As recycling drilled cuttings continues to grow in use, more companies are starting to claim they offer recycling services. When evaluating potential recycling vendors, oil and gas companies should be careful of sham recycling and ensure their waste is not being ineffectively treated. Legitimate recycling, like the services Scott Energy offers, will reduce operators’ costs and liability by minimizing the risk of waste and turning it into an asset for operators.
Oil and gas companies have a lot to consider when running their operations, including how to properly dispose of their wastes, and should ensure that they are aware of possible pitfalls and changes. One of those pitfalls is when the United States Environmental Protection Agency (EPA) considers a company’s treatment of its drilling waste as “sham recycling.”
Exploration and production (E&P) activities produce wastes and by-products. At the federal level, these wastes are governed by the EPA under the Resource Conservation and Recovery Act (RCRA). Per current RCRA definitions, E&P wastes such as solid drilling waste (drilling mud and cuttings that are produced from drilling a new wellbore into the subsurface) are exempt from hazardous-waste rules, and are therefore left up to individual states to regulate. As innovations and changes are made that enhance efficiency in drilling, the physical and chemical characteristics of drilling wastes evolve. EPA last issued a regulatory determination for E&P wastes in 1988; however, in a recent consent decree issued by the U.S. District Court for the District of Columbia, EPA will be required to review its regulations for E&P wastes by 2019 and, if necessary, make appropriate updates by 2021. E&P companies should be proactive in their waste management policies and ensure that their current practices are not only in compliance with current regulations, but also are scientifically defensible and, whenever possible, compliant with any expected regulatory changes.