Abstract
Wastes generated by oil and gas exploration, development, and production include many environmental contaminants, such as heavy metals, organic compounds, and inorganic constituents. For various reasons, the 1980 amendments to the Resource Conservation and Recovery Act (RCRA) temporarily exempted certain categories of wastes from regulation as hazardous wastes. This exemption included drilling fluids, produced water, and other wastes associated with the exploration, development, or production of crude oil or natural gas or geothermal energy. The amendments also required that the Environmental Protection Agency (EPA) study these wastes to determine whether they should be regulated under the hazardous waste management provisions of RCRA (Subtitle C), whether existing federal and state regulations are adequate, or whether other options should be explored. The conclusions of EPA's review of these exempt wastes may have significant implications for oil and gas operators. This paper examines waste management practices that are currently employed, with particular focus on operations in the Appalachians. Oil and gas production in the Appalachian basin tends to be dominated by small operators and is often on the edge of economic viability. This makes regulatory requirements for waste disposal a major issue in this province.
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