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PRELIMINARY DATA SUMMARY
FOR THE
COASTAL, ONSHORE AND STRIPPER SUBCATEGORIES.
OF THE
OIL AND GAS EXTRACTION
POINT SOURCE CATEGORY
Office of Water Regulations and Standards
Office of Water
United States Environmental Protection Agency
Washington, D.C.
September, 1989
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PREFACE
This is one of a series of Preliminary Data Summaries
prepared by the Office of Water Regulations and Standards of the
U.S. Environmental Protection Agency. The Summaries contain
engineering, economic and environmental data that pertain to
whether the industrial facilities in various industries discharge
pollutants in their wastewaters and whether the EPA should pursue
regulations to control such discharges. The summaries were
prepared in order to allow EPA to respond to the mandate of
section 304(m) of the Clean Water Act, which requires the Agency
to develop plans to regulate industrial categories that
contribute to pollution of the Nation's surface waters.
The Summaries vary in terms of the amount and nature of the
data presented. This variation reflects several factors,-.
including the overall size of the category (number of
dischargers), the amount of sampling and analytical work
performed by EPA in developing the Summary, the amount of
relevant secondary data that exists for the various categories,
whether the industry had been the subject of previous studies (by
EPA or other parties), and whether or not the Agency was already
committed to a regulation for the industry- With respect to the
last factor, the pattern is for categories that are already the
subject of regulatory activity (e.g., Pesticides, Pulp and Paper)
to have relatively short Summaries. This is because the
Summaries are intended primarily to assist EPA management in
designating industry categories for rulemaking. Summaries for
categories already subject to rulemaking were developed for
comparison purposes and contain only the minimal amount of data
needed to provide some perspective on the relative magnitude of
the pollution problems created across the categories.
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Persons interested in obtaining additional copies of this summary may write to the
following address:
U.S. Environmental Protection Agency
Industrial Technology Division (WH-552)
401 M St SW
Washington, DC 20460
Telephone (202)382-7131
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RULEMAKING HISTORY
COASTAL SUBCATEGORY
*
- BPT effluent limitations guidelines were promulgated on April 13, 1979. Allow for a
discharge of oil and grease in the produced water of 72 mg/L (maximum for any one
day) and 48 mg/L (avg. of values for 30 days).
- 1976 Geographical Area: Established as all land and water areas landward of the
inner boundary of the territorial seas and bounded inland by a series of longitude and
(attitude points in Louisiana and Texas (the Chapman line).
- 1979 Geographical Area: Revised to be any body of water or wetlands adjacent to
such waters landward of the inner boundary of the territorial seas. This stands as the
current geographical area of the coastal subcategory. Court decision (API v. EPA, 1981)
invalidated the reclassification of approximately 1200 on land facilities as coastal. (See
Related Regulatory Background section for more details).
- 1989 Notice: Considering modification of the coastal subcategory geographical area
to include only those facilities in saline water ( > 0.5 parts per thousand) landward of the
inner boundary of the territorial seas. (This would reclassify facilities located inland over
saline and fresh water areas to the onshore or another separate subcategory).
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ONSHORE SUBCATEGORY
- BPT effluent limitations guidelines were promulgated on April 13,1979. Imposed a zero
discharge requirement for waste water pollutants.
- 1976 Geographical Area: Established as all land and water areas landward from the
inner boundary of the territorial seas (including the Great Lakes). Excluded those facilities
located in the coastal, beneficial use and stripper subcategories.
- 1979 Geographical Area: Revised to include facilities located landward of the inner
boundary of the territorial seas and not included in the coastal, agricultural and wildlife
water use, or stripper subcategories.
- 1989: If the coastal subcategory were modified, those facilities in freshwater (and
inland saline water) would be reclassified as onshore or possibly placed in another
separate subcategory. Additionally, any facilities currently -located on land but classified
as "coastal" as a result of the 1981 court decision would be reclassified to the onshore
subcategory.
STRIPPER SUBCATEGORY
- No effluent limitations guidelines have ever been established for "onshore" stripper
facilities and the subcategory remains as reserved.
- 1976 Geographical Area: Established to include those facilities producing 10 barrels
per day or less of crude oil located onshore. Onshore was defined as all land and water
areas landward from the inner boundary of the territorial seas including the Great Lakes.
- 1979 Geographical Area: Onshore was redefined as all land areas landward of the
inner boundary of the territorial seas.
- 1989: The proper subcategory classification needs to be addressed, i.e., classifying
and regulating stripper oil wells in the stripper subcategory regardless of where they are
geographically located; eliminating the stripper subcategory and classifying and
regulating stripper oil wells in each individual subcategory (onshore, coastal and
agricultural and wildlife water use) or retaining the present classification and reserved
status for the onshore stripper subcategory and clarifying that coastal stripper facilities are
not reserved but are covered by the coastal subcategory.
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RELATED REGULATORY BACKGROUND
SUSPENSION OF REGULATIONS
- Due to the 1979 change in definition of coastal to be facilities in water landward of the
inner boundary of the territorial seas, approximately 1200 facilities (which were located on
land but considered to be coastal in 1976) were reclassified as onshore and were to
achieve the zero discharge requirement.
- In response to the decision in American Petroleum Institute v. EPA, (5th dr., 1981), EPA
suspended the applicability of the zero discharge requirement (onshore subcategory) for
those 1200 wells and any other wells in the 1976 coastal geograpical area that came
into existence after issuance of the 1979 regulations so as to treat all wells in this
geographcial area the same.
- The Agency is again considering the modification of the definition of coastal which may
cause the original 1200 facilities and additional facilities in fresh water to be reclassified
to the onshore or another subcategory.
- The 1981 court decision also said that the Agency should re-examine the problems of
marginal gas wells: 1) to develop an appropriate definition for marginal gas wells; and
2) to consider treating marginal gas wells similarly to stripper oil wells. In the July 21,
1982 Federal Register (47 FR 31555), the Agency set forth a list of issues to examine
applicable to marginal gas wells, but no additional work was conducted.
PETITION TO THE ADMINISTRATOR FROM THE OIL AND GAS INDUSTRY
- The BPT effluent limitations guidelines in the onshore, coastal and agricultural and
wildlife water use subcategories are applicable to marginal gas wells as no distinction has
ever been made by the Agency between full size gas production facilities and marginal
gas wells. (The stripper subcategory does not include marginal gas wells).
*
- The oil and gas industry has petitioned the Agency to re-examine the applicability of
the zero discharge requirement to onshore marginal gas wells and to consider treating
such facilities in a manner similar to stripper oil wells, e.g., development of a separate
subcategory or inclusion in the stripper subcategory.
- In the same petition, the Agency is requested to re-examine the applicability of the zero
discharge requirement for full size oil and gas gacilities in the onshore subcategory due
to treatment technologies and regional factors not considered in the development of
onshore BPT regulations. State permit writers have also sent information on present
practices and problems of implementing the BPT zero discharge regulations.
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DESCRIPTION OF THE INDUSTRY
EXPLORATION AND DEVELOPMENT OPERATIONS
- Exploration and development activities for the extraction of oil and gas include work
necessary to locate, drill and complete wells. The waste streams associated with drilling
operations are drilling muds, fracturing fluids, and other well stimulation fluids. These
waste streams are typically disposed into onsite earthen pits.
- Pits are constructed for the receipt of wastes. These wastes are generated regardless
of whether the well becomes a full size producer, a stripper, or a dry hole. Pit dimensions
vary from 10 ft by 30 ft for certain air drilling operations and up to several acres for a
single mud drilling operation.
PRODUCTION OPERATIONS
- Production operations include all post-completion work necessary to bring hydrocarbon
reserves from the producing formation to the point of transmission. For the onshore
facilities produced water is reinjected, stored in earthen pits for evaporation or percolation,
or is sent to centralized treatment facilities for treatment and discharge. In coastal areas,
produced waters are discharged into rivers, streams, lakes and coastal wetlands following
compliance with BPT oil and grease limitations.
- In addition, drilling muds and cuttings are stored in pits (and buried during site
reclamation); and combinations of drilling wastes and produced waters are treated by
mobile treatment operations and the effluents discharged both from onshore and coastal
facilities.
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COASTAL PROFILE
- The Agency's initial analysis of the coastal subcategory has involved the identification
of oil and gas extraction fields in the coastal counties of states which border the Atlantic,
Pacific and Gulf coasts and includes Alaska through the use of a data base purchased
from Petroleum Information Inc.
- This preliminary profile indicated that there are 23,891 oil wells and 6,777 gas wells in
coastal counties. This county-by-county analysis does not differentiate between onshore,
fresh water, marine water, estuarine water, stripper oil wells or marginal gas wells as this
information is not available in the Petroleum Information data base.
ONSHORE PROFILE
- The onshore subcategory was profiled through the use of Petroleum Independent,
Sept, 1988. The total number of producing oil wells for 1987 was 620,181 of which
451,787 were stripper oil wells (National Stripper Well Survey). This left 168,394 as full-
size producing oil wells for that year.
- The total number of gas wells was reported to be 253,856. However, there was no
information as to how many of these gas wells were marginal gas wells.
STRIPPER PROFILE
- The National Stripper Well Association publishes an annual stripper oil well survey which
represents on a state-by-state basis the number of stripper oil wells, production statistics
reserve statistics, and the previous ten years of the same information. There is no
distinction of where the stripper oil wells exist in within the state in terms of subcategories,
e.g., onshroe, coastal or agricultural and wildlife water use.
- The most recent survey indicates that there were 451,787 stripper oil wells in the United
States during the year of 1987.
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ISSUES RELATING JO THESE SUBCATEGORIES
ISSUE 1 - NRDC Intent to Sue '
- NRDC has listed the coastal subcategory in its notice of citizen's suit under Section
304(m).
'ISSUE 2 - API v. EPA (1981)
- The 5th Circuit decision said that EPA should re-examine the problems of marginal gas
wells and consider adding them to the final guidelines for stripper oil wells.
ISSUE 3 - July 21, 1982 Federal Register Notice (47 FR 31555)
- The Agency set forth a list of issues regarding marginal gas wells which it was
examining and solicited public comment on such issues.,
ISSUE 4 - July 14, 1987 Petition from Industry
- Petition requests 1) EPA to revise effluent guidelines applicable to the onshore oil and
gas industry located in Kentucky, New York, Ohio, Pennsylvania, Tennessee, Virginia and
West Virginia; and 2) Reconsideration of the appropriateness of the zero discharge
requirement to marginal gas wells.
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RANKING OF PRIORITY POLLUTANT LOADINGS FOR REGULATED INDUSTRIES
VS. DRUM RECONDITIONING
DIRECT DISCHARGERS
TOTAL PRIORITY ORGANICS
TOTAL PRIORITY INORGANICS
INDUSTRY
RAW
LOADING
(Ibs/day)
INDUSTRY
RAW
LOADING
(Ibs/day)
ORGANICS/PS4SF* 483,546
Coastal IRON 6 STEEL 105,296
41 417*"~""*LEACHATES(HWT) 35,4 08
' PULP & PAPER 32,794
PETROLEUM REFINING 17,119
METAL FINISHING 9,343
PHARMACEUTICALS** 6,425
TEXTILES 3,656
FOUNDRIES 2,248
AQUEOUS(HWT) 1,274
COPPER FORMING 858
NONFERROUS METALS 495
ELECTRICAL 409
COAL MINING 400
DRUM RECONDITIONING
LEATHER TANNING 303
SCRUBBERS(HWT) 151
COIL COATING 16
ALUMINUM FORMING 9
NONFERROUS FORMING 6
PORCELAIN
OREMINING
BATTERIES
INORGANIC CHEM.
PESTICIDES
339
Coastal.
1,558*
IRON t STEEL 917,027
METAL FINISHING .240,178
ORE MINING 166,723
COAL MINING 134,373
AQUEOUS(HWT) ' 100,396
ORGANICS /PfcSF* 83,304
FOUNDRIES 51,307
COPPER FORMING 41,813
INORGANIC CHEM. 21,958
SCRUBBERS(HWT) 20,429
PULP t PAPER 8,501
PETROLEUM REF. 4,077
LEATHER TANNING 3,595
NONFERROUS FORMING 3,033
ALUMINUM FORMING 2,943
NONFERROUS FORMING 2,525
TEXTILES 2,358
LEACHATES(HWT) 2,279
.BATTERIES 2,265
^PORCELAIN 1,109
COAL COATING 968
ELECTRICAL 250
PHARMACEUTICALS** 229
PLASTICS 135
PESTICIDES
DRUM RECONDITIONING 61
Source : Industry Status Sheet Report (ISS).
* Loadings based on ITD information (3/87).
** Loadings based in ITD information (10/87)
* Indicates that loadings for the Coastal Subcategory were calculated after BPT treatment.
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COASTAL
Onshore, Coastal and Stripper Subcategories
Estimated Pollutant Loadings Using US EPA Onshore Data Base
in Produced Water Waste Stream
Population and Production (1986)
Total Number of Facilities 30,668
Total Number of Oil Wells 23,891
Total Number of Gas Wells 6,777
Inorganics
Barium
Fluoride
Chromium
Nickel
Cadmium
Lead
Arsenic
Boron
Chloride
Sodium
Ibs/yr
12,745,587
1,424,482
96,816*
19,221*
4,983*
71,900*
196,480*
8,557,568
6,906,634,840
3.082.206.830
Total Inorganics 10,011,958,000 Ibs/yr
Total Priority Inorganics 389,400 Ibs/yr
Organics
Toluene
Benzene
2-Butanone
Phenol
Phenanthrene
192,209*
344,125*
277,208
54,601*
17.868*
Total Organics 886,011 Ibs/yr
Total Priority Organics 608,803* Ibs/yr
Total Inorganic
and Organics 10,120,466,000 Ibs/yr
Total Priority Inorganics
and Organics 998,203* Ibs/yr
Data Sources:
Pollutant Concentrations - US EPA Onshore Data Base
Population - ITD Initial Profile of Coastal Subcategory
Water Production - Petroleum Information Data Base
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COASTAL
Onshore, Coastal and Stripper Subcategories
Coastal Subcategory: Estimated Pollutant Loading Proportions
Based on the 30-Platform Offshore Study
Profile Information for Coastal Facilities
Population and Production in 1986
Total Number of Facilities
Total Number of Oil Wells
Total Number of Gas Wells
30,668
23,891
6,777
Total Annual Water Production 2,031,216,372 bbls/yr
Total Priority Organic Pollutants in Produced Water Waste Stream
(Ibs/yr)
Benzene 1,642,986
2,4-Dimethylphenol 47,993
Ethylbenzene 452,030
Naphthalene 91,832
Phenol 619,321
Toluene 1,215,154
Benzo-a-pyrene 834
Total
4,070,150
Total Priority Inorganic Pollutants in Produced Water Waste Stream
Zinc 123,862 Ibs/yr
Total Priority Organic and
Inorganic Pollutants 4,194,012 Ibs/yr
in Produced Water Waste Stream
Data Sources:
Pollutant Concentrations - 30-Platform Offshore Study
Population - ITD Initial Profile of Coastal Subcategory
Water Production - Petroleum Information Data Base
—Q—
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COASTAL
Onshore, Coastal and Stripper Subcategories
Estimated Pollutant Loading' Information for Coastal Facilities (continued)
Muds
Priority Organics and Metals
Other Organics
Number of wells drilled per year
Industrywide Priority Organics
and Metals
Industrywide Other Organics
Cuttings
Priority Organics and Metals
Other Organics
Number of wells drilled per year
Industrywide Priority Organics
and Metals
Industrywide Other Organics
6,902 Ibs/well
1,125lbs/well
1,347
9,296,994 Ibs/yr
1,515,375 Ibs/yr
333 Ibs/well
1,313 Ibs/well
1,347
448,551 Ibs/yr
1,768,611 Ibs/yr
Total Muds and Cuttings
Industrywide Priority Organics
and Metals
Industrywide Other Organics
9,745,545 Ibs/yr
3,283,986 Ibs/yr
Data Sources:
Priority Organics, Metals and Other Organics - Offshore Data
Number of Wells Drilled in 1986 - ITD estimation based upon API report submitted for offshore
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ONSHORE
Onshore, Coastal and Stripper Subcategories
Estimated Pollutant Loadings Using US EPA Onshore Data Base
in Produced Water Waste Stream
Population and Production M987)
Total Number of Facilities
Total Number of Oil Wells
Total Number of Gas Wells
Inorganics
Barium
Fluoride
Chromium
Nickel
Cadmium •
Lead
Arsenic
Boron
Chloride
Sodium
Total Inorganics
Total Priority Inorganics
Organics
Toluene
Benzene
2-Butanone
Phenol
Phenanthrene
Total Organics
Total Priority Organics
Total Inorganics
and Organics
Total Priority Inorganics
and Organics
422,250
168,394
253,856
, Ibs/yr
130,544,147
14,589,971
991,622*
196,866*
51,039*
736,425*
2,012,410*
87,649,195
70,739,834,000
31.568.890.000
102,545,490,000 Ibs/yr
398,362* Ibs/yr
1,968,662*
3,524,634*
2,839,248
559,246*
183.013*
9,074,803 Ibs/yr
6,235,555* Ibs/yr
102,554,560,000 Ibs/yr
6,633,917* Ibs/yr
Data Sources:
Population and Production - Petroleum Independent, Sept. 1988 and National Stripper Well Survey 1988
Pollutant Concentrations - US EPA onshore data base
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ONSHORE
Onshore, Coastal and Stripper Subcategories
Estimated Pollutant Loadings Using 30-Platform Offshore Study
in Produced Water Waste Stream
Population and Production (1987)
Total Number of Facilities 422,250
Total Number of Oil Wells 168,394
Total Number of Gas Wells 253,856
Total Annual Water Production: 20,804,329,000 bbls/yr
Total Priority Organic Pollutants
Benzene
2,4-Dimethylphenol
Ethylbenzene
Naphthalene
Phenol
Toluene
Benzo-a-pyrene
Total
(Ibs/yr)
1,682,412
481,228
4,630,000
940,582
6,343,465
12,446,316
8.530
26,532,533
Total Priority Inorganic Pollutants
Zinc
Total Priority Organic and
Inorganic Pollutants
1,268,693 Ibs/yr
27,801,226 Ibs/yr
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ONSHORE
Onshore, Coastal and Stripper Subcategories
1987 Estimated Pollutant Loadings Using 30-PIatform Offshore Study
(continued)
Muds
Priority Organics and Metals 6,902 Ibs/well
Other Organics 1,125 Ibs/well
Number of wells drilled per year 33,031
Industrywide Priority Organics
and Metals 227,979,962 Ibs/yr
Industrywide Other Organics 37,159,875 Ibs/yr
Cuttings
Priority Organics and Metals 333 Ibs/well
Other Organics 1,313 Ibs/well
Number of wells drilled per year 33,031
Industrywide Priority Organics
and Metals 10,999,323 Ibs/well
Industrywide Other Organics 43,369,703 Ibs/well
Total Muds and Cuttings
Industrywide Priority Organics
and Metals 238,979,285 Ibs/yr
Industrywide Other Organics 80,529,578 Ibs/yr •
Data Sources:
Priority Organics, Metals and Other Organics - Offshore Data
Number of Weils Drilled - Petroleum Independent. Sect. 1988
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STRIPPER
Onshore, Coastal and Stripper Subcategories
Estimated Pollutant Loadings Using US EPA Onshore Data Base in Produced
Water Waste Stream
Population and Production (1987)
Total Number of Facilities 451,787
Total Annual Water Production: .4,021,530,849 bbls/yr
Inorganics
Barium
Fluoride
Chromium
Nickel
Cadmium
Lead
Arsenic
Boron
Chloride
Sodium
Total Inorganics
Total Priority Inorganics
Organics
Toluene
Benzene
2-Butanone
Phenol
Phenanthrene
Total Organics
Total Priority Organics
Total Inorganics
and Organics
Total Priority Inorganics
and Organics
Ibs/yr
25,234,522
2,820,279
191,683*
38,055*
9,866*
142,353*
389,004*
16,942,816
13,674,193,000
6.102.348.337
19,822,309,000 Ibs/yr
770,961* Ibs/yr
380,547*
681,320*
548,834
108,104*
35.377*
1,754,182 Ibs/yr
1,205,348* Ibs/yr
19,824,064,000 Ibs/yr
1,976,309 Ibs/yr
Data Sources:
Population and Production - National Stripper Welt Survey, 1988
Pollutant Concentrations - US EPA Onshore Data Base
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STRIPPER
Onshore, Coastal and Stripper Subcategories
Estimated Pollutant Loadings Using 30-Platform Offshore Study
in Produced Water Waste Stream
Population and Production (1987)
Total Number of Facilities 451,787
Total Annual Water Production: 4,021,530,849 bbls/yr
Total Priority Organic Pollutants in Produced Water Waste Stream
(Ibs/yr)
Benzene 1,471,983
2,4-Dirnethylphenol 102,337
Ethylbenzene 107,945
Naphthalene 165,422
Phenol • 1,366341
Toluene 1,007,458
Benzo-a-pyrene Q
Total
4,221,986
Total Priority Inorganic Pollutants in Produced Water Waste Stream
Zinc 1,97,666 Ibs/yr
Total Priority Organic and Inorganic Pollutants in Produced Water Waste
Stream
4,419,652 Ibs/yr
Data Sources:
Population and Production - National Stripper Well Survey, 1988
Pollutant Concentrations - 30-Platform Offshore Study
Government Printing Office : 1990 - 719-389/05903
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