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CLASSFICATION
OF
OIL & GAS
WASTES
AUTHOR : KANYIKE ROGERS ARNOLD
COURSE UNIT : WASTE MANAGEMENT
DATE OF PREPARATION : 12-OCT-2019
ACRONYMS;
RRC Railroad Commission)
RCRA Resource Conservation and Recovery Act
CFR Code of Federal Regulations
2
Oil and Gas are one of the most important resources in the world and it plays a role in the global
economy. However, the activities of Oil and Gas from most of companies in the world have many
negative impacts on the environment. One of the reasons is due to the waste production from the oil
and gas industry. According to Environmental Quality Act 1974, waste can be defined as any matter
prescribed whether liquid, solid, gaseous or radioactive, which is discharged, emitted, or deposited
in the environment in such volume, composition or manner as to cause an alteration of the
environment.
Oil and Gas sector involves majorly three sectors , that’s the Upstream ,Midstream and Downstream
sector ,with all these sectors producing different types of wastes. The Oil and Gas industry wastes
are widely classified under :
■ Hazardous Wastes
■ Non-Hazardous Wastes
The Hazardous and Non-Hazardous classification of these wastes is further broken down as we are
to see briefly.
3
HAZARDOUS WASTES
Rule 98, subsection (e) requires that you determine if any waste you generate is hazardous oil and
gas waste. You must also maintain a record of each determination for three years. A hazardous Oil
and Gas waste is a waste that meets all four of the following criteria:
 It is an Oil and Gas waste regulated by the RRC(Railroad Commission).
 It is a solid waste as defined by federal hazardous waste regulations.
 It is not specifically exempt from federal hazardous waste regulations in 40 CFR Part 261 (i.e., a
“nonexempt waste”).
 It is either listed as a hazardous waste or exhibits a hazardous waste characteristic.
Solid Wastes as defined by the RCRA(Resource Conservation and Recovery Act):
 A solid waste is any discarded material as defined in 40 CFR (Code of Federal Regulations)
section (§) 261.2. "Solid waste" may be in a solid, semi-solid, liquid, or gaseous form other
discarded material.
4
Discharged Material may include;
 Abandoned materials;
 Materials recycled in a manner that constitutes disposal.
Classification of Hazardous wastes depending on “Listing Hazardous Oil and Gas Wastes”
The first step in determining if a nonexempt oil and gas waste is hazardous is to see if it is listed as a
hazardous waste. EPA has listed numerous types or classes of solid wastes as hazardous wastes
because they:
 Typically exhibit one or more of the characteristics of hazardous waste;
 Have been shown to meet certain human toxicity criteria; or
 Contain any one of the chemical compounds or substances listed by EPA as hazardous
constituents
EPA's regulations contain four lists of listed hazardous wastes; the F, K, P, and U lists.
The Table below “Listed RCRA Hazardous Oil and Gas Wastes,” provides a brief description of the
four lists.
5
Listed RCRA Hazardous Oil and Gas Wastes,” provides a brief description of the four lists.
F-List Hazardous wastes from non-specific
sources
Spent solvents (trichloroethylene,
methylene chloride,
tetrachloroethylene, xylene,
acetone, benzene, ethyl benzene,
methyl ethyl ketone, n-butyl
alcohol, methanol, toluene, and
solvent mixtures/blends that
contain more than 10% of these
solvents)
K-List Hazardous waste from specific sources
EPA LIST TYPE OF WASTE EXAMPLES OF THE OIL AND GAS
WASTES THAT MAY BE ON THE
EPA LISTS
None identified
6
P-List
Commercial chemical products
that become acute
hazardous wastes when disposed
of)
Acrolein, beryllium, carbon
disulfide, vanadium pentoxide
U-List Commercial chemical products
that become toxic wastes when
disposed of)
Acetone, benzene, carbon
tetrachloride, chloroform,
chrysene, formaldehyde,
formic acid, hydrogen fluoride,
hydrogen sulfide, lindane,
mercury, methanol, methyl
ethyl ketone, methyl isobutyl
ketone, methylene chloride,
naphthalene, toluene, xylene
NOTE : Commercial chemical products (P and U lists) are defined as materials which contain either
the pure or technical grade of the listed chemical, crude product, or a formulation in which the listed
chemical is the sole active ingredient.
7
Characteristically categorized Oil and Gas Wastes:
If the nonexempt oil and gas waste is not identified on any of the lists of hazardous waste, it must be
determined whether the waste exhibits one or more of the four hazardous waste characteristics.
Typically, characteristic hazardous oil and gas waste will be of more concern to operators of oil and
gas exploration and production facilities. If the nonexempt oil and gas waste is determined to
exhibit one or more of the characteristics, it is classified as a characteristically hazardous oil and gas
waste. The four characteristics of hazardous waste are;
IGNITABILITY:
A substance is ignitable if it displays any of the following properties.
 Liquids with a flash point less than 140F
 Ignitable compressed gas
 Materials other than liquids that at standard conditions are capable of causing fire by spontaneous
chemical changes, by absorption of moisture, or through friction.
Examples: certain cleaning solvents (may also be listed hazardous wastes), certain degreasers,
certain transportation-pipeline pigging wastes, certain paint wastes
8
REACTIVITY;
 Any waste that reacts violently with water, forms explosive mixtures with water, or generates any
toxic fumes with water - Any waste that is explosive at standard conditions or if heated.
 Any waste that contains cyanide or sulfide at a concentration that will emit toxic cyanide or
sulfide gases when exposed to a pH of 2.0 to 12.5.
Examples: certain waste oxidizers
CORROSIVITY;
A substance is reactive if it displays any of the following properties;
 Aqueous materials with a pH of less than or equal to 2.0 or greater than or equal to 12.5.
 Liquid materials that corrode steel (SAE 1020) at a rate greater than 0.250 inch per year at a test
temperature of 130F.
Examples: certain acid or caustic cleaning wastes, unused well acidizing fluids (that have not been
down the borehole), certain rust removers, waste battery acid
TOXICITY;
 Potential to contaminate ground water by leaching as determined in a laboratory using the
Toxicity Characteristic Leaching Procedure (TCLP) Test
9
NON-HAZARDOUS WASTES
Nonhazardous wastes are subject to regulation under RCRA Subtitle D. Railroad Commission
Statewide Rule 98, “Standards for Management of Hazardous Oil and Gas Wastes,” establishes
equivalent requirements for generators and transporters of hazardous oil and gas waste.
These Oil and Gas wastes are generally categorized under;
Exempt ;
The exempt oil and gas wastes are unique, which is the rational for the exemption. They are
generated in large quantities, but are relatively low in toxicity. Exempt oil and gas wastes are
generated by a large number of individual oil and gas operations.
Exempt wastes make up the bulk (over 99.9%) of all wastes that are regulated by the Railroad
Commission
10
Oil and Gas wastes exempt from RCRA hazardous waste regulation include;
 Produced water
 Drilling fluids and drill cuttings
 Drilling fluids and cuttings from offshore operations disposed on-shore
 Rigwash
 Well completion, treatment, and stimulation fluids
 Workover wastes
 Cooling tower blowdown
 Spent filters, filter media, and backwash (assuming the filter itself is not hazardous and the
residue in it is from an exempt waste stream)
 Packing fluids
 Produced sand
 Pipe scale, hydrocarbon solids, hydrates, and other deposits removed from piping and equipment
prior to transportation
 Hydrocarbon-bearing soil
 Pigging wastes from gathering lines
11
NON-EXEMPT WASTES;
The wastes that EPA has determined are not covered under the exemption may be hazardous wastes
subject to regulation under Rule 98 and RCRA Subtitle C. Nonexempt wastes include, no matter
where generated, those wastes that are not uniquely associated with an exploration and production
activity, such as cleaning wastes or lubricating oil. Further, all wastes that are not associated with
primary field operations, such as wastes associated with pipeline transportation or manufacturing
(e.g., refining) activities, are nonexempt. Table 2 provides the list of nonexempt wastes in EPA’s
regulatory determination.
This is a listing of most, but not all, oil and gas wastes that are not exempt from regulation as
hazardous wastes.
Not all nonexempt wastes are hazardous wastes , some may be non-hazardous For example, empty
drums and insulation will probably not be hazardous waste.
12
RCRA Non-exempt oil and gas wastes include the following;
 Used equipment lubrication oils
 Waste compressor oil, filters, and blowdown.
 Used hydraulic fluids
 Waste in transportation pipeline-related pits
 Caustic or acid cleaners
 Boiler cleaning wastes
 Boiler scrubber fluids, sludges, and ash
 Laboratory wastes
 Sanitary wastes
 Pesticide wastes
 Radioactive tracer wastes
 Insulation, and miscellaneous solids
13
Primary field operations are also categorized under the Non-exempt wastes.
These primary field operations include
 Primary.
 Secondary.
 Tertiary production of oil or gas.
With respect to Oil production, primary field operations include activities occurring at or near the
wellhead or production facility, but before the point where the custody of the oil is transferred from
an individual field facility or a centrally located facility to a carrier for transport to a refiner. In the
event no custody transfer occurs, the primary field operation ends at the last point of separation.
Crude oil stock tanks are considered separation devices for the purpose of defining areas of primary
field operations.
With respect to Natural gas production, primary field operations are those activities occurring at or
near the wellhead, production facility, or gas plant (including gathering lines to the plant), but before
the point of transfer of the gas from an individual field facility, a centrally located facility, or a gas
plant to a carrier for transport to market, or before the point of the use of natural gas in a
manufacturing process.
14
END
OF
PRESENTATION

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Classfication of Oil and Gas Wastes

  • 2. AUTHOR : KANYIKE ROGERS ARNOLD COURSE UNIT : WASTE MANAGEMENT DATE OF PREPARATION : 12-OCT-2019 ACRONYMS; RRC Railroad Commission) RCRA Resource Conservation and Recovery Act CFR Code of Federal Regulations 2
  • 3. Oil and Gas are one of the most important resources in the world and it plays a role in the global economy. However, the activities of Oil and Gas from most of companies in the world have many negative impacts on the environment. One of the reasons is due to the waste production from the oil and gas industry. According to Environmental Quality Act 1974, waste can be defined as any matter prescribed whether liquid, solid, gaseous or radioactive, which is discharged, emitted, or deposited in the environment in such volume, composition or manner as to cause an alteration of the environment. Oil and Gas sector involves majorly three sectors , that’s the Upstream ,Midstream and Downstream sector ,with all these sectors producing different types of wastes. The Oil and Gas industry wastes are widely classified under : ■ Hazardous Wastes ■ Non-Hazardous Wastes The Hazardous and Non-Hazardous classification of these wastes is further broken down as we are to see briefly. 3
  • 4. HAZARDOUS WASTES Rule 98, subsection (e) requires that you determine if any waste you generate is hazardous oil and gas waste. You must also maintain a record of each determination for three years. A hazardous Oil and Gas waste is a waste that meets all four of the following criteria:  It is an Oil and Gas waste regulated by the RRC(Railroad Commission).  It is a solid waste as defined by federal hazardous waste regulations.  It is not specifically exempt from federal hazardous waste regulations in 40 CFR Part 261 (i.e., a “nonexempt waste”).  It is either listed as a hazardous waste or exhibits a hazardous waste characteristic. Solid Wastes as defined by the RCRA(Resource Conservation and Recovery Act):  A solid waste is any discarded material as defined in 40 CFR (Code of Federal Regulations) section (§) 261.2. "Solid waste" may be in a solid, semi-solid, liquid, or gaseous form other discarded material. 4
  • 5. Discharged Material may include;  Abandoned materials;  Materials recycled in a manner that constitutes disposal. Classification of Hazardous wastes depending on “Listing Hazardous Oil and Gas Wastes” The first step in determining if a nonexempt oil and gas waste is hazardous is to see if it is listed as a hazardous waste. EPA has listed numerous types or classes of solid wastes as hazardous wastes because they:  Typically exhibit one or more of the characteristics of hazardous waste;  Have been shown to meet certain human toxicity criteria; or  Contain any one of the chemical compounds or substances listed by EPA as hazardous constituents EPA's regulations contain four lists of listed hazardous wastes; the F, K, P, and U lists. The Table below “Listed RCRA Hazardous Oil and Gas Wastes,” provides a brief description of the four lists. 5
  • 6. Listed RCRA Hazardous Oil and Gas Wastes,” provides a brief description of the four lists. F-List Hazardous wastes from non-specific sources Spent solvents (trichloroethylene, methylene chloride, tetrachloroethylene, xylene, acetone, benzene, ethyl benzene, methyl ethyl ketone, n-butyl alcohol, methanol, toluene, and solvent mixtures/blends that contain more than 10% of these solvents) K-List Hazardous waste from specific sources EPA LIST TYPE OF WASTE EXAMPLES OF THE OIL AND GAS WASTES THAT MAY BE ON THE EPA LISTS None identified 6
  • 7. P-List Commercial chemical products that become acute hazardous wastes when disposed of) Acrolein, beryllium, carbon disulfide, vanadium pentoxide U-List Commercial chemical products that become toxic wastes when disposed of) Acetone, benzene, carbon tetrachloride, chloroform, chrysene, formaldehyde, formic acid, hydrogen fluoride, hydrogen sulfide, lindane, mercury, methanol, methyl ethyl ketone, methyl isobutyl ketone, methylene chloride, naphthalene, toluene, xylene NOTE : Commercial chemical products (P and U lists) are defined as materials which contain either the pure or technical grade of the listed chemical, crude product, or a formulation in which the listed chemical is the sole active ingredient. 7
  • 8. Characteristically categorized Oil and Gas Wastes: If the nonexempt oil and gas waste is not identified on any of the lists of hazardous waste, it must be determined whether the waste exhibits one or more of the four hazardous waste characteristics. Typically, characteristic hazardous oil and gas waste will be of more concern to operators of oil and gas exploration and production facilities. If the nonexempt oil and gas waste is determined to exhibit one or more of the characteristics, it is classified as a characteristically hazardous oil and gas waste. The four characteristics of hazardous waste are; IGNITABILITY: A substance is ignitable if it displays any of the following properties.  Liquids with a flash point less than 140F  Ignitable compressed gas  Materials other than liquids that at standard conditions are capable of causing fire by spontaneous chemical changes, by absorption of moisture, or through friction. Examples: certain cleaning solvents (may also be listed hazardous wastes), certain degreasers, certain transportation-pipeline pigging wastes, certain paint wastes 8
  • 9. REACTIVITY;  Any waste that reacts violently with water, forms explosive mixtures with water, or generates any toxic fumes with water - Any waste that is explosive at standard conditions or if heated.  Any waste that contains cyanide or sulfide at a concentration that will emit toxic cyanide or sulfide gases when exposed to a pH of 2.0 to 12.5. Examples: certain waste oxidizers CORROSIVITY; A substance is reactive if it displays any of the following properties;  Aqueous materials with a pH of less than or equal to 2.0 or greater than or equal to 12.5.  Liquid materials that corrode steel (SAE 1020) at a rate greater than 0.250 inch per year at a test temperature of 130F. Examples: certain acid or caustic cleaning wastes, unused well acidizing fluids (that have not been down the borehole), certain rust removers, waste battery acid TOXICITY;  Potential to contaminate ground water by leaching as determined in a laboratory using the Toxicity Characteristic Leaching Procedure (TCLP) Test 9
  • 10. NON-HAZARDOUS WASTES Nonhazardous wastes are subject to regulation under RCRA Subtitle D. Railroad Commission Statewide Rule 98, “Standards for Management of Hazardous Oil and Gas Wastes,” establishes equivalent requirements for generators and transporters of hazardous oil and gas waste. These Oil and Gas wastes are generally categorized under; Exempt ; The exempt oil and gas wastes are unique, which is the rational for the exemption. They are generated in large quantities, but are relatively low in toxicity. Exempt oil and gas wastes are generated by a large number of individual oil and gas operations. Exempt wastes make up the bulk (over 99.9%) of all wastes that are regulated by the Railroad Commission 10
  • 11. Oil and Gas wastes exempt from RCRA hazardous waste regulation include;  Produced water  Drilling fluids and drill cuttings  Drilling fluids and cuttings from offshore operations disposed on-shore  Rigwash  Well completion, treatment, and stimulation fluids  Workover wastes  Cooling tower blowdown  Spent filters, filter media, and backwash (assuming the filter itself is not hazardous and the residue in it is from an exempt waste stream)  Packing fluids  Produced sand  Pipe scale, hydrocarbon solids, hydrates, and other deposits removed from piping and equipment prior to transportation  Hydrocarbon-bearing soil  Pigging wastes from gathering lines 11
  • 12. NON-EXEMPT WASTES; The wastes that EPA has determined are not covered under the exemption may be hazardous wastes subject to regulation under Rule 98 and RCRA Subtitle C. Nonexempt wastes include, no matter where generated, those wastes that are not uniquely associated with an exploration and production activity, such as cleaning wastes or lubricating oil. Further, all wastes that are not associated with primary field operations, such as wastes associated with pipeline transportation or manufacturing (e.g., refining) activities, are nonexempt. Table 2 provides the list of nonexempt wastes in EPA’s regulatory determination. This is a listing of most, but not all, oil and gas wastes that are not exempt from regulation as hazardous wastes. Not all nonexempt wastes are hazardous wastes , some may be non-hazardous For example, empty drums and insulation will probably not be hazardous waste. 12
  • 13. RCRA Non-exempt oil and gas wastes include the following;  Used equipment lubrication oils  Waste compressor oil, filters, and blowdown.  Used hydraulic fluids  Waste in transportation pipeline-related pits  Caustic or acid cleaners  Boiler cleaning wastes  Boiler scrubber fluids, sludges, and ash  Laboratory wastes  Sanitary wastes  Pesticide wastes  Radioactive tracer wastes  Insulation, and miscellaneous solids 13
  • 14. Primary field operations are also categorized under the Non-exempt wastes. These primary field operations include  Primary.  Secondary.  Tertiary production of oil or gas. With respect to Oil production, primary field operations include activities occurring at or near the wellhead or production facility, but before the point where the custody of the oil is transferred from an individual field facility or a centrally located facility to a carrier for transport to a refiner. In the event no custody transfer occurs, the primary field operation ends at the last point of separation. Crude oil stock tanks are considered separation devices for the purpose of defining areas of primary field operations. With respect to Natural gas production, primary field operations are those activities occurring at or near the wellhead, production facility, or gas plant (including gathering lines to the plant), but before the point of transfer of the gas from an individual field facility, a centrally located facility, or a gas plant to a carrier for transport to market, or before the point of the use of natural gas in a manufacturing process. 14