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Proper Management of Oil and Gas Exploration and Production Waste

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Natural Gas Extraction by Hydraulic Fracturing

Wastes generated from crude oil and natural gas exploration and production (E&P wastes) are generally subject to regulation under RCRA Subtitle D and state regulations, and many state governments have specific regulations and guidance for E&P wastes. In addition, some states are developing legislation and regulations in response to the increase in the use of hydraulic fracturing, including requirements related to waste management.

As the use of hydraulic fracturing has increased, so too have concerns about potential impacts on public health and the environment, including potential impacts arising from improper management of wastes from E&P activities. Proper waste management is important for all E&P wastes, including those that are associated with hydraulic fracturing activities.

Wastes from Hydraulic Fracturing | State Regulations | Voluntary Management Practices

Wastes Associated with Hydraulic Fracturing

Natural gas plays a key role in our nation's clean energy future. The United States has vast reserves of natural gas that are commercially viable as a result of advances in horizontal drilling and hydraulic fracturing technologies enabling greater access to gas in shale formations. Responsible development of America's shale gas resources offers important economic, energy security, and environmental benefits.

Oil and gas exploration and production well installation operations typically comprise three stages:

  1. Well Drilling and Completion Stage
    Wastes Produced:
  2. Well Stimulation Stage (hydraulic fracturing)
    Wastes Produced:
  3. Well Production Stage
    Wastes Produced:

During hydraulic fracturing specially engineered fluids containing chemical additives and proppant (eg., sand) are pumped under high pressure into a well to create and hold open fractures within the geologic formation. Hydraulic fracturing is often performed in stages, and following each stage, some fluids return to the surface as fracturing fluid returns ('flowback').

It is important to note that the use of horizontal drilling in conjunction with hydraulic fracturing can often result in large volumes of flowback, a key attribute distinguishing wastes generated during hydraulic fracturing in unconventional reservoirs from wastes generated during other types of E&P activities. For example, larger volumes of flowback require larger on-site storage capacity, either using land-based units (pits) or tanks.

State Regulations for Management of Wastes from Oil and Gas and E&P Activities

While many E&P wastes are exempt from regulation as hazardous waste under the Resource Conservation and Recovery Act (RCRA) Subtitle C, these wastes are generally subject to non-hazardous waste regulation under RCRA Subtitle D and applicable state regulations. Many state governments have specific regulations and guidance for E&P wastes.

Over the last several years, many states have been developing and updating legislation and regulations in light of the increase in the use of hydraulic fracturing, including requirements related to waste management. E&P activity occurring on federal lands is regulated under the jurisdiction of the Department of Interior's Bureau of Land Management (BLM), subject to BLM regulations and guidance. EPA strongly believes that the management of E&P wastes should occur in a manner that prevents releases of hazardous constituents to the environment, particularly releases that may impact groundwater and surface water resources.

US EPA reviewed the waste-related provisions of state regulations as of March 2014, for oil and natural gas waste pits and storage tanks for 26 of 33 gas producing states (ie., states with the most significant shale gas activity). The review examined only the state statutes and regulations and did not include a review of permitting decisions, compliance monitoring, or enforcement actions. EPA consulted the following sources:

In addition, EPA staff contacted each of the 26 reviewed states' primary regulatory agencies to verify cited regulations and ensure recent and ongoing updates to regulations were reflected in the review.

State regulations continue to evolve as hydraulic fracturing issues become more prevalent and additional information becomes available. Below are individual state summaries, and a link to a resource for state regulatory programs.

State E&P regulation summary (PDF) (41 pp, 393 KB)

Voluntary Management Practices for Oil and Gas E&P Wastes

In concert with the application of state regulatory requirements, there are a variety of voluntary management practice guidances (often referred to in industry as "Best Management Practices," or "BMPs") for operators to evaluate and use in the development of site-specific E&P waste management plans.

EPA strongly urges operators to evaluate and, as appropriate, employ practices best suited to prevent releases during the generation and management of E&P wastes including wastes from hydraulic fracturing. EPA agrees with the statement from the Bureau of Land Management that voluntary management guidances for oil and gas E&P wastes should be matched and adapted to meet the site-specific requirements of the project and local environment. Operators should also integrate source reduction and recycling measures into their operations, where practicable.

EPA conducted a literature review/internet search and developed a list of more than 80 publicly available sources of voluntary management practices for oil and gas E&P wastes as they relate to pits, tanks, and land application/disposal. From this list, EPA focused on fourteen key documents/websites that are widely used and developed summaries of the pit, tank, and land application-related management practices contained in the fourteen selected sources.

There is much existing guidance developed and being used by industry, federal, state, and non-governmental organizations. The scope ranges from local to state, regional, national, and international. The guidance documents/websites compiled in this review are readily available to the public. In addition, there are ongoing efforts by the various stakeholder groups to continuously develop additional guidances and improve existing ones.

The report contains six sections:

  1. introduction
  2. methodology
  3. list of publicly available sources of voluntary management practices for oil and gas E&P wastes as they relate to pits, tanks, and land application/disposal
  4. list of selected guidance documents/websites for further analysis
  5. summaries of the relevant practices in the selected guidances
  6. our findings

The summaries in Section 5 contain the following information for each document: sponsoring organization, document/website title, date of publication, website location, general description, and excerpts of the specific sections that concern pits, tanks, and/or land application.

Compilation of Publicly Available Sources or Voluntary Management Practices for Oil and Gas Exploration & Production (E&P) Wastes as They Address, Pits, Tanks, and Land Application (PDF) (98 pp, 722 K)

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