Regulatory Issues

Most types of oil field wastes are exempted from the hazardous waste requirements of the Resource Conservation and Recovery Act (i.e., they are considered to be nonhazardous oil field wastes (NOW)).

States take the lead on regulating NOW (see below).

Injection of fluids into the ground, as in a disposal cavern, is regulated through the Underground Injection Control (UIC) program (see below).

There are no Federal NORM regulations:

States take the lead on regulating NORM.

NORM-contaminated E&P wastes are still considered to be nonhazardous.

Permission to dispose of NOW or NORM in caverns must come from State agencies (see below).

Underground Injection Control (UIC) Program

EPA has identified five classes of injection wells:

Class I – wells used to inject hazardous and radioactive wastes below an underground source of drinking water (USDW)

Class II – wells used to inject wastes brought to the surface in connection with oil and gas production, enhanced recovery of oil and gas, and wells used for storage of hydrocarbons
- NOW and NORM disposal caverns fall into this class
Class III – wells used to inject fluids for the purpose of mineral extraction

solution mining of new caverns may be regulated as Class III wells

Class IV wells – wells used to inject hazardous wastes into or above a USDW

these are prohibited

Class V wells – all other injection wells not in Classes I – IV

typically these are wells that inject nonhazardous fluids into or above a USDW

For more information, see the Groundwater Protection Council Web Site.

States Take the Lead on Regulating NORM

Features of State NORM Control Programs include:

Exemption standard or action level for determining whether the radiation level is high enough to be of concern

Licensing for possessing, handling, or disposing NORM

Requirements for releasing remediated NORM sites

Worker protection requirements

NORM waste disposal requirements

For more information on NORM, visit the NORM Technology Connection.

Permission to Dispose of NOW or NORM in Caverns

There are no outright prohibitions against the concept of NOW or NORM disposal in caverns (except for NORM disposal in Louisiana)

States may need to revise their NOW and NORM management regulations before cavern disposal will be allowed

Texas has issued permits for NOW and NORM disposal in caverns (see figure below), and as of June 2003, Louisiana has adopted regulations governing disposal of E&P waste in salt caverns

As of August 2002, 11 caverns are permitted at 7 locations

All these caverns may dispose of NOW waste and 3 may also dispose of NORM waste

In Canada, Alberta and Saskatchewan have issued a small number of cavern disposal permits

Location of Permitted NOW and NORM Disposal Caverns in Texas

Lotus, LLC; Andrews County; horizontal caverns; accepts NOW and NORM

NES Permian Basin – Permian Brine-Grimmett Bros., Andrews County; accepts NOW

NES Permian Basin – Big Springs; Howard County; 3 caverns; accepts NOW and NORM

NES Permian Basin – Fort Stockton; Pecos County; accepts NOW and NORM

Taylor Disposal Operating, Inc.; Freestone County; 2 caverns; accepts NOW

Trinity Storage Services, Inc.; Liberty County; 2 caverns; accepts NOW

Wasson Solid Waste Disposal LLC; Yoakum County; accepts NOW