SIMS, BART C.
Railroad Commission of Texas, Austin, TX

Abstract: Regulation of Hazardous Waste in the Oil Field: the Railroad Commission of Texas' Approach

Many wastes generated in association with crude oil and natural gas exploration and production activities are exempt from regulation as hazardous waste. However, nonexempt oil and gas waste is subject to a hazardous waste determination, and if determined to be hazardous waste, is subject to standards for management of hazardous waste. Hazardous waste management standards are established by the federal Resource Conservation and Recovery Act, Subtitle C (RCRA Subtitle C). A state may enforce these standards through a hazardous waste program authorized by the U.S. Environmental Protection Agency (EPA), or EPA may retain RCRA Subtitle C authority in a state. The Railroad Commission of Texas enforces standards equivalent to RCRA Subtitle C through Statewide Rule 98, "Standards for Management of Hazardous Oil and Gas Waste." The Railroad Commission of Texas' hazardous oil and gas waste program has not yet been authorized by EPA; therefore, the Railroad Commission of Texas and EPA share parallel authority over hazardous oil and gas waste in Texas.

Statewide Rule 98 is structured to address the application of federal hazardous waste regulation to the unique circumstances of oil and gas operations. This paper provides an overview of the regulatory process for hazardous oil and gas waste in Texas, including the application of important exemptions and exclusions and the most common applicable management standards.

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