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Document Record Detail



Full Document:
Title:STATUS OF SPENT SYNTHETIC PIT LINERS USED IN OIL AND GAS EXPLORATION AND PRODUCTION (E&P) OPERATIONS
RCRA Online Number:14815
Date:09/15/2010
To:Seman and Cambell
From:Dellinger
Organization of Recipient:Colorado Petroleum Association
Description: Synthetic pit liners used in oil and gas exploration and production (E&P) operations are not covered by the exploration and production exemption because they are not intrinsically derived from, or uniquely associated with, operations associated with the exploration, development, or production of crude oil and natural gas. Not all wastes generated by E&P operations are exempt; EPA has consistently interpreted that the exemption extends only to those wastes studied in the Report to Congress or otherwise identified in the 1988 Regulatory Determination or the 1993 Clarification. Reserve pits are an integral part of drilling operations but are not intrinsic to drilling operations. Synthetic liners are used for a variety of other applications and therefore not "uniquely associated" with E&P operations. Synthetic liners are not employed to facilitate the extraction, development, and production of the resource; rather, they are employed to facilitate its containment. EPA does not consider the placement of exempt E&P waste on a non-exempt pit liner to constitute the creation of a mixture. Mixtures constitute a comingling or blending of two or more substances. (See Also: 14816)
Regulatory Citation(s) : 261.4(b)(5) EXIT disclaimer
Statutory Citation(s):NA Read US Code 42, Chapter 82 EXIT disclaimer
Topic(s):Exclusions (RCRA); Mining Waste
Approximate Number of Hardcopy Pages:11
EPA Publication Number:NA
RPPC Number (if applicable): NA
Official OSW Policy:Yes

 

 
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