--> Abstract: The RCRA Exemption for Oil & Natural Gas Exploration and Production Wastes - What You May Not Know!, by D. L. Hippensteel; #90928 (1999).

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HIPPENSTEEL, DAVID L.
U.S. Dept. Of Energy - Nevada Ops Office

Abstract: The RCRA Exemption for Oil & Natural Gas Exploration and Production Wastes - What You May Not Know!

The U.S. Environmental Protection Agency, in 1988, ruled that wastes associated with exploration, development and production of crude oil or natural gas were exempt from regulation under Subtitle C of the Resource Conservation and Recovery Act. Along with this ruling, the U.S. Environmental Protection Agency created lists of wastes related to oil and natural gas exploration, development and production which were exempt from and not exempt from Subtitle C regulation. The key defining criteria as to whether a given waste is exempt or not exempt lies in the waste's application to the exploration, development or production of crude oil or natural gas. For a waste to be exempt, it must be unique to the oil and natural gas exploration, development or production industry. This criteria has been applied and modified throughout its existence to exempt several groups of such wastes. The correct application of this exemption to offshore oil and natural gas exploration, development or production is critical to successfully managing wastes associated with all aspects of offshore drilling. Too often, serious mistakes are made in offshore waste management due to a misunderstanding of the exemption. While many types of offshore service company wastes are well associated with hydrocarbon exploration and production, those wastes have equally strong associations with other non-hydrocarbon industries. Many wastes commonly associated with offshore service companies are not exempt and pose detailed requirements for storage and disposal. Understanding exactly what wastes meet the exemption and what wastes do not is critical to continued, successful and efficient offshore oil and gas exploration.

AAPG Search and Discovery Article #90928©1999 AAPG Annual Convention, San Antonio, Texas