Environmental Considerations
1361
Under the RCRA exemption, wastes intrinsically associated with the explora-
tion and development of oil and gas do not have to follow Subtitle C regulations
for disposal. Under Subtitle C, hazardous wastes must follow strict guidelines
for storage, treatment, and transportation and disposal. The cost of handling
materials under the Subtitle C scenario
is
overwhelming. Under the exemption,
the operator is allowed to dispose of wellsite waste in a prudent manner and is
not obliged to use licensed hazardous waste transporters and licensed Treatment,
Storage, and Disposal Facilities (TSDF).
Covered by the exemption are drilling fluids, cuttings, completion fluids, and
rigwash. Not covered by the exemption are motor and chain oil wastes, thread
cleaning solvents, painting waste, trash and unused completion fluids.
A
waste
product, whether exempt or not, should always be recycled if economically
possible. Oil-based drilling mud typically is purchased back by the vendor for reuse.
Unused chemicals are similarly taken back for resale. Arrangements should be made
with the mud company for similar arrange for partial drums/sacks
of
chemical.
Muds also may be used on more than one hole. With the advent
of
closed system
drilling, the mud must be moved off location in the event of a producing well.
If a waste is generated that is a listed or characteristic, the operator must
follow certain guidelines
[232].
A listed hazardous waste (i.e., mercury, benzene)
is considered hazardous if the concentrations in which they naturally occur are
above certain limitations (40
CFR
261.31-261.33).
The listed hazardous waste
may not be diluted to achieve lesser concentrations and thus become non-
hazardous.
A
characteristic hazardous waste
(40
CFR
261.21-261.24)
may be
diluted to a nonhazardous status.
Most nonexempt nonacute hazardous waste generated on location
is
considered
a small quantity. In this case, the waste may remain
on
location for
90
days. At
that time, a Department of Transportation licensed motor carrier must transfer
the waste to a EPA certified TSDF for disposal. Appropriate documentation and
packaging must be conformed to. The operator continues to be liable for the
waste as denoted by the cradle to grave concept
[233].
Exempt wastes are usually disposed of on location following permission from
the state oil and gas division. Liquid wastes,
if
not evaporated or fixated on
location, are usually injected into Class I1 injection wells-refer to Chapter
6,
Environmental Considerations. Solid wastes, if not acceptable to local landfills,
are remediated onsite
or
buried in some instances. Table
4-175
shows exempt
and nonexempt waste
[234].
Table
4-175
Exempt and Nonexempt
Oil
and Gas Production Related Wastes
Exempt Wastes Nonexempt Wastes
Produced water
Drilling fluids
Drill cuttings
Rigwash
Well
completionlstimulation fluids
Unused well completionlstimulation fluids
Radioactive tracer wastes
Painting wastes
Service company wastes such as empty
drums, drum rinsate, vacuum truck
rinsate, sandblast media, spent solvents,
spilled chemicals, and waste acids
Vacuum truck and drum rinsate contain-
ing nonexempt wastes