FOX, TIMOTHY C., State of Montana, Billings, MT

ABSTRACT: Oil and Gas Production Solid Waste Management in Montana: A Report on the Montana Board of Oil and Gas Conservation Solid Waste Management Project

The U.S. EPA's July 6, 1988, document entitled "Regulatory Determination for Oil and Gas and Geothermal Exploration, Development and Production Wastes," concluded that regulation for E & P wastes was not necessary under Subtitle C of the Resource Conservation and Recovery Act (RCRA). The EPA's regulatory determination also concluded that some waste management regulatory gaps exist among those states with oil and gas production. The EPA pledged to work with the states to develop effective E & P waste management regulatory programs. This paper will briefly outline the Montana Board of Oil and Gas Conservation's (Board) existing solid waste management regulatory program, and will report the findings of a $300,000, EPA-funded, oil and gas production waste characterization and wast management project conducted by the Board in 1992.

The results of six weeks of field work will be selectively reviewed, including data collected in over seventy oil and gas well environmental site assessments, and more than 140 production solid waste sample analyses. Wastes were analyzed for ignitability, corrosivity, reactivity, toxicity (TCLP), and total petroleum hydrocarbons (TPH). The project evaluates the environmental impacts of past and present production waste management practices. The results of the project's production waste management technology, literature, and regulatory review will also be briefly presented. The project, and this paper, will conclude with suggestions for environmentally preferred and economically feasible oil and gas production waste handling, treatment, and disposal methods, and with a look at possible changes to Montana's oil and gas production solid waste management regulatory program.

The paper presenter Mr. Fox, is the author of the research model for the EPA grant application, and is the project manager for the project. Mr. Fox is the Environmental Practices Committee Chairman of the newly formed American Association of Petroleum Geologist's (AAPG) Division of Environmental Geosciences (DEG).

AAPG Search and Discovery Article #90987©1993 AAPG Annual Convention, New Orleans, Louisiana, April 25-28, 1993.