*«aJ** "'* .—* ^^'* • "^vw^lFr I J Recycled/Recyclable Ij Printed with soy/canola ink on paper that|| contains at least 20% postconsumer fibe ------- ------- NTRODUCTION n the 1987 Report to Congress entitled "Management of Wastes from the Exploration, Development and Production of Crude Oil, Natural Gas and Geothermal Energy," the U.S. Environmental Protection Agency (EPA) presented estimates on the amount of oil and gas drilling and production wastes generated in the United States. Those estimates were provided to the Agency by the American Petroleum Institute (API). Specifically, API esti- mated that 361 million barrels of drilling wastes and 20.9 billion barrels of produced water were generated in 1 985 from exploration and produc- tion (E&P) operations. API later estimated that 1 1 .8 million barrels of other wastes associated with E&P operations were generated that same year. ivity in the United States has declined significantly since 1985, . i > which wouB result in a corresponding reduction in the generation of drill- ing wastes. According to the fntemotftirKil Association of Drilling Contrddof4$">e total footQQe drilled for ail oil and gas wells dropped from 31 $J4" million feet in 1 985 to 1 33.1 million feet in 1 991 , a decrease '!' V of 58 pfljpqEStit. It seems logical *g> assume that driHing waste volumes 'i would have declined proportionately during tilts time. On the other hand, ------- In 1985, 361 million barrels of drilling wastes and 20.9 billion barrels of produced as hydrocarbons from producing wells deplete, produced water vol- umes typically increase. Because no attempts have been made to update the 1985 E&P waste vol- ume data, it is uncertain what effect the downward trend in drill- ing activity has had on total E&P waste generation volumes. water were + + generated from Neverthe|ess'mana9'ngaiithese wastes in a manner that protects E&P operations. human health and the environ- ment is essential for limiting operators' legal and financial liabilities and makes good business sense. The preferred option for preventing pollution is to avoid generating wastes whenever possible (source reduction). Examples include process modifications to reduce waste volumes and materials substitution to re- duce toxicity. Also, a determination should be made as to whether the waste is subject to hazardous waste regulations. At times this determina- tion is misunderstood and may lead to improper waste management decisions. Prudent waste management decisions, even for nonhazardous ------- wastes, should be based on the inherent nature of the waste. Not all waste management options are appropriate for every waste. Additionally, operators should be familiar with state and federal regulations governing the management of hazardous and nonhazardous wastes. + 4- This publication was produced by EPA to provide an understanding of the exemption of certain oil and gas exploration and production (E&P) wastes from regulation as hazardous wastes under Subtitle C of the Resource Conservation and Recovery Act (RCRA). * 4- The information contained in this booklet is intended to furnish the reader with: • A basic background on the E&P exemption. • Basic rules for determining the exempt or non-exempt status of wastes. • Examples of exempt and non-exempt wastes. • Status of E&P waste mixtures. • Clarifications of several misunderstandings about the exemption. • Answers to frequently asked questions. • Recommendations for sensible waste management. • Additional sources of information. ------- Understanding the procedures for determining the exempt or non- exempt status of a waste is a valuable tool, especially for operators who choose to develop voluntary waste management plans. When these pro- cedures are used in conjunction with a knowledge of the nature of the waste, the operator will be better prepared to develop site-specific waste management plans and to manage E&P wastes in a manner that protects human health and the environment. ------- COPE OF THE EXEMPTION ! 'ecember 1978, EPA proposed hazardous waste manage- •nent standards that included reduced requirements for several types of large volume wastes. Generally, EPA believed these arge volume "special wastes" are lower in toxicity than other wastes being regulated as hazardous waste under RCRA. Sub- sequently, Congress exempted these wastes from the RCRA Subtitle C hazardous waste regulations pending a study and regulatory determination by EPA. In 1 988, EPA issued a regula- tory determination stating thaf control of E&P wastes under RCRA Subtitle C regulations is not warranted. Hence, E&P wastes have remained exempt from Subtitle C regulations. The RCRA Subtitle C exemption, however, did not preclude these wastes from control under state regulations, under the less strin- gent RCRA Subtitle D solid waste regulations, or under dfher federal regulations. In addition, although they are relieve^ from regulation as hazardous wastes, the exemption does not mptin these wastes could not present a hazard to human health <|n environment if improperly managed. * ------- Among the wastes covered by the 1 978 proposal were "gas and oil drilling muds and oil production brines." The oil and gas ex- emption was expanded in the 1 980 legislative amendments to RCRAto include "drilling fluids, produced water, and other wastes associated with the exploration, development, or produc- tion of crude oil or natural gas...." (Geothermal energy wastes were also exempted but are not addressed by this publication.) According to the legislative history, the term "other wastes associ- ated" specifically includes waste materials intrinsically derived from primary field operations associated with the exploration, de- velopment, or production of crude oil and natural gas. The phrase "intrinsically derived from the primary field operations" is intended to distinguish exploration, development, and produc- tion operations from transportation and manufacturing operations. ------- With respect to crude oil, primary field operations in- clude activities occurring at or near the wellhead and before the point where the oil is transferred from an in- dividual field facility or a centrally located facility to a carrier for transport to a refinery or a refiner. With respect to natural gas, primary field opera- tions are those activities occurring at or near the wellhead or at the gas plant but before the point where the gas is transferred from an individual field facility, a centrally located facility, or a gas plant to a carrier for transport to market. Examples of carriers include trucks, interstate pipelines, and some intrastate pipelines. Primary field operations include exploration, development, and the primary, secondary, and tertiary production of oil or gas. Crude oil processing, such as water separation, de-emulsifying, degassing, and storage at tank batteries associated with a ------- specific well or wells, are examples of primary field operations. Furthermore, because natural gas often requires processing to remove water and other impurities prior to entering the sales line, gas plants are considered to be part of production opera- tions regardless of their location with respect to the wellhead. In general, the exempt status of an E&P waste depends on how the material was used or generated as waste, not necessarily whether the material is hazardous or toxic. For example, some exempt E&P wastes might be harmful to human health and the environment, and many non-exempt wastes might not be as harmful. The following simple rule of thumb can be used to de- termine if an E&P waste is exempt or non-exempt from RCRA Subtitle C regulations: > Has the waste come from down-hole, i.e., was it brought to the surface during oil and gas E&P operations? + Has the waste otherwise been generated by contact with the oil and gas production stream during the removal of produced water or other contaminants from the product? If the answer to either question is yes, then the waste is most likely considered exempt from RCRA Subtitle C regulations. ------- -I \ RMiifffi*^^^^^! XEMPTAND NON-EXEMPT WASTES s 1 988 regulatory determination, EPA published the follow- ing lists of wastes that were determined to be either exempt or non-exempt. The lists are provided as examples of wastes regarded as exempt and non-exempt and should not be considered compre- hensive. The exempt waste list applies only to those wastes generated by E&P operations. Similar wastes generated by activities other than E&P operations are not covered by the exemption. ------- Exempt E&P Wastes Produced water Drilling fluids Drill cuttings Rigwash Drilling fluids and cuttings from offshore operations disposed of onshore Geothermal production fluids Hydrogen sulfide abatement wastes from geothermal energy production Well completion, treatment, and stimulation fluids Basic sediment, water, and other tank bottoms from storage facili- ties that hold product and exempt waste Accumulated materials such as hydrocarbons, solids, sands, and emulsion from prodjction separators, fluid treating vessels, and production impoundments Pit sludges and contaminated bottoms from storage or dis- posal of exempt wastes Gas plant dehydration wastes, including glycol-based com- pounds, glycol filters, and filter media, backwash, and molecu- lar sieves Workover wastes Cooling tower blowdown Gas plant sweetening wastes for sulfur removal, including amines, amine filters, amine filter media, backwash, precipitated amine sludge, iron sponge, and hydro- gen sulfide scrubber liquid and sludge Spent filters, filter media, and backwash (assuming the filter itself is not hazardous and the residue in it is from an exempt waste stream) Pipe scale, hydrocarbon solids, hydrates, and other deposits removed from piping and equip- ment prior to transportation Produced sand Packing fluids Hydrocarbon-bearing soil Pigging wastes from gathering lines Wastes from subsurface gas stor- age and retrieval, except for the non-exempt wastes listed below Constituents removed from pro- duced water before it is injected or otherwise disposed of Liquid hydrocarbons removed from the production stream but not from oil refining Gases from the production stream, such as hydrogen sulfide and carbon dioxide, and volatil- ized hydrocarbons ------- Materials ejected from a produc- ing well during blowdown Waste crude oil from primary field operations Light organics volatilized from exempt wastes in reserve pits, impoundments, or production equipment Non-Exempt Wastes Unused fracturing fluids or acids Gas plant cooling tower clean- ing wastes Painting wastes Waste solvents Oil and gas service company wastes such as empty drums, drum rinsate, sandblast media, painting wastes, spent solvents, spilled chemicals, and waste acids Vacuum truck and drum rinsate from trucks and drums transport- ing or containing non-exempt waste Refinery wastes Liquid and solid wastes gener- ated by crude oil and tank bot- tom reclaimers1 Used equipment lubricating oils Waste compressor oil, filters, and blowdown Used hydraulic fluids Waste in transportation pipeline related pits Caustic or acid cleaners Boiler cleaning wastes Boiler refractory bricks Boiler scrubber fluids, sludges, and ash Incinerator ash Laboratory wastes Sanitary wastes Pesticide wastes Radioactive tracer wastes Drums, insulation, and miscella- neous solids Although non-E&P wastes generated from crude oil and tank botton reclama- tion operations (e.g., waste equipment cleaning solvent) are non-exempt, residu- als derived from exempt wastes (e.g., produced water separated from tank bottoms) are exempt. For a further discussion, see the Federal Register notice, "Clarification of the Regulatory Determination for Waste from the Exploration, Development, and Production of Crude Oil, Natural Gas and Geothermal En- ergy," March 22, 7993, Federal Register Volume 58, Pages 75284 to 75287. ------- The following flowchart should be useful in determining whether a waste is exempt or non-exempt from RCRA Subtitle C regulation. Exempt/Non-Exempt Waste Yes L^ Waste From Exploration, Development, iYes Associated? ires Waste Mixture? No Exempt From RCRA Subtitle C (Subject to Subtitle D and Other State and Federal Statutes) See Mixture Flowchart No _No Listed Hazardous Waste? iMo Exhibit Hazardous Characteristic? JlMo V Non-hazardous Waste (Subject to Subtitle D and Other State and Federal Statutes) Hazardous Waste Subject to RCRA c. ,L.A;.I|_ r* Yes Yes __^^. -*J ------- IXING WASTES ig wastes, particularly ex- t and non-exempt wastes, tes additional considera- ic s. Determining whether a mixture is an exempt or non- exempt waste requires an understanding of the nature of the wastes prior to mixing and, in some instances, might require a chemical analysis of the mixture. Whenever possible, avoid mix- ing non-exempt wastes with exempt wastes. If the non-exempt waste is a listed or characteristic hazardous waste, the resulting mixture might become a non-exempt waste and require manage- ment under RCRA Subtitle C regulation. Furthermore, mixing a characteristic hazardous waste with a non-hazardous or exempt waste for the purpose of rendering the hazardous waste non- hazardous or less hazardous might be considered a treatment process subject to appropriate RCRA Subtitle C hazardous waste regulation and permitting requirements. NOTE: As this document was being prepared, the "mixture rule" was being re- examined by EPA as a result of a court challenge. Because the rule could be amended or clarified, the status of fhe rule should be determined prior to mix- ing any E&P wastes with hazardous wastes. For additional information, refer to the Federal Register notice "Land Disposal Restrictions for Ignitable and Corro- sive Characteristic Wastes Whose Treatment Standards Were Vacated; Interim Final Rule," May 24, 1993, Federal Register Volume 58, Pages 29860 to 29887. ------- Below are some basic guidelines for determining if a mixture is an exempt or non-exempt waste under the present mixture rule. A mixture of an exempt waste with another exempt waste remains exempt. EXAMPLE: A mixture of stimulation fluid that returns from a well with produced water results in an exempt waste. Mixing a non-hazardous waste (exempt or non-exempt) with an exempt waste results in a mixture that is also exempt. EXAMPLE: If non-hazardous wash water from rinsing road dirt off equipment or vehicles is mixed with the contents of a reserve pit containing only exempt drilling waste, the wastes in the pit remain exempt regardless of the char- acteristics of the waste mixture in the pit. If, after mixing a non-exempt characteristic hazardous waste with an exempt waste, the resulting mixture exhibits any of the same haz- ardous characteristics as the hazardous waste (ignitability, corrosivity, reactivity, or toxicity), the mixture is a non-exempt hazardous waste. EXAMPLE: If, after mixing non-exempt caustic soda (NaOH) that exhibits the hazardous characteristic of corrosivity in a pit containing exempt waste, the mixture also exhibits ------- the hazardous characteristic of corrosivity as deter- mined from pH or steel corrosion tests, the entire mixture becomes a non-exempt hazardous waste. EXAMPLE: If, after mixing a non-exempt solvent containing ben- zene with an exempt waste also containing benzene, the mixture exhibits the hazardous characteristic for benzene, the entire mixture becomes a non-exempt hazardous waste. If, after mixing a non-exempt characteristic hazardous waste with an exempt waste, the resulting mixture does nof exhibit any of the same characteristics as the hazardous waste, the mixture is exempt. Even if the mixture ex- hibits some other characteristic of a hazardous waste, it is still exempt. EXAMPLE: If, after mixing non-exempt hydrochloric acid (HCI) that exhibits the corrosive characteristic only with an ex- empt waste, the mixture does nof exhibit the hazardous characteristic of corrosivity but does exhibit some other hazardous characteristic such as toxicity, the mixture is exempt. EXAMPLE: If, after mixing a non-exempt waste exhibiting the haz- ardous characteristic for lead with an exempt waste exhibiting the characteristic for benzene, the mixture ex- hibits the characteristic for benzene but not for lead, the mixture is exempt. ------- Generally, if a listed hazardous waste2 is mixed with an exempt waste, regardless of the proportions, the mixture is a non-exempt haz- ardous waste. EXAMPLE: If any amount of leaded tank bottoms from the petro- leum refining industry (listed as waste code K052) is mixed with an exempt tank bottom waste, the mixture is considered a hazardous waste and is therefore non- exempt. It is also important to emphasize that a mixture of an exempt waste with a listed hazardous waste generally becomes a non- exempt hazardous waste regardless of the relative volumes or concentrations of the wastes. Similarly, if a mixture of an exempt waste with a non-exempt characteristic hazardous waste exhibits any of the same hazardous characteristics as the hazardous waste, the mixture becomes a non-exempt hazardous waste re- gardless of fhe relative volumes or concentrations of the wastes. In other words, for both scenarios, the wastes could become non-exempt even if only one barrel of hazardous waste were mixed with 1 0,000 barrels of exempt waste. NOTE: Mixing a characteristic hazardous wasfe with a non-hazardous or exempt waste for the purpose of rendering the hazardous waste non-hazardous or less hazardous might be considered a treatment process subject to RCRA Subti- tle C hazardous waste regulations and appropriate permitting requirements. Listed hazardous wastes are those wastes listed as hazardous in the Code of Federal Regulations under Subpart D of 40 CFR Part 261. ------- The following flowchart depicts the various possible mixtures and their exempt and non-exempt status. Possible Waste Mixtures Exempt Waste >c Does Mixture Exhibit Any Hazardous Characteristic Exhibited by Non-exempt Waste? Yes Listed Hazardous Waste Non-hazardous Waste Exempt Waste Exempt Waste (See Note on Previous Page) Non-exempt Characteristic Hazardous Waste ------- OMMON MISUNDERSTANDINGS •icomplete understanding of the hazardous waste regula- 'ions can result in misinterpretations of the regulatory status of various wastes. The most common misunderstandings of that arise with the RCRA Subtitle C exemption and hazardous waste determinations are presented here for clarification. Misunderstanding: All wastes located at E&P sites are exempt. IFcict: All wastes located at E&P sites are not necessarily ex- empt. To be considered an exempt waste, the waste must have been generated from a material or process uniquely associated with the exploration, development, and production of crude oil and natural gas. For exam- ple, a solvent used to clean surface equipment or machinery is not exempt because it is not uniquely as- sociated with exploration, development, or production operations. Conversely, if the same solvent were used in a well, it would be exempt because it was generated through a procedure that is uniquely associated with production operations. ------- Misunderstanding: All service company wastes are exempt. Fact: Not all service company wastes are exempt. As with all oilfield wastes, only those wastes generated from a material or process uniquely associated with the explo- ration and production of oil and gas are considered exempt. The previous example of solvents used for cleaning equipment and machinery would also apply in this case — the solvent is not an exempt waste. Misunderstanding: Unused products are exempt. Facts Unused products, if disposed of, are not exempt, re- gardless of their intended use, because they have not been used and therefore are not uniquely associated with the exploration or production of oil and gas. When unused products become waste (e.g., they are disposed of), they are subject to RCRA Subtitle C haz- ardous waste regulations if they are listed or exhibit a hazardous characteristic. Misunderstanding: All exempt wastes are harmless to human health and the environment. Fact: Certain exempt wastes, while excluded from RCRA Sub- title C hazardous wastes control, might still be harmful ------- to human health and the environment if not properly managed. The exemption relieves wastes that are uniquely associated with the exploration and produc- tion of oil and gas from regulation as hazardous wastes under RCRA Subtitle C but does nof indicate the hazard potential of the exempt waste. Additionally, some of these wastes might still be subject to state haz- ardous or non-hazardous waste regulations or other federal regulations (e.g., hazardous materials transpor- tation regulations, reserve pit regulations, and National Pollutants Discharge Elimination System (NPDES) or state discharge regulations) unless specifi- cally excluded from regulation under those laws. *+ * Misunderstanding: Any mixture of a non-exempt hazardous waste with an exempt waste becomes an exempt waste. Fact: Not all mixtures of a non-exempt hazardous waste with an exempt waste become exempt wastes. Generally, a mixture of a listed hazardous waste with an exempt waste becomes a non-exempt hazardous waste. Also, a mixture of a hazardous waste that exhibits one of the characteristics of a hazardous waste (ignitability, cor- rosivity, reactivity, or toxicity) with an exempt waste, becomes a non-exempt characteristics hazardous waste if the mixture exhibits one of the same hazard- ous characteristics as the original hazardous waste. Conversely, if the mixture does not exhibit one of the same hazardous characteristics of the hazardous ------- waste, the mixture becomes a non-hazardous exempt waste. As previously noted, mixing a non-exempt haz- ardous waste with an exempt waste for the purpose of rendering the hazardous waste non-hazardous or less hazardous may be considered a treatment process and must be conducted in accordance with applicable RCRA Subtitle C regulations and permitting requirements. Misunderstanding: A waste exempt from RCRA Subtitle C regulation is also exempt from state and other federal waste man- agement regulations. Fact: The exemption applies only to the federal requirements of RCRA Subtitle C. A waste that is exempt from RCRA Subtitle C regulation might be subject to more strin- gent or broader state hazardous and non-hazardous waste regulations and other state and federal program regulations. For example, oil and gas exploration and production wastes are subject to regulation under the Clean Air Act (CAA), Clean Water Act (CWA), Safe Drinking Water Act (SDWA), and Oil Pollution Act of 1990(OPA). ------- JREQUENTLY ASKED QUESTIONS Deceives calls on a regular basis requesting answers to ques- s related to the E&P exemption. The most common questions answers are listed below. Are RCRA-exempt wastes also exempt under other federal laws? Not necessarily. Unless specifically excluded from regulation under other federal laws, RCRA-exempt wastes might still be subject to regulation under authorities other than RCRA. Q A What is the benefit of the RCRA exemption if the operator is still liable for cleanups under RCRA? Although the operator might still be liable for cleanup actions under RCRA for wastes that pose an imminent and substantial endangerment to human health and the environment, the RCRA exemption does allow the operator to choose a waste manage- ment and disposal option that is less stringent and possibly less costly than those required under RCRA Subtitle C. However, the operator should make every effort to choose the proper manage- ment and disposal procedures for the particular waste to avoid the need for later cleanup action. ------- Q A Q A Q A When is a waste considered "uniquely associated with" exploration and production operations? A waste is "uniquely associated with" exploration and production operations if it is generated from a material or procedure that is necessary to locate and produce crude oil or natural gas. Also, a waste is "uniquely associated with" exploration and production operations if it is generated from a material or procedure that only occurs during the exploration and production of crude oil or natural gas. A simple rule of thumb for identifying "uniquely associated wastes" is whether the waste came from downhole or otherwise was generated in contact with the oil or gas production stream for the purpose of removing water or other contaminants from the well or the product. *+ * Are wastes generated from a transportation pipeline considered exempt wastes under RCRA Subtitle C? No. The RCRA Subtitle C exemption only applies to wastes generated from the exploration, development, and production (i.e., primary field operations) of crude oil or natural gas. Hence, wastes generated from the transportation of crude oil or natural gas are not RCRA-exempt. Do exempt wastes lose their exempt status if they undergo custody transfer and are transported offsite for disposal? No. Custody transfer is used to define the endpoint of production operations for crude oil and applies only to the change ownership of the product (e.g., crude oil). Exempt wastes maintain their exempt status even if they undergo custody transfer and are transported offsite for disposal or treatment. ------- Q A Q A Are all wastes generated at facilities that treat or reclaim exempt wastes also exempt? No. The exemption applies only to those wastes derived from ex- empt wastes, not to additional wastes generated by the treatment or reclamation of exempt wastes. For example, if a treatment facility uses an acid in the treatment of an exempt waste, any waste derived from the exempt waste being treated is also exempt but the spent acid is not. * +* When does transportation begin? For crude oil, transportation begins at the point of custody transfer of the oil or, in the absence of custody transfer, after the endpoint of production separation and dehydration. Storage of crude oil in stock tanks at production facilities is considered part of the production separation process, not transportation, and is included in the exemption. For natural gas, transportation begins at the point where the gas leaves the facility after production separation and dehydration at the gas plant. Natural gas pipelines between the gas well and the gas plant are considered to be part of the production process, rather than transportation, and wastes that are uniquely associated with production that are generated along such a pipeline are exempt. ------- EPA periodically issues interpretive letters regarding the oil and gas exemption. One such letter was in response to a request for clarification of the exempt or non-exempt status of wastes gener- ated at natural gas compressor stations. In some regions, such as the Appalachian states, natural gas might not require sweet- ening or extensive dehydration. Therefore, the gas generally does not go to a gas plant but is carried from the wellhead to a main transmission line and, in some cases, directly to the cus- tomer. Compressor stations are located as needed along the pipelines that run between the wellhead and the main transmis- sion line or the customer to maintain pressure in the lines. The Agency has taken the position that these compressor stations (in the absence of gas plants, and handling only local production) should be treated the same as gas plants, and that wastes gener- ated by these compressor stations are exempt. On the other hand, compressor stations located along main gas transmission lines are considered to be part of the transportation process, and any wastes generated by these compressor stations are non-exempt. ------- ENSIBLE WASTE MANAGEMENT • n r ent operators will design E&P facilities and processes to •i mize potential environmental threats and legal liabilities. A has been promoting sensible waste management practices ough a number of joint efforts with organizations such as API and the Interstate Oil and Gas Compact Commission (IOGCC). The following waste management suggestions have been com- piled from publications produced by these organizations as well as from literature available from industry trade associations, trade journals, and EPA. ------- Suggested E&P Waste Management Practices Size reserve pits properly to avoid overflows. Use closed loop mud systems when practical, particularly with oil-based muds. Perform routine equipment in- spections and maintenance to prevent leaks or emissions. Reclaim oily debris and tank bottoms when practical. Review material safety data sheets (MSDSs) of materials used, and select less toxic alter- natives when possible. Minimize waste generation, such as by designing systems with the smallest volumes possible (e.g., drilling mud systems). Reduce the amount of excess fluids entering reserve and production pits. Do nof place non-exempt wastes in reserve or production pits. Design the drilling pad to con- tain stormwater and rigwash. Recycle and reuse oil-based muds and high density brines when practical. Minimize the volume of stored at facilities. Construct adequate around materials an age areas to contain Perform routine ins materials and wast areas to locate leaking contai Train personne waste manage ------- itt^^^ OURCES OF INFORMATION tional information regarding the exemption of E&P wastes RCRA Subtitle C regulations can be obtained from the fol- ng publications and organizations. Publications Title: EPA "Report to Congress: Management of Wastes from the Exploration, Development, and Production of Crude Oil, Natural Gas, and Geothermal Energy," December 1987, NILS Publication No. PB 88-146212. Available from: National Technical Information Service 5285 Port Royal Road Springfield, VA 22161 703 487-4650 Title: "Regulatory Determination for Oil and Gas and Geo- thermal Exploration, Development, and Production Wastes," July 6, 1 988, Federal Register Volume 53, Pages 25446 to 25459. Available from: RCRA/Superfund Hotline Washington, DC 800 424-9346 ------- Title: "Clarification of the Regulatory Determination for Wastes from the Exploration, Development, and Pro- duction of Crude Oil, Natural Gas and Geothermal Energy," March 22, 1993, Federal Register Volume 58, Pages 1 5284 to 15287. Available from: RCRA/Superfund Hotline Washington, DC 800 424-9346 Title: "API Environmental Guidance Document: Onshore Solid Waste Management in Exploration and Produc- tion Operations," January 1989. Available from: American Petroleum Institute 1 220 L Street, NW. Washington, DC 20005 202 682-8375 Title: "Oil and Gas Exploration and Production Field Personnel Pollution Prevention Training." Available from: National Environmental Training Association 2930 East Camelback Road, Suite 1 85 Phoenix, AZ 85016-4412 602 956-6399 ------- OTHER SOURCES OF INFORMATION U.S. Environmental Protection Agency Office of Solid Waste Oil and Gas Industry Section (5302W) 401 M Street, SW. Washington, DC 20460 703 308-8424 RCRA/Superfund Hotline Washington, DC 800 424-9346 Safe Drinking Water Hotline Washington, DC 800426-4791 ------- We welcome your comments. Please let us know if you found this publication to be informative and helpful. We would also like to receive your suggestions for improving this publication and for adding information that would be useful to you on this topic. Thank you. Comments: FOLD HERE Optional: Name: Company: Street: City: State: Zip: ------- PLACE POSTAGE HERE U.S. Environmental Protection Agency Office of Solid Waste Oil and Gas Industry Section (5302W) 401 M Street, SW Washington, DC 20460 ------- |