paint) to be RCRA-exempt wastes.9. 3. Purchasing less toxic. showers. Paint wastes can be reducedin volume and toxicityby the following: l. Catch basins should be provided in loading areas so that hydrocarbon spills and leaks can be properly managed. . and cement cuttings.STD-API/PETRO ES-ENGL L777 m 0732270 0 5 b 4 7 1 5 429 m 41 MANAGEMENT WASTE IN EXPLORATION AND PRODUCTION OPERATIONS 6. When burning for energy recovery. Drum rinsate that cannot be used originally intended or as unidentified residual chemicals should be considered a nonexempt waste. and pieces of downhole equipment such as sealing elements and pumping equipment. Testing should be performed if necessary to determine the characteristics of the waste. hydraulic fluids. and recycled for scrap metal or sent to a permitted solid waste disposal facility. paraffin solvents and dispersants to control formation of downhole paraffin. and minimizing solvent usage. c. leaks. f. and any other chemicals or materials in their entirety. Workover fluids are primarily freshwater. paint. The filters should be recycled and managed as discussed later under 6. Sanitary wastewater and sewage should be collected and treated prior to dischargeor disposal to satisfy state and local effluent requirements. and stimulation fluids. biocides. and so forth) is strategically located onthe drilling location so that large volume spills. 2. or hauling to a permitted sewage facility.4 WORKOVER AND COMPLETION WASTES RCRA-exempt workover and completion wastes include well completion. operators should ensure that well treatment equipment (pump trucks. returned to the vendor. g. packaged wastewater treatment units. they should be triple rinsed. frac tanks. Excess quantities should remain with the rig for successive operations or be returned to the vendor. h.4. Options include using septic systems. Paint and solvent waste that is generated should be recycled onsite or offsite via distillation to reclaim the solvent. Empty buckets can be sent to a metal reclaimer or disposed of in a permitted landfill. Examples include acids to dissolve scale and increase permeability. less volatile paints and solvents. If the drums cannot be returned to the vendor or a drum reclaimer and theycontain a hazardous or suspected hazardous material. Using cleaning solvents as thinners when too contaminated for use as a cleaner. Rig equipment wastessuch as used lubricationoils should be segregated from materialgoing into reserve pits and recycled or disposed of at a permitted offsite facility.or saltwaterbased fluids with additives for special purposes. i. garbage. well treatment waste liquids should be segregated and separately contained for reuse at another well. or portable commercial containers. Painting less frequently. using all of the paint mixed. inert materials originating from downhole. the waste can also be recycled by burning for energy recovery (for example. Chemical storage areas should be surrounded with containment devices to prevent migration of spills or leaks offsite. crushed. Using water-based or high-solids coatings whenever possible. 3. Groundwater wells used in the operation must be properly abandoned to prevent groundwater contamination or conveyed to the landowner (seek legal advice) at his request when drilling activities stop. Efforts should be made to use pipe dope. Bulk containers should be substituted for drums and other containers when practical. The volume of filters (for example. Ensuring that paint containers are emptied and dried prior to disposal. the waste stream is a substitute product for virgin fuels. and cans should be managed in accordance with state solid waste regulations and should be recycled where practicable. EPA does not consider materials necessary to maintain or operate the workover rig (such as used oils. If this recycling option is not available.
consistent with wastes. treatment. Waste fluids generated duringthese operations should be collected in lined pits or tanks.equipment. and density. Heavy hymaterials thatcollect in the bottom of treating and storage fadrocarbon materials are a primary constituent of road oil or cilities. in tanks. These materials are similar but shouldbe tested for treating vessels. and pieces inert downhole of equipment should be collected after circulation through the rig fluid handling system to ensure that no free oil is present. cement cuttings.oilysludgescould be usedasan Table 2 should be consulted for identification of other alternative fuel source for cement kilns. The addition of heat to liquefy heavy hydrocarbons and d.EMULSIONS. The modification of process. The improvementof downhole solids control techniques to reduce the volume of solids produced. Exempt and nonexempt wastes should be segregated. a. e. For example. They should be comfound in bottoms include accumulated heavy hydrocarbons. is prudent for operators to notify it EPA considersthesematerialsto be RCRA-exempt state and local agencies and the landowner. g. The followingare other considerations: a. Operators should consider site selection. g. roadspreading SOLIDS should be investigated. and to document these acand heavy hydrocarbons should be to maximize hydrocarbon tivities by retaining records. The surveying of the process to identify sources of solids and emulsions and then attempting to correct any problems. gathering lines. f. Workover or completion fluids shouldbe segregated from unused commercial productsor contaminated additives that would be considered nonexempt if disposed. d. paraffin. produced solids with little or no oil contamination may be used as asubstitute raw material (that is. The main goal in managing tank bottoms. and production impoundments. The well surface location of all miscellaneous wastes should be cleaned at the end of the workover or completion operation. f. and pigging wastes from this practice. Recycling by burningfor energy recovery (that is. waste management options. Reclamation should be investigated first. The addition of heat and/or demulsifiers separate emulto sions into produced water and saleable crude. The prohibition of oxygen from thesystem to prevent the formation of iron oxides. e. b. lease obligations and regulations. unless soil or usable groundwater environments will not be adversely impactedby them. b. practices. 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. c.HEAVY the manufacture of cement. and emulsions. Offsite reclaimers range from companiesthat only collect tank bottoms until they have sufficient volumes to sell ato refinery to those that operate small refineries. On the other hand. allowing their recombination with crude oil sales proper containment (for example. Landspreading of materials containing hydrocarbons Source reduction techniques that should be investigated are should be practiced in accordance with Section5 and consisas follows: tent with lease obligations and regulatory requirements. substituting for virgin fuel) is another option that shouldbe considered. Whenever practical. a number of offsite recycling. Exempt solid waste such as produced sand. Before roadspreading.42 API E5 Waste handling considerations include the following: a. parable to those for commercial road oil or mix. metals content. lined pits. Whenever practical. General good housekeeping practices can prevent and/or reduce the volume and toxicity of the waste generated. unusual or special completion fluids such as hydrocarbon-based materials or saturated brines should be handled in closed systemsand recycled for future use. Materials flash point. fluid mix. HYDROCARBONS. or disposal options are available. emulsions. c. recovery.In the same category as tank require permitsfor roadspreading. source ofsilica) in 6. while other states prohibit bottoms are pit sludges. c. waste fluids should transported by be flowline or truck to the operator’s production facilities for reprocessing with production streams.5 TANKBOTTOMS. For those heavy hydrocarbons that cannot be managed onsite. streams. The addition of heat in combination with centrifuging and/or filtration to separate crude from BS&W. these materials may used as a subbe Bottoms are basic sediment and water (BS&W) and other stitute for commercial road surfacing materials. Some states solids. or piping to prevent or reduce the creation emulsion problems and keep of to solids in suspension. For materials that cannot be reclaimed. these wastes should be stored with paraffins.AND PRODUCED b. sand. Before disposal. and contractual provisions to limit potential liabilities of offsite commercial reclamation and disposal of a reclaimer’s waste. or COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . formation and pipe scale. These facilities include production separators. d.
STD*API/PETRO S-ENGL E L777 m 0 7 3 2 2 7 0 05b11717 ZTL W WASTE MANAGEMENT IN EXPLORATION PRODUCTION OPERATIONS AND 43 diked and lined piles) to protect soil. instead of by a routine maintenance schedule. the following source reduction options should also be considered: a. 6. Other onsite treatment.and produced-water-contaminated soils are also RCRA-exempt. double-walled tanks and containers. and regulations make this alternative equipment. Installing mechanical solids removal systems (for example. Soil must be managed under RCRA Subtitle C rules if it is contaminated with a listed chemicalor tests tobe a characteristic hazardous waste. drilling. or used for paraffin dissolving or cutting). and other environmental conditions. Using EPA's logic. Disking to promote biodegradation. that some may be considered hazardous. centrifuges. every effort should be made to remove free hydrocarbons for recycling. or magnets) directly on equipmenuengines to extend the oil life. workover.for groundwater contamination. and of general good housekeeping. 6. appropriate measures to stop and contain the spill or leak should be taken. prevention of the contamination is especially important. API believes sulfur. c. This may include regeneration. and gas plant tics. This should be done only when reservoir characterisand lubricating production. nonflammable solvents) or less toxic should be purchased to increasemanagementoptions. whether exempt or nonexempt. Extending the life of the lubricating oil by changing the oil only when dictated by testing. managing these wastes isrecycling. The practice chosen should be dictated by the extent of contamination. EPA lists hydrocarbon-bearing soil as a RCRA-exempt waste. If possible. The most environmentally soundpractice for feasible.6 CONTAMINATED SOIL 6.1 General e. local. regenerated. capacitors. and sur6. This can include cathodic protection. and produced water. Emulsions that are untreatable by reprocessing through production facilities may be disposed via Class II injection Used oils and solvents are generated when maintaining wells. Exempt or nonhazardous-material contaminatedsoil that be must be reclaimedto allow revegetation may managed by any combination of the following procedures: a. sulfur. or burning for energy recovery in lieuof virgin fuels. Mixture with other soils. Soil that must be removed from a site should be taken to a nonhazardous waste disposal facility. A potential exception to these practices is electrical oil contained in large electrical switches. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . groundwater. Optimizing the operation of equipment to minimize degradation and contamination of the oil. and leak detection equipment are also used to prevent or minimize contamination. Irrigation to leach salts. c. d.7 USED OILS AND SOLVENTS face water. which may containPCBs.7. transportation. however. petroleum-based solvents should be recycled onsite (for example. However. drip pans.2 Used Oil Disposal of soil that becomes contaminated with commercial chemical productsmay be subject to RCRA hazardous waste regulation andCERCLA reporting requirements. TSCA specifies storage. and so forth). For contaminated soil. b. Landspreading or roadspreadingmay be feasible if conducted according to Section 5.3 Solvents Solvent usage shouldbe eliminated or minimized to the extent possible. Current EPA regulations allow used oil to be recycled into the crude stream. As discussed in Section 4. and/or landowner approval may be required to initiating treatprior ment or disposal. Solvents that are nonhazardous (for example. liners. replacement equipment or piping. Impervious secondary containment (for example. potential. Proper maintenance and inspection of equipment and piping can prevent the leaks and spills from occurring. reuse. Other acceptable management practices are recycling or disposal of used oils and solvents at an offsite commercial facility. When spills or leaks do occur. high-level alarms.7. State. Segregated solvents may also be sent to acommercial recycling or disposal facility that is permitted to accept these materials. These oils arenot exempt and must be managed under TSCA regulations if PCBs are present above specifiedlevels (50 ppm or greater and even2 ppm or greater when burned for energy recovery).7. In the collection process. d. permanent filters. Following a regular inspection and maintenance program to minimize leaks. and recordkeeping f requirements for PCB-containing oils (see 40 Code o Federal Regulations Part 761). disposal. 6. recycled into crude oil.5 and applicable regulations and lease restrictions. one should be aware. and transformers. b. operational factors.
8DEHYDRATIONANDSWEETENINGWASTE 6. API believes these same wastes are exempt when generated at field facilities. or evaporation pits. sulfinol. Iron sponge consists of iron-impregnated wood chips. Where there is no market or capability to recycle these liquids (suchas with spent caustic). and forth) the dehydration and io sweetening units to minimize waste and emissions. The first preference is to recycle onsite if practical.5. b. filter media.9. EPA lists dehydration and sweetening wastes generated in gas plants as exempt. 6. nonhazardous disposal facility. Burial mustbe consistent with lease provisions and applicable regulations or it must be taken to an offsite.9.1 General EPA lists the following oily debris and filter media waste as RCRA exempt: spent filters. 6. State regulations on managementof spent iron sponge should be consulted prior to choosing an option.4. c. If they cannot be managed onsite. Spent sock. heavy hydrocarbons.5. or other process solutions.2 Liquids Liquids from backwashing filter media normally consist of fresh or produced water. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . slurries of sulfur and sodium salts may be landspread accordance in with 5. Any recoveredliquids should be returnedto the treatment facilities for reprocessing and recycling.8. buried onsite as detailed in 5.NPDES discharge.5.3 Solid Wastes Solid wastes generated from dehydration sweetening and processes consist of filter media. spent iron sponge. Although typically regenerated onsite.3 Filter Media and Filters Solid filter media such as gravel.9.8. 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. it is seldom done. Returning sweetening wastes to the original product vendor or a reclaimerfor commercial regeneration a feasible offsite is alternative. Spent molecular sieve and solid desiccants may be usedas fill material as a substitute for virgin commercial materials. emulsions. amines. lar sieve may beextended by installing activated carbon upstream to remove potential contaminants (for example. a.8. Free hydrocarbons shouldbe removed for recycling and the resulting solids roadspread.9OILYDEBRISANDFILTERMEDIA 6. landspread. mayburned for energy reair covery or incinerated with state control agency approval. After the iron is consumed. the life of molecu- 6. These solutions may be contaminated with light hydrocarbons and salts. and diatomaceous earth should be treated as previously described for tank bottoms. It should be noted that some states have recently banned used oilfilters from municipallandfills. corrosion inhibitors. and backwash (assuming the filter itself is not hazardous and theresidue in it is from an exempt waste stream). the waste iron sponge is removed and kept wet to avoid spontaneous combustion. caustic. and produced solids. Hydrocarbon contamination of these waters may preclude some of these disposal or discharge options. temperature. as Oily wastes such hay andsorbents used in water treatment be and produced fluid spill cleanup. and glycols).or sent to offsite disposal facilities after being drained of all liquids. the filters may be sent to municipalor commercial landfills. sand. 6.1 General As described in Section 4. Usually. It is important to properly maintain and operate (for example. amine. or taken to offsite disposal sites as describedin 6.44 API E5 6. sometimes containing asurfactant to aid in oil removal. 6.2 or disposed of offsite at a nonhazardous waste facility. Contamination of filter media with hazardous substances may lead to CERCLAexposure. flow rate. Water from the dehydration process should be released as water vapor or.2 Liquid Wastes Liquid dehydration and sweetening wastesmay include glycol. The most environmentally sound practice to return these is liquids to treatment facilities where free oil can be recycled and theremaining liquids disposed of with produced waters. they may be taken offto site nonhazardous waste disposal sites disposed in Class II or injection wells operated under state/federal UIC regulations and permitted for such wastes. While incineration of spent iron sponge is possible. buried. after being drained to remove free liquids. disposed of via Class II if injection wells. The iron sponge is then allowed toundergo oxidation prior to burial onsite. coal. These react with hydrogensulfide in the sweetening process to form iron sulfide. spent molecular sieve. Liquids should be captured and returned to treatment facilities for recycling and treatment. andor slumesof sulfur and sodium salts. since iron sponge is generated infrequently and in small quantities sites where commercial incineration faat cilities are generally unavailable. it condenses.
piping.4(b)(4)]. Spent or degraded absorption oil. Certain catalysts may be recycled to reclaim precious metalsor may be used as a raw material inthe manufacture of cement. This softening pro- 6. injection for enhanced recovery or disposal). In addition. EPA considers wastes generated from the operation and maintenance of facilities such as cleaning compounds. These pits separate the hydrocarbons fromproduced water. returning fluif ids to a sump or clarifier/classifier pit and recycling solids. Sumps and clarifier/classifier systems should be used wherever justified to minimize disposal of reclaimable hydrocarbons.scales that are formed on the process side within segments of tubing. enhanced recovery ordisposal). and so forth to be nonexempt.5).BOILER WATER.12DOWNHOLEANDEQUIPMENTSCALE During the production process. Scale usually consists of barium sulfate. which should be disposed of in Class II injection wells (for example. some waters used in boilers and most water used in thermally enhanced oil recovery (TEOR) steam generators must be softened before use inthe steam generation process to prevent scale formation. Sumps and clarifier/classifier pits are process vessels and should always be maintained in leak-free condition.) All of the above waters may be (a) injected into Class II prior to inwells alone or commingled with produced water jection for enhanced recovery or disposal. or other inert materials. scale-producing waters by using and scale inhibitors. Lubrication oils. 6. Scale formation can be prevented or minimized by not mixing incompatible. These sulfur oxides are often scrubbed usinga slightly caustic solution [flue gas scrubber waste is exempt by regulation-see 40 Code of Federal Regulations Part 261. scales may form within wellbores and production equipment dueto temperature and pressure changes.7).13 STORM WATEWRIGWASH Facilities should be constructed to allow segregationof rigwash and storm water in areas impacted by the operation COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . or sending them offsite to municipal or commercial landfills. NPDES discharge. It should be noted that. used oils and solvents (6. from process equipment) should be checked for the presence of NORM (see 6. or evaporation pits. Hydrocarbons should be managed according to 6. (b) placed into evaporation pits. refractory bricks. These waters are blown down or bled off fordisposal. as described in Section 4.5. should be considered nonexempt waste.7. the waste should be sent to offsite landfills. which should be recombined with produced waters (for example. iron sulfide. cooling waters. c. As discussed in Section 4. d. catalyst. disposing of them onsite via landfill burial consistent with or regulations and landowner obligations. which should be recycled and managed according to 6. such as in boilers. calcium carbonate. Other RCRA-exempt solid wastes such filters.20).10 PLANT GAS PROCESS SULFUR AND RECOVERY WASTE Gas plants and production operations produce many of the same wastes.8). Wastewaters. Management practices for scale that does not contain NORM should include the recoveryof any free oil and landspreading or burial as described in Section 5 .11COOLINGTOWERBLOWDOWN. if onsite disposal is precluded by lease or other restrictions.S T D * A P I / P E T R O E S . b.emulsions. I I cess also generates wastewater. it must be done in compliance with state and federal regulations and to protect sources of drinking water. and produced solids (6. nonhazardous lubricating oils. and tank bottoms.E N G L 2777 m 0732270 05b11717 07q WASTE MANAGEMENT EXPLORATION PRODUCTION OPERATIONS IN AND 45 6. SCRUBBER LIQUIDS. Whatever disposal method is used. and run-off are typically collected via a series of sumps into a central clarifier/classifier pit. 6. (c) dischargedunder a state and/or federal NPDES Permit. deionized water is used to reducenitrogen dioxide in stack emissions. AND STEAM GENERATOR WASTES Water used in boilers and cooling towers eventually becomes contaminated with salts and must be supplemented over time. Production scale (that is. b. in cogeneration TEOR steamgenerators. it should be disposed of in a Class II injection well. For similar wastes refer to the sections on dehydration and sweetening (6. Sulfur dioxide concentrations in stack must be gases removed to reduce emissions in some areas of the country. Generated wastes include the following: a. c. Alternatively. as and oilydebris should be drained necessary. Scale formedin production equipment on the nonprocess side. If no other outlet is available. The production of deionized water generates two waste streams: excess deionized water and blowdown from the deionization process. RCRA-exempt liquid wastes should be collected in plant sump systemswhere washwaters. which should be reclaimed where possible by sending it to a reclaimer or returning it to the vendor. a. heavy hydrocarbons. (See Section for additionaldetails re4 garding TEOR steam generators and their associated air pollution and watersoftening equipment. Last. or heat exchangers containing wellbore fluids are the result of primary field operations and are exempt waste. Cooling tower and boiler blowdown water. which is disposed viaClass II injection wells or NPDES discharge.
these waters should be collected for or use reuse (for example. forts should be made to identify and label. stored. cleanup standards. Generators of lead-acid batteries are specifically exempt from RCRA hazardous waste generation regulations. 1984. makeupwater for drilling or completion operations. or 6. Used COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . They may also be sold to other companies or industries with appropriate applications. most PCB-containing equipmentcan remain in serducted to minimize exposure to personnel and the public. d. per OSHA a. b. and (b) The less-than-50-ppm concentrationis not the result of Rechargeable and recyclable batteries should be purdilution or the cleanup of leaks and spills. chased whenever feasible. Batteries that are no longer needed.3 Nonrecyclable Used alkalis and lithium batteries are examples of batteries that are typically not recycled. Spills of PCB-containing oils are subject to specific become friable(that is. Materials containing than 50 ppm PCBs are excluded less from the TSCA regulations if the following conditions are 6. efforts should be made to ensure that the asbestos does not b. Depending on the level of Any activity involving asbestos materials must be conPCBs. Asbestos is a hazard when it becomes friable. Equipment should be properly maintained 6. it should be kept coveredor sealed so cleanup standards and shouldbe reported to federal.processed. Therefore. an individual trained and certified in both removal taining PCBs wouldsimilarly be subject to the above TSCA and disposal techniques should remove it. These batteries should be substituted with recyclable batteries. all sources of asbestos within a given facility.14UNUSEDTREATMENTCHEMICALS Efforts should be made to plan an operation in a way that minimizes the volume of unused chemicals. electrical switches. 6. state. Use of waste oil with any detectable concentration of should be used at an operation where theyare needed. If it is impossible to prevent theasbestos from becoming c. good housekeeping practices. proper management of storm and water run-onare important to minimize contamination. and other equipment confriable. These batteries may be hazardous and must be disposed properly accordingto apof plicable regulations. 6. storage.15 ASBESTOS and operated to prevent leaks. Asbestos is not a hazardous waste. Waste oils containing PCBs in quantities of 50 ppm or regulations. batteries should be stored in a manner that prevents any spillage of electrolyte.Covering the facilities or potential sources of contamination is another minimizationoption. to vendors for exchange. spillfleak prevention. More specific state regulations 6. greater must be disposed at a TSCA-permitted disposal a. c. or used at another suitable site. These regulations apply tothe use.2 Recyclable Both lead-acid and nickel-cadmium batteries are examples of used batteries that are hazardous and can be recycled. 6. facility. equipment washing. and used batteries should be returned tothe manufacturer. but itsdisposal is subject to TSCA requirements.~~~~~~ ~ STD*API/PETRO ES-ENGL L997 0732290 0 5 b q 7 2 0 8 9 b M 46 API E5 from uncontaminated storm water (that is. Efvice unless leaking. but are not spent. c. servicing. orto a State and local agencies should be contacted regarding reclaimer for recycling. b.16. The system should be tested to ensure that the chemical treatment is needed and is working. requirements. a.16. Capacitors. provided the batteries are recycled. b. Since storm water canbecome contaminated upon contact with leaks and spills. containment. Operating and inventory control procedures should be established to ensure that only the proper amount of chemicals are purchased andthen used in a timely fashion. 6. if feasible.18NON-PCBTRANSFORMER OIL can also apply. Spent nickel-cadmium batteries.1 General distributed in commerce or used before October 1. are still subject to hazardouswaste regulations. and cleanup procedures. runoff fromareas not impacted by the operation). a. and local agencies. that it doesnot become awaste or a hazard). even if recycled.17 PCB TRANSFORMEROIL PCB fluids are regulated under the Toxic Substances Control Act in 40 Code of Federal Regulations Part 761. and agricultural purposes). a. Where feasible.16. disposal and recordkeeping for PCBs and items containing 50 ppm or more of PCBs.16 USED BATTERIES met: (a) The PCBs were legally manufactured. Unused treatment chemicals should be returned to the supplier.
It is also recommended that operators maintain records of types. bulk containers that are reusable should be used in order to prevent unnecessary generation of empty drums. Conon sult API Bulletin E2. while oilfield sludges ranges from backgroundlevels to several hundred picocuries/gram. steps should be taken to minimize the direct and indirect impact of exploration operations on these areas. Hydrocarbons are recycled by returning them to sales streams.20 NATURALLYOCCURRINGRADIOACTIVE MATERIAL Naturally occurring radioactive material (NORM) may be present in oil and gas operations at some locations. b. NPDES discharge. saltwater disposal/injection wells and associated equipment. Bulletin on Management of Nuturally Occurring Radioactive Materials (NORM)in Oil & Gas Production for more detailed guidance on NORM and its prevention. volumes. including filters. storage. and others are prohibiting disposal until regulations 6. c. Reducing the amount of waste generated by such operations. These include the following: a. this oil cannot be applied to the land. c. b. every of attempt shouldbe made to minimize the amount residual material remaining in a drum. Some states (i. when drums are required. Recycling those wastes that are generated. There. 6. and haulers of NORM wastes. some sensitive. 6. and so forth are typically collected via a series of sumps. well lease as as or landowner agreements. enhancedrecovery or disposal).. In other words.However. A P I / P E T R O. soils contaminated as a result of well workovers. 2 ppm or greater) of PCBs must be in accordance with 40 Code o Federal Regulations Part 761. b. Such nonintrusive methods shouldalways be considered when designing an exploration program to minimize the environmental impact and amount of waste generated by exploration activities.e. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . water is removed for disposal in Class II injection wells (for example. b. The NORM activity level in pipe scale can range from backgroundlevels NORM activity in to thousands of picocuries/gram. It is recommended that operators consult applicable state and regulatory local agencies. handling. Recycling of used oil with any quantifiable level (that is. Refer to the Environmental Guidelinesfor Worldwide Geophysical Operations by the International Association of Geophysical Contractorsfor more complete detail.19 EMPTY OIL AND CHEMICAL DRUMS Where practical. Return of the drum to the originalsupplier is the preferred management option. 6. Attempts include the following: a. or dust control agent is prohibited. Such methodsare particularly appropriate over national parks and other protected areas where surface access may be restricted. and disposal. C. The drums should be well rinsed and washed (that with is. tank cleaning. should be recycled disposed as described earlier in this section and in Section 5 . This is primarily a state issue.21GEOLOGICALANDGEOPHYSICAL OPERATION WASTES Geological and geophysical operations associated with the exploration for oil and gas are conducted throughout the world in a variety of environments. before disposing of NORM. transportation. as well in aboveground processing equipment. water-handling equipment exhibits the greatest NORM activity levels. Texas. As of the publication date of this document. NORM as may be found in downhole tubing. Remote sensing and aerial geomagnetic surveys can provide useful subsurface information for the interpretation of geologic structures without disturbing or harming the environment. an appropriate material) before sending a to waste metal/plastic recycler or disposal site.22RECOMPRESSIONANDFACILITYUTILITY WASTES Liquid wastes should be disposed of via thefacility sump system where washwaters. Therefore. or c.E N G L E5 1997 0732290 05b4721 7 2 2 WASTE MANAGEMENT IN EXPLORATIONAND P O U TO OPERATIONS R D CI N 47 PCBs as a sealant. Used oil with less than 2 ppm PCBs should be recycled into the crude oil-also with refinery approval. or evaporation pits. some states are currently developing regulations. and pipe cleaning and other associated operations. Rinsate materials should be usedas originally intended in the process or properly handled and disposed of.S T D . a. and saltwater leaks. and Louisiana) have developed regulations for NORM disposal. the hydrocarbons should be sent to waste oil collection and reclamation facilities. no federal regulations directly apply to thedisposal of oilfield NORM. depending the location. New Mexico. are adopted. In production facilities. analytical data. Properly handling and disposing the waste once the opof erations have been completed. coating. destinations. followed by recycling at a drum reconditioner or as scrap metal. which may inf clude recycling into the crude oil (with refinery approval). Fluids are usually collected from the sumps into a central oiYwater separator. lubricating oils.20(e). cooling waters.If sales streams are not available. Other solid wastes.
API/PETRO ES-ENGL L777 W 0732270 05b11722 bb7 M Appendix A-Guidelines For Developing Area-Specific Waste Management Plans A. Prepare andImplement Plan IO.and economics Choose best practice for area’s operation & location Implement any new or modified practices Provide specific instructions for selected practice Compile allpreferred waste management and disposal options Write management summaries for eachwaste 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 l . As the wastesare identified. Categorize Wastes Generated 6. It could even become a state plan for the specific area.) The following sections outline this approach. Many of these steps be done concurrently (for example.l INTRODUCTION A.2 ~~ While many processes canaid in shaping waste management decisions into action steps.1 for the Ten-Step Plan for Preparing a Waste Management Plan and the summary in Section 2. (See Table A. and so forth. Define Plan’s Area 3. andlocal laws and regulations Evaluate landownerflease agreement restrictions Define operating conditions and requirements Exempt Nonexempt hazardous Nonexempt nonhazardous Volume reductiodminimization analysis Toxicity reduction Recycle. state. Perform Regulatory Analysis 5 . List and Evaluate Waste Management and Disposal Options 8. NPDES. (The formal plan could be expanded to include multiple companies operating within the same area or multiple divisions of the company working in the same area. area-specific waste managementplanshaveworked for many API member companies. A TEN-STEP PLAN MANAGEMENT FOR WASTE A solid waste management plan is an area-specific document identifying the appropriate waste management practice for each type of waste generated in E&P operations within the company. operating feasibility.) Table A-1-Ten-Step Plan for Preparing a Waste Management Plan ~ Stet. Action 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 certaintype of operation Determine all pertinent wastes generated within plan’s area Complete a brief description for each typeof waste Determine volumes and frequenciesof waste generation Evaluate federal. reclaim. 49 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Identify Wastes 4.STD. Select Preferred Waste Management Practices 9. Obtain Management Approval 2. Steps 3 & 4. engineering limitations. the particular laws and regulations can that apply to each can be reviewed. CERCLA.Exempt wastes are subject to RCRA Subtitle D and may be subject to UIC. reuse Implement procedures to reduce waste generation List all allowed waste managernent and disposal options Determine which options have acceptable environmental consequences as Consider other issues such regulatory restrictions.Review and Update Plan Note: E&P exemption appliesonly to RCRA Subtitle C. Steps 6 & 7). Plan Waste Minimization Practices 7.
other resources. and approximate volume).)which mud. The key to defining an area is consistency in both regulatory and environmental issues. drilling. if any. RegulatoryAnalysis Step 2. Area Definition Describe the area for the plan: a. and local laws and regulations to determine the types of wastes (for example. as appropriate. Therefore. Note: Although many types of E&P wastes are similar. The waste management plan is area-specific. an E&P facility or company should use the ten generalsteps outlined below. landowner restrictions and/or preferred waste management practices are specified that may re- COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . 19XX. b. Minimizing the volume and toxicity of waste produced (that is. To develop an area-specific waste management plan. which should be written from the field perspective. percent oil and/or saltwater content. the area of coverage is generally within onestate and. In any case. waste minimization/pollutionprevention). completion/workover. an oil field. a mission statement should develbe oped for the Waste Management Plan. For aplan with a restricted focus. Conducting ongoingtraining of field personnel. in some cases. Field personnel should identify all wastes generated within the area defined for each E&P activity (that is. Waste Identification Identify each waste generated: a. output: List of wastes. Complete abrief description for each waste(for example. even within one county/parish. with a brief description of each. The acceptable waste management practices for each type of waste should be defined through this evaluation process. Example: Company X is committed to running its operations in an environmentally sound manner. production. goals. The company intends to have waste managementplans developedfor each of the areas in which it operates by January 1. The overall project goal should be set. Review applicable federal. d. Small operations may prefer beto gin witha larger area such a state or a district withina state. Example: The plan is developed for the Sable Fieldin West Texas. Later. Since application of regulations must be consistent within a given waste management plan. Step 3. the area-specific waste management plan can be used for the following purposes: a. the plan for a small area may be expanded to cover a larger area by incorporating the different types of wastes generated in thelarger area.STD=API/PETRO ES-ENGL 50 API E5 The plan. output: Waste Management Plan mission statement. Example: Field Production: Produced water[ 10. To develop it. The waste management plan should be evergreen docan ument. ora lease). ManagementApproval Obtain management approvaland support: a. b. The following sections provide more detailed information on each step of the process. a relatively small area is recommended for the initial waste management plan (for example. and (b) the E&P activities to be controlled by the waste management plan. c. On execution.since regulations and/or the environmentvary from one location to another. and objectives. and measurable objectives should be established.000ppm Total Dissolved Solids (TDS)] Tank bottoms [8 percent hydrocarbons (HC)] Drilling Operations: Mud and cuttings (water-based) Cement returns CompletionsMrorkovers: Spent hydraulicfluids (from rig) Spent acid [ 15 percent hydrochloricacid (HCI)] Gas Plants: Used filters (lean oil) Spent amine Step l . For example. defines specific guidance for handling eachwaste generated in the area. individual waste management plansare not necessarily transferable. for waste management and disposal requirements are clearly defined. state. output: Description of (a) the area.a unit. b. and scheduling should be resolved so that management can support the timing and scope of the project. Ensuring ongoing regulatory compliance and continued protection of the environment. source(s). Step 4. b. If the company does not have an environmental mission statement. subject to periodic review and revision. produced water. new waste management practices or options should be evaluated whenever they become available and the plan should be revised. as Complete regulatory analysis: a. management approval and issues involving key personnel. b. review lease provisions to determine what. Evaluating and monitoring waste management practices. drilling etc. one should be considered.and gas plants).
This evaluation should target only the options available and under consideration. etc. as appropriate. WasteMinimization Review the waste generating processes and implement procedures to reduce waste generation: a. environmental considerations. d. andor treatment. For each waste with more than one waste management practice allowed by law or regulation. etc. output: Categorized list of wastes with waste classification identified. and requirements.determine if each is nonhazardous or hazardous. WasteClassification Categorize each identified waste: a. output: List of wastes andtheir operating stipulations. You may have to test periodically if the waste composition varies. Implement practices. etc. Output: Testing and evaluation of any potential waste minimization practices. Review the waste generating processes and options. b. Identify any waste types for which the regulations do not adequately define management requirements. and potential long term liability. e. After reviewing the waste generating processes and taking advantageof source reduction opportunities. The list of acceptable waste management practice options and desirability of each should be reviewed by appropriate operations personnel and management. b. list potential waste management options for each waste. Evaluation should include regulatory restrictions. Example: Reduce the volumeof contaminated soil by increasing the use and maintenance of drip pans under the valves that could leak oil. engineering limitations. burial onsite. recycling andreclaiming. When a potential waste minimization practice arises. 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 7. Step 5. conditions.A P I / P E T R O ES-ENGL L997 0732270 05611724 1131 m 51 MANAGEMENT WASTE IN EXPLORATION PRODUCTION AND OPERATIONS strict options allowed by regulations. For nonexempt wastes. Example: Step 6. Identify potential opportunities to reduce or eliminate waste volumes through volume or toxicity reduction. c. economics. Substitute a chemical product with lower environmental risk constituents to eliminate a waste that requires special handling. In order to find source reduction alternatives. regulated under TSCA. c. list the management and disposal options potentially available (see Section 6 ) . rec. identified as NORM. msk Low chloride drilling fluid Completiordworkover Pit waste Cooling tower blowdown PracticelReauirementS Landfarming.S T D . This analysis will identify the waste types that are not adequately addressed in the regulations and for which additional guidance is required. perform a pilot test and evaluate.). location. operating feasibility. it is important to understand how and why each waste is generated. Determine each option’s acceptabilityfor that area’s environment. h. etc. List and Evaluate Waste Management and Disposal Options a. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . c. Burial onsite after waste de-watered. Determine if each waste is classified as exempt or nonexempt under RCRA or regulated as a special waste under some other authorization (for example. output: List and evaluation of environmentally acceptable waste management practice options for review by field personnel and management. Implement any waste reduction practices identified and vise the waste management plan accordingly. injection. Priority should be placed on reducing those waste streams that maypose the highest potential risk. Discharge injection.
The availability of new technologies that can applied be to waste management practices.” e. Select Preferred Waste Management Practice(s) Select a waste management optionfor each waste: a. select the best practice for that operation and location. ensure that the iron sponge is completely oxidized. therefore. which will be implemented March 1 . Example: Dispose spent iron sponge at the Keep Clean Landfill. b. 3. Burial onsite after complete oxidation. Step 8. c. your company will always strive for the best method of handling the wastes generated in each area. Describe only those wastes generated the operationsin that specific by area or within an operator’s responsibility. Through this ongoing process.) COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Step 10. Disposal at an offsite nonhazardous disposal facility. (See Appendixes B and D and reference materials for an example of a plan for a specific waste that can used in debe veloping waste management plans. output: An area-specific waste management plan. Texas. volume. 2. Through this process. a nonhazardous disposal facility. Prior to removal from thesite. summary listA ing the designated waste management practice for each waste identified. Implement modified practices and revise the waste management plan as new or modified practices are defined.A changein the type. Recently receivedinformation indicates that “Keep Clean Landfill” is currently under enforcement action by the state. Step 9. 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. as appropriate. 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. Drain free liquids. Establish a procedureto review and update the waste management plan. in Small Town. operations personnel mayjustify several of the current waste management practices. Backwash and return liquids to treatmentfacilities. Pros: Most cost effective Cons: Landowner concerns b. describe the waste and the designated waste management and disposal practice. or toxicity of the waste being generated. For final disposal. (At a minimum. periodic review the plan should have an established of frequency. and the plan should be revised accordingly. Implement any new or modified practices. 19XX. ensuring that the plan is modified as appropriate: a. Example: Gas Plant Operator: To dispose of spent filters from the lean oil absorption unit: c. Review and Update Waste Management Plan Define a review and update procedure for each waste management plan. Effective waste management is an ongoing process. Collect and store in clean. b. output: Implementation of these practices. use the “Look Nice Commercial Landfill” for future disposal of nonhazardous wastes.~ 4. Summarize the recommended waste management practices in concise documents for useat the field level.area-specific waste management plan. For each waste.) b.~~ ~~ STD. send to “Look Nice Commercial Landfill. output: Periodic reviewof the wastemanagement plan and implementation of the revised designated practices. From the evaluation of waste management and disposal options. New waste minimization techniques. Applicable information which will reduce the company’s future liability.API/PETRO ES-ENGL L777 0732270 05b11725 378 D 52 API E5 Example: Spent iron sponge disposal options: a. Prepare and Implement An Area-Specific Waste Management Plan Develop and implement the plan: a. b. Example: The best available technology for treating spent acids from workover operations is neutralization. Pros: Flexibility in selecting disposal location Cons: Future liability potential a. and covered drums. d. to reduce the company’s potential liability. labeled. c. The types of issues that may trigger a review of the plan are as follows: l. New waste management practices or options shouldbe evaluated whenever they become available. Maintain file of shipping records.
and additional data that may be important for evaluating the feasibility of the acceptable waste management options. It is suggested that the following personnel also be included: a. These personnel bring numerous resources to the team: a. Engineering staff. a variety of personnel within the company will have valuable experience to contribute. However. b.) d. or gas plant operator) are key to the development process.3 RESOURCES TO WASTE DEVELOP MANAGEMENT PLAN The most effective waste management plan is developed with the ultimate end users-field personnel-in mind. can provide information. e. Field or operations personnel (for example. and handling practices at the site of interest and be responsible for implementing any new will waste management practices. (An onsite engineer or an engineer dedicated to that operation/area would provide the best insight. b. company man.STD. They canfacilitate information transfer to other areas that are developing waste management plans. Safety and environmental support staff and drilling and production operations groups can provide technical advice during the process of developing theplan. c. I COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . They know the operations. Environmental professionals should be available as advisor(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. Engineering staff. Operating environmental professionals. Operations personnel. d. design/operational options.API/PETRO ES-ENGL L777 m 0732290 05b1172b 2 O V m WASTE MANAGEMENT IN EXPLORATION AND PRODUCTION OPERATIONS 53 A. knowledgeable in the processes at a given location. Outside consultants can be recruited to provide selected expertise or prepare the entire plan(s). Technical advisors from support staff. C. production foreman. current waste generation sources.
4-1 Materialmaste Documentation . and Environmental Contacts 3. . . Waste Classifications Texas Waste Classifications . . Containing Chemicals DrumsiContainers... State-Permitted Transporters 5.. . Surplus Chemicals. .. . Transportation Requirements Overview of DOT Requirements . .. ... . Terms Acronyms and Abbreviations Glossary The following table is a sample excerpt from TheWaste Management Field Manual: 55 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services Waste Management Field Manual Table of Contents 1. . .. . Nonhazardous Materialmaste Manifesting . EPA and State Generator ID Numbers 4.. .. Treatment. . State-Permitted Disposal or Recycle Facilities 6..2-3 3. . Liquid Metal.. . . . Uncontaminated Drilling FluiddCuttings I I i ... . Lube Oil. and Bailing Wastes Caustics Cement Chemical Toilet Waste Chemicals.1 PollutionPrevention . .2-2 Health and Safety and WasteManagement . .. . Violation Penalties Table 2.. Slop Oil.. PCB Contaminated Solvents SulfachecWChemsweet Waste Tank Bottoms and Basic Sediment Thread Protectors Vacuum Truck Rinsate Well Completion.. . .. . Lube Oil Contaminated Soils.. Lead-acid Blowdown. .... . ... DrumsiContainers...4-4 . . Stimulation Fluids. .. ......S T D . .. ... Management and Disposal by Waste Material Overview Cross Reference Aerosol Cans Amines Asbestos Batteries.. .. ..4-3 Hazardous Materialmaste Manifesting .. ... Process Glycol Hydraulic Fluids Iron Sulfide Scale and Iron Sponge Mercury.. . .. . It can be used as a model in developing a customprogram for your company... . .. ..3-3 Guidelines for Nonexempt Classifications .. Waste Management Policy Environmental Policy .. Mercury Contaminated Soils. . Containing Lube Oil DrumsiContainers. Unusable Condensate Debris.. Scrap Methanol NORM Oil......Empty Filters.. .. Weathered Paint Paraffin PCBs Pesticides and Herbicides Pigging Wastes Pipe Dope Plastic Liners Produced Water Sandblast Material Soils. Onsite Waste Storage Insert: Drum Label for Hazardous Waste 7.. . .. Analytical Laboratories 8. . .3. ..1 RCRA Exempt and Nonexempt Classifications ... .4-8 Inserts: Hazardous Materials Warning Labels and Placards Texas Water Commission (TWC) Uniform Hazardous Waste Manifest Nonhazardous Waste Manifest Shipping 5 .... Crude Oil Contaminated Soils. . . . .3-4 4.. . . Chemical Contaminated Soils. . Lube Oil Filters. Introduction Waste Management Program . . . .4-6 Shipping Orders . .l.. ... Chemical Contaminated Debris... ... ... . .. Crude Oil Soaked Debris.. .. and Unused Appendixes l . Lube Oil Contaminated Debris.A P I I P E T R O E5-ENGL L777 H 0732290 05b11727 L110 D Appendix B-Waste Management Planning Aids The following is an example of a Waste Management Field Manual outline... . .......l-2 2. . Health.... .. . .1 How to Use This Manual. CrudeOil Stained Debris. . Safety. . . ... . . Swabbing.2.
Oklahoma 37337 9501555-2744 Borgnas Disposal. Special Handling Spread iron sponge out on bareground in an open. with adequate oxygen. keepin permanent file in area office. Incorporated 2000 Borgnas Lane Medicine Bow. Do not mix with acid or acidic water.It reacts with hydrogen sulfide and sulfur. Allow a minimum of 1 week for material to oxidize and cool to air temperaturebefore transporting offsite. Iron sponge is a coating ofiron oxide on wood chips or other carriers. Treat production streams with biocide or scale inhibitorto reduce iron sulfide formation. For temporary storage on the ground. see Special Handling above Offsite ManagementDisposal DOT Requirements None required unless it auto-ignites. State-Permitted Transporters State-Permitted Disposal or Recycle Facilities Marashi’s Disposal Mud Services 1905 Marashi Boulevard Marashi. Waste Reduction COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . in confined space. Must record the following: Volume/weight of waste Name of leaselsite Leaselsite location (nearest town) Name of transporter Date of transport Name of disposal/receiving/recycling facility Date of receipt by facility Recordkeeping 9 9 9 Disposal Alternatives Waste Category approved. it may explode. contact your compliance coordinator to determine appropriate DOT requirements. Use Nonhazardous Waste Manifest.~ S T D * A P I / P E T R O ES-ENGL L997 U 0732290 05b4728 087 I 56 API E5 Table B-1-Iron Sulfide Scale and Iron Sponge Description Iron sponge is used on a limited basis to remove hydrogen sulfide from the gas stream. Onsite ManagementIDisposal No onsite disposal. Wyoming 28746 9501555-2674 Consider alterative methods of removing hydrogen sulfide from gas stream. Iron sulfide may be present in tank bottoms and may be associated with well stream fluids and production systems. WARNING: Contact with acid will release hydrogen sulfide. WARNING: Dry iron sulfide and iron sponge will auto-ignite. Always keep it wet. fenced area. Send tofacility state-permitted disposal RCRA: Exempt Texas:Class I IndustrialNonhazardous Any transporterpermit RRC with and MWA.
. . - .S T D . .A P I / P E T R O ES-ENGL 1777 0732270 05b4727 Ti3 m APPENDIX >SUMMARY WASTE TABLE L I I I 57 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . .
58 API E5 I I BaAoDat V I COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .
E N G L L977 m 0732290 05b11731 b7L m WASTE MANAGEMENT IN EXPLORATION PRODUCTION AND OPERATIONS 59 t COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .S T D * A P I / P E T R O E S .
60 API E5 I COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .
increases liability limits cleanup and funds and other measures Requires detailed environmental reviews of major actionspermitted by federal agencies if there may be significant impact human health on and environment Sets guidelinesfor land management by the Bureau of Land Management (BLM) Protects endangeredor threatened plant and animal species Sets requirementsfor onshore and offshore wells and facilities Provides for registration and proper management of pesticides. other conor tracts may impose additional requirements. the number and magnitude of environmental requirementshave increased significantly. Amendment HSWA Amendments TCLP amendments 1974 1972 Safe Drinking Water Act (SDWA) Clean Water Act (CWA) Clean Air Act (CAA) I970 1990. In addition to these and other federal regulations. tobacco. drugsand 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. landowner agreements. processing. Amendment I977 Toxic Substances ControlAct (TSCA) Comprehensive Environmental Response. state. hazardous and air pollutants. and food. nuclear materials and by-products. The federal laws summarized in this section are only those that have the greatest impact on E&P operations. The following table summarizes key federal legislation and regulations. S. E&P operations are impacted by a number of federal. Compensation. and local environmental laws and regulations.STD-API/PETRO E5-ENGL 1777 m 0732270 0 5 b 4 7 3 3 4 4 4 m Appendix D-Summary Of Environmental Legislation And Regulations also have environmental requirementsthat will affect E&P sites. Local governments. such as countiesor cities.and Rodenticide Act (FIFRA) Hazardous Materials Transportation (HMTA) Act Naturally Occumng Radioactive Materials (NORM) 1976 1973 1982 1947 1975 NA 6 1 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Operatorsmust be aware of the various levelsof regulations and ensure that necessary permits and approvals are obtained before operations begin.acid deposition. states Table D-1-Summary of Key Legislationand Regulations Statutes Resource Conservation and Recovery Act (RCRA) Purpose Requires EPA to set up procedures for identifying solid wastes as hazardous or nonhazardous and issue requirements for their management. Regulates the manufacture. and Liability Act (CERCLA) or Superfund Superfund Amendments and Reauthorization Act (SARA) Oil Pollution Act (OPA) of 1990 National Environmental Policy Act (NEPA) 1980 1986 I990 1969 Federal Land Policy and Management Act (FLPMA) Endangered SpeciesAct (ESA) Federal O&G Royalty Management Act (FOGRMA) Federal Insecticide. or distribution of chemical substances. Lease agreements. motor vehicles and and fuels Regulates all chemical substancesand mixtures in the US. Manages NPDES Point Source permits Includes stormwaterpermits Regulates Spill Prevention Control and Countermeasures Plans (SPCC) Covers dredge and fill permits Wetlands use Regulates air quality standards. Fungicide. excludingpesticides. food additives. ozone protection. may also impose requirements. permits enforcement. including disposal Regulates hazardous material shipment (includes hazardous waste) Only a few states have rules Date Enacted 1976 1980. described in detail in Section 4. Underground Injection Control Public water systems Controls point source dischargesinto navigable waters of the U. Since the early 1970s. and tobacco products.
and Cosmetic Act FIFRA Federal Insecticide. Endangered Species Act ESA “F” Wastes Hazardous waste from nonspecific sources FFDCA Federal Food. and Rodenticide Act FLPMA Federal Land Policy and Management Act FOGRMA Federal Oil andGas Royalty Management Act FOIA Freedom of Information Act Free-Water Knockout FWKO . E&P Exploration and Production Extraction Procedure for determining toxEP icity characteristic EPA United States Environmental Protection Agency EPCRA Emergency Planning & Community Right-to-Know Act of 1986. also known as SARA Title III. corrosivity. Compensation.S T D * A P I / P E T R O ES-ENGL 1777 m 0732270 05b4734 380 m Appendix E . Drug. British Thermal Unit Clean Air Act-the 1970 Clean Air Act as amended in 1977. Conditionally Exempt Small Quantity Generator 63 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services CFR CN CO BAF BAT BATEA BDAT BDT BIF BLM BMP BOD BPT BTU CAA CAAA CAMU CERCLA CESQG Code of Federal Regulations Cyanide Carbon Monoxide Carbon Dioxide c 2 0 COD Chemical Oxygen Demand COE Army Corps of Engineers CPIS Corrugated Plate Interceptors CWA Clean Water Act Coastal Zone Management CZM bL V Wastes considered hazardous by virtue of D Wastes a characteristic: ignitability. based generally upon the average pollution control performance achieved by the best existing plants. and Liability Act(commonly known as Superfund) of 1980. Amended by Superfund Amendments and Reauthorization Act of 1986 (SARA). 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 technically and economically feasible but which may not yet have been applied in any facility. clean-up. Best Available TechnologyEconomically 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. or toxicity DMR Discharge Monitoring Reports DOC Dissolved Organic Carbon Department of Energy DOE DOI Department of the Interior DOT Department of Transportation DRE Destruction and Removal Efficiency (incineration) Effective Concentration EC Expanded Characteristics Option (RCRA) ECHO API Environmental Guidance Document EGD Extremely Hazardous Substances (MateriEHS als listed under SARA) Environmental Impact Statement-a logiEIS cal analysis of the effects on the environment that will or may reasonably be expected to occur as a result of a proposed action. and emergency response for hazardous substances released into the environment and the clean-up of inactive hazardous waste disposal sites.Acronyms AAC ACL API ARAR BACT 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. Clean Air Acts Amendments of 1990 Corrective Action Management Unit (RCRA) Comprehensive EnvironmentalResponse. 1977. Provides for liability. reactivity. End-of-Pipe-Treatment-those processes EOP that treat a combined plant wastestream for pollutant removal prior to discharge. Fungicide.
The most stringent control applied or required anywhere without consideration of cost or energy impact. MCWMCLG Maximum Containment LeveVMaximum Containment Level Goal FWPCA MDL MEA MOU MSDS MTR NCP NEPA NESHAP NGL NMFS NOAA NOX NORM NPDES NPL NRDA NSPS NSR OMB OPA OSHA osw OSWER OTS Method Detection Level Monoethanolamine Memorandum of Understanding Material Safety Data Sheet Minimum Technology Requirements [RCRA Sec 3004(0)] National Contingency regulaPlan-basic tions governing the cleanup of Superfund sites. United States Occupational Safetyand Health Administration Office of Solid Waste (EPA) Office of Solid Waste and Emergency Re sponse (EPA) Office ofPesticides and ToxicSubstances o=A) COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Natural ResourceDamages Assessment (CERCLA. Lethal Concentration LC Leak Detection andRepair Procedures for LDAR Fugitive Emissions Land Disposal Restrictions (RCRA) LDR Local Emergency Planning Committee LEPC Large Quantity Generator LQG Maximum Achievable ControlTechnolMACT ogy-level of control required for new and existing major sourcesof hazardous air pollutants underthe reauthorized Clean Air Act. Hydrocarbons HC Halogenated Organic Compounds HOC HON Halogenated Organic NESHAP-”ACT rule forSynthetic Organic Chemical Manufacturing Industry (SOCMI) Hazardous Materials Transportation Act HMTA Hazard Ranking System-scoring system HRS that determines whether a site will be added to the National Priority List (NPL) Hazardous Substances(Materials listed HS under CERCLA) Hydrogen Sulfide H2S Hazardous and Solid Waste Amendments HSWA -1984 Amendments to RCRA Hazardous Waste Identification Rule HWIR (RCRA) Industrial Toxics Project ITP “K”Wastes Hazardous wastes from specific sources LAER Lowest Achievable Emission Rate-control level required onnew major sources of VOC missions in nonattainment areas.A P I / P E T R O ES-ENGL L997 m 0732290 05b11735 2L7 m 64 API E5 Federal Water Pollution Control Act of 1972-sets effluent control limits for all industries discharging into waters of the United States. GAO General Accounting Office GCKD Gas ChromatographKonventionalDetector GC/MS Gas Chromatograph/Mass Spectrometer HAP Hazardous Air Pollutant HAZCOM Hazard Communications HAZWOPER Hazardous Waste Operations and Emergency Response-lawlregulations requiring training for various waste manage ment and emergency responseduties. New Source Review under CAA Office of Management and Budget Oil Pollution Act of 1990-addresses response. 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. National Priorities List-list of sites to be cleaned up under thefederal Superfund program. liability. but for which no nationalair quality standards have been established.S T D . Natural Gas Liquids National MarineFisheries Service National Oceanic& Atmospheric Admin istration Abbreviation for nitrogen oxides oxides or of nitrogen Naturally Occurring Radioactive Material National Pollutant Discharge Elimination System-the national permitting system authorized under Section 402of the FWPCA. National Environmental Policy Act-a federal statute that established basic federal policy and procedures for review of the impacts on the environment that would result from a proposed project. National Emission Standard Hazfor ardous AirPollutants-emission limitations established by EPA for pollutants that the Agency judges to possessa significant potential for causing health problems. and penalties for oil and chemical spills to navigable water. GACT Generally Available Control Technology-level of control for area sources of hazardous air pollutants.
SIP SOX SPCC SQG SS STEP Superfund SWMU TC TCLP TDS TEOR THC TITLE III of SARA 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. Solid Waste Management Unit(RCRA) Toxicity Characteristic-concentration levels for 39 compounds used as one way to define solid waste as hazardous. Pretreatment Standards Existing for Sources of indirect discharges under Section 307(d) of the Clean Water Act. Sulfur Oxides Spill Prevention Control and Countermeasure Small Quantity Generator Suspended Solids Strategies for Today’s Environmental Partnership Popular term applied to the Comprehensive Environmental Response. off-specification. Storage. or Disposal Facility (RCRA) TSP Total Suspended Particulates TSS Total Suspended Solids TUR Toxic Use Reduction “U” Wastes Commercial chemical products considered toxic hazardous wastes when discarded.WASTE MANAGEMENT IN EXPLORATION PRODUCTION AND OPERATIONS 65 T ’ wastes PAISI PAVE PCBs PH PIC PM POTW PPA PPb PPm PRP . or solid. Compensation and Liability Act of 1980 and the Superfund Amendments and Reauthorization Act of 1986. liquid. 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. Department of Commerce to denote segments of industry. Toxicity Characteristic Leaching Procedure (RCRA) Total Dissolved Solids Thermally EnhancedOil Recovery Total Hydrocarbons Emergency Planning and Community Right-to-Know-Act of 1986 TLV Threshold LimitValues Threshold PlanningQuantity TPQ Toxicity Reduction Evaluation TRE Toxic Release Inventory under A R A S TRI Title III TSCA Toxic Substances Control Act TSDF Treatment. or spill cleanup residues Preliminary AssessmentJSite Investigation Program for Assessing Volatile Emissions Polychlorinated Biphenyls A measureof the acidity or alkalinity of material. Must be approved by EPA. Geological Survey VOC Volatile Organic Compounds-organic compounds that may be involved in photochemical reactions that produce ozone. Volatile Organic Liquid VOL COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Negotiating Rulemaking Remedial Facility Investigation Remedial InvestigationFeasibility Study Record of Decision Reportable Quantities (Superfund) Superfund Amendments and Reauthorization Act of 1986 Data collection under Section 313of the Emergency Planning and Community Right to Know-Act of 1986 Safe DrinkingWater Act State Emergency Response Commission Surface Impoundment Standard Industrial Classification-a numerical categorization scheme used by the U.S. Resource Conservation and Recovery Act of 1974-establishes controls for the handling and disposal of solid wastes and hazardous wastes. Quality Assurance Reasonably Available Control Technology ”applied to existing major sources in nonattainment areas. 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. or spilled UCR Upper Confidence Range UIC Underground Injection Control USDW Underground Sourceof Drinking Water USGS U. Pretreatment Standards New Sources for of Indirect Discharges under Section 307(b) and (c) of the Clean WaterAct.S.
STD.API/PETRO ES-ENGL L777 m 0732270 05b11737 07T m 66 API E5 WETT WQC Whole Effluent Toxicity Testing-program for testing the toxic effects on aquatic lifeof an effluent. based upon the latest scientific knowledge concerning the effects of the pollutant on health and welfare. alongwith a plan of enforcement. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .or specified pollutants in an effluent. 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 useor uses for the water Segment. Water Quality Criteria-acceptable concentration of a pollutant..
U. July 6. and 503.S. 1992. “Underground Injection Control Program: Criteria and Standards.S. and 503.l REFERENCES l . 1990. ‘‘StatKhds for the Use or Disposal of Sewage Sludge?” 40 Code of Federal Regulations Parts 257. Metals Criteria for Land Management of Exploration and Production Wastes: Technical Support Document for API Recommended Guidance Values. 1 l . U. 1988. 403. CERCLA and SARA lïtle III. 2. U.sodiumabsorptionratio. August 1.E N G L L777 m 0732270 05b4738 T2b Appendix F-Reference Materials F. Publication 4600. U. 3. Environmental Guidance Document on Well Abandonment and Inactive Well Practices for U. Interstate Oil Compact Commission. Environmental Protection Agency. F. American Petroleum Institute.” 40 Code of Federal Regulations Part 146. 1992. 1993. January 1993.S. 7. 12. 4. March 1992. April 1. Evaluation of Limiting Constituent Suggested for Land Disposal of Exploration and Production Wastes. Publication 4595. Bulletin D16. EPNIOCC Study of State Regulation of Oil and Gas Exploration and Production Waste. Bulletin E4. Development and Production Wastes. American Petroleum Institute. 1993. Exploration and Production. 1O. June l.S. Metals guidance is developed in API Publication 4600. Environmental Protection Agency.” 40 Code of Federal Regulations Part 146. and oil andgrease guideline values are described in detail in API Publication 4527. American Petroleum Institute.exchangeable sodium percentage.S T D . Suggested Procedures for Development of Spill Prevention. American Petroleum Institute. 67 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Environmental Protection Agency. 403. Bulletin on the Generic Hazardous Chemical Category List and Inventoryfor the Oil a& Gas hploration and production Industry. 1994. American Petroleum Institute. Credible Decisions. Credible Science.S.S. Environmental Guidance Document on Release Reporting for the Oil and Gas Exploration and Production Industry as Required by the CWA. U. Regulatory Determination for Oil and Gas Geothermal Exploration. 5. 1989. 15. “Standards for the Use or Disposal of Sewage Sludge. August 1993. 13. “Underground Injection Control Program: Criteria and Standards. 14. 1992. December 1. 1993. American Petroleum Institute. The pH values are detailed in API Publication 4595. Environmental Protection Agency. Bulletin E2. Criteriafor pH in Onshore Solid Waste Management in Exploration and Production Operations. 9. Environmental Protection Agency. 8.” 40 Code of Federal Regulations Parts 257. 1994. Control and Countermeasure Plans. Bulletin on Management ofNaturally occurring dioactive Materials (NORM) in Oiland Gas Production. 6 . American Petroleum Institute.A P I / P E T R O E S . Bulletin E3. Environmental Protection Agency.S. U. Bulletin E 1. December 1990. Publication 4527. American Petroleum Institute.2 SOURCESFORJUSTIFICATIONAND ANALYTICAL METHODS IN TABLE 4 Electricalconductivity.
during this time. Specifically. Drilling activity in the United States has declinedsignifiUnderstanding the proceduresfor determining the exempt cantly since 1985. a determination should made as be not warranted. under the less stringent RCRA Subtitle waste management decisions. the toagement plans. The RCRA Subtitle C exemptions. API estimated that 361 million barrels Clarifications of several misunderstandings about the of drilling wastes and20. generated in the United States. produced water volumes typically SCOPE OF EXEMPTION increase.S.Subsequently. however. possible (source reduction). When these proceduresare used in conjunctal footage drilled for all oil and gas wells dropped from tion with a knowledge of the nature of the waste. According to for operators who choose to develop voluntary waste manthe International Association of Drilling Contractors. (API). Hence. E&P wastes have remained exempt to whether the waste is subject to hazardous waste regulafrom Subtitle C regulations. API later estimated that 1 1. D solid wasteregulations. Natural Gas.1 million feet in 1991. of Crude Oil. Not all In addition. Because no attempts have been made to update the In December 1978. vided to the Agency by the American Petroleum Institute Status of E&P waste mixtures. were generated in 1985 from exploration and production Answers to frequently asked questions. The information contained in this booklet is intended to furnish the reader with: In the 1987 report to Congress entitled “Management of Wastes from the Exploration. EPA bewaste generation volumes. Examples includeprocess modIn 1988. Generally. and Geothermal Energy. even for nonhazardous wastes. EPA issued a regulatory determination stating that ifications to reduce waste volumes and materials substitution control of E&P wastes under RCRA Subtitle regulations is C to reducetoxicity. Among the wastes covered by the 1978 proposal were This publication was produced by EPA to provide an un“gas and oil drilling muds and oil production brines. or under other federal regulations. At times this determination is misunderstood and may tion. (E&P) operations.EPA proposed hazardous waste man1985 E&Pwaste volume data. are hazardous wastes. did not preclude these wastes from control unlead to improper waste management decisions. Those estimates were proExamples of exempt and nonexempt wastes. managing all these wastes in a mannerthat lieved these large volume “special wastes” are lower in toxicity than other wastes being regulated as hazardous wastes protects human health and the environment is essential for limiting the operators’ legal and financial liabilities and underRCRA. Prudent der state regulations. produced 69 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services ~ . a will be better prepared to develop site-specific waste mandecrease of 58 percent.A P I / P E T R O ES-ENGL L997 m 0732240 05b11739 9 b 2 m Appendix G-REPRINT OF EPA PUBLICATION (EPA 530-1<-95-003). as hydrocarbons from producing wells deplete.4 million feet in 1985 to 133. On the other hand. Also. It seems logical to assume that agement plans and to manage E&P wastes in a manner that drilling waste volumes would have declined proportionately protects human health and the environment. operators should familiar with state and be fedcould not present ahazard to human health andthe environeral regulations governing the management hazardous and of ment if managed improperly. Development and Production U.9 billion barrels of produced water exemption. Nevertheless. The preferred option for prewastes from the RCRA Subtitle C hazardous wasteregulaventing pollution is to avoid generating wastes whenever tions pending a study and regulatory determination by EPA. the operator 315.” the A basic background of the E&P exemption.” The derstanding of the exemption of certain oil and gas explooil and gas exemptionwas expanded in the 1980 legislative ration and production (E&P) wastes from regulation as amendments to RCRA to include “drilling fluids.8 million barRecommendations for sensible waste management.Congressexemptedthese makes good business sense. Environmental Protection Agency (EPA) presented estimates Basic rules for determining the exempt or nonexempt on the amount of oil and gas drilling and production wastes status of wastes.~ S T D . should bebased on the inherent nature of the waste. rels of other wastes associated with E&P operations were Additional sources of information. nonhazardous wastes. which would resultin a corresponding reor nonexempt status of a waste is a valuable tool. it is uncertain whateffect the agement standards which included reducedrequirements for downward trend in drilling activity has had on total E&P several types of large volume wastes. especially duction in the generation of drilling wastes. although they are relieved from regulation as waste management options appropriate for every waste. generated that same year. MAY 1995Crude Oil and Natural Gas Exploration and Production Wastes: Exemption from RCRA Subtitle C Regulation INTRODUCTION hazardous wastesunder Subtitle C of the Resource Conservation and Recovery Act(RCRA). the exemption does not mean these wastes Additionally.
. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .” (Geothermal energy wastes were also exempted but are not addressed by this publication.70 API E5 water. EXEMPT AND NONEXEMPT WASTES In its 1988 regulatory determination. or a gas plant to a carrier for transport to market. and someintrastate pipelines. and other wastes associated with the exploration. and tertiary production of oil gas. In general. then the waste is most likely considered exempt from RCRA Subtitle C regulations. the primary.) According to the legislative history. de-emulsifying. Similar wastes generatedby activities other than E&P operations are not covered by the exemption. Examples of carriers include trucks. becausenatural gas often requires processing toremove water and other impurities prior to en- tering the sales line. Crude oil processing suchas water separation. some exempt E&P wastes might harmful to human be health and the environment and many nonexempt wastes might not be as harmful. secondary. or production of crude oil or natural gas. and storage attank batteries associated with a specific well or wells are examples of primary field operations. development. The phrase “intrinsically derived from the primary field operations” is intended to distinguish exploration. development. degassing. the exemptstatus of an E&P waste depends on how the material was used or generated as waste. With respect to natural gas. The lists are provided as examples of wastes regardedas exempt and nonexempt and should not be considered comprehensive. For example. EPA published the following lists of wastes that were determined to be either exempt or nonexempt. Primary field operations include exploration.. primary fieldoperations include activities occurring at or near the wellhead and before the point where the oil transferred from anindividual field fais cility or a centrally located facility to a canier for transport to a refinery or a refiner. 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. was it brought to the surface during oil and gas E&Poperations? 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. Furthermore.. The exempt waste list applies only to those wastes generated by E&P operations. or production of crude oil and natural gas.e. development or and. and production operations from transportation and manufacturing operations. gas plantsare considered part of production operations regardless their location with respect the of to wellhead. not necessarily whether thematerial is hazardous or toxic. development. i. the term “other wastes associated” specifically includes waste materials intrinsically derived from primary field operations associated with the exploration. With respectto crude oil. interstate pipelines. a centrally located facility. primary field operations are those activities occurring or near the wellheador at the gas at plant but before the point where the gas is transferred from an individual field facility.
and molecular sieves Gas plant sweetening wastes for sulfur removal. Natural Gas and Geothermal Energy. and waste acids Vacuum truck drum and rinsate trucks from and drums transporting or containing nonexempt waste Refinery wastes Liquid and solid wastes generated by crude oil and tank bottomreclaimersl Used equipment lubricating oils Waste compressor oil. and miscellaneous solids notice “Clarification of the Regulatory Determination for Wastes from the Exploration. fluid treating vessels. and volatilized hydrocarbons Materials ejected from a producingwell during the process known as blowdown Waste crude oil from primary field operations in Light organics volatilized from exempt wastes reserve pits or impoundments or production equipment . hydrocarbon solids.S T D . o . Pages I5284 to 15287. spent solvents. backwash. and backwash (assuming the filter itself is not hazardous and the residue in it is from an exempt wastestream) Pipe scale. o . iron sponge. I NONEXEMPT E&P WASTES 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. amine filter media. and blowdown Used hydraulic fluids Waste in transportation pipeline related pits Caustic or acid cleaners Boiler cleaningwastes Boiler refractory bricks Boiler scrubberfluids. 1993. produced water separated from tank bottoms) are exempt. glycol filters. aminefilters. sludges and ash Incinerator ash Laboratory wastes Sanitary wastes Pesticide wastes Radioactive tracer wastes Drums. residuals derived from exempt wastes (e. including glycol-based compounds.except for the nonexempt wastes listed below Constituents removed from produced water before it is injected or otherwise disposedof Liquid hydrocarbons removed from the production stream but not from oil refining Gases from the production stream such as hydrogen sulfide and carbondioxide. painting wastes. and production impoundments Pit sludges and contaminated bottoms from storage or disposal of exempt wastes Gas plant dehydration wastes.A P I I P E T R O ES-ENGL L797 m 0732270 05b474L 520 WASTE MANAGEMENT AND IN EXPLORATION PRODUCTION OPERATIONS 71 EXEMPT E&P WASTES Produced water Drilling fluids Drill cuttings Rigwash Drilling fluids andcuttings from offshoreoperations disposed of onshore Geothermal production fluids Hydrogen sulfide abatement wastes from geothermal energy production Well completion. o . drum rinsate. precipitated amine sludge. . treatment.g. . March 22. 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. Volume 58.. filter media. solids. 1 Although non-E&P wastes generated from crude oil and tankbottom rechmation operations( e g . insulation. and emulsion from production separators. including amines. sands. see the Federal Register COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . hydrates. For a further discussion. and Production of Crude Oil.waste equipmentcleaning solvent)are nonexempt. and hydrogen sulfide scrubber liquid and sludge Workover wastes Cooling tower blowdown Spent filters. filters.” Federal Register. spilled chemicals. and other deposits removed from piping and equipment prior to transportation Produced sand Packing fluids Hydrocarbon-bearingsoil Pigging wastes from gathering lines Wastes fromsubsurface gas storage and retrieval. sandblast media. Development. backwash. . filter media. o o .
Development. or Production? Yes No > > Listed Hazardous Waste? Yes I No +No v Exhibit Hazardous Characteristic? -Yes - I A f Nonhazardous Waste (Subject to Subtitle D and other State and Federal Statutes) Exempt from RCRA Subtitle C (Subject to Subtitle D and other State and Federal statutes) See Mixture Flowchart Hazardous Waste Subject to RCRA Subtitle C 4 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . ExempVNonexempt Flowchart Waste from Exploration.~~ STD*API/PETROES-ENGL L777 0732270 05bL17L12 L157 W 72 API E5 The following flowchart may be useful in determining whethera waste is exempt or nonexempt fromRCRA Subtitle C regulation.
Whenever possible. butdoes exhibit some other hazardous characteristic such as toxicity. after mixing nonexempt caustic soda (NaOH) (corrosive) in a pit containing exemptwaste. after mixing a nonexempt characteristic hazardous waste with an exempt waste. the mixture is a nonexempt hazardous waste. Note: As this document was being prepared. the mixture exempt. it is still exempt. 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. reactivity. the wastes could become nonexempt even if only one barrel of hazardous waste was mixed with 10. creates additional considerations. Example: If. after mixing a nonexempt characteristic hazardous waste with an exempt waste. Pages 29860 to 29887. or toxicity). Even if the mixture is exhibits some other characteristic of a hazardouswaste. the mixture exhibits the characteristic for benzene but not for lead. If the nonexempt waste isa listed or characteristic hazardous waste. the of wastes in thepit remain exempt regardless the characteristics of the waste mixture in the pit.’’ Federal Register Volume 58. Example: If any amount of leadedtankbottomsfrom the petroleum refining industry (listed as waste code K052) is mixed with an exempt tank bottom waste. Subpart D. If. the mixturebecomesa nonexempt hazardous waste regardless of the relative volumes or concentrations of the wastes. 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 mixture is considered a hazardous waste and is therefore nonexempt. In other words.A P I / P E T R O ES-ENGL L777 m 0732270 05b11743 373 m WASTE MANAGEMENT IN EXPLORATION AND PRODUCTION OPERATIONS 73 MIXING WASTES Mixingwastes. . the for entire mixture becomes a nonexempt hazardous waste. Example: If. For additional information. avoid mixing nonexempt wastes with exempt wastes. after mixing nonexempt hydrochloric acid (HCI) that exhibits the corrosivecharacteristic only with an exempt waste. the mixture exhibits the hazardous characteristic benzene. Example: If. the status of the rule should be determined prior to mixing any E&P wastes with hazardous wastes. 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. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . for both scenarios. exemptwastewithanotherexempt waste remains exempt.S T D . Mixing a nonhazardous waste (exempt or nonexempt) with an exempt waste resultsin a mixture that is also exempt. the mixture is exempt. the resulting mixture exhibits any of the same hazardous characteristics as the hazardous waste (ignitability. the mixture also exhibits the hazardous characteristic of corrosivity as deentire mixtermined frompH or steel corrosion tests. the mixture does not exhibit the hazardous characteristic of corrosivity. Furthermore. 1993. the resulting <mixturedoes not exhibit any of the same characteristics as the hazardous waste. 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 processsubject to appropriate RCRA Subtitle C hazardous waste regulation and permitting requirements.particularlyexemptandnonexempt wastes. if a mixture of an exempt waste with a nonexempt characteristic hazardous waste exhibits any of the same hazardouscharacteristicsas the hazardouswaste. in some instances. the mixture is a nonexempt hazardous waste. Determining whether a mixture is an exempt or nonexempt waste requires an understandingof the nature of the wastes prior to mixing and. after mixing a nonexempt waste exhibiting the hazardous characteristic for lead with an exempt waste exhibiting the characteristic for benzene. I . the resulting mixture may become a nonexempt waste and require management under RCRA Subtitle C regulation. regardlessof the proportions. Interim Final Rule. Example: If. “Land Disposal Restrictions for Ignitable and Corrosive Characteristic WastesWhose Treatment Standards Were Vacated.May 24. A mixture ofan Llsted hazardous wastes are those wastes listed as hazardous in the 40 Code of Federal RegulationsPart 261. might require a chemical analysis of the mixture. corrosivity. the mixture is exempt. Similarly. the ture becomes a nonexempt hazardous waste.000 barrels of exempt waste. Generally. If. the mixture rule was being reexamined by EPA as a result of a court challenge. after mixing a nonexempt solvent containing benzene with an exempt waste also containing benzene. 2 i Below are some basic guidelines for determininga mixif ture isan exempt or nonexempt waste under the present mixture rule. refer to the Federal Register notice. Because the rule could be amended or clarified. Example: A mixture of stimulation fluid that returns from a well with produced waterresults in an exempt waste. if a listed hazardous waste’ is mixed with an exempt waste.
Possible Waste Mixtures Exempt Waste Exempt Waste Nonhazardous Waste W 4 Exempt Waste - Exempt Waste Exempt Waste (See Note on Previous Page) No J Does Mixture Exhibit any Exhibited by Nonexempt Waste? Nonexempt Characteristic Hazardous Waste Yes W Nonexempt Characteristic Hazardous Waste Exempt Waste Listed Hazardous Waste Listed Hazardous Waste COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .STD-APIIPETRO ES-ENGL L997 m O732290 0 5 b 9 7 4 9 22T I ' 74 API E5 The following flowchart depicts the various possible mixtures and their exempt and nonexempt status.
a mixture of a hazardous waste that exhibits one of the characteristics of a hazardous waste (ignitability. Additionally. the waste must have been generated froma material or process uniquely associated with the exploration. Misunderstanding: A waste exempt fromRCRA Subtitle C regulation is also exempt from state and other federal waste management regulations.. are not exempt. and production of crude oil and natural gas. Conversely. only those wastes generated from amaterial or process uniquely associated with the exploration and production of oil and gas are considered exempt.WASTE MANAGEMENT IN EXPLORATION AND PRODUCTION OPERATIONS 75 COMMON MISUNDERSTANDINGS An incomplete understandingof the hazardous waste regulations can result in misinterpretations about the regulatory status of various wastes. Misunderstanding: Unused products are exempt. and National Pollutants Discharge Elimination System (NPDES) state discharge or regulations) unless specifically excluded from regulation under those laws. The most common misunderstandings that arise with the RCRA Subtitle exemption and hazC ardous waste determinations are presented for here clarification. For example. regardless of their intended use.g. Conversely. if the same solvent were used in a well. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . development. As with all oilfield wastes. a mixture of a listed hazardous waste with an exempt waste becomes a nonexempt hazardous waste. mixing anonexempt hazardous waste with an exempt waste for the purpose rendering the hazardous waste nonof hazardous orless hazardous may be considered a treatment process and must be conducted in accordance with applicable RCRA Subtitle C regulations and permitting requirements. some of these wastes may still be subject to state hazardous or nonhazardous waste regulations or other federal regulations (e. it would be exempt because was genit erated through a procedure that is uniquely associated with production operations. Misunderstanding: Any mixture of a nonexempt hazardous waste with an exempt waste becomes exempt waste. Fact: The exemption applies only to the federal requirements of RCRA Subtitle C. Fact: Certain exempt wastes. hazardous materials transportation regulations. reserve pit regulations. For example. Misunderstanding: All wastes located at E&P sites are exempt. 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. reactivity.g. or production operations. Fact: Unused products. Fact: Not all service company wastes are exempt. becomes nonexempt charactera istic hazardous waste if the mixture exhibitsone of the same hazardous characteristics as the original hazardous waste. oil and gas exploration and production wastes are subject to regulation under the Clean Air Act (CAA). while excluded from RCRA Subtitle C hazardouswaste control. or toxicity) with an exempt waste. the mixture becomes a nonhazardous exempt waste. if disposed of. Also. To be considered an exempt waste. Generally. corrosivity. Clean Water Act (CWA). Misunderstanding: All exempt wastes are harmless to human health and theenvironment. might still be harmful to human health andthe environment if not properlymanaged. Fact: All wastes located at E&P sites are not necessarily exempt. they are disposed of) they are subject to RCRA Subtitle C hazardous waste regulations if they are listed or exhibit a hazardouscharacteristic. development. an Fact: Not all mixtures ofa nonexempt hazardous waste with an exempt waste become exempt wastes. and Oil Pollution Act of 1990 (OPA).. The previous example of solvents used for cleaning equipment and machinery would also apply in this case-the solvent is not an exempt waste. As previously noted. 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 but does C not indicate the hazard potentialof the exempt waste. When unused products become waste (e. because they have not been used and therefore are not uniquely associated with the exploration or production of oil and gas. if the mixture does not exhibit one of the same hazardous characteristicsof the hazardous waste. Misunderstanding: All service company wastes are exempt. asolvent used to clean surface equipment or machinery is not exempt because it is not uniquely associated withexploration. Safe Drinking Water Act (SDWA).
Hence. 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. the operator should make every effort to choosethe proper management disposal proceand dures for the particular waste to avoid the need for later cleanup action. The Agency has takenthe in position that these compressor stations (in the absence of gas plants. A: For crude oil. Q: Are RCRA-exempt wastes also exempt under other federal laws? A: Not necessarily. The RCRA Subtitle C exemption only applies to wastes generated from the exploration. not to additional wastes generated by the treatmentor reclamation of exempt wastes. The exemption applies only to thosewastes derived from exempt wastes. Unless specifically excluded from regulation under other federal laws. In some regions. directly to the customer. any waste derivedfrom the exempt waste being treated is also exempt but the spent acid is not. For example. rather than transportation. development. and that wastes generatedby these compressor stations are exempt.g. Q: When does transportation begin? 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.e. However. EPA periodically issues interpretive letters regarding the oil and gas exemption. Q: When isa waste considered “uniquelyassociated with exploration and production operations? ” A: No.crude oil). Storage of crude oil in stock tanks at production facilities is considered part of the production separation process. and is includedin the exemption. not transportation. primary field operations) of crude oil or natural gas. and handling only local production) should be treated the same as gas plants.. if a treatmentfacility uses an acid inthe treatment of an exempt waste. such as the Appalachian states. Naturalgas pipelines between the gas well and the gas plant are considered to be part of the production process. and in the some cases.. natural gas does not require sweetening or extensive dehydration. and wastes that are uniquely associated with production that are generated along such a pipeline are exempt. after the end point of production separation and dehydration. On the other hand. Therefore the gas generally does go to a gas plant but is not canied from wellhead to a main transmissionline. transportation begins at the point where the gas leaves the facility after production separation and dehydration at the gas plant. transportation begins at the point of custody transfer of the oil or. Also. compressor stations located along main gas transmission lines are considered tobe part of the transportation process and any wastes generated by these compressor stations are nonexempt. the RCRA exemption does allow the operator to choose awaste management and disposal option that is less stringent and possibly less costly than those required under RCRA Subtitle C. wastes generated from the transportation of crude oil or natural gas are not RCRA-exempt. in the absence of custody transfer. RCRA-exempt wastes might still be subject to regulation under authorities other than RCRA. 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. 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 the lines.76 API E5 FREQUENTLY ASKED QUESTIONS EPA receives calls on a regular basis requesting answers to questions related to the E&P exemption. A simplerule of thumbforidentifying“uniquelyassociatedwastes”is whether the waste came from downholeor otherwise was generated in contact with the oil gasproduction stream for or the purpose of removing water or other contaminants from the well or the product. 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. For natural gas. Q: Are wastes generated from a transportation pipeline considered exempt wastes under RCRA Subtitle C? A: No. and production (i. Exempt wastes maintaintheir exempt status even if they undergo custody transfer and are transported offsite disposal or treatfor ment. Q: Do exempt wastes lose their exempt status if they undergo custody transferand are transported ofssite for disposal? COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Q: Are all wastes generated at facilities that treator reclaim exempt wastes alsoexempt? A: Although the operator might still be liable cleanup acfor tions under RCRA for wastes that pose an imminent and substantial endangerment to human health and the environment. The most common questionsand answers are listed below. Q: What is the benejìt of the RCRA exemption ifthe operator is still liable for deanupsunder RCRA? A: No.
Perform routine inspections of materials and waste storage areas to locate damaged or leaking containers. Available from: American Petroleum Institute 1220 L Street.. Pages 25446 to 25459. (800)426-479 1 Title: API Environmental Guidance Document: Onshore Solid Waste Management in Exploration and Production Operations. Publications Title: EPA Report to Congress: Management of Wastes from the Exploration. 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. January 1989.g. particularly with oil based muds. Recycle and reuse oil based muds and highdensity brines when practical. Suggested E&P Waste Management Practices Size reserve pits properly to avoid overflows. 1993.C. Natural Gas. Minimize the volume of materials stored at facilities. D. and Production Wastes. Use closed loop mud systems when practical. VA 22161 (703) 487-4650 Title: Regulatory Determinationfor Oil and Gas and Geothermal Exploration. 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). and select less toxic alternatives when possible. Available from: RCRNSuperfund Hotline Washington. Available from: National Technical Information Services 5285 Port Royal Road Springfield. such as by designing systems with thesmallest volumes possible(e. Available from: RCWSuperfund Hotline Washington. 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. Development. Construct adequate berms around materials and waste storage areas to contain spills. July 6. 1988. D. Washington. Natural Gas and Geothermal Energy. PB 88-146212.C. March 22. and Production of Crude Oil. D. NTIS Publication No. The following waste management suggestions have been compiled from publications produced by these organizations as well as from literature available from industry trade associations. Suite 185 Phoenix. Development. Perform routine equipment inspections and maintenance to prevent leaks or emissions. Minimize waste generation. Train personnel to use sensible waste management practices.S T D * A P I / P E T R O ES-ENGL L777 m 0732290 05b11747 T37 m WASTE MANAGEMENT EXPLORATION PRODUCTION OPERATIONS IN AND 77 SENSIBLE WASTE MANAGEMENT Prudent operators will designE&P facilities and processes to minimize potential environmental threats and legal liabilities. Arizona 85016-4412 (602) 956-6399 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Federal Register Volume 53. and Geothermal Energy. Design the drilling pad to contain storm water and rigwash. Federal Register Volume 58. Review material safety datasheets (MSDS’s) of materials used. Development. and Production of Crude Oil. Pages 15284 to 15287. Reduce the amount of excess fluids entering reserve and production pits. Reclaim oily debris and tank bottoms when practical. December 1987. N. drilling mud systems). (800) 426-4791 Title: Clari’cation of the Regulatory Determinationfor Wastes from the Exploration. trade journals. Do not place nonexempt wastes in reserve or production pits . and EPA.C.W.
Environmental Protection Agency Office of SolidWaste Oil and Gas Industry Section (5306W) 401 M Street. D. (800) 424-9346 Safe Drinking Water Hotline Washington. (800) 426-479 1 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . 20460 (703) 308-8424 RCWSuperfund Hotline Washington.W. S.C.78 API E5 OTHER SOURCES OF INFORMATION U. D. D.S.C. Washington.C.
~~ STD=API/PETRO E5-ENGL 1777 m 0732270 05b4748 7 7 5 m COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .
Northwest Washington. GE5002 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . 20005-4070 202-682-8000 Order No. D.Additional copies available from API Publications and Distribution (202) 682-8375 Information about API Publications.C.api. Programs and Services is available on the World Wide Web at: http://www.org American Petroleum Institute 1220 L Street.
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