Environmental Guidance Document: Waste Management in Exploration and Production Operations


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.

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

American Petroleum Institute

COPYRIGHT American Petroleum Institute Licensed by Information Handling Services


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

Every effort has been made by the institute to assure the accuracy and reliability data contained in them. It must use environmentally sound operating practices to manage materials. D. well completions and workovers. 1220 L Street. The oil and gas industry must operate where oil andgas deposits are found. warranty. which include exploration. drilling. of the the institute makes no representation.C. b. Washington. under the jurisdiction of the API Exploration and Production Department Executive Committee on Environmental Conservation. and gas plant operation. N. and the waste generated from exploration and production activities. Suggested revisions are invited and should be submitted director of the Exploration to the and Production Department. It provides guidancefor minimizing the direct and indirect environmental impacts of solid wastes originating from typical exploration and production (E&P) activities. whose sensitivity to the activities man will vary widely. This manual was prepared by the API Production Waste Issues Group. 20005.W. This means that the exploration and production activities listed above will beconducted in a variety of ecosystems. or municipal regulation with which this publication mayconflict. API publications may be used by anyone desiring to do so.. state. field production. however. 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. The oil and gas inof dustry must be environmental stewards two critical ways: in a.FOREWORD This document reflects our industry’s continuing commitment to environmental protection. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . American Petroleum Institute. It must produce oil and gas reserves as efficiently and prudently as possible in order to prevent squandering critical natural resources.

........................... 17 ENVIRONMENTAL LEGISLATION AND REGULATIONS Introduction .............. 25 The Toxic Substances Control (TSCA) ...................................................................................................4 2............................2 2........................................................................ Understanding Operational Impacts Pollution Prevention and waste Minimization ..........................................................................1 6................ 41 V COPYRIGHT American Petroleum Institute Licensed by Information Handling Services ...................3 2..............................................3 3........................ 16 Offshore Operations .............................................. 10 Gas Plant Operations.........2 6................................................................. Auditing............................................ 22 The Clean Water Act (CWA) ......1 3............... 38 Produced Water.........8 The Oil Pollution Act of 1990 (OPA 90) ................................................................................................................................1 1..................and Liability Act (CERCLA) ........................................................5 3 3........................... 27 27 4. 23 The Clean Air Act(CAA) .................4 3........... WASTE MANAGEMENT SYSTEM Introduction ......................5 6 6..............................................2 1..............................API/PETRO ES-ENGL L777 m 0 7 3 2 2 9 0 05b4b73 L4T CONTENTS page 1 1.... and 17 The Safe Drinking Water Act (SDWA) ...................................................................................................... 30 Disposal .......................3 6.................................................................................................................. 9 Field Production .............................................................................................................5 2 2..........................................................................................................2 4..................................................................................................................................................................9 Other Federal Acts........................................4 1........5 3.......................................................8 4 4..................................................................4 5......................................................................... 39 Drilling Wastes ..................................................................... 30 Treatment..................................1 5....................................... ........................................................6 4..................................................................................................................................................................................~~ STC........... Compensation..................................... API’s Management Practice for Pollution Prevention...................................................................3 4..........................................................................................................4 4.......... 4.............7 POLLUTION PREVENTION Introduction .............2 3.........................1 4.................................... 29 5 5.........................................................................................1 2...............................................................2 5.................................................................................................................... 30 IDENTIFYING MANAGEMENT OPTIONS FOR SPECIFIC WASTES Introduction ..................5 4....................... Training ............................................... 25 4...........................................................3 5... 6 Exploration ...................... Summary of a Ten-Step Plan for Waste Management.................... 17 The Resource Conservation Recovery Act (RCRA) ........ 1 1 1 3 3 4 4 4 5 5 WASTE GENERATION IN EXPLORATION AND PRODUCTION OPERATIONS Introduction ...........................................................................................6 3...................... 7 Completion and Workover ........ 6 Drilling ..... 29 Source Reduction ....10 Other Regulations and Agreements .........................................3 1......... 25 Act The ComprehensiveEnvironmental Response.... Waste Tracking ............7 3..................... 29 Recycling andReclaiming...............4 WASTE MANAGEMENT METHODS Introduction ................................ 39 Workover and Completion Wastes ....................................................... 14 Transportation Pipelines ............................ Media ...........................................................................................................................................

...............................................Crude Oil and Natural Gas Exploration Production Wastes: Exemption from and RCRA Subtitle C Regulation ......................................... A................................................12 Downhole and Equipment Scale ............................................................................................................................................................................. 46 6.................................................................. APPENDIX E-Acronyms ...................... 45 6...1-Ten-Step Plan for Preparing a WasteManagement Plan .................................... 46 6........................................................................................................... 5 30 33 34 49 56 57 61 vi COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .......................................... APPENDIX F-Reference Materials .............................. Emulsions................. Figures 1-Media 49 55 57 61 63 67 69 Pathways ........................................................................................... 3-API Metals Guidance: Maximum Concentrations .... Soil &Example of E&P Waste...................................7 Used Oils and Solvents......................................................................................................................................... 45 6............................ 45 6............1 ” S u m m q of Key Legislation and Regulations................................................................................................................................................... 47 6................. 43 6........ C.............18 NonPCB Transformer Oil ... 43 6............................. 2 Tables 1-Ten-Step Plan Summary .................. 47 6........................................................................ APPENDIX B-Waste Management Planning Aids .... Scrubber Liquids.............. 2-Overview of Waste Management Methods ........... and Applicable Constituent Criteria ................................ 46 6........................... APPENDIX G-EPA Publication: (EPA 530-K-95-003)...................................Page 6.................................................................................... D .......15 Asbestos .................................................... 44 6......................................9 Oily Debris and Filter Media .............................22 Recompression and Facility Utility Wastes.............................10 Gas Plant Process and Sulfur Recovery Waste........................................20 Naturally Occurring Radioactive Material 6.............................. May 1995....17 PCB Transformer Oil ................................................................................ B-1-Iron Sulfide Scale and Iron Sponge................................................................................ 42 6..........14 Unused Treatment Chemicals ............. APPENDIX D-Summary of Environmental Legislation and Regulations.........................................I-Summary Waste Table ................. Heavy Hydrocarbons.............. 47 APPENDIX A-Guidelines for Developing Area-Specific Waste Management Plans .......................................................13 StormwaterRigwash ............ APPENDIX C-Summary Waste Table ........... Disposal Technique............................................ 46 6........................................ and Produced Solids .....................19 Empty Oil and Chemical Drums .............8 Dehydration and Sweetening Waste .......................................................................................................................................5 Tank Bottoms....................................... 44 6......................... and Steam Generator Wastes .........................16 Used Batteries .... Boiler Water..... 45 6.......6 Contaminated Soil ....................1 1 Cooling Tower Blowdown.......................................................................................................................... 47 ..............................21 Geological and Geophysical OperationWastes ....... 46 6.......

To recognize and to respond to community concerns about our raw materials. identifying their sources. 1. and waste materials. Including pollution prevention objectives in research efforts and in the design of new or modified operations. including sharing of industry experiences and accomplishments. use. including the EPA hierarchy of waste management. operational impacts. handle. 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. use. beneficial use. technology and economics. To work with others to resolve problems created by handling and disposal of hazardous substances from our operations. j. water. workplace. regulations. g. Supporting an outreach program to promote pollution prevention opportunities within the industry. waste minimization. transport. b. customers. health. To participate with government and others in creating responsible laws. and waste materials. e. and wastes. and others in the safe use. .~~ ~ STD. and environment. petroleum products. f. health. This section presents an overview of media. processes. and standards to safeguard the community. or land. waste treatment. Industry should review its use of materials. or dispose of similar raw materials. products. employees. To develop and produce natural resources economically and to conserve those resources by using energy efficiently. practices. which are as follows: a. health. environmentally sound recycling. and operations. They provide specific guidelines for compliance with these Guiding Environmental Principles. water. actions. To promote these principles and practices by sharing experiences and offering assistance to others who produce. d. and settinggoals and schedules for reducing releases and measuring progress. source reduction. processes. soil. Steps to consider in developing and operating such a program include the following: a. and environmental effects of our raw materials. products. 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. and/or land disposal Details are presented in 1. To make safety. These basic concepts are critical in achieving pollution prevention goals. 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. and proper disposal practices. and environmental hazards and to recommend protective measures. d. It includes the development of more environmentally acceptable products. Pollution prevention requires continuous improvement in operating practices. proper waste handling. and products. To operate our plants and facilities. processes. and evaluating their impact on human health and the environment. developing approaches for reducing releases. Waste can be transported via three natural carriers-water. b. and development of new products and processes. i. and waste minimization methods. transporters. To extend knowledge by conducting or supporting research on the safety.1 INTRODUCTION Pollution prevention is the practice of reducing or eliminating pollutant discharges to air. c.2 API’SMANAGEMENTPRACTICE FOR POLLUTION PREVENTION Both management commitment and comprehensive planning are critical to a successful pollution prevention program. and the publicof information on significant industryrelated safety. and land. e. Periodically reviewing and identifying pollution prevention options and opportunities.2. consider the issues of community concerns. c.3 MEDIA Proper management of wastes is important to the protection of human health and the environment. and products in order to identify ways to reduce or eliminate pollution. and resource commitments.3. Developing an inventory of significant releases to air. To counsel customers. and impact on human health and the environment. (most preferred) (least preferred) I 1. To commit to reduce overall emissions and waste generation. communications.API/PETRO ES-ENGL L777 m 0732270 05bVb75 T L 2 111 Waste Management in Exploration and ProductionOperations 1 Pollution Prevention 1. and environmental considerations a priority in our planning. Providing management supportfor ongoing pollution prevention activities through appropriate policies. changes in processes and practices. h. 1 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services f. transportation. and air. k. and disposal of our raw materials. products. To advise promptly appropriate officials. 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.

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). Most fresh water is stored in underground reservoirs called aquifers. and recreational uses. once in the soil. industrial. Thus. Soil acts to retain spilled. pollutants can migrate to air and water and be picked up plants and animals. and reservoirs. recreation.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. domestic needs. The quality of aquifer waters can be degraded by pollutants to such a degree that it is not practical to restore the aquifer to drinking water standards. 1.STD. lakes. or disposedmaterials. some of these pollutants may cause that water to fail drinking water standards. and industry comes from underground aquifers.3. and other sources. human. irrigation of crops. Air. stock water. improperly stored. Materials fromspills or improper waste disposal may contaminate aquifers. Of major concern are those aquifers that contain water suitable for drinking.2 Soil Spills can adversely affect the capacity of soil to support agricultural. These porous formations or sediments can store and transport groundwater from rain. streams. 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. and Water Can Transport Pollutants Away From Their Original Source COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Contamby Evaporation and transpiration from bgd = billion gallons per day Figure 1-Basic Media of Soil. however.1 Water Fresh water for human consumption. leakage of stream beds. 1. Also important are aquifers used for agricultural purposes.3.

liquid. while more significant threats remain ignored.4 UNDERSTANDING OPERATIONAL IMPACTS Because exploration and production (E&P) operations can affect all environmental media.5. or contained gaseous material. and Gaseous waste released to the air can potentially affect huefforts to reduce potential environmental liabilities.3. and the economy. 1. subject to federal permits under the Clean Water Act. and be leached downward into groundwater. are not considered solid wastes. inherently generates wastes. reduce. a solid waste is any material that is discarded or intended to be discarded.2 EPA Hierarchy ofMethods EPA has developed the following hierarchy waste manof agement methods to guide generations toward waste minimization. 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. gaseous wastes may alter the chemical minimization programs. 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. The four waste management hierarchy steps. Ozone deplewaste management and incorporate pollution prevention tion and global warming thought by some to be the result are concepts. such as materials recovery or energy production. inants can evaporate into the atmosphere. of human impact on the atmosphere.4 Summary A properly implemented pollution prevention program can reduce or eliminate pollutant discharges to air.5POLLUTIONPREVENTIONANDWASTE MINIMIZATION Waste minimization is a major component of pollution prevention. increasing complexity of waste management regulations. through the following methods: reuse reprocess reclaim use as fuel underground injection for enhanced recovery roadspreading 1. 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. API suggests the use of sound science to identify adverse impacts and the means to mitigate.~ STD. be carried by rainwater to a lake. or other surface water. Recycling/Reuse-reuse and recycle material for the original or some other purpose. Point source water discharges. in decreasing order of preference are as follows: a. Some of these wastes are similar to those c. 1. Without sound scientific information.an extractive procedure. ecosystems.1SolidWasteDefinition According to federal regulations. 1. Sound science is the to determining which environkey mental problems pose the greatest risk to human health.3. balance in the atmosphere. for expanding waste management options reto duce risk. 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.5. high profile but low risk problems may possibly be targeted. Science provides the foundationforidentifyingmethodstopreventorreduce pollution. 1. animals. and plant life through inhalation or dermal API member companies have implemented in-house waste contact. and for developing and improving pollution control technologies. many mans.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. Acid rain is a known result of alThese programs go beyond traditional approaches to tering the chemical makeup of the atmosphere. Treatment-destroy. Science is also critical to developing cost-effective strategies that address environmental risks. this may occur onsite or offsite. The goals of a waste minimization planare to reduce the total volume or quantity of waste generated and to reduce the toxicity of waste.3 Due to large increases in costs of waste management. Solid wastes may be either solid. or land. detoxify. Indirectly. Hydrocarbon recovery. semi-solid. 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 . water. Air 1. or eliminate them. creek.

f. A system for pollution preventiodwaste minimization. Protect public health and worker health and safety.5. Form a basis for training. c.4 API E5 chemical stabilization incineration landfarming landspreading d. and/or national waste minimization goals. e. andauditing are also discussed. A system for maintaining knowledge of pertinent laws and regulations. g. and recordkeeping. This section introduces the concept of a waste management plan-the tool for implementing these key elements at the field level. f. Meet company. waste tracking. Provide proper management guidance each waste genfor erated in E&P operations. Reduce potential environmental liabilities. A transportation program. This plan is described in detail in Appendix A. The key elements of training. Federal agencies also mandate personnel training as follows: a.2 SUMMARY OF A TEN-STEP PLAN FOR WASTE MANAGEMENT A waste management plan should a. Legal liability. Be used to ensure regulatory compliance and environmentally sound management of wastes. Emergency response to a release of hazardous chemicals COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . A health and safety program. a company may consider scheduling periodic training to cover updatesof procedures. d. includingrisk reduction for future liabilities. waste management needs be viewedas an to integrated system. A proper waste storage and disposal program. The U.3 Summary By incorporating waste minimization practices into the waste management program.the generator may further efforts to a.A good waste management system should include the following key elements: a. j. associated with improper handlingof waste. 2 Waste Management System 2. and feedback fromfield personnel. Benefits of proper waste management. inventories. b. Be periodically reviewed and updated as new practices and options are discovered. state. b. Offer a solid waste plan that is area-specific. h. environmental and legalspecialists. review of incidents. b. A system for waste tracking. d. both corporate and personal. where actual waste management decisions should be made. It has proven successful for a number of member companies. e. e. b. Save money by reducing waste treatment and disposal costs and other operating costs. Field personnel and management shouldbe trained in environmentally sound and safe waste management practices. c. Disposal-dispose of wastes through the following methods: landfills NPDES discharge solidification burial underground injection for disposal 2. 1. open communication amongfield operations personnel.1 INTRODUCTION In order to achieve pollution prevention and waste minimization goals. A training program. 2. Review of internal environmental policies and other documentation of management support.S. Instruction in waste management should include the following: a. detailed training for certain operations that may be associated with waste management. In addition. evaluation. and pollution prevention programs. e. A waste management auditing program. A system for proper waste identification. Environmental laws and regulations. Appendix B includes planning aids to help in preparing the waste management plan. c. Health and safety concerns related to waste handling. f. API suggests the ten-step waste management plan shown into in Table 1 for integrating the waste management system operations. c. The applicable facility waste management program. An incident response preparedness program. monitoring. b. Be written for field operations. Both technology andregulatory requirements in the environmental field are changing constantly. and management is crucial to conducting environmentally sound operations.3 TRAINING Training in the proper identification and handling waste of material is vital in any exploration or production operation. For these reasons. Protect the environment. i. g. d. Occupational Safety and Health Administration (OSHA) requires specific. d. General environmentalawareness.

workshops. e. Regulatory analysis-complete reviews of relevant federal. c. Step 7. Waste classification-categorize each identified waste. and waste management requirements. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .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. lease. 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. The EPA requires annual training for certain hazardous waste generators (40 Code of Federal Regulations Part 262.1 Company Facilities An onsite waste management auditing program assesses the compliance status of a company’s facilities and programs for waste management. Review and update waste management plan-Define a review and update procedure. 2. and incidents or accidents.subject a company toloss of business opportunities. criminal penalto available through academic institutions private companies.120).4 WASTE TRACKING is that company management provided with information on is To ensure proper waste disposal and to minimize individual waste management practices. imof Identification of types and amounts waste generated benof Table 1-Ten-Step Plan Summary Step I . Other potential benefitsinclude company liability for the cleanup of improperly disposed the following: and waste. c. Many training opportunities are ject directors. as as to civil and criminal penalties. seminars. State agencies may have additional health. OSHA also has training and information requirementsfor personnel who might be exposed to hazardous chemicals (HAZCOM-29 Code of Federal Regulations Part 1910. Management approvd-obtain management approval and support. 2. Step 9. Penalties for noncompliance are harsh. This should be documented by using a company waste b. of actions. enhancing evidence insurability. safety. Step 4. One of the benefits of a waste management audit program 2. An auditing program’s goal is to help companies achieve higher levels of environmental performance.STD.5. f. Step 6. Area definitiondefine operating area such as oil field. also review lease agreements and landowner agreements. determine whether itis “exempt” or “nonexempt” and “nonhazardous” or “hazardous. unit.702).management. Waste identification-identify each waste generated within Step 2 area and briefly describe eachwaste. and imprisonment.5 AUDITING Companies should consider developing audit programs for s may their own facilities a well as third-party facilities that accept their wastes. d. Step 10. Step 8. Department of Transportation (DOT) and some state agencies have transportation requirements for certain wastes.34). Improved financial planning efficiency by reducing civil ing for both onsite and offsite disposal. Summarize in documents. Improved compliance records and reductionof fines. or ties. and conferences available to in. List and evaluate waste management and disposal options-list the potential options for each waste and rank their desirability. and employees fines. and criminal exposure. officers. Tracking wastes offsite helps prevent significant costs associated with improper waste disposal. Step 5. Select preferred waste management practice(s)-select location. Step 2. Step 3. it is important to know the types amounts of waste a. Sound waste management techniques should include track. or state. state. as well as the ultimate disposition that waste. efits operations by allowing identification of waste minimization opportunities. The U.” Waste minimization-review processes that generate the waste and execute procedures to reduce waste generation. and local laws on waste types for which requirements exist. Noncompliance can also subdustry andthe general public.S. Improved communication between all levels of company tracking system. legal generated. Failure to comply with laws and regulations regarding waste management can Training can be done in-house or through enrollment in well schools.1200). Specific training is required for employees handling hazardous materials (49 Code of Federal Regulations Part 172.

7. 4 Geology. Housekeeping. Unacceptable sites should be utilized for waste disposal not or recycling. Compliance with permits. including: l . b. Environmental expertise and financial standing. ing: e. It is imperative to select commercial sociated environmental impact considerations. The regulatory aspects of a facility. 9. Exploration. Secondary containmentand spill prevention.2. be The environmental impact of each of these efforts should considered. Seismicsurveys and related geologic field work are conducted on potential locations. c. inclusive recycling. 6 . Drilling. Location of the disposal of secondary waste streams that the facility is permittedto manage. Physical aspects. Commercial disposal site audits should consider the follow. . Closure plans. 5 . Soil data. and reducing barriersto successful acquisitions and merger negotiations. Offshore operations. History of violations. Construction of seismic lines. Hydrogeology.a. This to which wastes are sent-operate in an environmentally and section summarizes wastes generatedeach phase and the in asfinancially sound manner. c. sure to future environmental liability that might result from im. 7. Manifesting records and procedures. Gas plant operations. Completion and workover. shouldbe established. Site reevaluation on a periodic basis is critical to ensuring that acceptable sites continue operate acceptably. 5. 4 Site security. 2. 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. 3. The operational aspects of a facility. Adequacy of disposal or recycling processes. 4. 3. Construction may involve clearing trees and brush and COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Relationship with regulatory agencies.2 OffsiteNoncompanyFacilities 3 Waste Generation in Exploration and Production Operations An integral partof a waste management program should be 3. 3. seismic surveys and reare lated geologic field work the primary exploration activities that generate appreciable amounts waste.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. Proper permits. . f. This guideline was developed by API specifically for the oiland gasE&P industry. Field production. Construction and maintenance of a base camp or camp sites. Decision criteria that will rate a commercial facility eias ther acceptableor unacceptable. 1l .6 API E5 proving public relations. S.d. a. 3. Adequate waste storage prior to disposal. l . These operations may begin with to identify unremote sensing and aerial geomagnetic surveys derground geologic structures where oil and gas may have accumulated. proper management by the commercial facility. Companies should consider auditing commercial facilities to limit potential expo. See AppendixC for a summary of E&P waste sources. 6 .2. 2. Incoming waste testing and verification procedures. Insurance or other surety bonds. Monitoring well data. Access to the area of interest. and disposal.2 EXPLORATION Exploration operations identify locations that contain potential oil andgas deposits.5. 10. Adequacy of onsite waste treatment equipment. S.1. to 2.1 Seismic Surveys Prior to drillingan exploratory well.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. including: g.b. b. 2.Adequate contingency plans and training. based on the collected insite formation. c. The work facilities that manage wastes properly. 3. Depth to groundwater. Three basic field of work activities contribute to waste generation: a. 5. Transportation. Adequacy of lab analysis. Remoteness of site location and public exposure potential. 6. 3. of phases are as follows: treatment or neutralization. Remediation projects in progress. including: l .

d.2.1 Drilling Rig 3. and so forth) should be dismantled and removed from the area when work is completed.2 Waste Summary A list of the major waste categories that may generated be during explorationoperations is shown below. equipment. nonexplosiveenergy sources. (b) collected and carried out by the seismic crew once operations cease. Retaining and replacing topsoil. exploratory drilling). helipads.2. c.2. the volume and toxicity of these wastes are minimal. bridges. oily Sanitary wastewater Scrap metal Soil. 3. Wastes generated include sewage effluent. In remote areas. to delineate a discovered reserve or to develop a reservoir for production.2SeismicLineConstruction Seismic lines are constructed by clearing a 3. f. and man-made structures (such as buildings. and maintenancelparkingareas for vehicles and helicopters. All food wastes and other putrefiable material should be collected and properly disposed. All material.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 .3.1 Introduction The drilling rig provides the power and equipment (including safety equipment and systems such as blowout preventers) necessary to drill the wellbore. or (c) otherwise appropriately managed.API/PETRO ES-ENGL L977 - ~ m 0732290 05b4b81 2Lb WASTE MANAGEMENT IN EXPLORATION AND PRODUCTION OPERATIONS 7 temporary displacement of topsoil'. Wastes requiring special handling such as used oil and filters should be kept segregated and disposed a manner in 3. Good management processes includethe following: a. earth-covered beds in suchway a as to not impact potable watersupplies. b. and domestic waste.3 DRILLING Drilling operations are conducted to locate the oil andgas (that is. the drilling rig and the circulation system. that prevents surface water or groundwater contamination. In such cases. The drilling operation has two key components.1. used oil and filters. Specific for steps to treatment and disposal include the following: a. Using cleared foliage in soil conservation and control. Disposal of these wastes can be a common problem for base campsin areas where water treatment and waste disposal facilities do not exist.3.STD. c. and building material wastes. Base camps are typically self-contained. The disposal of solid and liquid wastes is controlled by regulation. however. unless otherwise agreedupon by the landowner and the operators. Its keysystems and their uses areas follows: 3. used oil and filters. cooling orfire water) Wood 3. noncontact (forexample. a base camp to accommodate personnel and equipment is sometimes necessary. In general. 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. A system for the collection of sewage and watereffluents should be constructed and designed toflow through a soakaway systemof permeable. line stakes or markers. discarded Used oil Vegetation Washdown water (rigwash) Water. petroleum naphtha Stormwater Tires Unused materials. 3. 3.1. 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. provisions must be made proper treatmentor disposal.See Appendix C for a more complete listing of wastes generated by E&P. empty petroleum hydrocarbon storage containers. Wastes generatedduring this operation include explosives residue. An of alternative is to use vehicle-mounted.3.1. contaminated Solvents.steps should be taken to assure that all nonrecyclable material is either (a) incinerated or buried onsite when allowed by applicable regulations.to 6-footwide footpath. e. Shallow holes are typically drilled along the seismic line and explosives are placed in them to be detonäted. Solid and hydrocarbon wastes should be evaluatedfor recycling whenever possible. Any unused shot holes and/or craters caused explosions should by be backfilledto reduce the chance subsequent erosion. which are discussed below. Base camp operations may generate many different wastes. They will usually consist of personnel accommodations. b. domestic refuse. Residue from burned or incinerated wastes should be buried or transported offsite. vehicle/aircraft fueling facilities.1. The root stock and topsoil should be left in place.dining facilities. Encouraging revegetation by native flora.3 Base Camp Seismic exploration and geologic field work may require a large workforce.

centrifuges. and shale shakers). treated to fix or solidify contaminants).1. These wastes include washwater (rigwash).3 Reserve Pits Unlined or lined reserve pitsstore supplies of water.1. e. used to transport cuttings to the surface where they are mechanically removed from the mud system. drilling mud is stored in tanks before it is pumped down the drill string. hydraulic fluids. high-temperature. c. API E5 3. or high-anglewells. kgwash. cial drilling fluids such as oil. It also handles drill pipe when it is out of the wellbore and is used to run casing into the wellbore. 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). and remove the drilled cuttings from the wellbore. depending on the well's diameter.3. It protects the integrity of the wellbore duringdrilling.3. it cools the bit andflushes away any drilled cuttings and solids at the wellbore bottom. Wastes generated by the drilling rig result primarily from the operation and maintenance of rig equipment. Regulations applyas follows: a. After formulation.2 Drilling Mud The drilling mud. they also add the necessary weight to prevent formationfluids from entering the wellbore and support and prevent damage to the underground formations being drilled. formation cuttings. It allows fluids to flow to the surface for processing after well completion. Saltwater. and cuttings may be managed ensure protection of soil and to groundwater (for example. 3. or in those adjacent to fresh surface waters. b. high-pressure. In certain geographic regions. or in areas of shallow groundwater. empty grease and pipe dope containers. c. It provides a conduit for fluid movement both up and down the wellbore. State regulations usually require pit construction to comply with specified land use standards. lime.3. c. worn brake pads. Conversely. e.3.S T D * A P I / P E T R O ES-ENGL 1777 0732270 O5bllb82 1 5 2 m a sand formations. used drill bits and pipe.4 Casing Casing serves the following functions: a.2. type of mud system.1 Introduction The circulating system is the lifeblood of the drilling operation. The mud then carries these drilled solids to the surface where they are removed using cleaners (such as hydrocyclones or desilters. Drilling fluids (muds) and solids. used lubricating oils and filters. spe- COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Special regulations. These systems not require do reserve pits. may contain minor amounts of the detergents that are used to clean the rig andprovide asafe work area.3. the drilling fluid (that is. 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. It keeps drilling fluids from leaving the wellbore and seeping into the formation. In specific cases. gaskets. Wastes generated during drilling mud formulation typically include empty additive containers (such as bags and pails) and unused or contaminated additives. 3. It provides protection for underground sources of drinking water.2 Circulating System 3. and then returned to tanks wherethe process starts again. closed-loop drilling mud systems maybe required to protect environmentally sensitive areas. such as where soil and hydrogeological conditions preclude any adverse impact. The systemused to collect rigwash may also collect rainwater. Oil. circulated downhole to coolthe drill bit and flush drilled cuttings fromthe bottom of the wellbore. and similar materials. d.3. waste drilling fluids. Unlined pits are normally used for freshwater mud systems.3RotatingSystem The rotating system turns the drill bitso that it can penetrate underground rock and sandformations. The waste volumes generated will vary greatly. Wastes generated during drilling operations may include the following: a. b. including compliance with applicable wa- 3. and other operating factors. cut drill line. Liners may not be necessary for some oil. discarded thread protectors. waste mud. absorbent materials (such as clay and pads). Formation cuttings (such as shale. and stormwater runoff from the drilling location. mud) is formulated and maintained. depth.or saltwaterbased mud systems. rigwash. 3. Additives help cool the drill bit. As mud exits the drill bit nozzles. b. lubricate the drill string.2. mostly water-based clays and inert weighting materials.or saltwater-based muds are used when drilling deep. depending on expected well conditions. or soil. In this phase. salt. These wastes are typically collected in a reserve pit adjacent to the drilling rig. water-sensitive reservoirs. and dolomite).2. lined pits are normally used for oil-or saltwater-based mud systems. Cement returns. is formulated using various additives. liners may be required in areas that are hydrogeologically or otherwise sensitive. solvents. d.

A list of the major waste categories that may be generated during completion and workoveroperations is shown below. e. b. Workover rigs are typically used completion activities. acidizing or fracturing stimulations. produced sand and other solids. The amount and type waste generated of from completion.may be required in environmentally sensitiveareas. cans.O. and solvents. newly drilled wells must be completed before being put into production. garbage./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. Used oil and filters. a. well treatment.O. LSA [low specific activity (for example. c. d. Quarters./welltreatment fluids Constructioddemolition debris Pipdequipment hydrates Pipe/equipment scale Pit sludges Polychlorinated biphenyls (PCBs) Produced sand Produced water Radioactive waste. Domestic waste and sanitary sewage. noncontact (for example. and other maintenance wastes. Generally. due to the higher operating cost of a drilling rig as compared to a workover rig. Downhole equipment may also be installed to facilitate production or injection. Wastes can include the following: a. h. 3. pipe racks. discarded Used oil Vegetation Washdown water (rigwash) Water. spent acids. oily Sanitary wastewater Scrap metal Soil. Drilling Operations Waste Absorbent material Antifreeze Batteries Blasting sandmaterial Polychlorinated biphenyls (PCBs) Produced sand Produced water Radioactive waste. recompleting to new reservoirs. for in some cases. and other materials. The latter is not normal practice. Wastes generated fromthe workover rig itselfinclude hydraulic fluids. hydrocarbon (for example. Completions and Workover Operations Waste Absorbent material Antifreeze Batteries Blasting sandhaterial Cement returns CompletionlW. larger quantities of waste may be generated due to the rig's increased size. Workover operations include installing tubing and packer. and workover operations can range from virtually none for chemical treatments and logging operations to large volumes similar to those encountered during drilling operations.4 Waste Summary A list of the major waste categories that may begenerated during drilling operations is shown below. Equipment includes fuel tanks. replacing tubing or pumping equipment. Spent or used fluids are normally produced through flowlines to production facilities or trucked to operator-owned production facilities for further processing. tracer materials)] Rags.3. diatomaceousearth). Solid waste (including paper sacks. drilling rigs are also used. cooling or fire water) Wood Cement returns CompletionlW. the well casing must be'perforated to allow fluid flow.4COMPLETIONAND WORKOVER Once drilling operations are finished. tracer materials]) 3.3OtherDrillingRigOperations Support equipment located adjacent to the drilling rig is essential to the drilling operation. Other wastes include spent completion and workover fluids and filters example. c. existing production and injection wells require periodic maintenance utilizing workover rigs. See Appendix C for a more complete listing of wastes generated by E&P. In addition. The producing formation may also be acidized or fractured to enhance production or injection capacity.STD. When using a drilling rig. See Appendix C for a more complete listing of wastes generated by E&P. production or injection. used oils and filters. and drums). electric power generators. produced (for water.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. There are many methods of completing or preparing a well for COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . inhibitors.3. Workover fluids are also disposed of at commercial facilities when operators are unable to process them in their own production facilities. contaminated Solvents Spill cleanup waste. crude) Stormwater Thread protectors Tires Unused materials. and equipment used to support the maintenance of personnel quarters. LSA (low specific activity [for example. Contaminated fuel and spillage. or plugging andabandoning of wellbores.

dispersants. Oil and produced water treatment systems.2. oil purchasers typically limit the amountof basic sediment and water (BS&W) less than to 1 percent. The fluid (for example. g. workover. flow lines gathering crude production can plug from a buildup of paraffin and scale. However. and used gear boxlubrication oil. crude) Stormwater Tires Unused materials. Wells and gathering systems. and solids. contaminated Solvents Source sand Source water Spill cleanup waste. c.1 Introduction After a well is drilled and completed.5. Purchasers have contract standards for the oil and gas they will accept. gas. Dehydration and sweetening. hydrocarbon (for example. paraffin cut with downhole tools is generated at the wellhead. Well fluids are often a complex mixture of liquid hydrocarbons. e. For example. 3. Flow line ruptures or leaks generate crude oil and/or produced water-contaminated soil.2WellsandGatheringSystems 3. Pumping unit gear box lubricating oil mustbe replaced ocof casionally.2 Paraffin Removal Paraffin precipitates within tubing and piping when oil containing parafin is produced up a wellbore and pressures and temperatures are reduced. Paraffin solvents or dispersants. oil and produced water contaminatedsoils. d. Becauseof the continuous wearing action of the polished rod.API/PETRO ES-ENGL L777 E 0732270 05b11684 T 2 5 10 API E5 Crude oilkondensate. noncontact (for example. Periodically.2. water. discarded Used oil Vegetation Washdown water (rigwash) Water. either pipeline pigs are run through or the flow linesor hot oil is pumped through them to remove dissolve the plugging material.4 Lines Flow Flow lines gather produced fluids from wells for transport to field facilitiesfor processing. The following sections describe each field facility area and the wastes that may begenerated from it in the production process. carbon dioxide (CO.5. and sell the liquid hydrocarbons and gas. These wastes are more commonly found at oil wells than at gas wells.5. hydrogen sulfide (H2S). Depending on the severity and be manlocation of the release.2. The objective of the production process is to separate constituents of the mixture. either because gear box malfunction or for preventive maintenance. 3. Injection operations. cooling or fire water Wood 3. the stuffing box packingrequires periodic adjustment to minimize leakage. Scale material is also collected for disposal. or mechanical cutting remove it from the tubingandpiping. Paraffin solvents. Other field production facilities and operations. 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. f.2. Oil storage and sales.5. water vapor.5 FIELD PRODUCTION 3.5.).3 Stuffing Box 3. The field production facility can be grouped into the following areas: a.5. heating. or servicing operations. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . contaminated soils may either aged in situ removed for treatment disposal.andhot treatment fluids are normally handled and treated as part of the crude stream in the field processing facilities. The stuffing box on a pumping well is the mechanical seal between the tubing and polished rod. Gas purchasers set similar limits on water.1 Introduction Wastes generated at the well site include paraffin. field facilities collect oil and/or gas from the well and prepare it for sale. and BTU content.~ STD. 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. b. either onsite or or or offsite. Recovered paraffin solids can be heated and returned to the production system or hauled to a storage site for future reclaimingdisor posal. 3. crude oil) being pumped acts as the seal lubricant. When this occurs. Plugging material thatis not dissolved back into the crude oil is recovered at apig trap at the facility inlet. Compression and gas sales. oily Sanitary wastewater Scrap metal Soil. remove those that are nonsaleable.

5.8 3. The flocculated materials then rise to thesurface. in certain instances.3. Three-phase separators. which have additional float mechanisms.4DehydrationandSweetening 3. However. and filters and filter media. depending on the type of system operated. 3.5.3. The gas. crude. 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. water not linked to oil an emulsion) from other proin duced fluids and solids.3. spills should be as minimized via drip pans.2 and 3. injection. 3. as applicable.2 Free-Water Knockout Typically. these treaters are occasionally drained to removesolids and bottom sludges. emulsions (that is. and the absorption material must be replaced. spent glycol.3.3.3 Separators Two-phase separators isolate produced liquids from gases as they flow from the wells. and water are then further processed prior to or disposal.5. scale. Treaters that use hay or excelsior sections to absorb minute amounts of oil must be cleaned out periodically. Periodically. 3. 3.5. These units are used to remove small concentrations of insoluble oil and grease from produced water. pits or additional tanks are used to separate additional solids and oil from the produced water prior to discharge. and bottom sludges recovered during cleanout operations. Leaks from this process may result in chemical-contaminated soils. treatment. usually natural gas or air.3.or other options. provided it is also in accordance with applicable state and RCRAregulations (see Section 4).5 Injection Operations 3. 3. The units agitate the water by injecting a gas.5.1 Introduction Injection operations at field production facilities are used to either dispose of produced wateror to enhance recovery of crude oil from the reservoir. water.2. 3. 3. through the liquid stream. grease. Wastes may include iron sponge.5.5. Chemical injection pumps typically dispense chemicals from 55-gallon drums or bulk containers. This material may also be recoveredas oil (for example. and dirt.5. for Skim tanks. Each stream is then further treated in preparation for sale or disposal. spent caustic. There the gas. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Typically. This action flocculates the suspended oil.5.5.5. and corrugated plate interceptors (CPIs) rely on gravity and residence time to remove residual free oiland solids from produced water.1 Introduction When produced fluids and solids reach the field facilities. they enter the treatment system. Produced water separated in the treaters goes to a disposal or injection system. or disposal. and solids are separated into individualstreams. Another type of treatment system utilizes gas flotation. spent amine. Field dehydration and sweetening units perform the same function as that described in greater detail for gas plants in 3. Separated produced water then flows into the water treatment system for either disposal or reinjection. The (that is. desanders may be utilized to remove these solids.4Heater TreaterdElectrostatic Treaters Heater treaters and/or electrostatic treaters separate emulsified oil and water.5 Desanders Where produced water carries excessive solids (produced sand).5. returned to the oil treating system).3. 3. Any spill should be managed described in the preceding paragraph. oil or condensate. also separate produced water from produced fluids.3. Recovered may be oil returned to the oil treating system or recycled offsite. much of the produced sand is also removed in other treating vessels. where they are skimmedoff.6ProducedWaterTreatingEquipment Several typesof produced water treating equipment are used to prepare the water discharge. the free-water knockout (FWKO) is the first vesFWKO separates freewater sel to receive produced fluids.The sale primary waste generated by the separator consists of produced sand.5 Chemical Treating Treating chemicals such as corrosion inhibitors are sometimes injected into the well orflowline to provide protection.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.including oily sand and solids.3. These tanks must be cleaned occasionally to remove bottoms. or other disposal.5.5. 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. As is the case with the FWKO and other production vessels. injection. gun barrels.5.5. Occasionally.3 Oil and Produced Water Treatment Systems 3. solids bottom sludges are removed from and the FWKO for reclamation. Bottoms or sludges are generated if solids are recovered from the settling pit or tank.7ProducedWaterTanks Produced water tanks may be required toprovide storage and additional settling time for sandsolids removal prior to discharge.S T D .

deionization process involves The removing additional dissolved minerals present in water.5.Steam generators firedby crude orfuel oil may have sulfur dioxide air pollution scrubbers associated with them. steam is sometimes injected into reservoirs to reduce oil viscosity and to enhance fluid production.2 Disposal After initial treatment of producedwater. or canister units. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . or natural gas. Several methods of enhanced recovery may be used. Water softening resin is typically used when cena tral water plant is not available.4 TEOR SteamGenerators In heavy oil operations. sulfur dioxide liquor).To increase thermal efficiency of the generators. these include produced water injection.5.6 Air PollutionControl Scrubbers 3.API/PETRO ES-ENGL L997 U 0732290 05b4bdb A T A 12 API E5 3. TEOR steam generators use soft water (that is.) which reduces to NaHSO. Recently. Although these methods are most common. Permanentfilters are periodically backwashed with fresh or produced water.5. fuel oil. surplus soft water (for example. flooding.5.5. source water injection. The steam these generators make is injected into geological formations containing heavy crude oil. Typically.5.5 TEOR CogenerationUnits 3.5. As with injection disposal. Replaceable filters include sock. oilfield operators have generated steam using conventionally fired heaters known as thermally enhanced oil recovery (TEOR) steamgenerators. spent water softening resin. which sometimes contains a small amountof surfactant.5. Raw water used in the deionization process is either soft water or fresh water. In general. a TEOR cogeneration steam generator consists of a turbine and its associated heat recovery boilers (steam generators). Traditionally. The scrubber liquor waste typically has a neutral pH and low concentration of heavy metals. andflue duct ash. water with low concentrations of dissolved calcium and magnesium).5.backwash liquid should be returned to the production facilities for reprocessing.5.5. Other wastes from steam generators include fuel oil can filters. as described above. Surplus soft water for disposal (that is. soft water blowdown). fly ash impingeson the steam generator convection tubes. Waste lubricating oil and filters are typically generated at these facilities. they must be backwashed. Permanent filters may use diatomaceous earth or granular media suchas sand or coal. Na. backwash water from the deionization process. refractory waste. The method selected will be dictated by the formation type and method feasibility. Deionized water is injected into the turbine combustion chamber to reduce nitrogen oxide emissions. Backwash should be circulated to a solids treatment and disposal system.5. the types of equipment used and the wastes generated are the same as described above. soft water blowdown) isalso generated during startup and shutdownof both conventional andcogeneration steam generators. The process bubbles exhaust gas through abasic aqueous solution (usually SO. The water softening process creates a waste fluid identified as regeneration brine. cartridge. Excess deionization water. water utilizedfor enhanced recovery must be treated prior to injection. There. TEOR steam generatorsare fueled by either crude oil. Injected steam also drives pushes) the oil toward pro(or ducing wells. Steam is also generated and used in some field production facilities and gas plants by burning natural gas. 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. Waste fluids typically generated at TEOR facilities consist of water softener generation brine. as well as backwash from this water purification process. and stack wash. it heats the oil for easier recovery. 3. 3. scrubber waste (that is. seawater injection. When burning crude. and soft water blowdown prior to disposal. TEOR cogeneration steam generators have replaced some TEOR conventional steam generators. steam flooding. may be commingled with excess produced water. Air pollution control scrubbers may be required control to sulfur dioxide and particulate matter emissions from exhaust gases of oil-fired TEOR steamgenerators. NaOH or Na2C0. Filter media must be replaced on periodic a basis. if they are permanent.. 3. fly ash is removed by washing the tubes with water. The resulting effluent is referred to as stack wash water. A typical waste generated facilities using steam is boiler at blowdown water.7 Deionization Two other fluids associated only with TEOR cogeneration plants are deionized waterand backwash produced from the water purification process. regeneration brine. produced water can be injected into the disposal well. and Na2S04. Cogeneration of electricity and steam can significantly increase the energy efficiency of the process. Soft water is used as steam generator feedwater to prevent scaling. excess deionizedwater. or CO.SO. filtering is frequently used to improve water quality before injection.STD.. An electric motoror gas engine usually drives the injection pump. After filtering. pressurizing produced water into the injection well.

or allow flowinto central facilities.7CompressionandGasSales 3.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. b. and residues Mercury. sample wastes. c. The primary waste generated onsite from methanol injection is empty methanol containers. and drips and leaks from pumps and transfer lines. glycol systems. and maintenance facilities. After scrubbing. Construction and demolition.6. storage tanks. solvents. 3. Methanol is typically used in low concentrations. (Note that some of these wastes may be contaminated with naturally occurring radioactive material (NORM) and require special handling.9 Waste Summary A list of major categories of waste that can be generated during field production operations is shown below. waste Deionized water.2 and 3. If sufficient water or water vapor exists in the gas stream.5.S T D . hydrates (that is.5. and/or produced waters. Methanol is sometimes injected or line heaters are sometimes used to prevent hydrate formation.O. absorption oil systems. drainage from transfer hoses can be returned the system for reprocessing.5. acids. salts. discarded COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Oil in stock tanks is transported offsite for further processing or refining via pipeline. and detergents) and removed solids and/or hydrocarbons. e. oily Refractory waste Saltbath heater salt Sanitary wastewater Scrap metal 3./welltreatment fluids Constructioddemolition debris Cooling tower blowdown Crude oikondensate. These include engine cooling water containing glycol and used lubrication oil and filters. metallic liquid Mercury. permit vapor recovery. Office.) See Appendix C for a more complete listing of wastes generated by E&P. When shipping by tank truck or barge. Solids and water continue to separate by gravity and accumulate in stock tanks. Tank bottoms Tires Unused materials. or salt mixtures) used to transfer heat from heat sources to the gas stream. Equipment maintenance.5. excess Soil. Domestic and sanitary waste handling and treating. Laboratory testing. filters. caustics.5. scale. Wastes generated from line heaters include spent thermal fluids (such as glycol.6 Oil Storage and Sales Treated oil that leaves the treatment system goes to oil stock tanks and is ready for sale.1 Introduction Produced gas and fuel scrubbers are used where necessary to separate fluids from gas. these should be returned to the system for reprocessing.5. oil. tank truck.6. Warehousing. hydrogen sulfide Soft water.7.2 Hydrate Prevention Pressure and temperature decrease as gas is produced from a reservoir. oil. contaminated Solvents Source sand Source water Spill cleanup waste. process equipment Completion/W. solids Naturally occurring radioactive material (NORM) Pipe/equipment scale Pit sludges Polychlorinated biphenyls (PCBs) Produced sand Produced water Rags. and other solids that have built up and reduced field production efficiency.5. d. Wastes generated from onsite transfer operations include lubrication oils. 3. Wastes generated from compressor operation are identical to those wastes generated by gas plant compressors (see 3. to Internal cleaning of tanks. Wastes generated during cleaning include mixtures of spent cleaning solutions (for example.7. excess Domestic refuse Domestic wastewater Filters Flue dust ash (fly ash) first-aid waste Hydraulic fluid Incineration ash Insulation material Lab waste. 3.7. crude) Storm water Sulfur dioxide liquor Sweeteningldehydration liquids Sweetening/dehydration solids 3. treating and process vessels. the concentrations are dictated by field conditions. recovered fluids may include condensate. Compressors may be driven by electric motors or by internal combustion or turbine engines.8 Other Field Production Facilities and Operations Heat exchangers. and the like must be cleaned to remove hydrocarbons.3 Compressors Compressors are used to boost the gas pressure to sales line pressure and/or gas lift pressure. or barge.6). hydrocarbon (for example. inject gas back into the reservoir for pressure maintenance. These tank bottom materials may require periodic removal. and other equipment is also an operation that can generate wastes. Scrubber liquid. f. ice) may form and block flow lines. Other field production facilities or operations that may generate waste include the following: a. Field Production Operations Waste Absorbent material Antifreeze Batteries Blasting sand/material Boiler blowdown Catalyst Cleaning wastes. transportation.

Treated gas then enters an extraction facility that removes the heavier natural gas liquids (NGLs) such as ethane. Heat regeneration evaporates the water. Wastes generated during the dehydration processconsist of glycol-based fluids.2 Inlet Separation and Compression Gas can enter the facility in either an untreated or treated condition. and certain solid impurities. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . noncontact (for example.6GASPLANTOPERATIONS 3. Emergency pits are not disposal facilities. Warehousing. and reservoir formation material). 3. natural gas liquids recovery. all subsequent treatment. Wastes generated from plant inlet compressor operations are like wastes generated in field compressor operations. other sulfur compounds.Theseplantsprocessnaturalgasintoa marketable condition. pipe scale. The pits should be constructed and operated to prevent groundwater contamination. product storage.STD. condensed water. butane.6. Inlet separators are designed to send produced water and hydrocarbons to process vessels for additional treatment. is conducted at the gas plant. hydrogen sulfide. inlet filter media. silica-gel. however. product shipping.gas will be compressed toa sufficient pressureto allow the plant to operate. There. If necessary. Produced fluids such aswater and liquid hydrocarbons are usually separatedat the plant inlet. This protects the facility if a fluid slug (for example. Gas plant treating and extraction processes include inlet separation and compression. and recompression and plant utilities. Small amountsof pigging materials can also be recovered at the pig receivingtraps at the plantinlet. diethylene glycol. domestic and sanitary waste handling and treating. propane. hydrocarbons can be recovered sale and produced for water can be separated for disposal. and butane for separate sale. natural gas flows through tower vessels filled with alumina. Dehydration is the process extracting water vapor of to make the gas marketable. These can be removedby gas plant treating facilities. DOT 3. All natural gas contains water vapor. 3.6. sometimes sweeteningfacilities are providedaswell. and office facilities are other activities that can occur at a gas plant and generate wastes.) removal facilities where high hydrogen sulfide (H2S) and carbon dioxide concentrations exist. These include engine cooling water containingglycol and used lubrication oil and filters. It may also be conducted in dedicated sulfur recovery or carbon dioxide (CO.1 Introduction Natural gas plants often provide dehydration and compression facilities. Typically. silica-alumina beads.3 Dehydration 3. mercaptans.4. they also extract natural gas liquids such as ethane. Natural gas streamsentering gas processingplants vary in composition. that to are usually pits. Liquid desiccants such as ethylene glycol. and glycol is recovered reuse. produced water) that exceeds separator capacity should reach the plant or if gas pressure exceeds designcapacity.4 SweeteningBulfur Recovery 3. propane. glycol filters.6. or a molecular sieve to absorb water vapor. fluids from corrosion treatments. and butane. rust. These fluids and solids may in some of circumstances contain trace levels hydrocarbons and treating chemicals. propane. For safety reasons. and small amounts of solid material (such as. cooling or fire water) Water softener regeneration brine Water softening spent resin. this water content must be reducedto meet sales pipeline specifications. Processes used at gas plants are like those used at field production facilities where centralized dehydration is unavailable. equipment maintenance. construction and demolition. or triethylene glycolabsorb the water. The inlet gas may contain compounds such as carbon dioxide.6. dehydration. pigging materials. they provide control of emergency releases.1 Introduction Some natural gas contains hydrogen sulfide. Field production facilities can provide initial treatment. sweeteninghlfur recovery. Wastes typically associated with inlet separation include produced water that may contain methanolor other treating chemicals. Vented fluids should be recovered in accordance with state requirements or operating procedures.but smaller amounts of ethane. and heavier hydrocarbons are also present. The sweetening processmay be conducted using units identical in operationto those used at field production facilities where centralized sweetening facilities are not available.6.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. or other impurities that must be removedeither for field use or to meet the sales pipeline specifications. carbon dioxide. for In solid desiccant dehydration. Natural gas is dehydrated by contact with either liquid or solid desiccants. pentane. inlet separators are equipped with relief valves that vent emergency containment facilities.Methane is thepredominantcomponent. and spent solid desiccants. water.

4. 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.4IronChelateOxidation-Reduction Sweetening This desulfurization process uses an iron-chelating solution to selectively remove hydrogen sulfide from gas streams through a reduction reaction. incinerated. This process uses a nontoxic solution and creates little or no H. hydrogen sulfide is driven outof solution. and other sulfur-converting chemicals. 3. or sent to a sulfur recovery facility. 3. the caustic consumption is approximately 2.6 Caustic Sweetening Small volumes of hydrogen sulfide may be removed from natural gas and NGLs by contact with a caustic solution. or sent to a sulfur recovery facility.7OtherSulfur-ConvertingCompounds Other sulfur-converting compounds such as Sulfa-check are employed in one-step processes to remove low levels of hydrogen sulfide. and mercaptans (RSH) at feed gas pressure and temperature. Most caustic treaters consist of a simple vessel holding thecaustic solution through which gas is allowed to bubble. The primary waste is a nonhazardous slurry of sulfur and salts. Wastes generated in sulfinol sweetening include degraded amine and used filter cartridges or bags.4.6. Natural gas bubbles through the vessel until the sulfur-converting compound is spent.5IronSpongeSweetening In the iron sponge treating process.).6.4. carbon disulfide (CS. iron chelate reduction. The acid gases and absorbed gases are released at nearatmospheric pressure and somewhat higher temperatures. Hydrogen sulfide is removed from natural gas by contact with amines. normally carried out using air as the oxygen source. Here.6.4.3 Sulfinol Sweetening The sulfinol treating process utilizes an aqueous mixture of an aliphatic alkanolamine is. In the iron chelate oxidation-reduction process.4. Ironsponge. iron sponge. coated on a carrier such as wood shavings. iron oxide reacts with hydrogen sulfide to form iron sulfide. having air as the oxygen source) is used to regenerate the solution. Sulfolane).6. The primary waste from caustic treating is spent caustic solution. and the physical absorption of these acid gases and other sulfur-containing compounds such as carbonyl sulfide (COS). 3. When sour gas is contacted with a water solutionof chelated iron. used filter media. oxidation (that is.8ClausProcessSweetening The Claus process utilizes amine or sulfinol solutions to remove hydrogen sulfide from sour natural gas. and heavier sulfur compounds from COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . the H2Sis converted to elemental sulfur in an iron reduction reaction.4 pounds per pound of hydrogen sulfide removed. This process is based on the reaction between aliphatic alkanolamines and acid gases at moderate temperatures. The aluminum oxide does not react in the sulfur-making process but merely provides a greater surface area to speed and assist the process. 3. (that either di-isopropanolamine or methyl diethanolamine) and a physical solvent (that is. 3.9 pounds per pound of carbon dioxide removed.S or SO. The hydrogen sulfideis then burnedin the presence of oxygen to produce sulfur dioxide. The Claus process utilizes pelletized.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. Hydrogen sulfide and sulfur dioxide are then mixed and exposed to a heated catalyst to form elemental sulfur. caustic solutions. The resulting acid gas waste stream may be flared.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. emissions.6. sulfinol. caustic solutions.4. 3. The waste generated in the ironsponge process is the iron sulfide and wood shavings combination. Iron sponge is composed of finely divided iron oxide. 3. As part of the regeneration process. 3. In it.6.6.6. Heat regenerates amine and sulfinol for reuse. inert aluminum oxide as a catalyst. This process involves the chemical reaction of an alkanolamine with hydrogen sulfide and carbon dioxide. and 1. Amines are then regenerated by elevating the temperature to release acid gases. mercaptans. The primary waste generated is spent catalyst. Most caustic treaters utilize a 10to 20-percent by weight sodium hydroxidesolution. which must be flared. Wastes generated in amine sweetening include degraded or spent amine. which is reused until spent. The solution is regenerated by oxidation. and othersulfur-converting chemicals are spent in the process and are not regenerated. The solid waste generated by this sweetening process is a nontoxic wastewater stream.4. and acid gas. incinerated. a direct conversion using a single contact vessel occurs at ambient temperature.9MolecularSieveSweetening Molecular sieve absorbents are used to remove hydrogen sulfide.4.

Wastes generated during the cleaning process include mixturesof spent cleaning solutions (such as. spent solvents such as petroleum naphtha used for cleaning equipment. steam equipment. discarded Used oil 3. 3. process equipment Cooling tower blowdown Crude oilkondensate. Gas Plant Waste Absorbent material Antifreeze Batteries Blasting sand/material Boiler blowdown Catalyst Cleaning wastes. maintenance activities. product shipping. oily Refractory waste Saltbath heater salt 3. As one bed is sweetening.4. posits of naturally occurring radioactive material (NORM) and should be handled accordingly when removed fromservice. crude) Storm water Sulfur dioxide liquor Sweeteningldehydration liquids Sweeteningldehydration solids Tank bottoms Tires Unused materials.~ ~~ 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. which exist as liquids at moderate pressures. Molecular sieve sweetening is a batch-type regenerative operation requiring at least two beds for continuous processing.) See Appendix for a more completelisting of wastes C generated by E&P. wastewaters.6. domestic sanitary waste handling and treating. and detergents) and solids andlor hydrocarbons removed from the system. These pipelines are'usually referred to as transmission lines by the Department of Transportation (DOT). waste Deionized water. 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. and office operations.5. and boiler blowdown water. excess Soil. contaminated Solvents Spill cleanup waste. and so forth may be contaminated with de- COPYRIGHT American Petroleum Institute Licensed by Information Handling Services ~~~ . electrical generators. simultaneous sweetening dehydration may be acand complished in the same unit. noncontact (forexample. construction and demolition. caustics. The primary waste generated is spent molecularsieve. wastewaters.6.7 TRANSPORTATION PIPELINES When the processing of crude oil and naturalgas has been completed at field production facilities or gas plants. NGL extraction may use compression and cooling processes. Pigging wastesfrom DOT pipelines Pipe/equipment hydrates Pipelequipment scale 3.These engines. or cryogenic processes. cooling waters. internal combustion. Steam equipmentwastes are the same as those described in the field operations in 3.5NaturalGasLiquidsRecovery NGL recovery is the process which hydrocarbons heavby ier than methane.8 Waste Summary A list of major categories of waste that may be generated at gas plants is shown below. and utility systems generate used lubrication oils. laboratory testing. Wastes generated include lubrication oils. or turbine engines. excess Domestic refuse Domestic wastewater Filters Flue dust ash (fly ash) first-aid waste Hydraulic fluid Incineration ash Insulation material Lab waste. spent Wood 3. solvents. Transportation pipelines transport crude oil or natural gas and associated liquids to the market for sale or refining.6. spent or degraded absorption oil. Other activities that generate waste are warehousing. pumps. Naturally occurring radioactive Vegetation material (NORM) Paint-related material Pallets Washdown water (rigwash) Water.7 Other Gas Plant Facilities and Operations Process cleaning wastes identical to those generated at field production facilities are generated at gas plants. hydrocarbon (for example. and filters. valves. (Note that certain equipment. Constructioddemolitiondebris Sanitary wastewater Scrap metal Scrubber liquid. cooling tower water. sorbents. and residues Mercury. piping. cooling or fire water) Water softener regeneration brine Water softening resin. metallic liquid Mercury. acids. absorption processes. product storage. compressors. hydrogen sulfide Soft water. the oil and gas are metered andsold. are extracted from natural gas. They are also used to remove water vapor. the other is regenerating.5. samplewastes. 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. andoily debris such as rags.6ReCompressionandPlantUtilities Plant compression and utility systems (including fuel.6. Compressors are driven by electric motors. solids Pit sludges Polychlorinated biphenyls (PCBs) Produced sand Produced water Rags. Thus.

In addition. for 4 EnvironmentalLegislationand Regulations INTRODUCTION 4. States are required to submit Solid Waste Management Plans for EPA approval and funding. Nonhazardous waste disposal is regulated under RCRA Subtitle D and depends primarily on state controls. 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. it must be hauled to shore. Environmental violations may subject corporations. Dangers to human health and the environment. The EPA study was to include analysis of the following: a. Readers should contact appropriate legal counsel for assistance and advice. EPA established four different criteria or characteristics to determine whether a waste is hazardous: (a) ignitability. the transfer of land may present economic risks from environmental concerns. From a waste handling and disposalstandpoint. EPA also listed certain specific wastes (including known poisons and carcinogens) as innately hazardous. Congress directed EPA to study such wastes and recommend appropriate regulatory action. however. fines of $25. d.8 OFFSHORE OPERATIONS Since many wastes generated at offshore operations are identical to those generated onshore. and shareholders to varying degrees of liability. Actions cover the gambit from improper recordkeeping to willful violations of appropriate regulations. State and localrequirements vary. Sources and volume of waste. This refers to Title 40 of the Code of Federal Regulations. the U.2. Civil penalties may become quite costly through court and administrative agency involvement. Section 2. e. and (d) toxicity. Federal. transfer. Current disposal practices. They impose responsibility and liability for the protection of human health and the environment from harmful waste management practices or discharges. RCRA required EPA to establish procedures for identifying solid wastes as either hazardous or nonhazardous and promulgate requirements for managing both.2. it exempted oil and gas industry exploration and production wastes from regulation under RCRA hazardous waste provisions (Subtitle C). Impact of alternative disposal methods on exploration and production. 4. a separate offshore discussion is not included in this document.000 per day per violation are no longer uncommon and may also be assessed. geothermal operations. Liability has now been extended to include personnel who know or should know if a particular action is illegal.2 THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) 4. electric utilities. Costs of alternative disposal methods. Hazardous waste management is stringently regulated under RCRA Subtitle C. EPA has established criteria aimed at ensuring that nonhazardous waste management facilities operate as sanitary landfills rather than open dumps. To date. b. The U. (b) corrosivity. and cement kilns). Alternatives to current disposal methods. managers. Therefore.S. c.1 1980 RCRAAmendment When RCRA was amended in 1980. employees. An example of a reference or citation is the definition of solid waste. state. 3. Part 261. hazardous waste$ are described as either characteristically hazardous or as listed hazardous wastes. including documented cases. offshore operations are unique in that they may have the option to discharge in accordance with their NPDES (National Pollutant Discharge Elimination System) permit. f. Similarly. which is located in 40 CFR P 261. the wastes are handled and disposed in much thesame manner as those wastes generated at onshore operations. Thus. the United States Congress recognized the special nature. Once onshore. (c) reactivity. A good recordof property conditionprior to transfer can be very beneficial in dealing with claims from subsequent owners and government agencies. that interpretation of regulations varies.2.1. and low toxicity of wastes generated by oil and gas exploration and production operations (as well as by mining. If the waste stream is not permitted overfor board discharge. A careful evaluation of properties should be made to identify these liabilities prior to 4. Congress deemed that these wastes required special consideration. In addition to remediation expenses. Users are cautioned. high volume. including imprisonment. Information in this document is not all-inclusive and may not be applicable in all situations.S. References to specific regulations appear italicized and in brackets.1 Overview Enacted in 1976. and local regulations are constantly evolving andshould be compared with the information in this document to ensure consistency. Individuals may no longer claim ignorance as a defense against prosecution and the subsequent civil and criminal penalties.1 This section summarizes key federal environmental laws and regulations that affect E&P waste management and disposal practices.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. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .

Liquid. Comprehensive Environmental Response Compensation and Liabilities Act (CERCLA). had not been used in an environmentally sound manner.” 4. 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.1988 EPA Regulatory Determination EPA conducted the study on E&P wastes and submitted a report to the U. EPA has determinedthat produced waterinjected for enhanced recovery is not a waste for purposes of RCRA Subtitle C or D. .2) In simplest terms. certain regulatory gaps do exist. c.2. they are intended to be discarded.2 Definition of Solid Waste (40 Code of Federal RegulationsPart 261. a solid waste is any material that is discarded or intended to be discarded. and Safe Drinking Water Act. b. IOGCC maintains an ongoing effort to peer review state regulatory programs using these guidelines. . g. rather. the authorities available under the Clean Water Act or Safe Drinking Water Act can be more broadly utilized.2. Fungicide and Rodenticide Act (FIFRA). f. Regulatory Determination. Working with the Congress to develop any additional statutory authority that may be required. including: a. Specifically excluded fromthe solid waste definition are certain point source dischargessubject to National Pollutant Discharge Elimination System (NPDES) permits under the Clean Water Act. and c. Congress on December 28. however. b. Commercial products-including residues from spill cleanup-are not regulated aswastes unless. Associated wastes management. e. solid wastes may be the following: a. and enforcementof existing regulations in some States is inadequate. Enhanced recovery describes all efforts to increase ultimate productionof oil and gas from areservoir. Working with States to encourage changesin their regulations and enforcement to improve some programs. the Clean Water Act.” In the June 30. Superfund Amendments Reauthorization and Act (SARA). Toxic Substances Control Act (TSCA). 1987. Existing State and Federal regulations are generally adequate . and efforts are already underway to fill gaps under these programs. Semi-solid. 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. do not fully address the specific concerns posed by oil and gas wastes. Arctic operations (in general). In addition. d. c. According to RCRA. as stated in 4. Also.3 1990 IOGCC State Regulatory Guidelines In 1989. EPA has authority underSubtitle D to promulgate more tailored criteria. Nevertheless. Improving Federal programs under existing authorities in Subtitle D of RCRA. in specific instances. The practices themselves were not at issue. and until. These treatment methods/practices include the following: a.S.” EPA listed examplesof waste treatment methods and general field practices that.2. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . 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. This effort demonstrates that there is no need to increase federal regulation of E&P wastes. b. Land farming. 1988. the IOCCC published an update titled IOGCC Environmental Guidelines for state oil and gas regulatory programs. In 1994.2. 4. Abandonment of existing and previously abandoned wells. Central disposal and treatment facility management. In 1990. . the problem was the lack of state regulations for their oversight. this practice is regulated under the Safe Drinking Water Act’s Underground Injection Control (UIC) Program.1. Commercial products may be regulated under other statutes. 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. Thereport outlines goals and criteria for state programs to use in regulating these wastes. Contained gaseous materials. c. h. Pit construction. Federal Insecticide. d. . Solid. EPA also stated: “Existing Federal standards under Subtitle D of RCRA. Each of these will be discussed later in this section. Road spreading. the Agency madepublic its Regulatory Determination on June 30.2 June 30. Surface water discharge.1. d. b.18 API E5 4. 1988. Based on that study. it stated: “The Agency has decided notto promulgate regulations under Subtitle C (for E&P wastes).

4. It is a liquid and corrodes steel at a rate greater than 0. can generate toxic gases.2.2. thereby failing the Toxicity Characteristic Leaching Procedure Test (TCLP). or spontaneous chemical changes and.STD-API/PETRO E5-ENGL L797 0732290 O5b4b73 T38 m WASTE MANAGEMENT EXPLORATION AND PRODUCTION OPERATIONS IN 19 4. vapors. corrosivity. 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.4(b)(5)].or sulfide-bearing waste which.2. c. Chemical containers that are not empty by EPA's definition also are hazardous wastes.3.1 lgnitability solid waste is ignitable if a. b. b. c. It forms potentially explosive mixtures with water. The regulations contain four lists of hazardous wastes: a. EPA considers any nonexempt waste to be a hazardous waste if it exhibits any one of the characteristics of ignitability. when ignited. when exposed to pH concentrations between 2 and 12. exempt means an E&P exemption from Subtitle RCRA C regulation only. It is an ignitable compressed gas.3 Reactivity A solid waste is reactive if a.. It is not a liquid and is capable of causing fire through friction. or toxi- 4. e.2.4). See 4. Department of Transportation.2 Characteristically Hazardous Waste (40 Code of Federal RegulationsPart 261.2. It is readily capable of detonation or explosive decomposition under normal conditions (standard temperature and pressure).25 inches per year. 4.3.2. g.3. provided it meets one the of other exemption categories. It reacts violently with water.2.2.3.asdiscussedA above. Subpart C) The EPA has developed four tests for use in determining when a solid waste not listed a hazardous waste.2.5.g. It is normally unstable and readily undergoes violent change without detonating. must be managed as hazardous. reactivity. d. It is a cyanide.3.2 Corrosivity A solid waste is a corrosive if a.1 Listed Hazardous Waste (40 Code of Federal RegulationsPart 261. S . SubpartD) EPA has listed numerous types or classes of solid wastes as hazardous because they a. It is aqueous and has a pH less than or equal to 2 or greater than or equal to 12. or Class B explosive as defined by the U.2. b.5.2. absorption of moisture. Commercial chemical products considered acutely hazardous when disposed (P-listed). Commercial chemical products considered toxic when disposed (U-listed). COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . These characteristics are described in the following sections. It is an oxidizer. Have been shown tomeet certain human toxicity criteria. or fumes in a quantity sufficient to present a danger to human health or the environment.6 and 4.3 Hazardous Waste Criteria Determination Under RCRA. 4.2.4 Toxicity A solid waste is toxic if the extract from a representative sample of the waste contains any of the contaminants specifically listed in 40 Code of Federal Regulations Part 261. or fumes in a quantity sufficient to present a danger to human health or the environment. b.2. 4. city. burns so vigorously and persistently that it creates a hazard. it generates toxic gases. Other wastes are also considered exempt from Subtitle C under other provisions of RCRA (e. vapors. 40 Code of Federal Regulations Part 261. 4.3. Thus. In this document. d. Hazardous waste from nonspecific sources (F-listed).2.8 for those identified as nonexempt. It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated underconfinement.This is not intendedto imply that the waste is exempt from regulation under other statutesfiaws. wastes that are uniquely E&P have been specifically exempted from being considered hazardous [40 Code of Federal Regulations Part 261. h. When mixed with water. These include certain reclaimed materials and point source discharges subject to Section 402 of the Clean Water Act. It is a liquid and has a flash point less than 60°C (140°F). or specifas ically excluded from regulation as a hazardous waste. Typically exhibit one or more of the characteristics of hazardous waste (see below). Hazardous waste from specific sources (K-listed). c. Althoughconsidered to beasolidwaste.7 for wastes that have been identified as exempt and 4. It is a forbidden Class A. c.24 at a concentration equal to or greater than the respective value for each contaminant. a waste considered nonexempt be per the E&P exemption may still considered exempt from regulation as a hazardous waste. Contain any one of the chemical compounds or substances listed as hazardous constituents. d. f. b.

1.2. precipFederal Regulations Parts 261.5 and 262) itated amine sludge. EPA has begun rulemaking that may replace or greatly alter the mixture rule. filter media. and hydrogen sulfide EPA requirements for hazardous waste generators vary. depending on the volume of hazardous waste generated. a. backwash. including 4. Reference 40 Code of Federal Regulations Part 261. and other derequirements. fluid treating To prevent creating characteristic hazardous waste. Hydrocarbon-bearing soil. In particular. d. b. solids. Pipe scale. Shell Oil Co. Drilling fluids and cuttings from offshore operations disposed of onshore. including glycol-based nonexempt waste streams unless they have determined that compounds. storage facilities that hold product and exempt waste. Rigwash. waste generated and/or accumulated at a facility in a given n. Hazardous waste generated by a conditionally exempt small quantity generator is typically not subject to hazardous waste regulations (except for the identification requirements). hydrocarbon solids. December6.5 for the special requirements for hazardous waste generated by conditionally exempt small quantity generators. [2200 lbs] or greater per month) of hazardous waste have the p. f. filter media. and emulsion from production separators. Workover wastes. Only a few E&P facilities fall under these q. Gas plant dehydration wastes. The addition of organics to the TCLP list in 1990 expanded the potential universe nonexempt E&P wastes that of might be characteristically hazardous.lead.S. Most E&Pfacilities would probably fall under this category. Conditionally c. Produced sand. For the other generator categories. c.4 EPA’s Mixture Rule (40 Code o Federal f Regulations Part 261. Produced water. Spent filters. Small quantity generators (SQGs)are those facilities that prior to transportation. Pit sludges and contaminated bottoms from storage or other wastes.. and backwash (assuming the calendar month. b. hydrates.6 EPA’s List of Exempt E&P Wastes The following wastes are listed as exempt in EPA’s June 1988 Regulatory Determination: a. Drill cuttings. requirements are identif fied in 40 Code o Federal RegulationsPart 262. for organics such as benzene and toluene. treatment. tions). 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.2. CA DC. hazardous waste characteristics (such as benzene concentraj. e. iron sponge. Gas plant sweetening wastes for sulfur removal. Cooling towerblowdown. [The validity of the mixture rule has been overturned in court (U. Well completion. Accumulated materials such as hydrocarbons. and mercury. (2200 lbs). v. some wastes previously characterized as nonhazardous may now fail the TCLP test for benzene. opervessels. Large quantity generators (that is. sand. because some exempt wastes may have disposal of exempt wastes. posits generated and removed from piping and equipment b. backwash. operators should avoid commingling exempt and k. per month. ators should segregate characteristic hazardous waste from i. Basic sediment and water and other tank bottoms from containers. operators should segregate the following itemsfor separate management: 4. most restrictions. scrubber liquid and sludge. Because of the mixture rule. generators of 1000 kg o. h. glycol filters. generate greater than 100 kg (220 lbs).5 Quantity Determination (40 Code of amines. Other listed hazardous wastes from other wastes. Packing fluids. amine filters.. amine filter media. and production impoundments. but less than 1000kg r.2. and for pesticides.] The intent of this rule is to prevent avoidance of hazardous waste regulations through dilution. Unused U-listed and P-listed chemicals and their g. These requirements depend on the quantity of hazardous m.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. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .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. A facility may besubject to small generator requirements one month and large quantity generator requirements the next month. filter itself is not hazardous and the residue in it is from an exempt waste stream). a. Drilling fluids. molecular sieves. and the exempt waste does not have hazardous waste characteristics. 4. 950 E2D 751. exempt quantity small generators (CESQGs) are those facilities that generate 100 kg (220 lbs) or less per month. 1991). and stimulation fluids. Also.

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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.

4.2.9 Requirements

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.


State Permits

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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was most recently amended i n 1990. The others are carbon monoxide (CO). in appropriate circumstances. These controls include testing.6 additional data must be developed to make informed decisions. as such polychlorinated bypheryls (PCBs). CERCLA. TSCA regulates identification and management of certain chemicals. or disposal. this risk an may be reduced by banning or restricting a substance in some or all aspects of its manufacture. 4. acid deposition. sulfur oxides (SO. Under CERCLA. distributed.commonly known as the Clean Air Act Amendments of 1990. 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). All E&P facilities or locations are subject to TSCA. and notice requirements. TSCA also allows EPA to recommend product substitution. or by imposing labeling requirements.volatileorganiccompounds (VOCs) and nitrogen oxides (NO. TSCA Section 8(c) requires chemical producers and manufacturers to provide information periodically on production volumes for TSCA inventory updates. commonly known as Superfund.7. and lead.Thisrecentamendment. the Federal Food. substances regulated under these other laws are not subject to TSCA. For example. processed. or processing of a new substance not already on the TSCA inventory. Courts have interpreted the statute to be retroactive in its to application. These non-TSCA regulated substances include food additives regulated under the FFDCA and products such as biocides. and Cosmetic Act (FFDCA) and the Federal Insecticide. 4. 1977. Identify sites from which releases of hazardous substances into the environment might occur or have occurred. insecticides. TSCA was one of Congress’ responses to the dangers of human and environmental exposure to chemical substances and mixtures. TSCA empowers EPA to evaluate and regulate chemical substances and mixtures that may havean adverse impact on human health and the environment. and Rodenticide Act (FIFRA)]. This provides for strict liability without regard fault and. Drug. Care should be taken in handling CERCLA hazardous substances at E&P sites. THE TOXIC SUBSTANCES CONTROL ACT CrSCA) 4. COMPENSATION. recordkeeping. All areas of the nation are classified as attainment or nonattainment areas. effective January 1. Ensure that they are cleaned up by responsible parties or the government. Because E&P is an extractive rather than manufacturing industry. However. EPA can request jnformation or testing for a specific chemical substance or mixture manufactured. in order to avoid liability for expensive cleanup activities. or used for commercial purposes in the United States.1 Introduction TSCA. applies to all chemical substances and mixtures that are manufactured. use. imported. particulates (PM-lo). or used for commercial purposes in the United States. TSCA was established to fill the regulatory gaps left by other laws [for example.). depending on whether they achieve the national ambient air quality standard for ozone or four of six criteria pollutants. and motor vehicles and fuels. processed.5 THE CLEAN AIR ACT (CAA) The Clean Air Act. d. reporting.STD. enacted in 1970. b. c. CERCLA provides operators with a significant economic incentive to properly manage disposition of solid wastes at both onsite and offsite locations. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . E&P operations are excluded but gas processing plants are not. imported. TSCA recognizes that adequate data must exist to evaluate the chemical substances and mixtures. few other TSCA programs have routine impact. Therefore. stratospheric ozone protection.S. or processed by E&P. importation. Two criteriapollutants. They should be included in the waste management strategy. was enacted in December 1980 and established a program to: a. Create a claims procedure for parties who have cleaned up sites or spent money to restore natural resources. distributed. and herbicides regulated under FIFRA. or for the manufacture. permits and enforcement. distribution. in order to avoidcontaminating exempt E&P wastes withthose substances.API/PETRO ES-ENGL 1997 m 0732290 O5bllb77 45b W WASTEMANAGEMENT EXPLORATION PRODUCTION IN AND OPERATIONS 25 ration drill pads. If it is determined that unreasonable risk exists. imported. contains important attainment provisions for air quality standards. hazardous air pollutants (HAP). Only those chemical substances and mixtures that are on the TSCA inventory may be manufactured.7 THECOMPREHENSIVEENVIRONMENTAL RESPONSE. Evaluate damages to natural resources. Fungicide. are regulated as ozone precursors. AND LIABILITY ACT (CERCLA) 4. 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. and other activities fall under the above permits requirements. If required data is insufficient or unavailable.). TSCA imposes broad regulatory control over all chemicals produced in the U. for the imposition of joint and several liability.

discharging.7. No. wastes. leaking. This requirement is in addition to any reporting renot always treated RCRA-exempt production waste asexquired by CERCLA Section 103. or water). d. water.2 The Superfund Amendments and Reauthorization Act (SARA) Title III of the Superfund Amendmentsand Reauthorization Act of 1986 (SARA Title III). or contaminant. Section 304 requires immediate emergency notification applies. any hazardous or toxic chemical. EPA has interpreted the petroleum exclusion to include.7. Reporting is also required for onsite injection any hazardous substance or pollutant or contaminant). providing that the material is recovered. Section 303 requires such a facility to notify the LEPC of or sociated with the exploration. In addition. such as a concrete pad. leaching. and other closed receptacles containing chemicals. drilling fluids. 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. 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. 96th Congress. Section 31 1 requires any facility that is required under OSHA rules to maintain Material Safety Data Sheets 4. In addition. 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. A list of both exempt plans. leaching. Emergency reporting uncluded from the definition CERCLA hazardous substance. including indigenous hazardous substances). recyis exception is if the hazardous substance nonvolatile and the cling.1. EPA interprets the term petroleum to encompass crude oil. not land. Thus. or disposal into the enbrines that have been excluded by regulation are not hazvironment of any CERCLA “hazardous substance” or ardous substances. 2d SesSARA EHS that is in excess of the reportable quantity sion 28 (1980)l. 4.7. from the definition of hazardous substance. This section pertains to annual reporting ronment(including the abandonment or discardingof requirements for releases and emissions of certainlisted barrels.Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC) they are subthat posal Act has been suspended by Act of Congress. SARA Title National ResponseCenter. Section 313 of SARA Title III does not currently apply ing. RCRA.3 Reporting SpilldReleases (MSDS) to submit them or chemical inventory lists to the CERCLA also requires reporting releases of reportabIe SERC. also known as the Emergency Planning Community and Right-to-Know Act (EPCRA). 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. drilling muds and leak. stances. [S. the appropriate state III also requires that any facility covered underSections 31 1 and local agencies may also require notification. LEPC. emitting. and local fire department. pollutant. Revisions to this to quantities (RQ) of regulated hazardous substances the enlist must be reported within 90 days. vironment (that is. dumping.2 E&P WasteExclusion COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . air. includof ing crude oil or any fraction thereof.26 API E5 4. injection. has six programs affecting or with the potential to affect E&P: a. and 312 allow access to the local fire department for the CERCLA defines a release to mean: any spilling. containers. in their entirety. discharge.1. An and offsite transfers of listed chemicals for treatment. injectf. pumping. and other wastes asb. The EnvironmentalProtection Agency has (RQ).7. and refined products exam(for ple. Any changes at the facility that might affect the local B. 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. pouring. land. pure petroleum and pure petroleum fractions. “notwithstanding the presence in such substance of and follow-up reports to the SERC and LEPC of any spill. purpose of conducting anonsite inspection.Rep.1.” Thus. produced water. gasoline. even though they contain substances otherwise listed as hazardous. emptying. Under ject to the law. escaping. crude oil fractions. Source reduction and recycling activities i) release is into a contained area (that is. development. or disposing into the envito E&P operations. or disposal. which is not considered aspill or release to the environment. Any spill or release e. federal permitted releasesor discharges are exempt from this reporting requirement.1 Petroleum Exclusion CERCLA provides for the exclusion petroleum. orar are now required reporting under this section. TSCA 0 8(e)). 4. 848. Congress stated that the exclusion for E&P wastes c.

under what conditions. increases limits of liability.3). aformal consultation under Section 10of the ESA will proceed.S. If there is no adverse impact posed by the project. This plan should encompass identification of environmentally sensitive areas. b. revises the measure of damage of natural resources. as appropriate. 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. of the status of a species of wildlife or plant. The consultation will determine if the project can proceed. and Federal agenciesare required by Section 7of the Endangered Species Act (16 U. EPA has authority for nontransportation-related facilities. This determination should consider both beneficial and adverse effects on the environment that would result from the implementation of the proposal. 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. 1531through 1543). it is nevertheless required to prepare an environmental assessment to justify its decision (40Code of Federal Regulations Part 1501.4. If the agency decides that an EIS will not be necessary. such as moving the project location. 4. of OPA 90 amends Section 31 1 the Clean Water Act by revising the federal spill response system.5). Generic response plans. c.Coast Guard and DOT have authority for pipelines. 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.S. 4.C. Management (BLM)on how to manage public lands under its jurisdiction.S. addresses preventionand removal. a species is subject to protection under the Endangered SpeciesAct (16 U. The List of Endangered und Threatened Wildlife and Plants is published periodically in the Federal Register. disposal of recovered oil.9. while the U. a negative declaration will be issued under Section 7of the ESA. Once listed. and training. The spill response system includesthe following types of plans: a. A threatened species is one that is likely to become endangered. and sets up a research and development program.4). The authority to place species on the endangered or threatened list is vested in the Secretary of the Interior and the Secretary of Commerce. Single company plans. inclusive of onshore and offshore drilling and workover facilities.S. Conditions may be imposed to mitigate the probable impacts of the project to the species of concern. 1991. offsetting the impacts within a mitigation bank.C. 1536) to ensure such acthat tivities neither jeopardize endangeredor threatened species nor destroy or modify the critical habitat of such species.TheU. If a species may be adversely impacted.S. and report the suitability recommendations to the President of the United States no later than October 21.1 National Environmental Policy Act(NEPA) The National Environmental Policy Act of 1969 (NEPA) requires detailed environmental review. and tankers. Thelisting process may be initiated by the petition of any interested person requesting review. Section 603 of FLPMA (43 U. terminals. removal. 1701 through 1782) establishes comprehensive land use guidelines for the Bureau of Land COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .9 OTHER FEDERALACTS 4.S. increases financial responsibility.Fishand Wildlife Service (USFWS) or the National Marine Fisheries Service (NMFS).2 and 1501. This should be part of the project review and may become an integral part of the permitting process.9. establishes a fund for cleanup costs.S T D . 4. so forth.3 Endangered Species Act (ESA) The Endangered Species Act of 1973 was designed to protect endangered or threatened speciesor their critical habitatfromproposedactivities. Private response plans. under 50 Code of Federal Regulations Part 402. make determinations as to whether or not an E&P project (activity) will adversely impact a threatened or endangered species.C.C.2 Federal Land Policy and Management Act (FLPMA) The Federal Land Policy and Management Act of 1976 (FLPMA) (43U.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. or change of status of a species with regard to the protected species list follows formal rulemaking procedures. by the Secretary of the Interior. An endangered species is a species that is in danger of extinction throughout all or a significant portion of its range. d. in the form of an environmental assessment or environmental impact statement (EIS). Plans that address specific classes of facilities.8 THE OIL POLLUTION ACT OF 1990 (OPA 90) The Oil Pollution Act of 1990 mandatesnational contingency planning. The inclusion.9. and if so. determine their suitability or unsuitability for wilderness designation. establishing restrictions. 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 transportation or sale of oil and gas from federal onshore and Indian leases. including a hazardoussubstance. Controlling exposureby classifying and certifying pesticides for specific uses. Depending on the task(s) being performed or required to be performed in preparing a material for shipment. 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. 4. provided the materials are not shipped onor across public access roads or highways. safety. a person (for example. Suspending.or restricting the use of pesticides that pose arisk to the environment. 1701 et seq. zinc bromide). transporter. labeling notices. services. If the operator choosesto use or apply a regulated pesticide. wildlife. Ifthe material is subject to regulation.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. FIFRA has four main objectives including the following: a.8). operators. Establish the basis for cooperation with states and Indian tribes for onshorefederal leases. weeds. or transported. d. 43 Code of Federal RegulationsParts 3100 et. 4. or water. Address lease reinstatement. and so forth) must first determine if the material being shipped is a hazardous material subject to regulation by the DOT. insects. and other living pests. would still be subject to the DOT regulations. or restrict the use. Since there may be a need to use pesticides or other pest control chemicals at a facility. and others involved in the production.S T D = A P I / P E . Under this Act. 4. accepted. b. 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.S. however. and Rodenticide Act (FIFRA) The Federal Insecticide.. corporation.101.6 Hazardous Materials Transportation Act 4. c. Prescribe onshore field operations requirements for inspections and enforcement actions.9. it must be used and/or appliedin accordance withits label requirements. 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. that person must then determinewhich of the duties assigned by the regulations are required to be performed (that is. c. Enforcing requirements through inspections. This can help prevent the misuse these chemicals of or the potentially dangerous storage and disposal of unused products.4 Federal Oil and Gas Royalty Management Act (FOGRMA) The Federal Oil and Gas Royalty Management Act of 1982 (FOGRMA) (30 U. In addition. or disposal of pesticides. since they are either listed as a hazardous material or contain a regulated quantity of a hazardoussubstance. Regulated materials or wastes shipped by E&P are typically subject to either Department of Transportation (DOT) or Coast Guard regulations. Shipments completely within a facility or lease are not subject to DOTregulation. shipper.6. Address OCS matters. 25 Code o Fedf eral Regulations Part 226). that has been determined by the Secretary of Transportation to be capable of posing an unreasonable risk to health. b.C. and Rodenticide Act (FIFRA) was originally enacted in 1947 and subsequently amended to its current form. air.1 Shipper Responsibility Most importantly. seq. Evaluating the risks posed by pesticides using a registration system. public access roadsand highways).9. rail. f. measurement. FIFRA providesfor the registration and use pesticides andsimilar products intendedto of eliminate or control rodents. including instructions for the proper handling and disposal of the empty container. waterways. or vegetation without an incidental-taking permit. Fungicide. cancelling.although not subject to the hazardous waste regulations.5 Federal Insecticide. individual. as A hazardous material is defined a substance or material. A specific definition of the slupper is not provided in the regulations. e. A willful violation of this prohibition is subject to criminal punishment. and state authorities. Fungicide. EPA can control.9. Assure proper and timely revenue accountability for production fromonshore federal and Indian oil and gas leases. microorganisms.9. 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. import. or both). and property when transported in commerce and that has been so designated (49 Code o Federal RegulationsP r 17 1. In f at general terms. storage. d. the shipper a hazardous material for of COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . ban. Some E&P waste streams(for example. Establish duties of lessees. Appendix A) are subject to DOT regulation when shipped. or railroads.) was designed to: a. a hazardous material is defined as any material deemed to be hazardous by the DOT.. the regulations set out specific requirements and procedures that must be performed prior tothe hazardous material being offered.

All oil and gas producing state statutes. and local regulations are constantly evolving. or water. disposal.1 INTRODUCTION This section describes waste management practices for E&P wastes and their potential environmental impacts. Transfer of ownership has little bearing on the shipper responsibilities under the DOT regulations.1 0. Finally.2 Oil and Gas Lease Agreements Lease agreements may impose obligations withrespect to waste treatment. Although special circumstances may warrant regulatory approval of other specific practices. preparing the shipping paper. Transporter tasks include incident reporting.10. water.9. highway. shipping paper or dangerous cargo manifest requirements. rules. When more than one agency is involved. or criminal penalties. the carrier or transporter is defined as the person engaged in the transportation of passengers or property by land. Ownership of the hazardous material offered or accepted for transportation is only one of many factors that determine which party or parof ties perform. An overview of waste management methods and applicationsis presented in this section and summarized in Table 2. storage.1 Naturally Occurring Radioactive Materials (NORM) There are currently no federal statutes or regulations specifically covering generation. and providing placards when required. States are developing have deor veloped rules for the regulation of NORM. states have the authority to: a.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. or has a duty to perform. 5 Waste Management Methods 5. or reclamation and may be different or more stringent than regulatory requirements. contract. the operator may also be considered the carrier ortransporter if the hazardous materials are transported on company owned or leased vehicles or vessels. Users are cautioned. typically a Memorandum of Understanding (MOU)delineates the specific areas of authority for the agencies involved (for example. the following criteria have been shown to be effective in themanagement of wastes. marking or placarding the vehicle.6. E&Pwastes and practices are subject to regulation by state agencies responsible for environmental protection. and emergency response for accidents. b. training. other than regulations that apply generally to other radioactivematerials.10OTHERREGULATIONSANDAGREEMENTS All states have regulations to protect public health and the environment. state. rail.2 SOURCE REDUCTION Source reduction means eliminating or decreasing. State and local requirements vary and may be more stringent. These tasks include classifying the material waste. however. In certain instances. 4. civil. they should be reviewed to determine whetherinformation in this document is consistent with current laws and regulations. Issue cease and desist orders. Assess or seek administrative. 4. any the functions of the shipper. Oil and gas E&P takes place in states with widely diverse geological and environmental conditions. These sound practices not only serve to protect human health and the environment. 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. 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 . Ban further operations and sever an operator’s pipeline connection. segregating materials. the volume or relative toxicity of wastes that are generated. they should be conducted in accordance with lease and landowner obligations and local. 5. When thesepractices are implemented onsite. Sound practices should be employed all aspects of in waste management. 4. Federal. state. or disposal of oilfield NORM. providing emergency response information. To encourage pollution prevention. 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. or as a common. In general. certifying that the shipment is in accordance with the DOT requirements. they can help protect an operator from the long term liabilities of waste disposal. marking and labeling the package. Table 2 arranges available waste management optionsin a hierarchy. oil and gas agency and environmental agency). c.2 Transporter Responsibilities The DOT regulations also apply to each carrier who transports a hazardousmaterial by air. that the information in this document is not all-inclusive and may not apply in allsituations. Pending the outcome of an investigation. Order cleanups. and federal regulations. or selecting the packaging. or private carrier. d. 4. loading and unloading requirements. to the extent practical. The resulting state regulations exhibit a variety of approaches to environmental protection because they have evolved relatively independently.

The number of chemicals used should minimized to simplify trackbe ing and recordkeeping. can minimizewaste.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. or other characteristicsof waste. centrifugation. 5. cost-effective opportunities for source reduction exist and should be considered. d. c. Recovery of hydrocarbons from tank bottoms and separator sludges can be accomplishedat onsite production facilities or offsite commercial facilities. Treatment”emp1oy techniques to reduce volume. b. Product and process substitution to reduce the volume and toxicity of the waste generated. toxicity. reuse different processes. Reprocessing into products. c. burning for energy recovery. chemical precipitatiodflocculation. and to protect human health. e. returning unin used materials. Process modification through more effective use of mechanical means. Examples includethe following: a. Filtration. either in process. All treatment must be performed in accordance with applicable state or federal regulationsas described in Section 4. The volume of drilling muds generatedis generally linked to the numberof wells drilled and their depths. d. Biodegradation of organic material may result in transformation to less toxic compounds or in complete degradation. Suggestions include the following: a. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . 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. or with outside contractors.Used oils. Return of oil-based drilling mud to the vendor for reprocessing. such as the use of more effective drill bits rather than chemical additions. or releases to waterways.S T D . engine oil changes. State and local regulations should be consulted to ensure that any notification recordkeeping or and reporting requirements are met.A P I / P E T R O E S . Elementary neutralization may be applicable to the treatment of corrosives. accumulations of oily materials. or other characteristics should be considered. where permissible. Recycling hydrocarbons. Thermal treatment canresult in recovery or destruction of toxic organics. Improved controls to minimize mud changes. the age orstate of depletion of a producing property. or solvent usage. the volume of produced water typicallyincreases as the field is depleted. if any. f. First idfirst out inventory control should be practiced to ensure that chemicals do exceed their not expiration date. b. onsite. where practical. 5. thermal treatment (evaporation).5. or it may concentrate a constituent toa level where recovery is feasible. b. Recycling-reuse or reclaim valuable material from the waste generated. potentially cost-effective treatment steps to minimize waste volume. Nevertheless. and extraction maybe used to reducethe volume ofa waste. Suggestions include the following: a. c.3 RECYCLINGANDRECLAIMING After reviewing all reductionoptions. hper disposal-utilize environmentally-sound methods to dispose ofgenerated waste to minimize its impact.5 DISPOSAL 5. suchas hydrogen peroxide oxidation of phenol to carbon dioxide and water. Use of chemical clearinghouses to find a customer for waste materials. This volume reduction may produce lower disposal space requirements. and recovery for reuse in other industries. the operator should consider recycling or reclaiming the waste material.4 TREATMENT After examining source reduction recycling opportuand nities. hydraulic fluids.1 Evaluation Factors Disposal is the final waste management alternative to be considered after incorporating all practical source reduction. e. may be used to reduce or eliminate the toxicity of a chemicalwaste. For example. and oily sump watersmay be managed accordingto 6.7. Note: Check appropriate regulations prior to selecting waste management options. Good housekeeping to prevent spills to soils. Chemical treatment. Improved drilling techniques. d. relative toxicity. 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.

5. The following factors offsite should be considered when evaluating both onsite and disposal facilities. speed of reserve pit drying. and direction of flow for existing surface water bodies and aquifers characterized as an Underground Source of Drinking Water (USDW). net evaporation rates.5. Fora detailed description of these guidance values and their application.5.6 Presence of Special Conditions Environmentally-sensitive conditions such as wetlands.4 Conditions Loading Soil and Considerations Soil conditions should be checked since they will affect decisions on loading for landspreading and liners for pits.3AreaRainfallorNetPrecipitation Conditions Historical rainfall and distribution data should be evaluated to establish soil loading conditions for landspreading. 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. Based on soil and waste analysis. Characteristics and levels the wastes are such that of contamination of soil.5. absorption.5.5. hydrological.5. and federal regulations and consistent with lease obligations. For example. An example of the application of this procedure is given in Appendix F. reduction of organic and inorganic constituents by natural processes. 5. and(c) background soil salinity. and/or pH level after mixing with the soil. Landspreading should be practiced in accordance with local. 5.1.1. should be reviewed.5.1.1. exchangeable sodium percentage less than 15.7 Air Quality The potential air quality impact of solid waste management facilities should be considered. Landspreading. 5.In other areas.2 Landspreading Landspreading is a method of treatment and disposal for RCRA Subtitle C-exempt. groundwater. and pH overtopping potential.5. and runoff should not occur if landspreading is executed in a prescribed manner. electrical conductivity) of less than 4 mmho/cm. liners may be appropriate.2. This one-time loading is what differentiates landspreading from landfarming. onto. While initial loadings are designed to be protective.2 Hydrological Conditions A hydrological review should identify the location. Drainage devicesneeded to control water flow into. 5.5. Higher values may be appropriate for some sites dependingon (a) land use. size. minimizes impacts current and future to land use.3 Hydrocarbons API Publication 4527 also supports and describes the landspreading of wastes that contain hydrocarbons. one constituent will be found to be controlling-that is.2. low-toxicity wastes. hydrocarbons. and geological features. or the presence of endangered species should be identified. see API Publication 4527. it will limit the amount of waste that can be applied to soil.5 Drainage Areas Natural or existing drainage pattern should be determined. or from facility systems should be identified.5. Wastes are applied ina one-time loadingas determined by the absolute salt concentration. 5.1 General Conditions Site Area-wide topographical. and metals are discussed below. state. 5.1. Proximity to urban areas also affects disposal decisions.1.1. will not harm most agricultural crops or soil (based on one-time application). a processof applying a waste to the upper soil zone.5. It promotes COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . in high clay content and permafrost areas.2. and a sodium adsorption ratio less than 12. metals concentration. protected habitants. and biodegradation. August. 5. plants. and soil microbes. as well as sources of usable water. Evaluation of Limiting Constituents Suggested for Land Disposai of EdiP Operations. liners may be unnecessaryfor reserve pits. further reduction of organic and inorganic constituents generally occur by natural processes such as dilution. (b) salt tolerance of native vegetation. historical or archaeological sites. 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. which results in wastehoil mixtures with soluble salt levels (thatis. Sitespecific conditions may accommodate initial waste/soil mixtures with higher 5. and treatment options. Loading criteria for salts. hydrocarbon concentration. 5.2 Salts Studies have shown that landspreading.1 Loading Limits 5. Also. 1993.S T D .A P I / P E T R O ES-ENGL L997 WASTE MANAGEMENT ExPLownoN AND PRODUCTlON OPERATIONS IN 3 1 recycling. current and probable future activities around the disposal site should be evaluated.

It is assumed that the soil will be tilled a depth of 6 in.000 [ acre6"1 (1 lb waste) lb oil lb oil 0. 10 percent oil (100. 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 x IO6 lbs soil/acre.500 yd3 of waste: From the oil concentration in the waste.164 acre-6 Determine the land requiredto spread 1.&~. Enhanced techniques. Solution: a. S] A.) weighs 2x106 lbs.000 =40.000mgTDS) 1. The API document.5.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.000 ppm).6 Ib/ft3. This document describes methods determining and controlling pH in the field.1 5. and a density of 93.000 mg TDS g TDS ~](1.500 yd3 of waste: 5. Calculate the land requirementbased on the TDS content of the waste anda maximum loading of 3.5 Metals b. deep (1 acre-6 in. CriteriaforpH in Onshore Solid Waste Management inExploration and Production Operations. suchas repetitive disking and nutrient addition.000).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.: lbs oil Maximum lbs oivacre-6 in.5.000 lbs oivacre-6 in.2. Calculate lbs TDS/acre-6 in.000 ppm.S T D .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.-6 in. 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. Maximum waste-to-soil =40. should be consulted.mg Concentration of metals in the waste/soil mixture must also be controlled.000 ppm TDS (including TDS in the native soil). Note that the pounds of TDS per acre-6 in. Assume the native soil has 100 ppm TDS.500 yd3 of waste with 12.02 . 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 TDS. (6.=0.2. Convert maximum ppm TDS loading to lbs TDS/acre-6in.5. Table 3 presents API-recommended guidance values for metals in land disposedsoiYwaste mixtures. 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.000) is twice the loading of TDS in ppm (3.4 pH Convert poundsof waste to volume: Maximum waste volume loading = 4 x 1 lb waste 6 ft3 waste According to the API Publication 4595. 5. to and that 1 acre of soil 6 in.: Maximum lbs TDS I acre-6= 3.2. may be used to increase the rate of biodegradation. x lbs sod = 40.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.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. Metals Criteriafor Land Management of Explanation and Production Wastes.274 acred" [ [ Determine the land required to spread 1.

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. Less than 1 percent O&G by weight. Recommended criteria for buried or landfilled wastes include the following: a. Application of oily wastes to private or public roads should be at loading rates that minimize the possibility of surface runoff. and crude oil-contaminated soil may be used for road oil. Therefore. Soil Sampling and Methods o Analysis.500 750 300 17 .400 5. 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). and molecular sieve).5. 1994 (59 FR 9050). emulsions.Plants that accumulateSe in these soilsmay pose a threat to grazing animals. Boca Raf ton. waste characteristics such as naturallyoccurring radioactive material (NORM) should be considered. When the waste exceeds the suggested criteria (see Table 4 . Under certain conditions this interim level may not be protective of grazing livestock. these techniques should be used only in areas where soil and hydrological conditions would preclude or minispecial mize any threatof groundwater contamination. As describedin 5. oil is thelimiting constituent and 9. low-salt and low-hydrocarbon content inert materials (for example. pp. 1993. Laboratory Procedures for Analysis o Oiljïeld Waste. road mix. gas plant catalyst. Third Edition.5. spent iron sponge. However. Statewide OrderNo. flash point above 140"F). bLouisiana Departmentof Natural Resources.OOO 2m a d 26 1. 29-B.1 Exempt oily wastes such as tank bottoms.2. Testing Methods for Evaluating Solid Waste. if elevated levels of Se are found in the waste. 1986.WASTE MANAGEMENT EXPLORATION PRODUCTION OPERATIONS IN AND 33 Since the land requirement for oil loading is greater than for TDS loading. 5. Lewis Publishers. the operator should consider site conditions that control its availability (see Discussion of Limiting Exposure Pathways). Less than 4 mmho/cm electrical conductivity.a liner or encapsulation should be used. Also. 1989. f 'Carter. Roadspreading should have the approval of landowners and should meet appropriate state and local regulatory requirements.5. the potential for plant uptake of Se may be high in alkaline soilsunder arid and semi-arid conditions. Molybdenum: On February 25.SW-846. c. and encapsulation are methods used to modify adverse properties of wastes to make them suitable for burial. Wastes that do not meet the above guidelines may be safely landspread if additional management controls have been developed and properapprovals obtained. 2. Furthermore. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . 5. Notes: 1. Operators shouldmaintain complete records analytical of data. 91-93.2 Produced Waters aEPA. These wastes should be analyzed to ensure they are not ignitable (that is.4 Burial or Landfill It is suggested that operators limit burial or landfilling without a protective liner primarily to solid or semi-solid. and that they havea mixed density and metals contentconsistent with approved road oilsor mixes. Selenium: The limitingpathway concentration of 1 0 0 mgkg was generated by EPA using the risk-based multipathway analysis (see Table 3). Solidification. fresh water-based drilling muds. sites used.5 acres would be required to landspread this waste achieve the deto sired loadings. heavy hydrocarbons. 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.3 Roadspreading Oil Wastes Boron Cadmium Chromium Copper Lead Mercury Molybdenum Nickel Selenium Zinc 5. 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. Produced waters with higher electrical conductivity may be used lieu in of road salting withstate and local regulatory agency approval.ee Note 1 210 iee Note 2 1. or asphalt.3.5. Free oil should not be buried. and types and quantities of waste disposed. Burial may reduce the rate or amount of natural biodegradation that occurs. ) unless it can be shown that groundwater is either not present or is naturally protected from any significant threat of contamination.3. the presenceof heavy metals should also be considered.5. pipe scale. dGuidance for boron is based on the soluble concentration with units of mg/L rather than the total concentration (mgkg). 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. stabilization. b.

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 .

These fluids should be directed via a pipe or trench to the pit. e. Generally.5. Liners should be made of a natural clay or clay-like synthetic material that will withstand normal operating conditions. 5. Solids separation equipment (for example.5.5. pH outside of the range 6 to 9. Reserve pits should be strategically sited on drilling locations to collect the appropriate wastes and. where practical and appropriate. c. This action may include immediate removal of free hydrocarbons and special pit closure techniques. e. permeating. or closed mud systems should be employed as required in environmentally sensitive areas. liners shouldexhibit a hydraulicconductivitylessthan 1OE-7 c d s e c . based on geological areas or mud system additives. Any areas subject to spillage or contact by these muds should be lined with impermeable material. or hydrocarbons greater than 1 percent by weight should not be storedin unlined pits wheregroundwater requires protection.1 Reserve Pits f. Pit liners. special engineering considerations should be used toensure integrity of the pit and to prevent overflow of the pit during heavy rains. operation. Pit liquids should have their free oil removed and be sampled for conductivity prior to pitclosure. Pits should be sized to ensure adequate storage during drilling operations.5 Onsite Pits Onsite pits include reserve pits for drilling operations and emergency.5. additional sampling and analysis for metals or salts is necessary. percolation.1.5. special efforts may be needed to isolate these muds and cuttings from those already in the reserve pit. storm water runoff from the drilling pad. Wastes stored in reserve pits should be restricted to drilling muds. and certain completion fluids.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. barrier walls.1. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . cuttings. c. If materials will be encapsulated permanently. 5. unless soil and groundwater environments will not be significantly impacted.3 Reserve Pit Closure Reserve pits should be closed using the following guidelines: a.1 ReservePitConstruction Reserve pits should be constructed using the following guidelines: a. In areas where it is necessary to construct reserve pits adjacent to water bodiesor on the side of hills or bluffs. b. cuttings. 5. b. and closure of reserve pits should adhere to the following guidelines. described below. 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. d. Reserve pits andassociated trenches should be lined if the drilling fluids are saltwater or oil-based muds. 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.5. Reserve pits should be constructed so that the pit bottom does not penetrate usable groundwater. reacting). b. In certain cases. Operators must assure maintenance of liner integrity. Construction. and so forth) should discharge directly to the reserve pit. State and local regulations may allow freshwater-based muds. and spills. workover. basic sediment. Liners should protectthesides and bottom of thepit and providea sufficient barrier to any potential flow. Lined pits should be used with care. NPDES skimming.5. and rigwash discharge to unlined reserve pits. the pit contents should not significantly impact usable groundwater or surface waters.5. Operators must maintain dikes and liquid levels to prevent overfilling. cyclones. produced water or liquid hydrocarbons should not be placed in unlined pits. and evaporation pits for production operations. The operation should include measures to avoid damage of the liner either physical (tearing or puncturing) or chemical (dissolving. It is recommended that completion fluids with electrical conductivity greater than 4 mmhoskm. Waste management plans may address whether. remedial action may be needed. The pad should be constructed with storm water runodrunoff controls in place to minimize nondrilling pad storm water entering the reserve pit. 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.1. 5.5. Any hydrocarbons that inadvertently enter a pit when drilling and completion operations stop should be skimmed off. shale shakers. Pit dikes should be built to fully contain liquid volume and preventseepage. If in wetland areas. unpermitted discharges. excess cement. d. rigwash. historical rainfall patterns should be considered.

Fluids diverted to emergency pits should be removed as quickly as practical and in accordance with local.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. 5.2.5. injection into onsite Class II wells.5. For land application of fluids. and federal regulations should be reviewedprior to selecting a management option. Alternatively. State. 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. It may be possible to reduce the oil content of some muds by washing mud solids to reach this criteria. operation. Landspreading or burial as described in previous sections may be viable options. Records should be kept of pit locations. landspreading.3.5. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .2. 5. analytical data. They may be injected down the well annulus or Class II injection wells or disposed using other options approved by local. f. 5. i. Pit sites should be compacted. they may be hauledto offsite disposal sites. Under certain circumstances. and federal regulations. revegetated and where necessary to provide ground supportstability and prevent erosion of the well location. d. volume. e. hyto drological factors. fluid composition and loading rates should be considered.1BlowdownandEmergencyPits Blowdown and emergency pits (flare pits. one should consider segregating the saltwater-based system to minimize the wastes that must be managed using special techniques.2. When drilling deeper wells using both freshwater and saltwater-based muds. or pit solids may be removed and hauled to permitted offsite disposal facilities. When drilling wells using both freshwater and oil-based muds. state. 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.6). j.Thefollowingguidelines should be used for various onsite production pits. evaporation in arid areas. of surface or groundwater contamination. 5. c. Residual pit solids with electrical conductivity greater than 4 mmhokm.5. or transportation to offsite facilities. pits may be lined or tanks may be used. If site-specific considerations indicate that these waters could be endangered. destination.3BasicSedimentPits Basic sediment pits should be lined replaced with tankor age. local.5.5. Theresulting low-salt solids can be managed like freshwater solids. Basic sediment pits are used for temporary storage of oily wastes such as paraffin and vessel bottoms. discharging under state/NPDES permits. state. and hauler used for waste fluids and solids transported to offsite facilities. Siting of these pits should consider the presence groundwater and surface of waters.5. if any. Siting and construction should minimize the potential.2.5. Unlined onsite pits used for disposal of waste should be restricted areas where soilconditions.4 Percolation Pits Percolation pits allow liquid contents to migrate through their bottom and sides into surrounding soils.2 Workover Pits Workover pits used to contain workover fluids should be open only for the duration of the workover.5.~~~ ~~ 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. Operators should keep records of type. pressure vessel relief pits. and fluid overflow pits) should not be used for storage or disposal. solidification and stabilization may be practical for minimizing the mobility of specific constituents.2.2 Production Pits Construction. 5. and rainfall prevent significant soil or groundwatercontamination. contoured. Salts may be removed by washing and then injecting the resulting salty washwaterinto a Class II injection well as defined in 4. oil and grease greater than 1 percent by weight. Percolation pits should be used only for disposalof produced waters where permittedby regulatory agencies and where USDWs are not present or endangered. Information shouldbe applied in designing pit closure procedures that will ensure soil and groundwater protection of the drill site. 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. Oil-based mud liquids should generally be returned to vendors or reclaimed at permittedfacilities. 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 closure of onsite pits should generally follow thesame guidelines as thosefor reserve pits described above.5. segregating the oil-based system minimize total volume to of oily waste should be considered. Their contents are periodically cleaned outor burned. h. and federal regulations. g. Freshwater pit liquids can be managedby injection down the well annulus (see 5.

are regulated by the Clean Water Act's NPDES program (40 Code of Federal Regulations Part 435). recognizing their unique environmental aspects.2.5. This allows more complete residual oil separation.or injection-well-regulated disposal of the produced water. Properly constructed and monitored underground injection wells represent a safe environmental practice for disposal of produced water. 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.This program sets conditions for discharges in different areas. casing. Stripper discharges that are allowed for marginal wells under the CWA. Unlined skimminghettling pits should be used only in conjunction with permitted state/NPDES discharges. 5. E&P operations may discharge produced water. paraffin. Surface evaporation pits may be lined where groundwater or usable soils may be endangered. b. Current status should be evaluated before discharging. Operators must demonstrate mechanical integrity according to current requirements by ensuring that there is no leak in thetubing. Outer Continental Shelf (OCS) waters. and hydrocarbon-containing wastes. ments. In addition.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. landscape wastes. 5. facility waste fluids.5 UnlinedSkimming/SettlingPits Unlined skimmindsettling pits contain discharges to provide additional retention time for the settling of solids. Underground injection wells associated with E&P activities are classified by EPA as Class II wells.5.4 andlor specific onetime permission is granted by the state.7 Evaporation Pits In areas where small volumes of wastewaters are generated. Also.5. 5.2. in the following areas: a. However. subject to appropriate permit limitations. Operators should design injection wells to prevent endangerment of nonexempt USDWs. Pit walls should be constructed to prevent seepage and provide adequate free-board above normal operating conditions for precipitation. or packer and that an injected fluid is confined within the injection zone through proper cementing. Injection well classifications are summarized in 4.S. c.5.8 NPDES Discharges Point source discharges from oil and gas operations to navigable waters of the U. Beneficial usage.9 Open Burning and Incineration Open burning and incineration are typically used to dispose of nonhazardous materials with properties that make recycling unsuitable. They should not be used for produced water.2. Burning should be restricted to materials such as oily sorbents. EPA classified Class V wells should not be used for disposal of E&P wastes without specific regulatory agency approval.3. burning should be conducted during daytime hours and should not cause nuisance smoke and particulates. Maximum surface injection pressures are approved by the state and recorded in the injection permit.5. Disposal of wastewater by evaporation produces concentrations of salts and residual hydrocarbons.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).5. evaporation pits are used. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .5. 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.6ProducedWaterPits Produced water pits have been used in lieu of tankage. unless exempted according to 40 Code of Federal Regulations Part 146. Or if the following conditions are met: a. and board road material. b. Territorial seas.5. Class II wells are to be used for exempt E&P waste fluids. Coastal areas that contain brackishwaters not suitable for human usage.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.5. 5.2. operators must protect underground sources of drinking water with sufficient casing and cement to prevent contamination due to injected reserve pit fluids. Produced water pits may be lined and should be operated only as a substitute for process vessels with NPDES.5. state regulations should be consulted to evaluate specific require- 5. 5. These discharges occur primarily in Wyoming and California and are permitted by state or federal agencies.

The probable long term fate of the waste and its constituents should be considered. Federal. Recycling. however. b. In addition. operators should conduct them in accordance with lease and landowner obligations and federal. e. are all important when selecting a waste management option (see Appendix A). Wastes should be managed according to waste management guidancein this section and Section 5 .5. The options selected must be economically and technically practicable. A variety of considerations including federal. and incineration services. Where appropriate. great care should be exercised by operators in using these sites. that information in this document is not all-inclusive and may not applyin all situations. State and local requirements vary. and local regulations are constantly evolving. lease restrictions. and local) and lease provisions should be checked. 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. location of disposal. state. each of the following discussions is organized according to the waste management hierarchy. namely: l. Emulsions. volume.5. a review of all state and federal regulations. method of disposal. 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. c. Therefore. and economic and technical feasibility. Source reduction. state. state. The following guidelines are suggested for determining waste management options: a. When wastes are disposed in offsite commercial facilities. hazardous and nonhazardous treatment and disposal capabilities. of date disposal. 2. cost and technology) of the waste management options. these general options are not repeated or discussed individually unless specific options are identified. Class I and Class II fluid injection.10 OffsiteCommercialFacilities Offsite commercial facilities offer reclamation. Boiler Water. the options presentedin this document are not intended to be all inclusive or applicable to each E&P location. records shouldbe kept that document the type and quantity of the waste.2. and location records for wastes that have been disposed onsite should be maintained. Waste type. Disposal. All applicable regulations (federal. and a review and selection of appropriate waste management options (see Sections 4 and 5). as described in Section 4. Heavy Hydrocarbons. Other considerations should include the safety. Scrubber Liquids. and local regulations. waste stream segregation.~~ ~~~~ STD*API/PETRO E5-ENGL L997 c 0732290 OSb47L2 7 L T 38 API E5 5. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . availability. operating practices. 6 Identifying Management Options For Speciflc Wastes 6. Because of the great diversity of geological and geographical conditions across the United States. state.1 INTRODUCTION The followingmajor topics are covered in this section: ProducedWater Drilling Wastes Workover and Completion Wastes Tank Bottoms. and any other pertinent information that could prove useful insubsequent investigations to assess liability. spill prevention and minimization. Operators are cautioned. Pollution prevention options should be evaluated using the waste management hierarchy. Treatment. Waste management plan development should includean evaluation of existing environmental conditions current and management practices. d. and local regulations. they should bereviewed against information in this document to ensure consistency current and with laws regulations. Waste management options must be selected based on site-specific circumstances. 4. product substitution or elimination. it is recommended that oil and gas companies develop waste managementplans that address their specific operations and operating areas. It should be noted that certain source reduction options such as improved housekeeping. and practicality (for example. and purchasing and inventorycontrol procedures could be applior cable to eachof the following wastes activities. 3. Waste management practices are identified in Section 5 . and facility design. environmental factors. It is recommended that operators periodically review offsite commercial facilities as per 2. Due to the potential for long-term liability.

b. and federal regulations: a. differential pipe sticking occurs. d. Liquids-water. it may exceed 90 percent of the total produced volume. helps conThis trol subsurface pressures. They must be managed as part of the content of the waste drilling mud. Produced water may also contain trace quantities of petroleum hydrocarbons and naturally occurring metals. livestock or wildlife watering. the ratio of produced water to oil or gas increases over time. Thispractice is regulated under the Class II injection well program of the UIC regulations as authorized by the Safe Drinking water Act. c. and local. Most produced water is managed in this manner. example. corrosion inhibitors. The following practices may be used for managing produced water depending on its constituents. reverse emulsion breakers. cleaners. emulsion breakers. It is governed by the NPDES program of the Clean Water Act and/or individual state programs. Discharge to land. paraffin control agents. often bentonite clays. horizontal wells). the presence of usable groundwater or surface waters.000ppm. Lime and caustic soda increase alkalinity. c. and the length of time the field has been producing. and produced waters destined for disposal are defined by the EPA as an exempt waste. As described inSection 4. Most produced water is highly saline. which can be made with fresh saline water and are used for most types of drilling. Synthetic muds. lignitic material. Other COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . For These basic components perform various functions. Options include combinations of gravity and/or mechanicalseparation and chemical treatment.API/PETRO ES-ENGL L977 0732270 05b4713 b 5 b m WASTE MANAGEMENT EXPLORATION PRODUCTION OPERATIONS IN AND 39 6. d. Minimizing the volume and toxicity of the treatment chemicals that may end up in the produced water. Oil-based muds. starches. Using downhole fluid separation techniques or water shut-off (blocking) techniques. or when it is necessary to protect against severe drill string corrosion.1 General The largest volume of drilling-related wastes is used drilling fluids or muds. Probably the most common form of recycling for produced water is injection for enhanced recovery. c. Source reduction options include the following: a. b. which can be used when water-sensitive formations are drilled. Treatment options for produced water will vary by location and the ultimate disposition. Composition of modern drilling fluids can be quite complex and varies widely. oil.STD. high temperatures are encountered. such as barite. Water-based muds. Discharge tosurface water is allowed in certain circumstances. These are further discussed in Section 3. b. state. b. not onlyacross geographical areas but also by depth of the well.3. produced water injected enfor hanced recovery is not a waste. Underground injection. This option is rarely used onshore. clays increase viscosity and barium sulfate (barite) acts as a weighting agent to increase mud density. and scale inhibitors.000 ppm TDS. 6.2 PRODUCED WATER The primary environmental issue in managing produced water is the potential contamination of soil and sourcesof for usable water. Generally. the nature of the formation being produced. Muds fall into three general categories: or a.which may be usedas substitutes for the above muds or in other specialty situations. EPA considers used drilling muds to be RCRA-exempt waste. Discharge to water. or varying combinations. This option is rarely used. Drilling and completing wells to minimize water production (for example. 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. Inert solids-the density-building part of the system. dispersants. 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. synthetic materials. to Seawater by contrast is typically about 35. The quantity of water produced depends on the recovery method. geography. physical. Reperforating wells to minimize water production. They are produced from geologic formations encountered during the drilling process. However. The total dissolvedsolids (TDS) in produced water ranges from several hundred parts per million over 150. such as crop irrigation. and various other chemicals. It can also contain traceamounts of additives necessaryfor the production process. Additional conditioning materials may include polymers. 6 3 DRILLING WASTES . These includecoagulants. Drilling muds contain four essential parts: a. The use of percolation or evaporation is allowed in areas where freshwater is not present or is located suchthat contamination from produced waterscannot occur. All discharges must comply with these regulatory provisions. Cuttings consist of inert rock fragments and other solid materials. Other additives to control the chemical. Underground injection is a universally acceptable practice that returns produced waters to subsurface reservoirs that are isolated from Underground Sources of Drinking Water (USDWs). Active solids-the viscosity-building part of the system. and groundwater recharging. and biological properties of the mud. c.

empt wastes suchas drilling muds andcuttings. paint. empty cement.or saltwater-based muds. the mud system will increase the likelihood that onsite clog. Returning unused chemicals. At lected. Exceptions may be made in certain geographic areas. ple. pipedope. are soluble in freshwater b. Fuel oil storage tanks should be diked to prevent spills COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . drilling mud and other product sacks. used oils from engines. 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. guidelines: General good housekeeping practices (for example. and solvents) should not be placed in reserve pits. special drilling fluids such as oilis the volume of mud requiring disposal minimized.3. rigwash. spill and leak prevention) can prevent andor reduce the volume and toxicity of the waste generated. of drilling wastes. Time limits for storage spent completion fluids. additives. This practice will the mud system and washwater) and excess chemicals and also increase the number of management optionsavailable. drilling mud mixed with slag can be used as a substitute for cement. Collecting blow-out preventer test fluids to prevent Drill cuttings are also considered RCRA-exempt waste. The sumppit should be and so forth. Reducing theamount of excess fluids ind. ground contamination and returning them to the system if Efforts should be madeto reduce the volume and toxicity uncontaminated. Liners may be re6. a minimum. be depending on location andquality of groundwater. 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. Volume reduction options includethe following: a. Fluids accumulated in the sump or operation of drilling equipment. Nonexempt and 6. drainage directly to the reserve pit unfeasible). 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. Storm water fromoutside the drilling pad area should be directed away from the operational area. Wastes stored in reserve pits should be restricted to exthem in labeled. areas. leaks. to protect groundwater from contaminaThese wastes should be managed using the following tion due to oil. b. volume of cuttings generated. to be exempt wastes. these waters should drained to the reserve pit. lined. Using bulk and/or recyclable packagingkontainers. With this practice.3. materials. except in upset or emergency conditions. additives. such as sodium chloride. to service companies for reuse. In certain instances. Drilling personnel should gather these wastes and store a. Using closed systemsin certain environmentally sensitive and must be considered during disposal of drilling muds and cuttings. if necessary. may apply. Their introduc. elimination of hexavalent chrome and replacement of f. serve pits above ground level (thereby making location and empty paint. water additions to sure and disposal techniques can be used. a small sump EPA does not consider waste necessary for maintenance pit should be constructed. Segregation of waste streams is anotherimportant method of reducing the volume of waste generated. and muds to the formaldehyde with less toxic compounds) when preparing vendor or supplier. such asused oils. used oil filWhere it is necessary or more appropriate to construct reters. leak-proof containers in accordance with ap. c.3 Drilling Rig Waste quired to prevent hydrocarbon and contaminationof soil salt Wastes generated from drilling rig operations include and groundwater.STD-APIIPETRO ES-ENGL L997 m 0732290 O 5 b 4 7 L 4 572 m ' 40 API E5 a. paint. Substituting less toxic products and additives (for exame. or drainage of oily fluids. Using alternative mud types (for example. 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. Exempt and nonexempt materials should be segregated. or other product containers. Hydrocarbons and produced water encountered during Where practical and appropriate. Temporary production equipment should be provided onso Drilling operations should be designed that lubricating site to process these test fluids.2ReservePitWastes potentially hazardous wastes (suchas. pit should be removed periodically. spent hydraulic fluids. not only Whenever practical. and plicable state and federal regulations. Minimizing water usage (for example. lube oils. hauled offsite to a disposal facility.Reserve pit wastes should be collected and stored for proper disposal using the following general guidelines: tion in reserve pits is illegal. Optimizing solids control equipment. Any lubricants and product spills that do reach the reserve as pit should be removed soon as possible. Pumps and power generation equipment should have containment to collect spills.

and paint) to be RCRA-exempt wastes. keeping containers closed to prevent evaporation. and so forth) is strategically located onthe drilling location so that large volume spills. When burning for energy recovery. 2. testing. b. returned to the vendor. Training operators to minimize unacceptable quality and paint waste by reducing overspray. Using water-based or high-solids coatings whenever possible.or treated as a waste and managed according to regulatory reauirements. Catch basins should be provided in loading areas so that hydrocarbon spills and leaks can be properly managed. and any other chemicals or materials in their entirety. Paint wastes can be reducedin volume and toxicityby the following: l. operators should ensure that well treatment equipment (pump trucks. surfactants to break downhole emulsions. Where practical. 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. Permits are required to drill groundwater wells in some areas. Using cleaning solvents as thinners when too contaminated for use as a cleaner. they should be triple rinsed. and stimulation fluids. 3. Low-flow and low-water-use toilets. h. Painting less frequently. d.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. Excess quantities should remain with the rig for successive operations or be returned to the vendor. Increasing the time betweenfilter changes based on pressure drop. Examples include acids to dissolve scale and increase permeability.4. .4 WORKOVER AND COMPLETION WASTES RCRA-exempt workover and completion wastes include well completion. paraffin solvents and dispersants to control formation of downhole paraffin. using all of the paint mixed. inert materials originating from downhole. and cement cuttings. showers. and discharges may be directed to the reserve pit in emergencies. Chemical storage areas should be surrounded with containment devices to prevent migration of spills or leaks offsite. Drum rinsate that cannot be used originally intended or as unidentified residual chemicals should be considered a nonexempt waste. 2. packaged wastewater treatment units. and minimizing solvent usage. or hauling to a permitted sewage facility. 6 . 3. Unused chemicals should be used at the next drilling site. and pieces of downhole equipment such as sealing elements and pumping equipment. and recycled for scrap metal or sent to a permitted solid waste disposal facility. less volatile paints and solvents. Empty buckets can be sent to a metal reclaimer or disposed of in a permitted landfill. The volume of filters (for example. garbage. Purchasing less toxic. the waste can also be recycled by burning for energy recovery (for example. or disposed of properly. Using brushes instead of spraying for smaller jobs. well treatment waste liquids should be segregated and separately contained for reuse at another well. or portable commercial containers. Workover operations should be designed to ensure that the fluids and additives are completely spent when used. Optimizing operation of equipment to minimize degradation and contamination of fluids. such as produced sand. returned to the vendor. EPA does not consider materials necessary to maintain or operate the workover rig (such as used oils. frac tanks. Otherwise. Testing should be performed if necessary to determine the characteristics of the waste. paint. c. and faucets can be used to minimize the volume of water to be treated. biocides. Ensuring that paint containers are emptied and dried prior to disposal. and propant media used in fracturing operations. and so forth rather than replacement on a routine basis.or saltwaterbased fluids with additives for special purposes. ensuring that proper volumes are mixed. Sanitary wastewater and sewage should be collected and treated prior to dischargeor disposal to satisfy state and local effluent requirements. e. formation and pipe scale. Storm events should be considered. j. Efforts should be made to use pipe dope. Injection may also be a disposal alternative.9. Rig equipment wastessuch as used lubricationoils should be segregated from materialgoing into reserve pits and recycled or disposed of at a permitted offsite facility. crushed. Using permanent filters that can be cleaned and reused. leaks. The filters should be recycled and managed as discussed later under 6. Y Y < > COPYRIGHT American Petroleum Institute Licensed by Information Handling Services + and leaks from beingdischarged offsite. g. Workover fluids are primarily freshwater. 7. 5. f. Options include using septic systems. . treatment. If the drums cannot be returned to the vendor or a drum reclaimer and theycontain a hazardous or suspected hazardous material. the waste stream is a substitute product for virgin fuels. and the material should be handled accordingly. i. oil and fuel) generated can be reduced by: l . Domestic solid waste such as paper. and cans should be managed in accordance with state solid waste regulations and should be recycled where practicable. Paint and solvent waste that is generated should be recycled onsite or offsite via distillation to reclaim the solvent. hydraulic fluids. Bulk containers should be substituted for drums and other containers when practical. Hiring commercial household waste disposal companies for solid waste should be considered. cement kiln or other industrial boiler or furnace). If this recycling option is not available.

and contractual provisions to limit potential liabilities of offsite commercial reclamation and disposal of a reclaimer’s waste. Waste fluids generated duringthese operations should be collected in lined pits or tanks. sand. On the other hand. The well surface location of all miscellaneous wastes should be cleaned at the end of the workover or completion operation. These facilities include production separators. 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. and density. c. a. streams. Exempt and nonexempt wastes should be segregated. For example.AND PRODUCED b. General good housekeeping practices can prevent and/or reduce the volume and toxicity of the waste generated. source ofsilica) in 6. cement cuttings. these wastes should be stored with paraffins. metals content.equipment. and emulsions. g. lease obligations and regulations. unusual or special completion fluids such as hydrocarbon-based materials or saturated brines should be handled in closed systemsand recycled for future use. Some states solids. Workover or completion fluids shouldbe segregated from unused commercial productsor contaminated additives that would be considered nonexempt if disposed. Exempt solid waste such as produced sand. The followingare other considerations: a. consistent with wastes. gathering lines. c. Heavy hymaterials thatcollect in the bottom of treating and storage fadrocarbon materials are a primary constituent of road oil or cilities. treatment. parable to those for commercial road oil or mix. The improvementof downhole solids control techniques to reduce the volume of solids produced.oilysludgescould be usedasan Table 2 should be consulted for identification of other alternative fuel source for cement kilns. a number of offsite recycling. and to document these acand heavy hydrocarbons should be to maximize hydrocarbon tivities by retaining records. waste management options. lined pits. b. c. these materials may used as a subbe Bottoms are basic sediment and water (BS&W) and other stitute for commercial road surfacing materials.In the same category as tank require permitsfor roadspreading. These materials are similar but shouldbe tested for treating vessels. or COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . practices.42 API E5 Waste handling considerations include the following: a. unless soil or usable groundwater environments will not be adversely impactedby them. The main goal in managing tank bottoms. d. Whenever practical. d. The addition of heat in combination with centrifuging and/or filtration to separate crude from BS&W. while other states prohibit bottoms are pit sludges. The addition of heat and/or demulsifiers separate emulto sions into produced water and saleable crude. roadspreading SOLIDS should be investigated. paraffin.5 TANKBOTTOMS. e. recovery. Before roadspreading. HYDROCARBONS. Operators should consider site selection. 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. The prohibition of oxygen from thesystem to prevent the formation of iron oxides. f. The surveying of the process to identify sources of solids and emulsions and then attempting to correct any problems.EMULSIONS. For materials that cannot be reclaimed. Offsite reclaimers range from companiesthat only collect tank bottoms until they have sufficient volumes to sell ato refinery to those that operate small refineries. Whenever practical. The addition of heat to liquefy heavy hydrocarbons and d. They should be comfound in bottoms include accumulated heavy hydrocarbons. Before disposal. is prudent for operators to notify it EPA considersthesematerialsto be RCRA-exempt state and local agencies and the landowner. Materials flash point. formation and pipe scale. f. emulsions. or disposal options are available. allowing their recombination with crude oil sales proper containment (for example. and pigging wastes from this practice. and production impoundments. e. fluid mix. waste fluids should transported by be flowline or truck to the operator’s production facilities for reprocessing with production streams. b. g. in tanks. For those heavy hydrocarbons that cannot be managed onsite. substituting for virgin fuel) is another option that shouldbe considered. or piping to prevent or reduce the creation emulsion problems and keep of to solids in suspension. Recycling by burningfor energy recovery (that is. The modification of process. 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.HEAVY the manufacture of cement. Reclamation should be investigated first. produced solids with little or no oil contamination may be used as asubstitute raw material (that is.

and sur6. Solvents that are nonhazardous (for example. appropriate measures to stop and contain the spill or leak should be taken. 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. and so forth). high-level alarms. Installing mechanical solids removal systems (for example. and of general good housekeeping. Using EPA's logic. operational factors. and other environmental conditions.3 Solvents Solvent usage shouldbe eliminated or minimized to the extent possible.5 and applicable regulations and lease restrictions. This may include regeneration. and produced water. When spills or leaks do occur. Soil must be managed under RCRA Subtitle C rules if it is contaminated with a listed chemicalor tests tobe a characteristic hazardous waste. drip pans. disposal. which may containPCBs. State. A potential exception to these practices is electrical oil contained in large electrical switches.7 USED OILS AND SOLVENTS face water. 6. c. Current EPA regulations allow used oil to be recycled into the crude stream. The practice chosen should be dictated by the extent of contamination. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . prevention of the contamination is especially important. The most environmentally soundpractice for feasible. double-walled tanks and containers.and produced-water-contaminated soils are also RCRA-exempt. 6. petroleum-based solvents should be recycled onsite (for example.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. d. however. 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). Following a regular inspection and maintenance program to minimize leaks. Optimizing the operation of equipment to minimize degradation and contamination of the oil.2 Used Oil Disposal of soil that becomes contaminated with commercial chemical productsmay be subject to RCRA hazardous waste regulation andCERCLA reporting requirements. and transformers. instead of by a routine maintenance schedule. transportation. nonflammable solvents) or less toxic should be purchased to increasemanagementoptions. Mixture with other soils.for groundwater contamination. Proper maintenance and inspection of equipment and piping can prevent the leaks and spills from occurring. sulfur. Impervious secondary containment (for example. b. and gas plant tics. groundwater. replacement equipment or piping. This should be done only when reservoir characterisand lubricating production. As discussed in Section 4.1 General e. If possible. b. local. or magnets) directly on equipmenuengines to extend the oil life. recycled into crude oil.7. Disking to promote biodegradation. and regulations make this alternative equipment. In the collection process. the following source reduction options should also be considered: a. reuse. Other onsite treatment. Other acceptable management practices are recycling or disposal of used oils and solvents at an offsite commercial facility. managing these wastes isrecycling. Irrigation to leach salts. and leak detection equipment are also used to prevent or minimize contamination. permanent filters. API believes sulfur. Segregated solvents may also be sent to acommercial recycling or disposal facility that is permitted to accept these materials. that some may be considered hazardous. centrifuges. and/or landowner approval may be required to initiating treatprior ment or disposal. d. whether exempt or nonexempt. Soil that must be removed from a site should be taken to a nonhazardous waste disposal facility. drilling.6 CONTAMINATED SOIL 6. liners. EPA lists hydrocarbon-bearing soil as a RCRA-exempt waste. capacitors. TSCA specifies storage. For contaminated soil. Extending the life of the lubricating oil by changing the oil only when dictated by testing. 6. potential. or burning for energy recovery in lieuof virgin fuels.7. regenerated. Landspreading or roadspreadingmay be feasible if conducted according to Section 5. every effort should be made to remove free hydrocarbons for recycling. one should be aware. This can include cathodic protection. Exempt or nonhazardous-material contaminatedsoil that be must be reclaimedto allow revegetation may managed by any combination of the following procedures: a.7. workover. However. c. and recordkeeping f requirements for PCB-containing oils (see 40 Code o Federal Regulations Part 761). or used for paraffin dissolving or cutting).

buried onsite as detailed in 5. It should be noted that some states have recently banned used oilfilters from municipallandfills. or evaporation pits. temperature. corrosion inhibitors. lar sieve may beextended by installing activated carbon upstream to remove potential contaminants (for example. sand. the waste iron sponge is removed and kept wet to avoid spontaneous combustion. After the iron is consumed. Contamination of filter media with hazardous substances may lead to CERCLAexposure. Water from the dehydration process should be released as water vapor or.5. mayburned for energy reair covery or incinerated with state control agency approval.9. EPA lists dehydration and sweetening wastes generated in gas plants as exempt. sulfinol.NPDES discharge. b. the filters may be sent to municipalor commercial landfills.2 Liquids Liquids from backwashing filter media normally consist of fresh or produced water.8. and produced solids. Iron sponge consists of iron-impregnated wood chips. landspread. Returning sweetening wastes to the original product vendor or a reclaimerfor commercial regeneration a feasible offsite is alternative.1 General As described in Section 4.3 Filter Media and Filters Solid filter media such as gravel. c. 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. These react with hydrogensulfide in the sweetening process to form iron sulfide. slurries of sulfur and sodium salts may be landspread accordance in with 5. 6. State regulations on managementof spent iron sponge should be consulted prior to choosing an option. 6. Where there is no market or capability to recycle these liquids (suchas with spent caustic). heavy hydrocarbons. Spent molecular sieve and solid desiccants may be usedas fill material as a substitute for virgin commercial materials. Although typically regenerated onsite. coal. nonhazardous disposal facility. and diatomaceous earth should be treated as previously described for tank bottoms. after being drained to remove free liquids. Hydrocarbon contamination of these waters may preclude some of these disposal or discharge options. If they cannot be managed onsite. cartridge.2 Liquid Wastes Liquid dehydration and sweetening wastesmay include glycol. These solutions may be contaminated with light hydrocarbons and salts. API believes these same wastes are exempt when generated at field facilities.5. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . emulsions. While incineration of spent iron sponge is possible. filter media. Usually. as Oily wastes such hay andsorbents used in water treatment be and produced fluid spill cleanup.9OILYDEBRISANDFILTERMEDIA 6.4. spent iron sponge. sometimes containing asurfactant to aid in oil removal. Burial mustbe consistent with lease provisions and applicable regulations or it must be taken to an offsite.44 API E5 6.9.or sent to offsite disposal facilities after being drained of all liquids. The iron sponge is then allowed toundergo oxidation prior to burial onsite. amines. and forth) the dehydration and io sweetening units to minimize waste and emissions. or taken to offsite disposal sites as describedin 6.2 or disposed of offsite at a nonhazardous waste facility. Liquids should be captured and returned to treatment facilities for recycling and treatment. Any recoveredliquids should be returnedto the treatment facilities for reprocessing and recycling. buried.8. and backwash (assuming the filter itself is not hazardous and theresidue in it is from an exempt waste stream).9. 6. Free hydrocarbons shouldbe removed for recycling and the resulting solids roadspread.8. caustic. 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. 6. and glycols). or other process solutions.3 Solid Wastes Solid wastes generated from dehydration sweetening and processes consist of filter media. spent molecular sieve. it condenses. it is seldom done. Spent sock. andor slumesof sulfur and sodium salts.8DEHYDRATIONANDSWEETENINGWASTE 6. amine. since iron sponge is generated infrequently and in small quantities sites where commercial incineration faat cilities are generally unavailable. a. disposed of via Class II if injection wells. The first preference is to recycle onsite if practical. the life of molecu- 6. 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 important to properly maintain and operate (for example. flow rate.1 General EPA lists the following oily debris and filter media waste as RCRA exempt: spent filters.5.

The production of deionized water generates two waste streams: excess deionized water and blowdown from the deionization process. scale-producing waters by using and scale inhibitors. 6. Lubrication oils. used oils and solvents (6. or evaporation pits. Generated wastes include the following: a. b. Alternatively. which should be recycled and managed according to 6. injection for enhanced recovery or disposal). 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. Hydrocarbons should be managed according to 6. Cooling tower and boiler blowdown water.E N G L 2777 m 0732270 05b11717 07q WASTE MANAGEMENT EXPLORATION PRODUCTION OPERATIONS IN AND 45 6. which should be disposed of in Class II injection wells (for example. As discussed in Section 4. (See Section for additionaldetails re4 garding TEOR steam generators and their associated air pollution and watersoftening equipment. 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. and run-off are typically collected via a series of sumps into a central clarifier/classifier pit. Scale formation can be prevented or minimized by not mixing incompatible.10 PLANT GAS PROCESS SULFUR AND RECOVERY WASTE Gas plants and production operations produce many of the same wastes.5. It should be noted that. disposing of them onsite via landfill burial consistent with or regulations and landowner obligations. which is disposed viaClass II injection wells or NPDES discharge. as and oilydebris should be drained necessary. if onsite disposal is precluded by lease or other restrictions. This softening pro- 6. d. calcium carbonate. enhanced recovery ordisposal). or other inert materials. catalyst. Sulfur dioxide concentrations in stack must be gases removed to reduce emissions in some areas of the country. c.20). Whatever disposal method is used. (b) placed into evaporation pits. Other RCRA-exempt solid wastes such filters.8). 6. Production scale (that is. For similar wastes refer to the sections on dehydration and sweetening (6. These pits separate the hydrocarbons fromproduced water. it should be disposed of in a Class II injection well. it must be done in compliance with state and federal regulations and to protect sources of drinking water.4(b)(4)]. piping. Spent or degraded absorption oil. from process equipment) should be checked for the presence of NORM (see 6. Scale formedin production equipment on the nonprocess side.emulsions. the waste should be sent to offsite landfills. heavy hydrocarbons. cooling waters. If no other outlet is available. NPDES discharge. AND STEAM GENERATOR WASTES Water used in boilers and cooling towers eventually becomes contaminated with salts and must be supplemented over time. I I cess also generates wastewater.12DOWNHOLEANDEQUIPMENTSCALE During the production process.S T D * A P I / P E T R O E S . and so forth to be nonexempt. Sumps and clarifier/classifier systems should be used wherever justified to minimize disposal of reclaimable hydrocarbons. scales may form within wellbores and production equipment dueto temperature and pressure changes. iron sulfide. b. which should be recombined with produced waters (for example. deionized water is used to reducenitrogen dioxide in stack emissions.7). (c) dischargedunder a state and/or federal NPDES Permit. Certain catalysts may be recycled to reclaim precious metalsor may be used as a raw material inthe manufacture of cement. and produced solids (6.13 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 . as described in Section 4. returning fluif ids to a sump or clarifier/classifier pit and recycling solids. Last. In addition. should be considered nonexempt waste. 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 . or heat exchangers containing wellbore fluids are the result of primary field operations and are exempt waste. a.) 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. c. Wastewaters. Sumps and clarifier/classifier pits are process vessels and should always be maintained in leak-free condition. which should be reclaimed where possible by sending it to a reclaimer or returning it to the vendor. in cogeneration TEOR steamgenerators.scales that are formed on the process side within segments of tubing. nonhazardous lubricating oils. These waters are blown down or bled off fordisposal.7. refractory bricks.5). SCRUBBER LIQUIDS. RCRA-exempt liquid wastes should be collected in plant sump systemswhere washwaters.11COOLINGTOWERBLOWDOWN. or sending them offsite to municipal or commercial landfills. EPA considers wastes generated from the operation and maintenance of facilities such as cleaning compounds. such as in boilers. Scale usually consists of barium sulfate.BOILER WATER. and tank bottoms.

electrical switches. and cleanup procedures. to vendors for exchange. even if recycled. 6. Generators of lead-acid batteries are specifically exempt from RCRA hazardous waste generation regulations. state. all sources of asbestos within a given facility. 6. equipment washing.16. If it is impossible to prevent theasbestos from becoming c. 6. These batteries should be substituted with recyclable batteries. c. Capacitors.17 PCB TRANSFORMEROIL PCB fluids are regulated under the Toxic Substances Control Act in 40 Code of Federal Regulations Part 761. and other equipment confriable. Asbestos is a hazard when it becomes friable. Spent nickel-cadmium batteries. Materials containing than 50 ppm PCBs are excluded less from the TSCA regulations if the following conditions are 6. proper management of storm and water run-onare important to minimize contamination. d.processed. Efvice unless leaking.1 General distributed in commerce or used before October 1. They may also be sold to other companies or industries with appropriate applications. These batteries may be hazardous and must be disposed properly accordingto apof plicable regulations. and agricultural purposes). c. b.14UNUSEDTREATMENTCHEMICALS Efforts should be made to plan an operation in a way that minimizes the volume of unused chemicals. These regulations apply tothe use. Use of waste oil with any detectable concentration of should be used at an operation where theyare needed.18NON-PCBTRANSFORMER OIL can also apply. chased whenever feasible.16. an individual trained and certified in both removal taining PCBs wouldsimilarly be subject to the above TSCA and disposal techniques should remove it. if feasible. Therefore. Used COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . these waters should be collected for or use reuse (for example. makeupwater for drilling or completion operations.Covering the facilities or potential sources of contamination is another minimizationoption. Since storm water canbecome contaminated upon contact with leaks and spills. it should be kept coveredor sealed so cleanup standards and shouldbe reported to federal. forts should be made to identify and label. storage. or used at another suitable site.16. b. b. batteries should be stored in a manner that prevents any spillage of electrolyte. Batteries that are no longer needed. facility. More specific state regulations 6.3 Nonrecyclable Used alkalis and lithium batteries are examples of batteries that are typically not recycled. requirements. or 6. Equipment should be properly maintained 6. spillfleak prevention. Waste oils containing PCBs in quantities of 50 ppm or regulations. runoff fromareas not impacted by the operation). a. The system should be tested to ensure that the chemical treatment is needed and is working. orto a State and local agencies should be contacted regarding reclaimer for recycling. 1984. that it doesnot become awaste or a hazard). Spills of PCB-containing oils are subject to specific become friable(that is. stored. cleanup standards. 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. greater must be disposed at a TSCA-permitted disposal a. per OSHA a. Where feasible. good housekeeping practices. most PCB-containing equipmentcan remain in serducted to minimize exposure to personnel and the public. a. 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. provided the batteries are recycled.15 ASBESTOS and operated to prevent leaks. containment. but itsdisposal is subject to TSCA requirements. 6. efforts should be made to ensure that the asbestos does not b. a. and used batteries should be returned tothe manufacturer. Depending on the level of Any activity involving asbestos materials must be conPCBs. servicing.~~~~~~ ~ 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. Asbestos is not a hazardous waste.2 Recyclable Both lead-acid and nickel-cadmium batteries are examples of used batteries that are hazardous and can be recycled. and local agencies. Unused treatment chemicals should be returned to the supplier. disposal and recordkeeping for PCBs and items containing 50 ppm or more of PCBs. are still subject to hazardouswaste regulations.16 USED BATTERIES met: (a) The PCBs were legally manufactured. but are not spent.

the hydrocarbons should be sent to waste oil collection and reclamation facilities. lubricating oils. It is also recommended that operators maintain records of types. water is removed for disposal in Class II injection wells (for example. transportation. well lease as as or landowner agreements. when drums are required. Hydrocarbons are recycled by returning them to sales streams. saltwater disposal/injection wells and associated equipment. c. Therefore. some sensitive. every of attempt shouldbe made to minimize the amount residual material remaining in a drum. an appropriate material) before sending a to waste metal/plastic recycler or disposal site. destinations. 6. The drums should be well rinsed and washed (that with is. Recycling of used oil with any quantifiable level (that is. a. It is recommended that operators consult applicable state and regulatory local agencies. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . followed by recycling at a drum reconditioner or as scrap metal. while oilfield sludges ranges from backgroundlevels to several hundred picocuries/gram. or c. As of the publication date of this document.20(e). 6. which may inf clude recycling into the crude oil (with refinery approval). no federal regulations directly apply to thedisposal of oilfield NORM. handling. are adopted. C. Reducing the amount of waste generated by such operations. In other words. b. Other solid wastes.e. and disposal. or dust control agent is prohibited. depending the location. and pipe cleaning and other associated operations. Some states (i. and Louisiana) have developed regulations for NORM disposal.. These include the following: a. This is primarily a state issue. There. A P I / P E T R O. Refer to the Environmental Guidelinesfor Worldwide Geophysical Operations by the International Association of Geophysical Contractorsfor more complete detail. The NORM activity level in pipe scale can range from backgroundlevels NORM activity in to thousands of picocuries/gram. NPDES discharge. Return of the drum to the originalsupplier is the preferred management option. and so forth are typically collected via a series of sumps.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. steps should be taken to minimize the direct and indirect impact of exploration operations on these areas. cooling waters. Remote sensing and aerial geomagnetic surveys can provide useful subsurface information for the interpretation of geologic structures without disturbing or harming the environment. Rinsate materials should be usedas originally intended in the process or properly handled and disposed of. and haulers of NORM wastes. Conon sult API Bulletin E2. or evaporation pits. 6. should be recycled disposed as described earlier in this section and in Section 5 . and others are prohibiting disposal until regulations 6. and saltwater leaks. Texas. NORM as may be found in downhole tubing. Used oil with less than 2 ppm PCBs should be recycled into the crude oil-also with refinery approval.20 NATURALLYOCCURRINGRADIOACTIVE MATERIAL Naturally occurring radioactive material (NORM) may be present in oil and gas operations at some locations. Recycling those wastes that are generated.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. Such nonintrusive methods shouldalways be considered when designing an exploration program to minimize the environmental impact and amount of waste generated by exploration activities. Properly handling and disposing the waste once the opof erations have been completed. In production facilities.S T D . c. b. 2 ppm or greater) of PCBs must be in accordance with 40 Code o Federal Regulations Part 761.However. some states are currently developing regulations.19 EMPTY OIL AND CHEMICAL DRUMS Where practical. bulk containers that are reusable should be used in order to prevent unnecessary generation of empty drums. volumes. including filters. Fluids are usually collected from the sumps into a central oiYwater separator. analytical data.If sales streams are not available. b. enhancedrecovery or disposal). tank cleaning. New Mexico. Such methodsare particularly appropriate over national parks and other protected areas where surface access may be restricted. as well in aboveground processing equipment. coating. b. storage. Bulletin on Management of Nuturally Occurring Radioactive Materials (NORM)in Oil & Gas Production for more detailed guidance on NORM and its prevention.22RECOMPRESSIONANDFACILITYUTILITY WASTES Liquid wastes should be disposed of via thefacility sump system where washwaters. soils contaminated as a result of well workovers. Attempts include the following: a. water-handling equipment exhibits the greatest NORM activity levels. this oil cannot be applied to the land.

Select Preferred Waste Management Practices 9. area-specific waste managementplanshaveworked for many API member companies. NPDES.API/PETRO ES-ENGL L777 W 0732270 05b11722 bb7 M Appendix A-Guidelines For Developing Area-Specific Waste Management Plans A. the particular laws and regulations can that apply to each can be reviewed. reclaim. Steps 3 & 4. 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. 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.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. Obtain Management Approval 2. state. Plan Waste Minimization Practices 7. Define Plan’s Area 3. CERCLA.Review and Update Plan Note: E&P exemption appliesonly to RCRA Subtitle C. List and Evaluate Waste Management and Disposal Options 8. (See Table A. engineering limitations.1 for the Ten-Step Plan for Preparing a Waste Management Plan and the summary in Section 2. (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.) The following sections outline this approach. It could even become a state plan for the specific area. andlocal laws and regulations Evaluate landownerflease agreement restrictions Define operating conditions and requirements Exempt Nonexempt hazardous Nonexempt nonhazardous Volume reductiodminimization analysis Toxicity reduction Recycle.) Table A-1-Ten-Step Plan for Preparing a Waste Management Plan ~ Stet. and so forth. Prepare andImplement Plan IO. Perform Regulatory Analysis 5 . Identify Wastes 4. 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. Many of these steps be done concurrently (for example.2 ~~ While many processes canaid in shaping waste management decisions into action steps.l INTRODUCTION A. Steps 6 & 7).STD.Exempt wastes are subject to RCRA Subtitle D and may be subject to UIC. 49 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . operating feasibility.

c. Example: Field Production: Produced water[ 10. Example: Company X is committed to running its operations in an environmentally sound manner. produced water. b. state. drilling. if any. the area-specific waste management plan can be used for the following purposes: a. and objectives. b. Small operations may prefer beto gin witha larger area such a state or a district withina state. an E&P facility or company should use the ten generalsteps outlined below. Area Definition Describe the area for the plan: a. the area of coverage is generally within onestate and. percent oil and/or saltwater content. To develop it. new waste management practices or options should be evaluated whenever they become available and the plan should be revised. d.since regulations and/or the environmentvary from one location to another. and (b) the E&P activities to be controlled by the waste management plan. and scheduling should be resolved so that management can support the timing and scope of the project. and approximate volume). even within one county/parish. in some cases. management approval and issues involving key personnel. For example. other resources. ManagementApproval Obtain management approvaland support: a. In any case. The key to defining an area is consistency in both regulatory and environmental issues.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 . with a brief description of each. Waste Identification Identify each waste generated: a. 19XX. drilling etc. ora lease). source(s). b.a unit. completion/workover. Step 4. The waste management plan is area-specific. b.and gas plants). Later. and measurable objectives should be established. and local laws and regulations to determine the types of wastes (for example. subject to periodic review and revision. Complete abrief description for each waste(for example. Ensuring ongoing regulatory compliance and continued protection of the environment. which should be written from the field perspective. waste minimization/pollutionprevention). as appropriate. The waste management plan should be evergreen docan ument. 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. The overall project goal should be set. Evaluating and monitoring waste management practices. landowner restrictions and/or preferred waste management practices are specified that may re- COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . goals. The company intends to have waste managementplans developedfor each of the areas in which it operates by January 1. an oil field.STD=API/PETRO ES-ENGL 50 API E5 The plan. output: Description of (a) the area. The following sections provide more detailed information on each step of the process. a mission statement should develbe oped for the Waste Management Plan. Review applicable federal. as Complete regulatory analysis: a. If the company does not have an environmental mission statement. Conducting ongoingtraining of field personnel. b. On execution. output: List of wastes. individual waste management plansare not necessarily transferable. Step 3. Example: The plan is developed for the Sable Fieldin West Texas. To develop an area-specific waste management plan. Minimizing the volume and toxicity of waste produced (that is. Note: Although many types of E&P wastes are similar. For aplan with a restricted focus. a relatively small area is recommended for the initial waste management plan (for example.)which mud. one should be considered. Since application of regulations must be consistent within a given waste management plan. review lease provisions to determine what. production. Therefore. The acceptable waste management practices for each type of waste should be defined through this evaluation process. for waste management and disposal requirements are clearly defined. defines specific guidance for handling eachwaste generated in the area. Field personnel should identify all wastes generated within the area defined for each E&P activity (that is. RegulatoryAnalysis Step 2. output: Waste Management Plan mission statement.

For nonexempt wastes. regulated under TSCA. economics. Discharge injection.S T D . etc. as appropriate. Step 5. Example: Reduce the volumeof contaminated soil by increasing the use and maintenance of drip pans under the valves that could leak oil. e. Implement practices. burial onsite. environmental considerations. conditions. rec. WasteMinimization Review the waste generating processes and implement procedures to reduce waste generation: a. b. it is important to understand how and why each waste is generated. This analysis will identify the waste types that are not adequately addressed in the regulations and for which additional guidance is required. After reviewing the waste generating processes and taking advantageof source reduction opportunities. h. and requirements. output: Categorized list of wastes with waste classification identified. Implement any waste reduction practices identified and vise the waste management plan accordingly. c. Example: Step 6. engineering limitations.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. output: List and evaluation of environmentally acceptable waste management practice options for review by field personnel and management. injection. c. Determine each option’s acceptabilityfor that area’s environment. Determine if each waste is classified as exempt or nonexempt under RCRA or regulated as a special waste under some other authorization (for example. msk Low chloride drilling fluid Completiordworkover Pit waste Cooling tower blowdown PracticelReauirementS Landfarming. list potential waste management options for each waste. recycling andreclaiming. Identify potential opportunities to reduce or eliminate waste volumes through volume or toxicity reduction. identified as NORM. The list of acceptable waste management practice options and desirability of each should be reviewed by appropriate operations personnel and management. WasteClassification Categorize each identified waste: a. In order to find source reduction alternatives. When a potential waste minimization practice arises. etc. c. d. Review the waste generating processes and options. Identify any waste types for which the regulations do not adequately define management requirements. output: List of wastes andtheir operating stipulations. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . andor treatment. perform a pilot test and evaluate. list the management and disposal options potentially available (see Section 6 ) . List and Evaluate Waste Management and Disposal Options a. etc. etc. and potential long term liability. Priority should be placed on reducing those waste streams that maypose the highest potential risk.determine if each is nonhazardous or hazardous. operating feasibility. This evaluation should target only the options available and under consideration. Evaluation should include regulatory restrictions.). Output: Testing and evaluation of any potential waste minimization practices. 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. You may have to test periodically if the waste composition varies. For each waste with more than one waste management practice allowed by law or regulation. location. Burial onsite after waste de-watered. b. Substitute a chemical product with lower environmental risk constituents to eliminate a waste that requires special handling.

select the best practice for that operation and location. Pros: Most cost effective Cons: Landowner concerns b. Review and Update Waste Management Plan Define a review and update procedure for each waste management plan. Pros: Flexibility in selecting disposal location Cons: Future liability potential a.area-specific waste management plan. Example: Dispose spent iron sponge at the Keep Clean Landfill. ensuring that the plan is modified as appropriate: a. Through this ongoing process. Texas. For each waste. or toxicity of the waste being generated. c. (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. send to “Look Nice Commercial Landfill. in Small Town. describe the waste and the designated waste management and disposal practice. b. Example: Gas Plant Operator: To dispose of spent filters from the lean oil absorption unit: c. Summarize the recommended waste management practices in concise documents for useat the field level. Implement modified practices and revise the waste management plan as new or modified practices are defined. use the “Look Nice Commercial Landfill” for future disposal of nonhazardous wastes. as appropriate. to reduce the company’s potential liability. Through this process. 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. b. 19XX.~ 4. New waste management practices or options shouldbe evaluated whenever they become available. d. 2.) COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Establish a procedureto review and update the waste management plan. operations personnel mayjustify several of the current waste management practices.API/PETRO ES-ENGL L777 0732270 05b11725 378 D 52 API E5 Example: Spent iron sponge disposal options: a. volume. Drain free liquids. which will be implemented March 1 . Select Preferred Waste Management Practice(s) Select a waste management optionfor each waste: a. and the plan should be revised accordingly.A changein the type. Collect and store in clean. Step 9. output: An area-specific waste management plan. a nonhazardous disposal facility. therefore. The types of issues that may trigger a review of the plan are as follows: l. Maintain file of shipping records. Prepare and Implement An Area-Specific Waste Management Plan Develop and implement the plan: a.) b. periodic review the plan should have an established of frequency. Burial onsite after complete oxidation. Step 8. ensure that the iron sponge is completely oxidized. The availability of new technologies that can applied be to waste management practices. c.” e. summary listA ing the designated waste management practice for each waste identified. For final disposal.~~ ~~ STD. Implement any new or modified practices. 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. Example: The best available technology for treating spent acids from workover operations is neutralization. and covered drums. Describe only those wastes generated the operationsin that specific by area or within an operator’s responsibility. Effective waste management is an ongoing process. Prior to removal from thesite. Backwash and return liquids to treatmentfacilities. 3. (At a minimum. Recently receivedinformation indicates that “Keep Clean Landfill” is currently under enforcement action by the state. your company will always strive for the best method of handling the wastes generated in each area. Step 10. output: Implementation of these practices. output: Periodic reviewof the wastemanagement plan and implementation of the revised designated practices. b. Disposal at an offsite nonhazardous disposal facility. labeled. New waste minimization techniques. From the evaluation of waste management and disposal options. Applicable information which will reduce the company’s future liability.

Technical advisors from support staff. C. and additional data that may be important for evaluating the feasibility of the acceptable waste management options. Engineering staff. company man. b. knowledgeable in the processes at a given location. production foreman. They know the operations. b.API/PETRO ES-ENGL L777 m 0732290 05b1172b 2 O V m WASTE MANAGEMENT IN EXPLORATION AND PRODUCTION OPERATIONS 53 A. design/operational options. I COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . They canfacilitate information transfer to other areas that are developing waste management plans. Outside consultants can be recruited to provide selected expertise or prepare the entire plan(s). Field or operations personnel (for example. Engineering staff.STD. a variety of personnel within the company will have valuable experience to contribute.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. However. Safety and environmental support staff and drilling and production operations groups can provide technical advice during the process of developing theplan.) d. It is suggested that the following personnel also be included: a. current waste generation sources. Operations personnel. These personnel bring numerous resources to the team: a. and handling practices at the site of interest and be responsible for implementing any new will waste management practices. e. d. Operating environmental professionals. or gas plant operator) are key to the development process. c. 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. (An onsite engineer or an engineer dedicated to that operation/area would provide the best insight.

. Waste Management Policy Environmental Policy .4-3 Hazardous Materialmaste Manifesting .. Mercury Contaminated Soils.. Nonhazardous Materialmaste Manifesting .1 How to Use This Manual. . . . State-Permitted Disposal or Recycle Facilities 6. .4-6 Shipping Orders . .. .3-4 4.... .. Lube Oil Contaminated Soils. . and Bailing Wastes Caustics Cement Chemical Toilet Waste Chemicals.. . .l. . . EPA and State Generator ID Numbers 4.. . ..... and Unused Appendixes l . . .. ..4-8 Inserts: Hazardous Materials Warning Labels and Placards Texas Water Commission (TWC) Uniform Hazardous Waste Manifest Nonhazardous Waste Manifest Shipping 5 .2. . Chemical Contaminated Debris.1 RCRA Exempt and Nonexempt Classifications .. Treatment.. .. . . . PCB Contaminated Solvents SulfachecWChemsweet Waste Tank Bottoms and Basic Sediment Thread Protectors Vacuum Truck Rinsate Well Completion.. Transportation Requirements Overview of DOT Requirements .... . CrudeOil Stained Debris. . Lube Oil.. 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. 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.. Safety. ....1 PollutionPrevention . .... Lube Oil Contaminated Debris. . .....S T D ... .....2-3 3.. . . ... . Analytical Laboratories 8.. Slop Oil. . .3. . ..... . .. . ... Waste Classifications Texas Waste Classifications . Introduction Waste Management Program . .. Scrap Methanol NORM Oil. Crude Oil Contaminated Soils.. ... . . . Crude Oil Soaked Debris.. .... . . State-Permitted Transporters 5.4-4 . .. .... Uncontaminated Drilling FluiddCuttings I I i .. Management and Disposal by Waste Material Overview Cross Reference Aerosol Cans Amines Asbestos Batteries.. Swabbing.... Unusable Condensate Debris.... .Empty Filters. . .4-1 Materialmaste Documentation ..2-2 Health and Safety and WasteManagement ...... Violation Penalties Table 2... .l-2 2. Containing Chemicals DrumsiContainers. . Surplus Chemicals. .. Liquid Metal. Stimulation Fluids. . Process Glycol Hydraulic Fluids Iron Sulfide Scale and Iron Sponge Mercury... . .. Containing Lube Oil DrumsiContainers. . It can be used as a model in developing a customprogram for your company. . .. and Environmental Contacts 3.. . DrumsiContainers.. Lead-acid Blowdown. . .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. .. . .. .. . . Health.3-3 Guidelines for Nonexempt Classifications .. . Lube Oil Filters. . . . Chemical Contaminated Soils. ..

Oklahoma 37337 9501555-2744 Borgnas Disposal. Iron sponge is a coating ofiron oxide on wood chips or other carriers. see Special Handling above Offsite ManagementDisposal DOT Requirements None required unless it auto-ignites. Allow a minimum of 1 week for material to oxidize and cool to air temperaturebefore transporting offsite. Send tofacility state-permitted disposal RCRA: Exempt Texas:Class I IndustrialNonhazardous Any transporterpermit RRC with and MWA. State-Permitted Transporters State-Permitted Disposal or Recycle Facilities Marashi’s Disposal Mud Services 1905 Marashi Boulevard Marashi. keepin permanent file in area office. Special Handling Spread iron sponge out on bareground in an open. Onsite ManagementIDisposal No onsite disposal. Waste Reduction COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . in confined space. contact your compliance coordinator to determine appropriate DOT requirements. it may explode. Use Nonhazardous Waste Manifest. Iron sulfide may be present in tank bottoms and may be associated with well stream fluids and production systems. Wyoming 28746 9501555-2674 Consider alterative methods of removing hydrogen sulfide from gas stream. fenced area. Always keep it wet.It reacts with hydrogen sulfide and sulfur. Incorporated 2000 Borgnas Lane Medicine Bow. WARNING: Dry iron sulfide and iron sponge will auto-ignite.~ 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. 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. Do not mix with acid or acidic water. WARNING: Contact with acid will release hydrogen sulfide. with adequate oxygen. Treat production streams with biocide or scale inhibitorto reduce iron sulfide formation. For temporary storage on the ground.

. .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 .

S T D * A P I / P E T R O E S .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 .

60 API E5 I COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .

may also impose requirements. Since the early 1970s. 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. Lease agreements. In addition to these and other federal regulations. Regulates the manufacture. E&P operations are impacted by a number of federal. Amendment HSWA Amendments TCLP amendments 1974 1972 Safe Drinking Water Act (SDWA) Clean Water Act (CWA) Clean Air Act (CAA) I970 1990. food additives. 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. processing.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 . S. tobacco. ozone protection. nuclear materials and by-products. Compensation. hazardous and air pollutants. described in detail in Section 4. Local governments. Amendment I977 Toxic Substances ControlAct (TSCA) Comprehensive Environmental Response. and food. excludingpesticides. and tobacco products. Operatorsmust be aware of the various levelsof regulations and ensure that necessary permits and approvals are obtained before operations begin. landowner agreements. state.acid deposition. Underground Injection Control Public water systems Controls point source dischargesinto navigable waters of the U. permits enforcement. Fungicide. including disposal Regulates hazardous material shipment (includes hazardous waste) Only a few states have rules Date Enacted 1976 1980. other conor tracts may impose additional requirements. 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. and local environmental laws and regulations. or distribution of chemical substances. The federal laws summarized in this section are only those that have the greatest impact on E&P operations. motor vehicles and and fuels Regulates all chemical substancesand mixtures in the US. 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. 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. such as countiesor cities.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. the number and magnitude of environmental requirementshave increased significantly. The following table summarizes key federal legislation and regulations.

corrosivity. reactivity.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. 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. based generally upon the average pollution control performance achieved by the best existing plants. Clean Air Acts Amendments of 1990 Corrective Action Management Unit (RCRA) Comprehensive EnvironmentalResponse. 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. clean-up. Endangered Species Act ESA “F” Wastes Hazardous waste from nonspecific sources FFDCA Federal Food. Compensation. and emergency response for hazardous substances released into the environment and the clean-up of inactive hazardous waste disposal sites. 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. and Liability Act(commonly known as Superfund) of 1980. British Thermal Unit Clean Air Act-the 1970 Clean Air Act as amended in 1977. 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. and Cosmetic Act FIFRA Federal Insecticide. Amended by Superfund Amendments and Reauthorization Act of 1986 (SARA). 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 . 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. Fungicide. also known as SARA Title III. 1977. Provides for liability. Drug.S T D * A P I / P E T R O ES-ENGL 1777 m 0732270 05b4734 380 m Appendix E . End-of-Pipe-Treatment-those processes EOP that treat a combined plant wastestream for pollutant removal prior to discharge.

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. The most stringent control applied or required anywhere without consideration of cost or energy impact. 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. 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. 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 . but for which no nationalair quality standards have been established. New Source Review under CAA Office of Management and Budget Oil Pollution Act of 1990-addresses response. National Priorities List-list of sites to be cleaned up under thefederal Superfund program. 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. 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. Natural ResourceDamages Assessment (CERCLA. 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. liability. 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. 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.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. 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.S T D .

Quality Assurance Reasonably Available Control Technology ”applied to existing major sources in nonattainment areas. 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. liquid. Must be approved by EPA. Pretreatment Standards New Sources for of Indirect Discharges under Section 307(b) and (c) of the Clean WaterAct.S.S. Compensation and Liability Act of 1980 and the Superfund Amendments and Reauthorization Act of 1986. or solid. 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.WASTE MANAGEMENT IN EXPLORATION PRODUCTION AND OPERATIONS 65 T ’ wastes PAISI PAVE PCBs PH PIC PM POTW PPA PPb PPm PRP . 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. Department of Commerce to denote segments of industry. or spill cleanup residues Preliminary AssessmentJSite Investigation Program for Assessing Volatile Emissions Polychlorinated Biphenyls A measureof the acidity or alkalinity of material. Resource Conservation and Recovery Act of 1974-establishes controls for the handling and disposal of solid wastes and hazardous wastes. off-specification. Geological Survey VOC Volatile Organic Compounds-organic compounds that may be involved in photochemical reactions that produce ozone. 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. PSD PSES PSNS QA RACT RCRA REG NEG RF1 RVFS ROD RQ SARA SARA 313 SDWA SERC SI SIC Commercial chemical products consid ered acutely hazardous wastes if discarded off-specification. or spilled UCR Upper Confidence Range UIC Underground Injection Control USDW Underground Sourceof Drinking Water USGS U. Solid Waste Management Unit(RCRA) Toxicity Characteristic-concentration levels for 39 compounds used as one way to define solid waste as hazardous. Storage. 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. Volatile Organic Liquid VOL COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . 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. Pretreatment Standards Existing for Sources of indirect discharges under Section 307(d) of the Clean Water Act.

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. alongwith a plan of enforcement.or specified pollutants in an effluent. based upon the latest scientific knowledge concerning the effects of the pollutant on health and welfare.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.STD. Water Quality Criteria-acceptable concentration of a pollutant. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services ..

and 503. Metals Criteria for Land Management of Exploration and Production Wastes: Technical Support Document for API Recommended Guidance Values.E N G L L777 m 0732270 05b4738 T2b Appendix F-Reference Materials F.” 40 Code of Federal Regulations Parts 257. 1990. U.S T D . July 6. American Petroleum Institute. 67 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .A P I / P E T R O E S . Evaluation of Limiting Constituent Suggested for Land Disposal of Exploration and Production Wastes. 12. 1992. Bulletin D16. 1994. Bulletin on the Generic Hazardous Chemical Category List and Inventoryfor the Oil a& Gas hploration and production Industry. 14. 1992. U. U. Criteriafor pH in Onshore Solid Waste Management in Exploration and Production Operations. American Petroleum Institute. and 503. 13.S. Bulletin E3. December 1. EPNIOCC Study of State Regulation of Oil and Gas Exploration and Production Waste.S. “Underground Injection Control Program: Criteria and Standards. Publication 4595. 1988. Publication 4600. Environmental Protection Agency. ‘‘StatKhds for the Use or Disposal of Sewage Sludge?” 40 Code of Federal Regulations Parts 257. Bulletin E 1. The pH values are detailed in API Publication 4595. Bulletin on Management ofNaturally occurring dioactive Materials (NORM) in Oiland Gas Production.sodiumabsorptionratio. 1 l . March 1992. December 1990. Suggested Procedures for Development of Spill Prevention. and oil andgrease guideline values are described in detail in API Publication 4527. 1994. 2. “Underground Injection Control Program: Criteria and Standards. Environmental Guidance Document on Well Abandonment and Inactive Well Practices for U. American Petroleum Institute. Regulatory Determination for Oil and Gas Geothermal Exploration. 8. Metals guidance is developed in API Publication 4600. April 1. January 1993. 15. 7. 1993. Credible Decisions. American Petroleum Institute.” 40 Code of Federal Regulations Part 146. 6 . 5. Environmental Protection Agency.2 SOURCESFORJUSTIFICATIONAND ANALYTICAL METHODS IN TABLE 4 Electricalconductivity. CERCLA and SARA lïtle III. 9.l REFERENCES l . Bulletin E4. 1993. 4. June l.exchangeable sodium percentage. Interstate Oil Compact Commission.S. Environmental Protection Agency. U.S. American Petroleum Institute. Exploration and Production. American Petroleum Institute.S. 403. Publication 4527. F. Credible Science.S. Control and Countermeasure Plans.” 40 Code of Federal Regulations Part 146. August 1993.S. U. Environmental Protection Agency. 1992. 403. 3. Environmental Guidance Document on Release Reporting for the Oil and Gas Exploration and Production Industry as Required by the CWA. U. American Petroleum Institute. Environmental Protection Agency. Environmental Protection Agency. American Petroleum Institute. 1993. Bulletin E2. 1989. 1O. “Standards for the Use or Disposal of Sewage Sludge. August 1. Development and Production Wastes.

generated that same year.Congressexemptedthese makes good business sense. (API). produced water volumes typically SCOPE OF EXEMPTION increase. Specifically. 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. however. API later estimated that 1 1. under the less stringent RCRA Subtitle waste management decisions. the exemption does not mean these wastes Additionally. the toagement plans.” 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.1 million feet in 1991.” the A basic background of the E&P exemption. Not all In addition. are hazardous wastes. as hydrocarbons from producing wells deplete. Examples includeprocess modIn 1988. although they are relieved from regulation as waste management options appropriate for every waste. 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.Subsequently. were generated in 1985 from exploration and production Answers to frequently asked questions. EPA bewaste generation volumes. Prudent der state regulations. API estimated that 361 million barrels Clarifications of several misunderstandings about the of drilling wastes and20. Because no attempts have been made to update the In December 1978.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). 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.EPA proposed hazardous waste man1985 E&Pwaste volume data. rels of other wastes associated with E&P operations were Additional sources of information.~ S T D . a will be better prepared to develop site-specific waste mandecrease of 58 percent. (E&P) operations. and Geothermal Energy. Natural Gas. 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. the operator 315. Hence. Nevertheless. produced 69 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services ~ . At times this determination is misunderstood and may tion. D solid wasteregulations.9 billion barrels of produced water exemption. nonhazardous wastes. or under other federal regulations. 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. 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). even for nonhazardous wastes. possible (source reduction).S. Generally. Drilling activity in the United States has declinedsignifiUnderstanding the proceduresfor determining the exempt cantly since 1985. especially duction in the generation of drilling wastes. a determination should made as be not warranted. should bebased on the inherent nature of the waste. of Crude Oil. The RCRA Subtitle C exemptions. did not preclude these wastes from control unlead to improper waste management decisions. E&P wastes have remained exempt to whether the waste is subject to hazardous waste regulafrom Subtitle C regulations. generated in the United States. According to for operators who choose to develop voluntary waste manthe International Association of Drilling Contractors. 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. 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. Those estimates were proExamples of exempt and nonexempt wastes. during this time. 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. 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. which would resultin a corresponding reor nonexempt status of a waste is a valuable tool.8 million barRecommendations for sensible waste management. Development and Production U. vided to the Agency by the American Petroleum Institute Status of E&P waste mixtures. On the other hand. Also. 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.4 million feet in 1985 to 133.

. de-emulsifying. development. Furthermore. EPA published the following lists of wastes that were determined to be either exempt or nonexempt. Primary field operations include exploration. development or and. The lists are provided as examples of wastes regardedas exempt and nonexempt and should not be considered comprehensive. Crude oil processing suchas water separation. and storage attank batteries associated with a specific well or wells are examples of primary field operations. or production of crude oil or natural gas.) According to the legislative history.e. the term “other wastes associated” specifically includes waste materials intrinsically derived from primary field operations associated with the exploration. Similar wastes generatedby activities other than E&P operations are not covered by the exemption. the exemptstatus of an E&P waste depends on how the material was used or generated as waste. 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. Examples of carriers include trucks. 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. With respectto crude oil. or production of crude oil and natural gas. The phrase “intrinsically derived from the primary field operations” is intended to distinguish exploration. 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 someintrastate pipelines. gas plantsare considered part of production operations regardless their location with respect the of to wellhead. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . In general. The exempt waste list applies only to those wastes generated by E&P operations. a centrally located facility. some exempt E&P wastes might harmful to human be health and the environment and many nonexempt wastes might not be as harmful. i.. then the waste is most likely considered exempt from RCRA Subtitle C regulations. For example. EXEMPT AND NONEXEMPT WASTES In its 1988 regulatory determination. secondary. development. With respect to natural gas. development. or a gas plant to a carrier for transport to market. and production operations from transportation and manufacturing operations. the primary.” (Geothermal energy wastes were also exempted but are not addressed by this publication. and tertiary production of oil gas.. interstate pipelines. and other wastes associated with the exploration. becausenatural gas often requires processing toremove water and other impurities prior to en- tering the sales line. not necessarily whether thematerial is hazardous or toxic. 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. degassing.70 API E5 water.

1 Although non-E&P wastes generated from crude oil and tankbottom rechmation operations( e g . painting wastes. aminefilters. o . 1993. drum rinsate. residuals derived from exempt wastes (e. backwash. o . including glycol-based compounds. spent solvents. sandblast media. 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. March 22.” Federal Register. 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. solids. hydrocarbon solids. backwash. . filters. Natural Gas and Geothermal Energy.g. fluid treating vessels. and blowdown Used hydraulic fluids Waste in transportation pipeline related pits Caustic or acid cleaners Boiler cleaningwastes Boiler refractory bricks Boiler scrubberfluids. . sands. glycol filters. and production impoundments Pit sludges and contaminated bottoms from storage or disposal of exempt wastes Gas plant dehydration wastes. produced water separated from tank bottoms) are exempt. hydrates. and backwash (assuming the filter itself is not hazardous and the residue in it is from an exempt wastestream) Pipe scale. and emulsion from production separators.waste equipmentcleaning solvent)are nonexempt. Volume 58. 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 . 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. o o . iron sponge. For a further discussion. treatment. precipitated amine sludge. filter media. spilled chemicals. and hydrogen sulfide scrubber liquid and sludge Workover wastes Cooling tower blowdown Spent filters. including amines. and miscellaneous solids notice “Clarification of the Regulatory Determination for Wastes from the Exploration.S T D .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. 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. . o .. insulation. Development. and Production of Crude Oil. see the Federal Register COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Pages I5284 to 15287. amine filter media. filter media. sludges and ash Incinerator ash Laboratory wastes Sanitary wastes Pesticide wastes Radioactive tracer wastes Drums.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. and molecular sieves Gas plant sweetening wastes for sulfur removal.

ExempVNonexempt Flowchart Waste from Exploration. 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 .~~ 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.

if a listed hazardous waste’ is mixed with an exempt waste. 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. Example: If. or toxicity). the mixture is a nonexempt hazardous waste. the of wastes in thepit remain exempt regardless the characteristics of the waste mixture in the pit. the mixture is exempt. corrosivity. the mixture exhibits the characteristic for benzene but not for lead.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.S T D . the mixture does not exhibit the hazardous characteristic of corrosivity. if a mixture of an exempt waste with a nonexempt characteristic hazardous waste exhibits any of the same hazardouscharacteristicsas the hazardouswaste. In other words. “Land Disposal Restrictions for Ignitable and Corrosive Characteristic WastesWhose Treatment Standards Were Vacated. Note: As this document was being prepared. reactivity. 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. the resulting mixture may become a nonexempt waste and require management under RCRA Subtitle C regulation.’’ Federal Register Volume 58. refer to the Federal Register notice. Similarly. If. Generally. the ture becomes a nonexempt hazardous waste. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . 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. after mixing a nonexempt characteristic hazardous waste with an exempt waste. might require a chemical analysis of the mixture. For additional information. after mixing a nonexempt solvent containing benzene with an exempt waste also containing benzene. butdoes exhibit some other hazardous characteristic such as toxicity. the resulting mixture exhibits any of the same hazardous characteristics as the hazardous waste (ignitability. the wastes could become nonexempt even if only one barrel of hazardous waste was mixed with 10. exemptwastewithanotherexempt waste remains exempt. the mixture is a nonexempt hazardous waste. after mixing a nonexempt waste exhibiting the hazardous characteristic for lead with an exempt waste exhibiting the characteristic for benzene. Example: A mixture of stimulation fluid that returns from a well with produced waterresults in an exempt waste. the mixturebecomesa nonexempt hazardous waste regardless of the relative volumes or concentrations of the wastes. Mixing a nonhazardous waste (exempt or nonexempt) with an exempt waste resultsin a mixture that is also exempt. the mixture is considered a hazardous waste and is therefore nonexempt. after mixing nonexempt hydrochloric acid (HCI) that exhibits the corrosivecharacteristic only with an exempt waste. creates additional considerations. Example: If. If. Example: If. A mixture ofan Llsted hazardous wastes are those wastes listed as hazardous in the 40 Code of Federal RegulationsPart 261. Subpart D.000 barrels of exempt waste.May 24. Whenever possible. after mixing nonexempt caustic soda (NaOH) (corrosive) in a pit containing exemptwaste. in some instances. the for entire mixture becomes a nonexempt hazardous waste. 1993. Example: If any amount of leadedtankbottomsfrom the petroleum refining industry (listed as waste code K052) is mixed with an exempt tank bottom waste. Pages 29860 to 29887. Example: If. the mixture exhibits the hazardous characteristic benzene. it is still exempt. the mixture rule was being reexamined by EPA as a result of a court challenge. the mixture is exempt.particularlyexemptandnonexempt wastes. Even if the mixture is exhibits some other characteristic of a hazardouswaste. the resulting <mixturedoes not exhibit any of the same characteristics as the hazardous waste. regardlessof the proportions. Furthermore. avoid mixing nonexempt wastes with exempt wastes. If the nonexempt waste isa listed or characteristic hazardous waste. I . Because the rule could be amended or clarified. after mixing a nonexempt characteristic hazardous waste with an exempt waste. for both scenarios. the mixture exempt. the status of the rule should be determined prior to mixing any E&P wastes with hazardous wastes. Interim Final Rule. . 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. 2 i Below are some basic guidelines for determininga mixif ture isan exempt or nonexempt waste under the present mixture rule. Determining whether a mixture is an exempt or nonexempt waste requires an understandingof the nature of the wastes prior to mixing and. the mixture also exhibits the hazardous characteristic of corrosivity as deentire mixtermined frompH or steel corrosion tests.

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.

if the mixture does not exhibit one of the same hazardous characteristicsof the hazardous waste. are not exempt. Misunderstanding: All service company wastes are exempt. development. because they have not been used and therefore are not uniquely associated with the exploration or production of oil and gas. Fact: Not all service company wastes are exempt. and production of crude oil and natural gas. Misunderstanding: A waste exempt fromRCRA Subtitle C regulation is also exempt from state and other federal waste management regulations. an Fact: Not all mixtures ofa nonexempt hazardous waste with an exempt waste become exempt wastes. reserve pit regulations. reactivity. or production operations. it would be exempt because was genit erated through a procedure that is uniquely associated with production operations. and National Pollutants Discharge Elimination System (NPDES) state discharge or regulations) unless specifically excluded from regulation under those laws. Misunderstanding: All wastes located at E&P sites are exempt. Generally. Safe Drinking Water Act (SDWA). only those wastes generated from amaterial or process uniquely associated with the exploration and production of oil and gas are considered exempt. becomes nonexempt charactera istic hazardous waste if the mixture exhibitsone of the same hazardous characteristics as the original hazardous waste. As with all oilfield wastes. oil and gas exploration and production wastes are subject to regulation under the Clean Air Act (CAA).. 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. asolvent used to clean surface equipment or machinery is not exempt because it is not uniquely associated withexploration. The most common misunderstandings that arise with the RCRA Subtitle exemption and hazC ardous waste determinations are presented for here clarification. if disposed of. and Oil Pollution Act of 1990 (OPA). Conversely. a mixture of a hazardous waste that exhibits one of the characteristics of a hazardous waste (ignitability. 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. Fact: Certain exempt wastes. Conversely. Clean Water Act (CWA).g. or toxicity) with an exempt waste. the mixture becomes a nonhazardous exempt waste.. regardless of their intended use. the waste must have been generated froma material or process uniquely associated with the exploration. Also. Additionally. Misunderstanding: Unused products are exempt. As previously noted. they are disposed of) they are subject to RCRA Subtitle C hazardous waste regulations if they are listed or exhibit a hazardouscharacteristic. some of these wastes may still be subject to state hazardous or nonhazardous waste regulations or other federal regulations (e. Fact: Unused products. while excluded from RCRA Subtitle C hazardouswaste control.g. Misunderstanding: Any mixture of a nonexempt hazardous waste with an exempt waste becomes exempt waste. The previous example of solvents used for cleaning equipment and machinery would also apply in this case-the solvent is not an exempt waste. 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. might still be harmful to human health andthe environment if not properlymanaged. To be considered an exempt waste. Misunderstanding: All exempt wastes are harmless to human health and theenvironment. hazardous materials transportation regulations. a mixture of a listed hazardous waste with an exempt waste becomes a nonexempt hazardous waste. For example. Fact: The exemption applies only to the federal requirements of RCRA Subtitle C. corrosivity. For example. When unused products become waste (e. COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . if the same solvent were used in a well. development.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. Fact: All wastes located at E&P sites are not necessarily exempt.

crude oil). In some regions. For natural gas. 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. Naturalgas pipelines between the gas well and the gas plant are considered to be part of the production process. The exemption applies only to thosewastes derived from exempt wastes. 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. 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. For example. Q: What is the benejìt of the RCRA exemption ifthe operator is still liable for deanupsunder RCRA? A: No. primary field operations) of crude oil or natural gas. and in the some cases. The RCRA Subtitle C exemption only applies to wastes generated from the exploration. Exempt wastes maintaintheir exempt status even if they undergo custody transfer and are transported offsite disposal or treatfor ment. transportation begins at the point where the gas leaves the facility after production separation and dehydration at the gas plant.g. 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 located along main gas transmission lines are considered tobe part of the transportation process and any wastes generated by these compressor stations are nonexempt. Storage of crude oil in stock tanks at production facilities is considered part of the production separation process. Also. Q: When isa waste considered “uniquelyassociated with exploration and production operations? ” A: No. Q: Are RCRA-exempt wastes also exempt under other federal laws? A: Not necessarily. However. and that wastes generatedby these compressor stations are exempt. after the end point of production separation and dehydration. Therefore the gas generally does go to a gas plant but is not canied from wellhead to a main transmissionline. and production (i. not to additional wastes generated by the treatmentor reclamation of exempt wastes. 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. wastes generated from the transportation of crude oil or natural gas are not RCRA-exempt. 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. RCRA-exempt wastes might still be subject to regulation under authorities other than RCRA. natural gas does not require sweetening or extensive dehydration. any waste derivedfrom the exempt waste being treated is also exempt but the spent acid is not. transportation begins at the point of custody transfer of the oil or. 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. Hence. and handling only local production) should be treated the same as gas plants. not transportation. EPA periodically issues interpretive letters regarding the oil and gas exemption.. On the other hand. development. Q: Are wastes generated from a transportation pipeline considered exempt wastes under RCRA Subtitle C? A: No. Custody transfer is used to define the endpoint of production operations for crude oil and applies only to the change in ownership of the product (e. A: For crude oil. such as the Appalachian states.e. 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 . rather than transportation. The most common questionsand answers are listed below. and wastes that are uniquely associated with production that are generated along such a pipeline are exempt. and is includedin the exemption. Unless specifically excluded from regulation under other federal laws. directly to the customer. if a treatmentfacility uses an acid inthe treatment of an exempt waste.. 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. in the absence of custody transfer.

Minimize waste generation. (800)426-479 1 Title: API Environmental Guidance Document: Onshore Solid Waste Management in Exploration and Production Operations. July 6. particularly with oil based muds.C. Available from: RCWSuperfund Hotline Washington. such as by designing systems with thesmallest volumes possible(e. Minimize the volume of materials stored at facilities. VA 22161 (703) 487-4650 Title: Regulatory Determinationfor Oil and Gas and Geothermal Exploration. Natural Gas. 1988. Reclaim oily debris and tank bottoms when practical. The following waste management suggestions have been compiled from publications produced by these organizations as well as from literature available from industry trade associations. January 1989. and Production of Crude Oil.C. Publications Title: EPA Report to Congress: Management of Wastes from the Exploration. Recycle and reuse oil based muds and highdensity brines when practical. Natural Gas and Geothermal Energy. drilling mud systems). and EPA. Development. and Production Wastes. NTIS Publication No. Federal Register Volume 53. Train personnel to use sensible waste management practices. Review material safety datasheets (MSDS’s) of materials used. trade journals. December 1987. N. 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. Available from: National Technical Information Services 5285 Port Royal Road Springfield. Suite 185 Phoenix. D.C. Development. Washington. and select less toxic alternatives when possible. (800) 426-4791 Title: Clari’cation of the Regulatory Determinationfor Wastes from the Exploration. Reduce the amount of excess fluids entering reserve and production pits. Design the drilling pad to contain storm water and rigwash.. Construct adequate berms around materials and waste storage areas to contain spills.g. Do not place nonexempt wastes in reserve or production pits . Perform routine equipment inspections and maintenance to prevent leaks or emissions.W. Use closed loop mud systems when practical. Development. PB 88-146212. Pages 15284 to 15287. 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). Available from: American Petroleum Institute 1220 L Street. 1993. Arizona 85016-4412 (602) 956-6399 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . Federal Register Volume 58.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. March 22. Available from: RCRNSuperfund Hotline Washington. Perform routine inspections of materials and waste storage areas to locate damaged or leaking containers. and Geothermal Energy. D. 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. D. Suggested E&P Waste Management Practices Size reserve pits properly to avoid overflows. Pages 25446 to 25459. and Production of Crude Oil.

C.C.C. D. Environmental Protection Agency Office of SolidWaste Oil and Gas Industry Section (5306W) 401 M Street. S.W.78 API E5 OTHER SOURCES OF INFORMATION U. Washington. (800) 424-9346 Safe Drinking Water Hotline Washington. (800) 426-479 1 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .S. D. D. 20460 (703) 308-8424 RCWSuperfund Hotline Washington.

~~ STD=API/PETRO E5-ENGL 1777 m 0732270 05b4748 7 7 5 m COPYRIGHT American Petroleum Institute Licensed by Information Handling Services .

Additional copies available from API Publications and Distribution (202) 682-8375 Information about API Publications. Northwest Washington. GE5002 COPYRIGHT American Petroleum Institute Licensed by Information Handling Services . D.org American Petroleum Institute 1220 L Street.api.C. Programs and Services is available on the World Wide Web at: http://www. 20005-4070 202-682-8000 Order No.

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