Exemption of Oil and Gas Exploration and Production Wastes from Federal Hazardous Waste Regulations Exemption of Oil and Gas Exploration and ProductionWastes from Federal …

Scope of the Exemption. In December 1978, EPA proposed hazardous waste management standards that included reduced requirements for several types of large volume wastes. Generally, EPA believed these large volume “special wastes” are lower in toxicity than other wastes being regulated as hazardous waste under RCRA. Subsequently, Congress exempted these wastes from the RCRA Subtitle C hazardous waste regulations pending a study and regulatory determination by EPA. In 1988, EPA issued a regulatory determination stating that 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 stringent RCRA Subtitle D solid waste regulations, or under other federal regulations. In addition, although they are relieved from regulation as hazardous wastes, the exemption does not mean these wastes could not present a hazard to human health and the environment if improperly managed. Among the wastes covered by the 1978 proposal were “gas and oil drilling muds and oil production brines.” The oil and gas exemption was expanded in the 1980 legislative amendments to RCRA to include “drilling fluids, produced water, and other wastes associated with the exploration, development, or production 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 associated” specifically includes waste materials intrinsically derived from primary field operations associated with the exploration, development, or production of crude oil and natural gas. The phrase “intrinsically derived from the primary field operations” is intended to distinguish exploration, development, and production operations from transportation and manufacturing operations…

Source: http://www.epa.gov/

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