Many wastes generated during the exploration, development, and production of crude oil, natural gas, and geothermal (E&P Wastes) are excluded from regulation as a hazardous waste pursuant to a RCRA conditional exclusion at 40 CFR 261.4(b)(5). While an earlier article listed examples of wastes generated by the crude oil, natural gas, and geothermal industry during their exploration, production, and development that are excluded from regulation as hazardous waste, there are other wastes from the same industries and similar processes that are not excluded. A list of some examples of non-exempt E&P Wastes follows:
Non-Exempt E&P Wastes Include:
|Unused fracturing fluids or acids||Boiler scrubber fluids, sludge, and ash||Gas plant cooling tower cleaning wastes|
|Sanitary wastes||Painting wastes||Incinerator ash|
|Vacuum truck and drum rinsate from trucks and drums transporting or containing non-exempt waste||Liquid and solid wastes generated by crude oil and tank bottom reclaimers*||Oil and gas service company wastes such as empty drums, drum rinsate, sandblast media, painting wastes, spent solvents, spilled chemicals, and waste acids|
|Boiler cleaning wastes||Boiler refractory bricks||Laboratory wastes|
|Caustic or acid cleaners||Refinery wastes||Pesticide wastes|
|Waste in transportation pipeline-related pits||Waste compressor oil, filters, and blowdown||Drums, insulation, & miscellaneous solids|
|Used equipment lubricating oils||Used hydraulic fluids||Radioactive tracer wastes|
- *Although non-E&P wastes generated from crude oil and tank bottom reclamation operations (eg. waste equipment cleaning solvent) are non-exempt, residuals derived from exempt wastes (eg. produced water separated from tank bottoms) are exempt. Refer to the Federal Register notice for more information (FR 58 pages 15284 to 15287).
- The list of non-exempt E&P Wastes is not mean to be all inclusive.
Remember: Just because a waste is generated by the exploration, development, and production of crude oil, geothermal, or natural gas does not mean it is excluded from regulation as a hazardous waste
These wastes – unless excluded elsewhere or not meeting the definition of a listed or characteristic hazardous waste – must be managed as a hazardous waste. Or, as in the case of the Radioactive tracer wastes, they may be managed under regulations other than those of the Resource Conservation and Recovery Act (RCRA).
Not sure of your hazardous waste generator status?
The generation of a hazardous waste, depending on your hazardous waste generator status may require you to provide initial and annual training for all facility personnel who require knowledge of the regulations in order to complete their job duties. I provide this training. Contact me for a free training consultation.
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