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Waste Minimization in Production and Workover Operations

Waste minimization has been proven to be an effective and beneficial operating procedure. You will find that there are many economically and technically feasible waste minimization techniques that can be used in production and workover operations. In fact, many oil and gas operators have implemented waste minimization techniques and have enjoyed benefits such as:

    • reduced operating and waste management costs;
    • increased revenue;
    • reduced regulatory compliance concerns;
    • reduced potential liability concerns; and
    • improved company image and public relations.

Choosing feasible source reduction and recycling options (i.e., waste minimization) is a smart business decision.

Waste minimization is part of the concept of the "Waste Management Hierarchy." The Waste Management Hierarchy sets out a preferred sequence of waste management options. The first, and most preferred option is source reduction. Source reduction is any activity that reduces or eliminates either the generation of waste at the source or the release of a contaminant from a process. The next preferred option is recycling. Recycling is the reclamation of the useful constituents of a waste for reuse, or the use or reuse of a waste as a substitute for a commercial feedstock or as a feedstock in an industrial process. Together, source reduction and recycling comprise waste minimization. The last two options, and least preferred, of the hierarchy are treatment and disposal.

This document will provide a general overview of waste minimization techniques for wastes arising from oil and gas production and workover operations. In addition to a discussion of waste minimization techniques for these operations, the document provides case histories of successful waste minimization projects and a bibliography of useful technical references. Many of the references listed in the bibliography provide detail on the successful application the waste minimization opportunities discussed in this document.

The Railroad Commission also provides the publication Waste Minimization in the Oil Field. Waste Minimization in the Oil Field provides a general overview of waste minimization as a waste management practice and how to include it in an area-specific waste management plan. It also includes chapters on waste generation in oil and gas operations, identification of hazardous oil and gas waste, and the principles of waste minimization. Waste Minimization in the Oil Field is available from the RRC's Waste Minimization Program. Call (512) 463-6804 to obtain a free copy.

Waste Minimization in Production and Workover Operations

As noted in the introduction, there are many economically and technically feasible waste minimization techniques that may be applied to production and workover operations. An operator should consider all costs, including waste management and disposal costs, when evaluating the feasibility of a waste minimization option. For example, a substitute product or chemical may cost more, but the savings in waste management and disposal costs will make the substitution cost-effective.

Source Reduction

The following discussion will consider the various source reduction opportunities for wastes arising from production and workover operations.

Preplanning

The best place to start waste minimization efforts for production and workover operations is in the planning stages. Preplanning can make a significant impact on the waste management requirements of the production and workover operations.

Production Site Design and Construction: One of the first opportunities for waste minimization is in the design and construction of the production site and lease roads. The site and the associated roads should be planned so that they are constructed such that stormwater runoff is diverted away from the site and that any stormwater runoff, which may be contaminated, is collected. Construction of the location and roads should be planned so that erosion is minimized. These steps will help minimize the volume of contaminated stormwater runoff to be managed. Also, the location size should be only as large as absolutely necessary. Location construction costs, including the cost of the disposition of cleared trees and vegetation, can be reduced. As well, the image of such an operation, as perceived by the general public, is enhanced.

Spill Prevention and Control: A site should be constructed such that any releases of crude oil or produced water are contained, even if the site is not subject to the federal Spill Prevention Control and Countermeasure requirements (40 CFR Part 112). Such planning will help an operator recover most spilled crude oil and minimize the extent of soil contamination that must be remediated under Rule 91.

Site Equipment: An operator can also include in a production facility's design tanks, separators, and other associated equipment to enhance waste minimization. Features such as drip pans, elevated flowlines, drip or spill containment devices (e.g., beneath load line connections), stock tank vapor recovery systems, and constructed storage areas for containers of chemicals and wastes are good waste minimization ideas. Many of these waste opportunities are discussed further in the following sections.

Workovers and Well Servicing: A preplanning opportunity for workover and well treatment operations is to carefully design the operation so that only the volume of chemicals necessary for the operation are brought to the site. An operator who takes this step can reduce the amount of leftover chemicals (e.g., acids) that may have to be managed as waste. Also, the potential for contamination from spills is reduced. The selection of contractors for conducting workovers is an important step and is discussed under "Selection of Contractors" on page 9.

Product Substitution

Product substitution is one of the easiest and most effective source reduction opportunities. Vendors are becoming more attuned to operators' needs in this area and are focusing their efforts on providing less toxic, yet effective, substitutes. Some operators, such as the one featured in the case history on page 15, have found that vendors and suppliers will start offering less toxic substitutes in response to a company establishing inventory control procedures. A few examples of effective and beneficial product substitution for production and workover operations are provided below.

Organic Solvents: Organic solvents, such as trichloroethylene, and carbon tetrachloride, are commonly used for cleaning equipment and tools. These solvents, when spent, become listed hazardous oil and gas wastes and are subject to stringent regulation. Alternative cleaning agents, such as citrus-based cleaning compounds and steam may be substituted for organic solvents. By doing so, a hazardous waste stream may be eliminated, along with the associated waste management and regulatory compliance concerns. Another solvent commonly used is Varsol (also known as petroleum spirits or Stoddard solvent). While most Varsol has a flashpoint below 140oF, which is a characteristically ignitable hazardous waste when spent, some suppliers may provide a "high flash point Varsol" with a flash point greater than 140oF. Ask for non-toxic cleaners that reduce your regulatory compliance concerns.

Also, solvents such as xylene and toluene, which may become hazardous wastes, have been commonly used for dissolution and removal of organic deposits (e.g., paraffin) in well bores and producing formations. Service companies have developed non-toxic solvents that will substitute for xylene and toluene. Check with your service company or chemical vendor for these substitute solvents before purchasing aromatic solvents such as xylene and toluene.

Paints and Thinners: Oil-based paints and organic solvents (i.e., thinners and cleaners) are used less frequently today, nonetheless they are still used. These paints and thinners provide an excellent product substitution opportunity. Water-based paints should be used whenever feasible. The use of water-based paints eliminates the need for organic thinners, such as toluene. Organic thinners used for cleaning painting equipment are typically listed hazardous waste when spent. This substitution can eliminate a hazardous waste stream and reduce waste management costs and regulatory compliance concerns.

Pipe Dope: When running tubing, connections require the use of pipe dope. American Petroleum Institute (API) specified pipe dope contains about 30% lead by weight and, therefore, can be of concern when disposed of. One simple waste minimization technique is to ensure that all pipe dope is used and containers are completely empty. However, lead-free, biodegradable pipe dopes are now available and, if feasible, should be substituted for API specified pipe dope. Even if API specified pipe dope is necessary for making the required connections, pipe supply companies should be asked to provide pipe with lead-free pipe dope on the thread protectors. That way you can recycle the thread protectors with fewer regulatory concerns.

Equipment Modifications

Lubricating Oil Purification Units: In certain situations, production and workover operations use engines that typically generate large volumes of waste lubricating oil and lubricating oil filters. A lube oil testing program combined with extended operating intervals between changes is an effective waste minimization technique, as shown by the case history on page 16. (Even though the case history is from drilling operations, the concept may be applied anywhere.)

However, an equipment modification also can effectively reduce the volume of waste lubricating oil and filters. Commercial vendors offer a device called a lube oil purification unit. These units use 1 micron filters and fluid separation chambers and are attached to the lube oil system of an engine. The unit removes particles greater than 1 micron in size and any fuel, coolant, or acids, that may have accumulated in the oil. The unit does not affect the functional additives of the lube oil. The lube oil is circulated out of the system and through the purifier. The purified lube oil is then returned to the engine's lube oil system. Many operators have found that use of lube oil purification units has significantly reduced the need for lube oil changes, waste lube oil management, and concurrently, the cost of replacement lube oil. Also, a new engine that has been fitted with a lube oil purification unit will break in better and operate more efficiently over time, in part because bearing surfaces and piston rings seat better due to the polishing by particles less than 1 micron in size.

Chemical Metering, or Dosing, Systems: The occasional bulk addition of treating chemicals, such as inhibitors, can result in poor chemical performance and inefficient use of the chemical. A chemical dosing system that meters small amounts of the chemical into a system continuously can reduce chemical usage and improve its performance in the system. In many instances, this equipment modification can result in cost savings due to reduced chemical purchases and more efficient operation of the system.

Basic Sediment and Water, or Tank Bottoms: Many operators have used simple techniques to minimize the volume of BS&W that accumulates in tanks and sediments that accumulate in other production vessels. Devices such as circulating jets, rotating paddles, and propellers may be installed in crude oil stock tanks to roll the crude oil so that paraffin and asphaltene remain in solution (or at least suspension). Also, emulsifier can be added to the stock tank to accomplish the same result. Another method used is to circulate the tank bottoms through a heater treater to keep the paraffin and asphaltene in solution.

One operator in west Texas used an extra stock tank to collect tank bottoms from the regular crude oil stock tanks. The tank was painted black so that in the hot summer months the temperature would rise high enough to dissolve the paraffin and asphaltene, which would separate from the water. The heavy oil would then be transferred in appropriate amounts to the crude oil stock tank for sale. This simple solution reduced the ultimate volume of BS&W the operator had to manage as waste and added revenue from crude oil sales.

High Energy Ion Plating: Magnetic ion coating is a technology that has been advanced in recent years. The process uses impingement of metals such as chrome/gold alloy or pure copper. The high energy application of these metals to a steel surface causes them to penetrate the steel surface, thus forming superior adhesion and slip (low friction) properties (sort of a "metal lubricant"). The metal plating reduces friction such that valve stem packing may be tightened to essentially eliminate fugitive emissions, and the valve packing/stem unit lasts up to seven times longer than a conventional untreated unit. This technology has also been applied to polished rods and stuffing box rubbers on rod-pumps. In those applications, crude oil leakage has been essentially eliminated and the interval between stuffing box rubber changeouts significantly lengthened, resulting in cost savings, reduced soil contamination, and more efficient operation and production.

Vapor Recovery from Stock Tanks: The regulation of emissions of toxic air pollutants have become more strict since passage of the Clean Air Act Amendments in 1992. Many crude oil tank batteries may qualify as major sources, thus triggering Title V permitting, control, and monitoring requirements. A good way to avoid this situation is to install a vapor recovery system. Vapor recovery systems that use vacuum pumps are commercially available. However, one system has been designed and marketed that is simple and low-cost. That system uses only a pump and a venturi. The system uses produced water from the tank to pump through the venturi, which in turn draws a slight vacuum on the tanks. The vapors are entrained in the produced water which is sent to the separator. There the vapors are separated and returned to the production stream.

Conventional Filters: A good target for waste minimization are the conventional filters that typically comprise a large part of an operations waste stream. An operator can replace conventional filter units with reusable stainless steel filters or centrifugal filter units (spinners). These devices generate only filtrate as waste and eliminate from the waste stream the conventional filter media and filter body. Operators have found that the reduced costs of replacing lost oil, maintenance requirements, new filter purchases, and waste filter management recover the expense of installing these alternative filtering units.

If conventional filters must be used, an operator should change filters based on differential pressure across the unit. Differential pressure is a good indicator of the effectiveness of a filter unit and can be used to determine the actual need for replacement. This is a simple change that can significantly reduce waste filter generation. The case history provided on page 15 proves this point.

Process or Procedural Modifications

Cementing "On-the-Fly": When conducting cementing operations, a significant volume of unused premixed cement may remain after completing the job. Of course, one way to prevent excess cement is careful preplanning. However, service companies now provide systems that mix neat cement and additives on-the-fly. These systems are also referred to as automatic density control systems. The advantage of mixing on-the-fly is that the mixing process can be stopped as soon as the cementing job is complete. Also, the mixing system can be shut down if the cementing job is interrupted for some reason, thus saving the generation of a much larger volume of unusable premixed cement. The only unused cement mixture is that remaining in the mixing system. The unused neat cement and additives are not wastes and can be returned to the service company for use in the next cementing job.

"Frac Jobs" On-the-Fly: Oil field service companies now offer equipment that mixes fracturing fluids "on-the-fly," just as for the cements described in the preceding example. The "on-the-fly" system will continuously mix dry gel at a selected concentration or mix a liquid concentrate that is later diluted to the required concentration. Significant advantages of this type of system are elimination of the need for diesel-based liquid gel concentrates and reduced waste subject to more strict regulation. The process is also more efficient.

Remote Monitoring of Production Operations: Although it does not appear so, the remote monitoring of production operations is a source reduction technique. Microcomputer-based monitoring of parameters such as pumping unit load, stuffing box leaks, polished rod temperature, gun barrel water level, heater treater temperature and pressure, and tank levels and temperatures can be transmitted to the field office by microwave transmission. Because the system immediately alerts the operator of any upset condition or imminent equipment failure, the operator can quickly address the problem. By doing so, the operator can avoid unnecessary waste generation. For example the operator can prevent equipment failures that would require a workover (workovers generate waste), replace stuffing box rubbers prior to failure (oil leaking from a stuffing box may contaminate soil), prevent tank overflows, and detect loss of fluid from tanks (e.g., leaks or theft). Remote monitoring systems are offered commercially and according to vendors may replace, at a comparable cost, the routine manual measurements.

Workovers Using Coiled Tubing Units: Operations using conventional workover rigs typically generate wastes that must be managed after completion of the workover. An alternative to using workover rigs is to use coiled tubing units for through tubing workovers. Over the past several years, service companies have developed suitable through tubing tools for this purpose. A coiled tubing unit workover eliminates the need for pulling tubing, displacing well fluids, and well blowdown, all of which generate wastes. When feasible, coiled tubing units are a good choice for well workovers.

Paraffin Control: Paraffin deposition can cause operational problems and result in unwanted waste generation. Paraffin deposition can cause sticking and parted rods in the well bore, plugging and rupture of surface flowlines, increased tank bottom generation, and reduced crude oil quality at the sales point. Frequently, the results are ongoing hot oil and solvent treatments, cleanups of crude oil and salt water-contaminated soils, and dissatisfied crude oil purchasers. At the bottom line, the operator realizes reduced operating efficiency, reduced revenue, and increased regulatory compliance concerns.

Several techniques exist for reducing paraffin deposition and the related problems. One technique uses a device known as a magnetic fluid conditioner, or MFC. MFC's have been used in the oil field for some time, and not always successfully. However, in recent years, MFC technology has improved, and operators are finding success in their application (see the case history on page 12 for an example). An MFC may be installed in a producing oil well (e.g., on the downhole rod pump) for which it is specifically designed. Parameters such as pump dimensions, crude oil and water characteristics, and production parameters are accounted for in the design of the MFC. The MFC works by altering the properties of the crude oil and water as it passes through the intense magnetic field of the MFC's permanent rare earth magnet. As a result, the crude oil's pour point, yield point, and viscosity are reduced; and the temperature at which paraffin will deposit is lowered. Also, the MFC helps to inhibit scale formation.

Another technique for controlling paraffin deposition is the application of microbes in the well. Bacteria introduced into the producing well bore and formation biodegrade the high carbon chain paraffins, which in turn improves the properties of the crude oil with respect to paraffin deposition. The authors of one technical paper (SPE 22851) suggest that microbial treatment is "potentially limited to wells that produce water, are pumping wells, and have bottom hole temperatures below 210oF." Reports in that technical paper and in other technical papers indicate microbial control of paraffin deposition is effective.

Control of NORM Deposition

Naturally occurring radioactive materials (NORM) that are produced with formation waters may cause troublesome waste management and regulatory compliance concerns. When NORM contaminates production equipment and sites, it poses a special waste management problem and falls under Rule 94 regulation. While much of the NORM contamination in the oil field is historical, future NORM contamination may be reduced using any of several techniques which apply the source reduction opportunity categories discussed above.

Deposition of NORM is primarily controlled by pressure and temperature changes and commingling of incompatible formation waters. Radon gas co-produced with natural gas is also a source of NORM. While the presence of NORM in reservoir water and gas cannot be eliminated, the volume of NORM-contaminated waste that is generated can be reduced through control of its deposition. Source reduction methods for NORM include: well completions or formation treatments designed to reduce water-cut and sand production; scale inhibitor squeezes that help control deposition of NORM-contaminated scale in the well and in surface equipment; chemical coating or high-energy ion plating of material surfaces at critical points in the production system to reduce the availability of nucleation points for scale formation; piping and equipment design that minimizes turbulent flow and pressure drops, thereby reducing the precipitation of scale; and segregation of incompatible formation waters that result in NORM-contaminated scale deposition (e.g., mixing of waters containing barium and sulfates will cause precipitation of barium sulfate scale).

Reduction In Water Use

Water Floods for Enhanced Recovery: In many instances, operators of water floods for enhanced recovery use fresh water from surface sources or from water wells. If feasible, an operator should find sources of produced water to replace fresh water injection. Adjacent operators may produce water that is compatible with the injection zone and is also economically and technically feasible to transfer between leases.

Good Housekeeping and Preventative Maintenance

Drip Pans and Other Types of Containment: Tanks, containers, pumps, and engines all have the tendency to leak. A good housekeeping practice that can help reduce the amount of soil and water contamination that an operator has to remediate is installing containment devices. Even though a small investment is required, containment devices save money and regulatory compliance concerns in the long run. Also, they can capture valuable released chemicals that can be recovered and used. Some examples of containment include: drip pans beneath lubricating oil systems on engines; containment vessels beneath fuel and chemical storage tanks/containers; drip pans beneath the drum and container storage area (discussed in more detail in the next paragraph); and containment, such as a half-drum or bucket beneath chemical pumps and system valves/connections. Numerous companies have implemented good housekeeping programs to reduce the amount of crude oil, chemicals, products, and wastes that reach the soil or water. These companies have found these programs to be cost effective in the long run (i.e., less lost chemical and product plus reduced cleanup costs). Also, their regulatory compliance concerns and potential future liability concerns are reduced. The RRC's Waste Minimization Program has numerous examples of containment and spill control devices, which have been proven effective. Call the program for more information.

Chemical and Materials Storage: Another important aspect of good housekeeping is the proper storage of chemicals and materials. Chemicals and materials should be stored such that they are not in contact with the ground (e.g., on wooden pallets). Preferably, the raised storage area will include secondary containment and be protected from weather. All drums and containers should be kept closed except when in use. It is very important that all chemical and material containers always be properly labeled so that their contents may be identified at any time. Also, material data safety sheets (MSDSs) and other manufacturer information should be kept on file for all stored chemicals and materials. The use of bulk storage, rather than 55-gallon drums or smaller containers is a preferable way to store chemicals and materials. Proper storage and labeling of containers allows quick and easy identification and classification of chemical or material in the event of a leak or rupture, or if disposal is necessary. In some instances, that could save hundreds of dollars in soil or waste sampling and laboratory analysis costs.

Containment of Fluids Used in Workovers: As noted in the discussion "Selection of Contractors," wastes generated by workover rigs may add to the management concerns of an operator. One of the most common problems is contamination of soil by tubing runoff and other spills on the workover rig floor. Several techniques can control this source of waste. First, a containment device beneath a raised rig floor can capture runoff and direct it to collection tanks or containers (the Waste Minimization Program offers an example). Also, heavy duty tarps (commercially available) laid over the well site will perform the same function.

Another solution to the problem of tubing runoff and spills is construction of an impermeable wellhead sump (i.e., a better cellar) during preparation for the original drilling operations. Later, when the well is completed and producing, the wellhead sump will collect any runoff or spills associated with workover operations. As well, the wellhead sump will collect any crude oil leakage from stuffing boxes, thus preventing contamination of soil around the well head. The wellhead sump is covered by a metal grate for safety. At least one firm offers a one-piece fiberglass model for about $800.

Preventive Maintenance: The companion of good housekeeping is preventive maintenance. Regularly scheduled preventive maintenance on equipment, pumps, piping systems and valves, and engines will minimize the occurrence of leaks and releases of chemicals and other materials to containment systems, or if there are no containment systems, to the environment. Numerous companies have implemented preventive maintenance programs and found them to be quite successful. The programs have resulted in more efficient operations, reduced regulatory compliance concerns, reduced waste management costs, and reduced soil and/or ground water cleanup costs.

Inventory Control

Inventory control is one of the most effective ways to reduce waste generation, regulatory compliance concerns and operating costs. Especially, when combined with proper chemical and materials storage. The case history on page 15 illustrates the beneficial impact an inventory control system can have on an operation. An inventory control system is easy to implement, especially with the use of computer programs now available. An operator who tracks his chemicals and materials can use them more efficiently and reduce the volume of unusable chemical that must be managed as waste. (Note: Commercial chemical products that are returned to a vendor or manufacturer for reclamation or recycling are not solid wastes. Therefore, it is to the operator's advantage to require vendors to take back empty and partially filled containers for reclamation or reuse.)

Selection of Contractors

Operators should choose contractors who recognize the value of waste minimization and make efforts to apply it in their service. Contracted workover rigs are a good example of the need for waste minimization efforts by contractors. A producer can find himself dealing with unnecessary oil and gas waste if the service company's workover rig crew does not take steps to control sources of waste such as tubing runoff, spilled chemicals, and other associated waste (e.g., thread protectors, rubber seals and cups, and pipe dope containers). An operator should select workover rig contractors who use containment devices beneath the rig floor, exercise control over chemicals and products brought on-site, and collect all associated wastes for proper management. Also, the contractor will bring on-site well maintained equipment that will not leak fuel or lubricating oil or that will need maintenance which may generate wastes.

Recycling

The next preferred waste management option is recycling. Recycling is becoming a big business and more recycling options are available every day The following discussion offers some tips on recycling production and workover wastes.

Produced Water: Most produced water in Texas is injected in Class II wells. The largest proportion of produced water is injected in Class II wells that are permitted for disposal. Look for opportunities to redirect produced water to Class II wells that are permitted for enhanced recovery. Produced water that is injected for enhanced recovery is considered to be recycled. (Also, see "Reduction in Water Use.")

Tank Bottoms: Tank bottoms, or BS&W, are best managed by sending them to a crude oil reclamation plant. An operator should contact nearby RRC-permitted crude oil reclamation plants to determine if an economically feasible arrangement is possible before considering disposal options. The Waste Minimization Program can help operators locate reclamation plants in their area. Some of these plants also specialize in reclamation of waste paraffin.

Lubricating Oil and Filters: Currently, waste lube oil and waste lube oil filters are generally banned from landfill disposal. Recycling is now the primary method of managing these wastes. Companies that handle lube oil and filters for recycling are located in every area of Texas, so finding one is not difficult. The Waste Minimization Program will provide upon request a listing of these companies.

Also, an operator can recycle his waste lube oil by adding it to a crude oil stock tank. Amendments to 40 CFR (Code of Federal Regulations) Part 279 (regarding standards for management of lubricating oil) provide for this option. There is a regulatory limit of 1% lube oil by volume. An important consideration in choosing this recycling option is the requirements of the crude oil purchaser and the receiving refinery. Make sure they will accept a crude oil and lube oil mixture. (Some refineries are not able to handle such mixtures, and may suffer damage to catalysts and other processes.)

Sorbent Pads and Booms: When cleaning up spills of crude oil and chemicals, use recyclable sorbent pads or booms. Try to avoid using granular adsorbent materials that must be disposed of. Several vendors offer sorbent pads and booms that are designed for repeated reuse.

Spent organic solvents and other miscellaneous spent chemicals: Many companies accept spent chemicals for recycling. In many instances the spent chemicals (especially organic solvents) are reclaimed for reuse or blended to make fuels for energy recovery. See "Recycling Information" below to learn how to find these companies.

Cements: Leftover cement may be used for other purposes, such as construction of on-site erosion control structures or pads. Also, the Oklahoma Corporation Commission publication, "Oilfield Pollution Prevention," reports that one major service company has arranged to provide leftover cements to local governments for use in their construction projects.

Paint Solvent Reuse: A simple technique for reducing the volume of organic paint solvents is to reuse it in stages. An organic solvent, such as toluene, may be used for cleaning painting equipment, but eventually it will become spent and ineffective. The "spent" solvent is not a waste if it is used for another intended purpose. A solvent spent from cleaning painting equipment is still suitable for use in thinning paint. This simple technique can greatly reduce the volume of waste paint solvent that may be subject to stringent hazardous waste regulation.

Commercial Chemical Products: An operator should implement procedures that recycle any unused chemical products. Whenever a vendor is contracted to supply chemicals, the vendor should be required to take contractual responsibility for unused chemical products and the containers in which they were delivered. As noted under the source reduction opportunity, "Inventory Control," commercial chemical products that are returned for reclamation or recycling are not solid wastes. An operator that manages chemical products properly will avoid the unnecessary generation of unused chemical that must be disposed of. In many instances, those chemical wastes would be hazardous and subject to stringent regulation.

Scrap Metal and Drums: Scrap metal is a relatively easy waste to recycle. Many operators have found that scrap metal recycling companies will collect and remove materials such as tanks, drums, and other types of scrap metal from the lease at no charge to the operator. An additional consideration is regulatory requirements. Scrap metal that is recycled is not subject to hazardous oil and gas waste regulations; but it is if disposed of. For example, an old steel tank coated with lead-based paint would likely be determined hazardous if disposed of; however, if recycled it is excluded from regulation as a hazardous oil and gas waste.

An excellent way to ensure that steel 55-gallon drums are recycled is to require in the contract with a vendor the requirement that the vendor take back any delivered drum, including drums that still contain some chemical or product. Note that empty drums and commercial chemical product that is recycled are generally excluded from regulation as hazardous oil and gas waste. (Also, see the discussions in "Good Housekeeping" and "Inventory Control.")

Recycling Information

The RRC's Waste Minimization Program can help operators identify recycling options. More information on Waste Minimization Program assistance is presented on page 17. The Texas Commission on Environmental Quality (TCEQ) publishes two useful documents: Recycle Texas and RENEW. Recycle Texas is a listing of many of the companies that take various wastes for recycling. Those wastes include many that are typical of oil and gas operations. RENEW is a waste exchange that is published quarterly. RENEW lists companies that have generated wastes and are making them available for recycling, and RENEW also lists companies that want certain wastes for recycling. Recycle Texas and RENEW are available free of charge from TCEQ and can be obtained by calling 1-800-648-3927.

Training

Training is probably one of the best waste minimization opportunities. An operator's efforts to minimize waste and gain the associated benefits will be only be effective if the people in the field understand waste classification and the concept of waste minimization. Also, people in the field should be empowered to implement waste minimization techniques as they are identified. Waste minimization training is becoming more common. Oil and gas associations have begun publicizing waste minimization successes, and technical societies such as the SPE, are publishing more and more papers on effective waste minimization techniques. Also, the RRC offers inexpensive Waste Minimization Workshops at various locations across the state.

Assistance Available From the Waste Minimization Program

The Commission's Waste Minimization Program offers the following products and services to help you in your waste minimization efforts.

Waste Minimization in the Oil Field: This manual, developed with the assistance of the oil and gas industry, offers source reduction and recycling (i.e., waste minimization) concepts, cost effective and practical examples of source reduction and recycling opportunities in the oil field, and information on how to develop an individualized waste minimization plan. The manual also presents a discussion on how to identify hazardous and nonhazardous oil and gas wastes as defined by EPA regulations under the Resource Conservation and Recovery Act. This manual is used as a training aid in the Waste Minimization Workshops. The manual is available free of charge.

Waste Minimization Workshops: The Waste Minimization Program offers a one-day Waste Minimization Workshop designed to help operators and their employees reduce oil and gas waste volumes, operating costs and potential liabilities through effective waste minimization.

Technology Transfer: We provide oil and gas operators with technical assistance through the use of a technology transfer database. If you have a question about minimization of oil and gas exploration and production waste, contact the Waste Minimization Program. We can provide citations that include author, title, and an abstract. In many cases, we can also provide hard copies of cited technical papers and articles.

Service Company and Vendor Information: We maintain a file of companies and vendors who offer services and products that will help you in your waste minimization efforts. Several examples of these companies are cited in the preceding discussions of source reduction and recycling. Upon your request, we will send you materials provided by appropriate companies, along with a RRC disclaimer. Please note also, that any company or vendor who provides services that compliment waste minimization activities is welcome to provide their materials to the Waste Minimization Program for inclusion in the file.

Waste Minimization Planning Software: We have developed a waste minimization planning software package called WasteMin. WasteMin is a Windows-based PC program that will assist you in developing a waste minimization plan for a facility or site. Using WasteMin, you can tailor and generate, with some data entry, a document that will contain a plan introduction, an inventory of waste streams, specific waste management information, waste minimization opportunities, and pertinent technical references. The program also includes a cursory technical and economic feasibility analysis for selected waste minimization techniques. WasteMin is available on disk for a nominal fee of $7.00, and you can download WasteMin from the RRC web site.

On-Site Assistance in Waste Minimization Planning: We will assist oil and gas operators in assessing their operations and developing individualized waste minimization plans. First, we will help develop an inventory of waste streams generated in the operation and help classify each waste stream with respect to applicable regulations. Then we will help identify waste minimization opportunities. The operator can then develop a waste minimization plan that will provide the greatest benefits (e.g., cost savings and added revenue).

To contact the Waste Minimization Program contact Bart Sims at bart.sims@rrc.state.tx.us

References

SPE Technical Papers

Rogers, L.A., et al, "Use of Inhibitors for Scale Control in Brine-Producing Gas and Oil Wells", Society of Petroleum Engineers 15457 (June 1989)

Podio, A.L., et al, "Microcomputer-Based Lease Monitoring and Operating System Lowers Costs and Enhances Production" Society of Petroleum Engineers 16217 (March 1987)

McIntyre, et al, "Novel Breaker/Filtration Process Reduces the Cost of Recycling Viscisified Brine Completion Fluids", Society of Petroleum Engineers 17461 (April 1990)

Day, J.B., et al, "New Makeup Method for API Connections", Society of Petroleum Engineers 18697 (May 1990)

Stilwell, C.T., "Waste Management Plans for Drilling and Production Operations", 20713 Society of Petroleum Engineers(September 1990)

Pardue, J.E., "A New Inhibitor for Scale Squeeze Applications", Society of Petroleum Engineers 21203 (February 1991)

Seghier, M., et al, "Comparative Study of Microcomputer-Based Gas Flow Computers," Society of Petroleum Engineers 21510 (January 1991)

Himes, R.E., et al, "Environmentally Safe Temporary Clay Stabilizer for Use in Well Service Fluids", Society of Petroleum Engineers 21604 (June 1991)

Fowler, S.H., "A Reeled-Tubing Downhole Jet Cleaning System", Society of Petroleum Engineers 21676 (April 1991)

Hudgins, Jr., C.M., "Chemical Treatments and Usage in Offshore Oil and Gas Production Systems", Society of Petroleum Engineers 22477 (February 1992)

Ogassawara, et al, Optimum Use of Environmentally Safe Compound Grease for Application of Casing Tubing Connection Makeup", Society of Petroleum Engineers 22555 (October 1991)

Brost, D.F., et al, "Optical Methods for Monitoring Treating Chemicals in Oilfield Water Systems", Society of Petroleum Engineers 22781 (October 1991)

Schantz, S.S., et al, "Asphaltene Deposition: Development and Application of Polymeric Asphaltene Dispersants", Society of Petroleum Engineers 22783 (October 1991)

Thompson, J.E., et al, "New Continuous-Mix Process for Gelling Anhydrous Methanol Minimizes Hazards", Society of Petroleum Engineers 22800 (October 1991)

Coronado, M.P., et al "Thru-Tubing Inflatable Workover Systems", Society of Petroleum Engineers 22825 (October 1991)

Pleasants, C.W., et al, "Design, Testing, and Field Use of a New Selected Reeled Tubing Well Stimulation System", Society of Petroleum Engineers 22826 (October 1991)

Santamaria, et al, "Controlling Paraffin Deposition Related Problems by the Use of Bacteria Treatments", Society of Petroleum Engineers 22851 (October 1991)

Matthews & Dunn, "Drilling and Production Practices To Mitigate Sucker Rod/Tubing Wear-Related Failures in Directional Wells", Society of Petroleum Engineers 22852 (October 1991)

Miller, Bruce & Cook, "The Management of Occupational and Environmental Exposure to Naturally Occurring Radioactive Materials (NORM)", Society of Petroleum Engineers 22879 (October 1992)

Brown, A.D. F., et al "Coiled Tubing Milling/Underreaming of Barium Sulfate Scale and Scale Control in the Forties Field", Society of Petroleum Engineers 23106 (September 1991)

Bonnett, N., et al, "Application of a Novel Squeeze Scale Inhibitor in the Bery Field", Society of Petroleum Engineers 23107 (September 1991)

Alford, J. T. "Zero Discharge Design Considerations for Jackup Drilling Rigs", Society of Petroleum Engineers 23363 (November 1991)

Grice, K.J., "Naturally Occurring Radioactive Materials (NORM) in the Oil and Gas Industry: New Management Challenge", 23384 (November 1991)

Thayer & Racioppi, "Naturally Occurring Radioactive Materials: The Next Step", Society of Petroleum Engineers 23500 (November 1991)

Serrano & Penalver "Control of Erosion-Corrosion in Flowlines in Wells in Northern Monagas", Society of Petroleum Engineers 23651 (March 1992)

Pelger, J.W., "Wellbore Stimulation Using Microorganisms to Control and Remediate Existing Paraffin Accumulations", Society of Petroleum Engineers 23813 (February 1992)

Samuelson, M.L., "Alternatives to Aromatics for Solvency of Organic Deposits" Society of Petroleum Engineers 23816 (February 1992)

Stringfellow/Jacobs, Field Experience With an Environmentally Acceptable Rotary-Shouldered Thread", Society of Petroleum Engineers 23920 (February 1992)

Harder, et al, "Surfactant/Cement Blends Improve Plugging Operations in Oil-Based Muds", Society of Petroleum Engineers 23928 (February 1992)

Brown, F.G., "Microbes: the Practical and Environmental Safe Solution to Production Problems, Enhanced Production, and Enhanced Oil Recovery", Society of Petroleum Engineers 23955 (March 1992)

Lacy, R.D., "The Rotating Tubing Hangar System: A Unique New System Designed to Extend the Run Time of Rod Pumped Wells", Society of Petroleum Engineers 23977 (March 1992)

Wisdom & Gibson "Effective Maintenance Management of Operations" Society of Petroleum Engineers 24075 (March 1992)

Ballard, et al "An Overview of Exhaust Emissions Regulatory Requirements and Control Technology for Stationary Natural Gas Engines", Society of Petroleum Engineers 24306 (April 1992)

Duke, R.B., "Demulsifying the Produced Fluids From Marathon's M-1 Project", Society of Petroleum Engineers 24539 (January 1992)

Mason, et al "Reduction of Naturally Occurring Radioactive Material Disposal Volume by Chemical and Physical Treatment", Society of Petroleum Engineers 24563 (October 1992)

Foxenberg, et al, "Optimizing the Quality of High Density Brines for Maximum Performance and Economic Value", Society of Petroleum Engineers 24784 (October 1992)

Choi, et al, "Control of Aromatic Emissions from Glycol Dehydrators", Society of Petroleum Engineers 24828 (October 1992)

Haslegrave, et al, "The Development of Corrosion Inhibitors with Low-Environmental Toxicity", Society of Petroleum Engineers 24846 October (1992)

Paul & Fieler, A New Solvent for Oilfield Scales", Society of Petroleum Engineers 24847 (October 1992)

Mussig, S, "Possibilities for the Reduction of Emissions-In Particular the Greenhouse Gases CO2 and Ch4 in the Oil and Gas Industry", Society of Petroleum Engineers 25041 (November 1992)

Anderson & Hall, "Zero Generator Status", Society of Petroleum Engineers 25933 (March 1993)

Grizzle, P.L., "Hydrocarbon Emission Estimates ands Controls for Natural Gas Dehydration Units", Society of Petroleum Engineers 25950 (March 1993)

Caudle & Bansal, "Environmental Considerations in Production Chemical Usage", Society of Petroleum Engineers 26010 (March 1993)

Allen, T.E., "Pregel Blender Prototype Designed to Reduce Cost and Environmental Problems," Society of Petroleum Engineers 27708 (March 1995)

Reuters, et al, "Measurement and Enhanced Monitoring of BTEX and VOC Emissions from Glycol Dehydrators," Society of Petroleum Engineers 29698 (March 1995)

Smith, et al , "Economic Impact of Potential NORM Regulations", Society of Petroleum Engineers 29708 (March 1995)

Oddo, et al "The Mitigation of Norm Scale in the Gulf Coast Regions of Texas and Louisiana: A laboratory Field Study", Society of Petroleum Engineers 29710 (March 1995)

Shuler, et al, "Diagnosis and Prevention of NORM at Eugene Island 341-A", Society of Petroleum Engineers 29711 (March 1995)

Resch, R.A., "EPA's Natural Gas Star Program", Society of Petroleum Engineers 29731 (March 1995)

Brandon, et al, "Biocide and Corrosion Inhibition Use in the Oil and Gas Industry: Effectiveness and Environmental Impacts", Society of Petroleum Engineers 29735 (March 1995)

Yunus, et al, "Environmental Impact of a Flocculant Used to Enhance Solids Transport During Wellbore Clean-up Operations", Society of Petroleum Engineers 29736 (March 1995)