EPA Initiatives for Improving the Management of Crude Oil and Natural Gas Exploration and Production Wastes

Abstract

Abstract Pollution prevention and waste minimization have become essential components of exploration and production (E and P) operations. Environmental accountability necessitates including pollution prevention and waste minimization in well planning and engineering, and waste management programs. Viable approaches should include waste minimization guidelines, employee training, and development of innovative technologies in addition to good housekeeping practices and product substitution. This paper presents several initiatives instituted by the Office of Solid Waste (OSW) of the U.S. Environmental Protection Agency (EPA) for improving the management of E and P wastes. Through these initiatives OSW encourages a cooperative effort among industry, regulatory agencies, and other interested parties to develop creative solutions for improving E and P waste management practices. Introduction In 1980, Congress amended the Resource Conservation and Recovery Act (RCRA) and temporarily exempted from regulation as hazardous wastes those drilling fluids, produced water, and other wastes associated with the exploration, development, and production of crude oil and natural gas. The 1980 Amendments required EPA to study the exempted wastes and submit a Report to Congress detailing the findings of the study and to make recommendations based on the findings. In December 1987, EPA submitted a Report to Congress which concluded that the potential risks to human health and the environment were small and that only a few constituents appeared to be of potentially significant concern. The Report to Congress noted, however, that of the waste management methods in use at the time, some posed the potential for adverse environmental impact if improperly implemented. EPA published a regulatory determination in July 1988 recommending that E and P wastes not be regulated as hazardous wastes under RCRA Subtitle C. EPA further stated that, although existing state and Federal programs were generally adequate, improvements should be made in some programs. The regulatory determination announced EPA's intent to implement a "three-pronged strategy" to address the issues E and P wastes create by:improving federal programs under existing authorities in Subtitle D of RCRA, the Clean Water Act, and Safe Drinking Water Act;working with states to encourage changes in their regulations and enforcement to improve some programs; and,working with Congress to develop any additional statutory authorities that may be required. In the 1980 Amendments, Congress also directed EPA to develop a research, development, and demonstration (RD and D) plan outlining various topics that federal and state governments and/or industry could pursue. In EPA's regulatory determination, the Agency suggested that the RD and D plan should include, among other topics: alternative waste management technologies, waste minimization techniques, materials substitution, and recycling and reuse. OSW is pursuing opportunities to improve state and federal regulatory programs and to enhance E and P waste management practices. Projects underway or proposed include: sponsorship of a second environmental symposium to encourage the exchange of information, review of state regulations to identify possible program gaps, study of selected low volume - high risk waste streams, studies of industry trends in focused areas, and industry outreach. P. 17