Api api e5 1997 scan (american petroleum institute)

Environmental Guidance Document: Waste Management in Exploration and Production Operations API E5 SECOND EDITION, FEBRUARY 1997 American Petroleum Institute Strategies for Today’s Environmental Partnership `,,-`-`,,`,,`,`,,` - Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale One of the most significant long-term trends affecting the future vitality of the petroleum industry is the public’sconcerns about the environment Recognizing this trend, API member companies have developed a positive, forward looking strategy called STEP: Strategies for Today’s Environmental Partnership This program aims to address public concerns by improving industry’s environmental, health and safety performance; documenting performance improvements; and communicating them to the public The foundation of STEP is the API Environmental Mission and Guiding Environmental Principles API standards, by promoting the use of sound engineering and operational practices, are an important means of implementing API’s STEP program API ENVIRONMENTAL MISSION AND GUIDING ENVIRONMENTAL PRINCIPLES The members of the American Petroleum Institute are dedicated to continuous efforts to improve the compatibility of our operations with the environment while economically developing energy resources and supplying high quality products and services to consumers The members recognize the importance of efficiently meeting society’s needs and our responsibility to work with the public, the government, and others to develop and to use natural resources in an environmentally sound manner while protecting the health and safety of our employees and the public To meet these responsibilities, API members pledge to manage our businesses according to these principles: To recognize and to respond to community concerns about our raw materials, products and operations o To operate our plants and facilities, and to handle our raw materials and products in a manner that protects the environment, and the safety and health of our employees and the public o To make safety, health and environmental considerations a priority in our planning, and our development of new products and processes o To advise promptly appropriate officials, employees, customers and the public of in- formation on significant industry-related safety, health and environmental hazards, and to recommend protective measures o To counsel customers, transporters and others in the safe use, transportation and dis- posal of our raw materials, products and waste materials o To economically develop and produce natural resources and to conserve those re- sources by using energy efficiently o To extend knowledge by conducting or supporting research on the safety, health and environmental effects of our raw materials, products, processes and waste materials To commit to reduce overall emissions and waste generation o To work with others to resolve problems created by handling and disposal of haz- ardous substances from our operations o To participate with government and others in creating responsible laws, regulations and standards to safeguard the community, workplace and environment To promote these principles and practices by sharing experiences and offering assistance to others who produce, handle, use, transport or dispose of similar raw materials, petroleum products and wastes `,,-`-`,,`,,`,`,,` - Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale S T D - A P I / P E T R O ES-ENGL L797 m 2 05b4b70 430 m Environmental Guidance Document: Waste Management in Exploration and Production Operations Exploration and Production Department American Petroleum Institute Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale `,,-`-`,,`,,`,`,,` - API E5 SECOND EDITION, FEBRUARY 1997 STD.API/PETRO ES-ENGL L997 0732290 b b L 377 m SPECIAL NOTES `,,-`-`,,`,,`,`,,` - API publications necessarily address problems of a general nature With respect to particular circumstances, local, state, and federal laws and regulations should be reviewed API is not undertaking to meet the duties of employers, manufacturers, orsuppliers to warn and properly train and equip their employees, and others exposed, concerninghealth and safety risks and precautions, nor undertakingtheir obligations under local, state, or federal laws Information concerning safety and health risks and proper precautions with respect to particular materials and conditions should beobtained fromthe employer, the manufacturer or supplier of that material, or the material safety data sheet Nothing contained in any API publication is to be construed as granting any right,by implication or otherwise, for the manufacture, sale, or use of any method, apparatus,or product covered by letters patent Neither should anything contained in the publication be construed as insuring anyone against liability for infringement of letters patent Generally, API guidance documentsare reviewed and revised, reaffirmed, or withdrawn at least every five years.Sometimes a one-time extension of up to two years will be added to this review cycle This publication will no longer be in effect five years after its publication date as an operative API guidance documentor, where an extensionhas been granted, upon republication.Status of the publication canbe ascertained from the API Authoring Department [telephone (202) 682-8000] A catalog of API publications and materials is published annually and updated quarterly by API, 1220 L Street, N.W., Washington, D.C 20005 All rights reserved No part of this work may bereproduced, stored in a retrieval system, or transmitted by any means, electronic, mechanical, photocopying, recording or otherwise, without prior written permission from the publishel: Contact the Publishel; API Publishing Services, 1220 L Street, N W , Washington, D.C 20005 Copyright O 1997 American Petroleum Institute Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale FOREWORD This document reflects our industry’s continuing commitment to environmental protection It provides guidancefor minimizing the direct and indirect environmental impacts of solid wastes originating from typical exploration and production (E&P) activities, which include exploration, drilling, well completions and workovers, field production, and gas plant operation This manual was prepared by the API Production Waste Issues Group, under the jurisdiction of the API Exploration and Production Department ExecutiveCommittee on Environmental Conservation The oil and gas industry must operate where oil andgas deposits are found This means that the exploration and production activities listed above will beconducted in a variety of ecosystems, whose sensitivity to the activitiesof man will vary widely The oil and gas industry must be environmental stewardsin two critical ways: a It must use environmentally sound operating practices to manage materials, land, and the waste generated from exploration and production activities b It must produce oil and gas reserves as efficiently and prudently as possible in order to prevent squandering critical natural resources API publications may be used by anyone desiring to so Every effort has been made by the institute to assure the accuracy and reliability of the data contained in them; however, the institute makes no representation, warranty, or guarantee in connection with this publication an hereby expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal regulation with which this publication mayconflict Suggested revisions are invited and should be submitted to the director of the Exploration and Production Department, American Petroleum Institute, 1220 L Street, N.W., Washington, D.C 20005 `,,-`-`,,`,,`,`,,` - Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale ~~ STC.API/PETRO ES-ENGL L777 m 2 05b4b73 L4T CONTENTS page 1.1 1.2 1.3 1.4 1.5 POLLUTION PREVENTION Introduction API’s Management Practice for Pollution Prevention Media Understanding Operational Impacts Pollution Prevention and wasteMinimization 2.1 2.2 2.3 2.4 2.5 WASTE MANAGEMENT SYSTEM Introduction Summary of a Ten-Step Plan for Waste Management Training Waste Tracking Auditing WASTE GENERATION IN EXPLORATION AND PRODUCTION OPERATIONS Introduction Exploration Drilling Completion and Workover Field Production 10 Gas Plant Operations 14 Transportation Pipelines 16 Offshore Operations 17 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 1 3 4 5 4.1 4.2 4.3 4.4 4.5 4.6 4.7 ENVIRONMENTAL LEGISLATION AND REGULATIONS Introduction 17 The Resource Conservationand Recovery Act (RCRA) 17 The Safe DrinkingWater Act (SDWA) 22 The Clean Water Act (CWA) 23 The Clean Air Act(CAA) 25 The Toxic Substances ControlAct (TSCA) 25 The ComprehensiveEnvironmental Response, Compensation,and Liability Act (CERCLA) 25 4.8 The Oil Pollution Act of 1990 (OPA 90) 27 27 4.9 Other Federal Acts 4.10 Other Regulations and Agreements 29 5.1 5.2 5.3 5.4 5.5 WASTE MANAGEMENT METHODS Introduction 29 Source Reduction 29 Recycling andReclaiming 30 Treatment 30 Disposal 30 6.1 6.2 6.3 6.4 IDENTIFYING MANAGEMENT OPTIONS FOR SPECIFIC WASTES Introduction 38 Produced Water 39 Drilling Wastes 39 Workover and Completion Wastes 41 `,,-`-`,,`,,`,`,,` - Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS V Not for Resale Page 6.5 Tank Bottoms Emulsions Heavy Hydrocarbons and Produced Solids 42 6.6 Contaminated Soil 43 6.7 Used Oils and Solvents 43 6.8 Dehydration and Sweetening Waste 44 6.9 Oily Debris and Filter Media 44 6.10 Gas Plant Process and Sulfur Recovery Waste 45 6.1 Cooling Tower Blowdown Boiler Water Scrubber Liquids and Steam Generator Wastes 45 6.12 Downhole and Equipment Scale 45 6.13 StormwaterRigwash 45 6.14 Unused Treatment Chemicals 46 6.15 Asbestos 46 6.16 Used Batteries 46 6.17 PCB Transformer Oil 46 6.18 NonPCB Transformer Oil 46 6.19 Empty Oil and Chemical Drums 47 47 6.20 Naturally Occurring Radioactive Material 6.21 Geological and Geophysical OperationWastes 47 6.22 Recompression and Facility Utility Wastes 47 APPENDIX A-Guidelines for Developing Area-SpecificWaste Management Plans APPENDIX B-Waste Management PlanningAids APPENDIX C-Summary Waste Table APPENDIX D-Summary of Environmental Legislation and Regulations APPENDIX E-Acronyms APPENDIX F-Reference Materials APPENDIX G-EPA Publication: (EPA 530-K-95-003), May 1995- Crude Oil and Natural Gas Explorationand Production Wastes: Exemption from RCRA Subtitle C Regulation `,,-`-`,,`,,`,`,,` - Figures 1-Media 49 55 57 61 63 67 69 Pathways Tables 1-Ten-Step Plan Summary 2-Overview of Waste Management Methods 3-API Metals Guidance: MaximumSoil Concentrations &Example of E&P Waste Disposal Technique and Applicable ConstituentCriteria A- 1-Ten-Step Plan for Preparing a WasteManagement Plan B-1-Iron Sulfide Scale and Iron Sponge C- I-Summary Waste Table D - ” S u m m q of Key Legislation and Regulations vi Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale 30 33 34 49 56 57 61 ~~ ~ STD.API/PETRO ES-ENGL L777 m 0732270 05bVb75 T L 111 Waste Management in Exploration and ProductionOperations PollutionPrevention f To develop and produce natural resources economically and to conserve those resources by using energy efficiently g To extend knowledge by conducting or supporting research on the safety, health, and environmental effects of our raw materials, products, processes, and waste materials h To commit to reduce overall emissions and waste generation i To work with others to resolve problems created by handling and disposal of hazardous substancesfrom our operations j To participate with government and others in creating responsible laws, regulations, and standards to safeguard the community, workplace, and environment k To promote these principles and practices by sharing experiences and offering assistance to others who produce, handle, use, transport, or dispose of similar raw materials, petroleum products, and wastes 1.1 INTRODUCTION Pollution prevention is the practice of reducing or eliminating pollutant discharges to air, water, or land It includes the development of more environmentally acceptable products, changes in processes and practices, source reduction, beneficial use, environmentally sound recycling, waste minimization, proper waste handling, waste treatment, and proper disposal practices This section presents an overview of media, operational impacts, and waste minimization methods, including theEPA hierarchy of waste management These basic concepts are critical in achieving pollution prevention goals Pollution prevention requires continuous improvement in operating practices Industry should review its use of materials, processes, practices, and products in order to identify ways to reduce or eliminate pollution A practical approach encourages the use or production of environmentally acceptable products while working toward source reduction on the following waste management hierarchy: source reduction recyclinglreuse treatment, and/or land disposal 1.2 API’SMANAGEMENTPRACTICE FOR POLLUTION PREVENTION Both management commitment and comprehensive planning are critical to a successful pollution prevention program Steps to consider in developing and operating such a program include the following: (most preferred) I a Providing management supportfor ongoing pollution prevention activities through appropriate policies, actions, communications, and resource commitments b Developing and implementing a program to improve prevention and early detection and reduce impacts of spills of crude oil and petroleum products and other accidental releases from operations c Developing an inventory of significant releases to air, water, and land; identifying their sources; and evaluating their impact on human health and the environment d Periodically reviewing and identifying pollution prevention options and opportunities, developingapproaches for reducing releases, and settinggoals and schedules for reducing releases and measuring progress; consider the issues of community concerns, technology and economics, and impact on human health and the environment e Including pollution prevention objectives in research efforts and in the design of new or modified operations, processes, and products f Supporting an outreach program to promote pollution prevention opportunities within the industry, including sharing of industry experiences and accomplishments (least preferred) Details are presented in 1.3.2 The API Pollution Prevention Management Practices for API’s Strategies for Today’s Environmental Partnerships (STEP) program embody the petroleum industry’s practical commitment to pollution prevention They provide specific guidelines for compliance with these Guiding Environmental Principles, which are as follows: a To recognize and to respond to community concerns about our raw materials, products, and operations b To operate our plants and facilities, and to handleour raw materials and products in a manner that protects the environment and the safety and health of our employees and the public c To make safety, health, and environmental considerations a priority in our planning, use, and development of new products and processes d To advise promptly appropriate officials, employees, customers, and the publicof information on significant industryrelated safety, health, and environmental hazards and to recommend protective measures e To counsel customers, transporters, and others in the safe use, transportation, and disposal of our raw materials, products, and waste materials 1.3 MEDIA Proper management of wastes is important to the protection of human health and the environment Waste can be transported via three natural carriers-water, soil, and air `,,-`-`,,`,,`,`,,` - Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale STD.API/PETRO ES-ENGL L797 m 0732290 05b4b7b 957 W API E5 All three media may provide pathwaysby which potentially polluting materials can migrate from their original source Thus, materials used and wastes generatedin exploration and production operations should be managed by considering risk to human health and the environment via media pathways (see Figure 1) 1.3.1 Water Fresh water for human consumption, domestic needs, recreation, stock water, irrigation of crops, and industry comes from underground aquifers, lakes, streams, and reservoirs Most fresh water is stored in underground reservoirs called aquifers Aquifers are part of a large water-recycling system as illustrated in Figure These porous formations or sediments can store and transport groundwater from rain, leakage of stream beds, and other sources Materials fromspills or improper waste disposal may contaminate aquifers Of major concern are those aquifers that contain water suitable for drinking Also important are aquifers used for agricultural purposes Pollutants found in water are measured in concentrations of parts per billion (ppb); some of these pollutants may cause that water to fail drinking water standards The quality of aquifer waters can be degraded by pollutants to such a degree that it is not practical to restore the aquifer to drinking water standards 1.3.2 Soil Spills can adversely affect the capacity of soil to support agricultural, industrial, human, and recreational uses Soil acts to retain spilled, improperly stored, or disposedmaterials; however, once in the soil, pollutants can migrate to air and water and be picked upby plants and animals Contam- `,,-`-`,,`,,`,`,,` - Evaporation and transpiration from bgd = billion gallons per day Figure 1-Basic Media of Soil, Air, and Water Can Transport Pollutants Away From Their Original Source Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale ~ STD.API/PETRO ES-ENGL 1777 I I 0732270 U5b4b77 A WASTE MANAGEMENT IN EXPLORATION AND PRODUCTION OPERATIONS inants can evaporate into the atmosphere, be carried by rainwater to a lake, creek, or other surface water, and be leached downward into groundwater generated by the general public and can be managed similarly Most of the wastegenerated by the oil andgas industry consists of naturally occurring materials brought to the surface in association with extracted oil and gas Air 1.3.3 Due to large increases in waste costs of management, increasing complexity of waste management regulations, and Gaseous waste released to the air can potentially affect huefforts to reduce potential environmental liabilities, many mans, animals, and plant life through inhalation or dermal API member companies have implemented in-house waste contact Indirectly, gaseous wastes may alter the chemical minimization programs balance in the atmosphere Acid rain is a known result of alThese programs go beyond traditional approaches to tering the chemical makeup of the atmosphere Ozone deplewaste management and incorporate pollution prevention tion and global warmingare thought by some to be the result concepts of human impact on the atmosphere A properly implemented pollution prevention program can reduce or eliminate pollutant discharges to air, water, or land API supports cooperative efforts to research and develop scientifically based standards and promotes technical advancements for the evaluation and implementation of measures to address environmental impacts 1.4UNDERSTANDINGOPERATIONALIMPACTS Because exploration and production (E&P) operations can affect all environmental media, API suggests the use of sound science to identify adverse impacts and the means to mitigate, reduce, or eliminate them Science is also critical to developing cost-effective strategies that address environmental risks Science provides the foundationforidentifyingmethodstopreventorreduce pollution, for expanding waste management options to reduce risk, and for developing and improving pollution control technologies Sound science is thekey to determining which environmental problems pose the greatest risk to human health, ecosystems, and the economy Without sound scientific information, high profile but low risk problems may possibly be targeted, while more significant threats remain ignored A sound scientific understanding of environmental risks to populations and ecosystems will help create a more effective allocation of resources-resources which can be targeted towards hazards that pose the greatest environmental risk 1.5POLLUTIONPREVENTIONANDWASTE MINIMIZATION Waste minimization is a major component of pollution prevention The goals of a waste minimization planare to reduce the total volume or quantity of waste generated and to reduce the toxicity of waste Hydrocarbon recovery,an extractive procedure, inherently generates wastes Some of these wastes are similar to those Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS 1.5.1SolidWasteDefinition According to federal regulations, a solid waste is any material that is discarded or intended to be discarded Solid wastes may be either solid, semi-solid, liquid, or contained gaseous material Point source water discharges, subject to federal permits under the Clean Water Act, are not considered solid wastes 1.5.2 EPA Hierarchy ofMethods EPA has developed the following hierarchy of waste management methods to guide generations toward waste minimization The four waste management hierarchy steps, in decreasing order of preference are as follows: a Source Reduction-reduce the amount of waste at the source through the following: material elimination inventory control and management material substitution process modification improved housekeeping return of unused material to supplier b Recycling/Reuse-reuse and recycle material for the original or some other purpose, such as materials recovery or energy production; this may occur onsite or offsite, through the following methods: reuse reprocess reclaim use as fuel underground injection for enhanced recovery roadspreading c Treatment-destroy, detoxify, and neutralize wastes into less harmful substances through the following methods: filtration chemical treatment biological treatment thermal treatment extraction Not for Resale `,,-`-`,,`,,`,`,,` - 1.3.4 Summary T ’ wastes PAISI PAVE PCBs PH PIC PM POTW PPA PPb PPm PRP , PSD PSES PSNS QA RACT RCRA REG NEG RF1 RVFS ROD RQ SARA SARA 313 SDWA SERC SI SIC MANAGEMENT IN EXPLORATION AND PRODUCTION OPERATIONS Commercial chemical products consid ered acutely hazardous wastes if discarded off-specification, or spill cleanup residues Preliminary AssessmentJSite Investigation Program for Assessing Volatile Emissions Polychlorinated Biphenyls A measureof the acidity or alkalinity of material, liquid, or solid Product of Incomplete Combustion Particulate Matter Publicly Owned Treatment Works Pollution Prevention Act of 1990 Part per billion Part per million Potentially Responsible Parties (CERCLA) Prevention of Significant Deterioration-a policy implemented by regulations applying to attainmentareas of the USA to protect these areas from any future significant deterioration Pretreatment Standardsfor Existing Sources of indirect discharges under Section 307(d) of the Clean Water Act Pretreatment Standardsfor New Sources of Indirect Discharges under Section 307(b) and (c) of the Clean WaterAct Quality Assurance Reasonably Available Control Technology ”applied to existing major sources in nonattainment areas Resource Conservation and Recovery Act of 1974-establishes controls for the handling and disposal of solid wastes and hazardous wastes Negotiating Rulemaking Remedial Facility Investigation Remedial InvestigationFeasibility Study Record of Decision Reportable Quantities (Superfund) Superfund Amendments and Reauthorization Act of 1986 Data collection under Section 313of the Emergency Planning and Community Right to Know-Act of 1986 Safe DrinkingWater Act State Emergency Response Commission Surface Impoundment Standard Industrial Classification-a numerical categorization scheme used by the U.S Department of Commerce to denote segments of industry Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS SIP SOX SPCC SQG SS STEP Superfund SWMU TC TCLP TDS TEOR THC TITLE III of SARA 65 State Implementation Plans-a body of regulations and emissions standards developed by the state and designed to reach the air quality goals of the state Must be approved by EPA Sulfur Oxides Spill Prevention Control and Countermeasure Small Quantity Generator Suspended Solids Strategies for Today’s Environmental Partnership Popular term applied to the Comprehensive Environmental Response, Compensation and Liability Act of 1980 and the Superfund Amendments and Reauthorization Act of 1986 Solid Waste Management Unit(RCRA) Toxicity Characteristic-concentration levels for 39 compounds used as one way to define solid waste as hazardous Toxicity Characteristic Leaching Procedure (RCRA) Total Dissolved Solids Thermally EnhancedOil Recovery Total Hydrocarbons Emergency Planning and Community Right-to-Know-Act of 1986 TLV Threshold LimitValues Threshold PlanningQuantity TPQ Toxicity Reduction Evaluation TRE Toxic Release Inventory underS A R A TRI Title III TSCA Toxic Substances Control Act TSDF Treatment, Storage, or Disposal Facility (RCRA) TSP Total Suspended Particulates TSS Total Suspended Solids TUR Toxic Use Reduction “U” Wastes Commercial chemical products considered toxic hazardous wastes when discarded, off-specification, or spilled UCR Upper Confidence Range UIC Underground Injection Control USDW Underground Sourceof Drinking Water USGS U.S Geological Survey VOC Volatile Organic Compounds-organic compounds that may be involved in photochemical reactions that produce ozone Volatile Organic Liquid VOL Not for Resale `,,-`-`,,`,,`,`,,` - WASTE ,STD.API/PETRO ES-ENGL L777 m 0732270 05b11737 07T m API E5 66 WETT WQC Whole Effluent Toxicity Testing-program for testing the toxic effects on aquatic lifeof an effluent,or specified pollutants in an effluent Water Quality Criteria-acceptable concentration of a pollutant, based upon the latest scientific knowledge concerning the effects of the pollutant on health and welfare WQS `,,-`-`,,`,,`,`,,` - Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale Water Quality Standard-a regulatory program for a particular segment of a receiving water which will normally be based upon applicable water quality criteria and other relevant characteristics of the receiving water segment and will include designated useor uses for the water Segment, alongwith a plan of enforcement S T D - A P I / P E T R O E S - E N G L L777 m 0732270 05b4738 T2b Appendix F-Reference Materials F.l REFERENCES 1O Criteriafor pH in Onshore Solid Waste Management in Exploration and Production Operations, Publication 4595, American Petroleum Institute, 1994 l Credible Science, Credible Decisions, U.S Environmental Protection Agency, March 1992 Suggested Procedures for Development of Spill Prevention, Control and Countermeasure Plans, Bulletin D16, American Petroleum Institute, August 1, 1989 l Metals Criteria for Land Management of Exploration and Production Wastes: Technical Support Document for API Recommended Guidance Values, Publication 4600, American Petroleum Institute, 1994 Bulletin on the Generic Hazardous Chemical Category List and Inventoryfor the Oil a& Gas hploration and production Industry, Bulletin E 1, American Petroleum Institute, December 1, 1990 12 ‘‘StatKhds for the Use or Disposal of Sewage Sludge?” 40 Code of Federal Regulations Parts 257, 403, and 503, U.S Environmental Protection Agency, 1993 Bulletin on Management ofNaturally occurring dioactive Materials (NORM) in Oiland Gas Production, Bulletin E2, American Petroleum Institute, April 1, 1992 13 “Underground Injection Control Program: Criteria and Standards,” 40 Code of Federal Regulations Part 146, U.S Environmental Protection Agency, 1992 Environmental Guidance Document on Well Abandonment and Inactive Well Practices for U.S Exploration and Production, Bulletin E3, American Petroleum Institute, January 1993 14 “Standards for the Use or Disposal of Sewage Sludge,” 40 Code of Federal Regulations Parts 257, 403, and 503, U.S Environmental Protection Agency, 1993 15 “Underground Injection Control Program: Criteria and Standards,” 40 Code of Federal Regulations Part 146, U.S Environmental Protection Agency, 1992 Environmental Guidance Document on Release Reporting for the Oil and Gas Exploration and Production Industry as Required by the CWA, CERCLA and SARA lïtle III, Bulletin E4, American Petroleum Institute, June l, 1993 Regulatory Determination for Oil and Gas Geothermal Exploration, Development and Production Wastes, U.S Environmental Protection Agency, July 6, 1988 Electricalconductivity,sodiumabsorptionratio,exchangeable sodium percentage, and oil andgrease guideline values are described in detail in API Publication 4527 The pH values are detailed in API Publication 4595 Metals guidance is developed in API Publication 4600 EPNIOCC Study of State Regulation of Oil and Gas Exploration and Production Waste, Interstate Oil Compact Commission, December 1990 Evaluation of Limiting Constituent Suggested for Land Disposal of Exploration and Production Wastes, Publication 4527, American Petroleum Institute, August 1993 67 Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale `,,-`-`,,`,,`,`,,` - F.2 SOURCESFORJUSTIFICATIONAND ANALYTICAL METHODS IN TABLE ~ S T D - A P I / P E T R O ES-ENGL L997 m 0732240 05b11739 b m `,,-`-`,,`,,`,`,,` - Appendix G-REPRINT OF EPA PUBLICATION (EPA 530-1 > Listed Hazardous Waste? Yes No +- v Exhibit Hazardous Characteristic? -Yes - I A f Exempt from RCRA Subtitle C (Subject to Subtitle D and other State and Federal statutes) Nonhazardous Waste (Subject to Subtitle D and other State and Federal Statutes) See Mixture Flowchart Hazardous Waste Subject to RCRA Subtitle C Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale `,,-`-`,,`,,`,`,,` - No S T D - A P I / P E T R O ES-ENGL L777 WASTE MANAGEMENT IN m 0732270 05b11743 373 EXPLORATION AND PRODUCTION OPERATIONS MIXING WASTES If, after mixing a nonexempt characteristic hazardous waste with an exempt waste, the resulting