RCRA Exempt Oil & Gas Wastes

 

Produced water
Drilling fluids and drill cuttings
Rigwash
Well completion, treatment, and stimulation fluids
Workover wastes
Basic sediment & water and other tank bottom sludge from storage facilities that hold product and exempt waste
Accumulated materials such as hydrocarbons, solids, sand, and emulsion from production separators, fluid treating vessels, and production impoundments
Pit sludges and contaminated bottoms from storage or disposal exempt wastes
Spent filters, filter media, and backwash (assuming the filter itself is not hazardous and the residue in it is from an exempt waste stream)
Packing fluids
Produced sand
Pipe scale, hydrocarbon solids, hydrates, and other deposits removed from piping and equipment prior to transportation
Hydrocarbon-bearing soil
Pigging wastes from gathering lines
Wastes from subsurface gas storage and retrieval, except for the listed nonexempt wastes Constituents removed from produced water before it is injected or otherwise disposed of
Liquid hydrocarbons removed from the production stream but not from oil refining
Gases removed from the production stream, such as hydrogen sulfide and carbon dioxide, and volatilized hydrocarbons
Materials ejected from a producing well during blowdown
Waste crude oil from primary field operations and production
Light organics volatilized from exempt wastes in reserve pits or impoundments or production equipment

Note: All exempt waste must be generated in primary field operations.  

Exemption of Oil and Gas Exploration and Production Wastes from RCRA Subtitle C does not preclude these wastes from control under other federal regulations and state regulations.

Services Supporting Shale Gas Development

Analysis of Production Wastewater & Drill Cuttings

Princeton Analytical will assist you evaluating high-brine wastewasters for salts, metals and fracturing additives and characterize drill cuttings in preparation of proper disposal.  

We provide on-site and off-site capabilities to suit your needs and your timetable. 

 
Key DEP Forms for Generators
Form 26R
  • Form 26R: Chemical Analysis Of Residual Waste Annual Report By The Generator
  • Instructions including analytical parameters
  • Summary of Analytical Parameters
  • Waste Generator Requirements.  PA DEP Presentation: Wastewater Characterization and Transportation
    • Form 26R must be submitted to PADEP annually for each waste stream by March 
    • Within 30 days of the initial generation of wastewater from the fracing operation, the generator will need to characterize the actual impounded or stored fracing wastewater to be sent to the approved receiving facility.
    • Submit a copy of 26R form with this chemical characterization to the receiving facility.
    • Receiving facilities that do not receive a copy of this 26R for the wastewater within 30 days of initial delivery, can not accept further loads of the wastewater from the generator from that well site for processing, transfer, treatment or disposal.
    • For the first 30 days of wastewater generation after fracturing, the operator of the well site will provide and the receiving facilities will rely upon an oil and gas industry generic characterization of the wastewater.

FORM U

FORM R
  • Form R: Waste Analysis And Classification Plan (for new DEP clients).
  • Must identify the chemical constituents in the waste stream, sampling and testing procedures, frequency of analyses
  • Instructions including analytical parameters
Wastewater Treatment Permit
  • General Permit WMGR123: Processing & Beneficial Use of Gas Well Waste. Establishes water quality criteria that, if met, allow the processed water to be managed, stored and transported as freshwater. 
    • Facilities will test regularly for 39 constituents, including strontium, barium, total dissolved solids and radiation
    • The permit specifies that the processed wastewater may only be used to develop or hydraulically fracture an oil or gas well.
    • Wastewater that does not meet the freshwater criteria must continue to be managed, stored and transported as residual waste
On-Site Pre-Treatment
  • Form 5500-PM-OG0071: Request for Approval of Alternative Waste Management Practices, including onsite temporary containment or pre-treatment
RCRA Subtitle C Exemption
  • EPA Information Booklet: Exemption of Oil and Gas Exploration and Production Wastes from Federal Hazardous Waste Regulations
  • Exemption for wastes uniquely associated with primary field operations
    • Oil production: activities occurring at or near the wellhead or production facility, but before the point where the custody of the oil is transferred
    • Natural gas production: activities occurring at or near the wellhead, production facility, or gas plant (including gathering lines to the plant, but before the point of transfer
    • Unique to E&P operations: produced water and drilling fluid; however, other wastes commonly generated in other types of industries (e.g., cleaning wastes, painting wastes, and waste lubricating oil) are not exempt
  • RCRA EXEMPT OIL & GAS WASTES
  • RCRA NONEXEMPT OIL & GAS WASTES
Key Statutes
  • The Solid Waste Management Act: Sets requirements for the management of residual wastes.  
    • Excludes drill cuttings from the definition of solid waste (see Amendment) provided such materials are disposed of at the well site and pursuant to Section 206 of the Oil and Gas Act (Well Site Restoration).  
    • Requires a permit for residual waste disposal and processing facilities. 
    • See our Solid Waste area for regulations of solid waste disposal and receiving facilities

Residential Drinking Water Analysis / Pre-Drilling Baseline Testing

Princeton Analytical is a full-service environmental lab that can conduct testing of private drinking water before, during and after drilling activity.

What is the contaminant?  How did it get there?  Our unique forensics expertise can help answer these key questions.


  • We conduct on-site sampling
  • We partner with 3rd party environmental consultants
  • We provide direct access to lab technicians
  • We have experienced project managers to improve turnaround time, efficiency and accuracy
  • We provide secure online access to your data for tracking results and identifying trends
  • We are available when you need us.  24 hours a day. 

Please see our Environmental Testing section for a comprehensive list of our capabilities. 

NPDES and E&S Permitting & Compliance Monitoring


Princeton Analytical collaborates to prepare and meet the initial and ongoing requirements for NPDES and/or E&S Permits.
 
Useful Information
Oil and Gas Technical Guidance Documents
Erosion and Sediment Control

Inadvertent Releases & Spills

Emergency conditions like a spill require timely response and rapid turnaround to identify the extent and composition of the potential contamination.

In this demanding and fast-paced world, Princeton Analytical stands ready to meet your needs.  

We are available when you need us.  24 hours a day. 

 
 
Additional Information
Reporting an Incident
Notification requirements
  • The Oil & Gas Act notifications:  Requirements to Report Incidents Causing or Threatening Pollution:  25 Pa. Code 91.33
  • The Pennsylvania Clean Streams Law requires immediate notification of DEP when any pollutant is discharged. There is no reportable quantity, the requirement includes groundwater, and practically all substances are reportable.
  • The Solid Waste Act requires the generator or the transporter to notify DEP immediately if there is a spill of a hazardous waste which affects surface water or groundwater regardless of amount.  Requirements to Report Releases: Article III, Section 301(b)
Preparedness, Prevention and COntingency (PPC) Plans
Other

PA DEP Oil & Gas Reporting Website

Provides historical oil and gas, and waste production at each well


Oil & Gas Production

By Operator
By County
By Well (permit #)

Waste Reports

By Operator
By County
By Waste Facility

Links of Interests

Act 13 - Oil & Gas Act of 2012
 
title 25, Environmental Protection
Oil and Gas Technical Guidance Documents