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     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,

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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.

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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.

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       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.                 *

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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.

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                                    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.

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   -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.

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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

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    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.

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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


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               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.

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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

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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.

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     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.

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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

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       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.

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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

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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).

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    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.

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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.

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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.

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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.

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       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.

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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

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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

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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

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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

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We would also like to receive your suggestions for
improving this publication and for adding information
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                                     PLACE
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                                     HERE
U.S. Environmental Protection Agency
Office of Solid Waste
Oil and Gas Industry Section (5302W)
401 M Street, SW
Washington, DC 20460

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