BMP of Oil and Gas Development

Solid Waste

Solid Waste Management

The American Petroleum Institute (API) estimates that approximately 1.21 barrels of total drilling waste are generated for every foot drilled in the United States. Of this total drilling waste, nearly 50% is solid drilling waste. The accumulated volume of solid drilling waste generated yearly is approximately 139,961,305 barrels, which is equivalent to 29,097,984 cubic yards of solid drilling waste -- enough generated waste to fill almost 9000 Olympic swimming pools.  

The oil and gas industry must dispose of this waste in accordance with various laws and regulations of federal, state and local governments.   In 1976, Congress enacted the Resource Conservation and Recovery Act (RCRA) (codified at 40 C.F.R. 239 – 299),  to classify solid waste as either hazardous or nonhazardous and to provide guidance for managing both. Hazardous waste is regulated under Subtitle C of RCRA; other solid wastes are regulated under Subtitle D.  In 1978, EPA proposed to exempt oil and gas exploration and production (E&P) waste from the Subtitle C hazardous waste rules (43 Federal Register 58946). The exemption was first codified in the 1980 amendments to RCRA (Solid Waste Disposal Amendments Act of 1980), which was the 1980 amendment to RCRA. The Act required that the EPA conduct further studies about E&P waste and report to Congress by October 1982. EPA missed that deadline and submitted their study in December 1987. In 1988, EPA released a regulatory determination that regulation of oil and gas E&P waste under RCRA Subtitle C was not warranted. The exemption for oil and gas exploration and production waste is now codified at 40 C.F.R. 261.4 (b)(5). In 1988, EPA also published a list of exempt and non-exempt wastes.  (See Figure A-1)  Consequently, most oil and gas exploration and production waste is regulated under Subtitle D as “solid waste.”

For more information on RCRA, see the Law and Policy Waste Management page.

Regulatory Agencies

A State Solid Waste Plan must “address all solid waste in the State that poses potential adverse effects on health or the environment or provides opportunity for resource conservation or resource recovery” (40 C.F.R. 256.02(a)(1)).

The EPA is the federal agency with principal authority to implement RCRA, but EPA can delegate regulatory authority to states.  These states, said to have “primacy,” then regulate handling, treatment, and disposal of hazardous waste through statutes and regulations at least as effective as RCRA and EPA’s regulations. 

The states regulate nonhazardous (solid) waste through a solid waste management plan approved by EPA.  Unlike its Subtitle C regulations for hazardous waste, EPA has not promulgated regulations dictating how states should manage solid waste.  The only exceptions are criteria for nonhazardous, nonmunicipal landfills (40 C.F.R. Part 257) and municipal solid waste disposal facilities (40 C.F.R. Part 258).  EPA’s principal role in solid waste management is in setting national goals, developing educational materials and providing leadership and technical assistance.

Resources

Environmental Protection Agency:

   RCRA Regulations

 Solid Waste Laws and Regulations

Regulations/Closure Criteria

Solid Drilling Waste is not classified as either municipal waste or hazardous waste by RCRA, but put in its own category called Industrial D. Industrial D consists of all other solid wastes that cannot be classified as either municipal or hazardous waste. Because of this diverse classification category, there are no set federal criteria regulating design, operation, or closure of solid waste disposal facilities. Instead, the EPA states that “it is loosely regulated by RCRA Subtitle D and 40 CFR 257, Subpart A which governs those solid waste disposal facilities that do not meet the definitions of a municipal solid waste landfill.”

Practices for the design, construction, operation and closure of solid waste disposal facilities are beyond the scope of this website, which focuses on the surface impacts of development within an oil and/or gas field.   Nevertheless, the following references may be useful to the reader in choosing a waste disposal facility or in managing wastes on-site.

The “Guide for Industrial Solid Waste Management” is a document prepared by the EPA’s Headquarter Office and 12 representatives from the Association of State and Territorial Solid Waste Management Officials (ASTSWMO). The guide contains voluntary criteria to aid facility managers and state and tribal environmental agencies in utilizing best management practices and balancing protective design, monitoring, and operating practices for the disposal of industrial waste.

Guidelines for E&P Waste Management

http://www.api.org/aboutoilgas/sectors/explore/guidelines.cfm
These guidelines were a cooperative effort of representatives of the oil and gas industry, commercial waste management facilities, and state governments.  They are intended to identify design construction and operational options that may be used, depending on site-specific conditions at facilities, to protect human health and the environment.

The American Petroleum Institute (API) is a trade association that advocates for petroleum corporations and assists the industry in understanding regulations. They also fund and conduct research into topics such as the environmental effects of the petroleum industry. According to API, “more than 80% of the companies producing oil and natural gas in the United States are small often with fewer than 10 employees. Numbering in the thousands, these smaller companies usually operate the most marginal wells, and thus, are very sensitive to price and operating cost changes. A large number of proposed environmental regulations are in force or are under consideration and could affect the economic viability of many domestic operators.” -American Petroleum Institute

Environmental Guidance Document:  Waste Management in Exploration and Production Operations  (February 1997). API E5 (2nd ed.) American Petroleum Institute

This document reflects our industy’s continuing commitment to environmental protection.  It provides guidance for minimizing the direct and indirect environmental impacts of solid wastes originating from typical exploration and production (E&P) activities, which include exploration, drilling, well completions and workovers, field production, and gas plant operation.”

Other API resources:

Environmental Regulation of the Exploration and Production Industry

Waste Hierarchy

Solid waste means any garbage, refuse, sludge from a waste treatment plant, water supply treatment plant, or air pollution control facility and other discarded material, including solid, liquid, semisolid, or contained gaseous material resulting from industrial, commercial, mining, and agricultural operations, and from community activities, but does not include[, as applicable to oil and gas development] . . . industrial discharges which are point sources subject to [NPDES] permits . . ..      
40 C.F.R. 257.2 Definitions

The EPA, various state agencies and industry organizations and companies recognize that disposing of waste should not be the first line of defense for protecting the environment.  Rather, waste minimization – pollution prevention – should dominate the strategy.  The four steps in management of waste are:

Source Reduction

Avoiding waste generation, generating the least volume, or generating the least toxic waste possible.

  • Material elimination
  • Inventory control and management
  • Material substitution
  • Process modification
  • Improved housekeeping
  • Return of unused material to supplier

Recycling/Reuse

Reclaiming useful constituents of a waste material or removing contaminants from a waste so that it can be reused.  Also may involve the use of a waste as a substitute product for a commercial product.

  • Reuse
  • Reprocess
  • Reclaim
  • Use as fuel
  • Underground injection for enhanced recovery
  • Roadspreading

Treatment

Any method, technique, or process that changes the physical, chemical, or biological character of a waste. (Note that treatment does not necessarily prevent the creation of pollutants.)

  • Filtration
  • Chemical treatment
  • Biological treatment
  • Thermal treatment
  • Extraction
  • Chemical stabilization
  • Incineration
  • Landfarming
  • Landspreading

Disposal

Colorado Drill Cutting Injection Study
ExxonMobil Development Company conducted the first subsurface injection of drill cuttings in Colorado an effort to reduce the environmental footprint of drilling operations. The operator demonstrated injection as a technically feasible option for drilling waste disposal during full-field development.

The discharge, deposition, injection, dumping, spilling, leaking, or placing of any waste into or on land, water, or air.

  • Landfills
  • NPDES discharge
  • Solidification
  • Burial
  • Underground injection for disposal

BMP Spotlight:
Scott Environmental Services INC.

SESIRecognizing the enormous problem of waste generated by the oil and gas industry and the need for reducing the environmental footprint of operations, Scott Environmental Services Inc. (SESI) is a progressive company providing environmental waste management services to the oil and gas industry.  SESI brings innovative solutions to the variety of environmental, safety and operational problems of the industry approaching each problem with an understanding of the latest technologies, in a cost-effective manner, and in accordance with best management practices.   In their work, SESI applies the Environmental Protection Agency’s (EPA) waste hierarchy of methods  – source reduction, recycling/reuse, treatment, and disposal. 

For more information on Scott Environmental Services and their work, see the SESI BMP Spotlight.

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