
Environmental  Considerations 
1361 
Under the RCRA  exemption, wastes intrinsically associated with  the explora- 
tion and development of  oil and gas do not have to follow Subtitle C regulations 
for disposal.  Under  Subtitle  C, hazardous  wastes must  follow strict guidelines 
for storage, treatment,  and transportation  and disposal.  The cost of handling 
materials under the Subtitle C scenario 
is 
overwhelming. Under the exemption, 
the operator is allowed to dispose of wellsite waste in a prudent manner and is 
not obliged to use licensed hazardous waste transporters and licensed Treatment, 
Storage, and Disposal  Facilities (TSDF). 
Covered by  the exemption  are drilling fluids, cuttings, completion fluids, and 
rigwash. Not covered by  the exemption are motor and chain oil wastes, thread 
cleaning  solvents, painting waste, trash and unused completion fluids. 
A 
waste 
product, whether exempt or not, should always be recycled if  economically 
possible. Oil-based drilling mud typically is purchased back by  the vendor for reuse. 
Unused chemicals are similarly taken back for resale. Arrangements should be made 
with  the  mud  company  for similar arrange for partial  drums/sacks 
of 
chemical. 
Muds also may  be used on more than one hole. With the advent 
of 
closed system 
drilling, the mud must be moved  off location in the event of  a producing well. 
If  a waste is  generated that  is a listed  or characteristic,  the operator  must 
follow certain guidelines 
[232]. 
A listed hazardous waste (i.e., mercury, benzene) 
is considered hazardous  if  the concentrations in which they naturally  occur are 
above  certain  limitations  (40 
CFR 
261.31-261.33). 
The listed hazardous  waste 
may  not  be  diluted  to  achieve  lesser  concentrations  and  thus  become  non- 
hazardous. 
A 
characteristic  hazardous  waste 
(40 
CFR 
261.21-261.24) 
may  be 
diluted  to a nonhazardous  status. 
Most nonexempt nonacute hazardous waste  generated on location 
is 
considered 
a small quantity. In this case, the waste may  remain 
on 
location for 
90 
days. At 
that time, a  Department of Transportation licensed motor carrier must transfer 
the waste to a EPA  certified TSDF for disposal. Appropriate documentation and 
packaging must be conformed to. The operator  continues to be liable for the 
waste as denoted  by  the cradle to  grave concept 
[233]. 
Exempt wastes are usually disposed of  on location following permission from 
the  state  oil and  gas  division.  Liquid wastes, 
if 
not  evaporated  or fixated  on 
location,  are usually  injected  into Class I1  injection  wells-refer  to  Chapter 
6, 
Environmental Considerations. Solid wastes, if  not acceptable to local landfills, 
are remediated  onsite 
or 
buried  in some instances. Table 
4-175 
shows exempt 
and nonexempt waste 
[234]. 
Table 
4-175 
Exempt and Nonexempt 
Oil 
and Gas Production Related Wastes 
Exempt Wastes  Nonexempt Wastes 
Produced water 
Drilling fluids 
Drill cuttings 
Rigwash 
Well 
completionlstimulation fluids 
Unused well completionlstimulation fluids 
Radioactive tracer wastes 
Painting wastes 
Service company wastes such as empty 
drums, drum rinsate, vacuum truck 
rinsate, sandblast media, spent solvents, 
spilled chemicals, and waste acids 
Vacuum truck and drum rinsate contain- 
ing nonexempt wastes