Simone Lawson
Oil and gas waste in Texas is a highly regulated area, with the Railroad Commission of Texas (RRC) and the Texas Commission on Environmental Quality (TCEQ) playing key roles in overseeing waste management and environmental quality. Oil and gas waste can include a variety of materials, such as lubricating oils, wastewater, and naturally occurring radioactive materials (NORM). NORM waste, in particular, is closely monitored due to its radioactive nature, with specific requirements for identification and disposal. To minimize waste generation, operators are encouraged to adopt waste minimization techniques, select recyclable processes, and utilize less toxic product substitutes. The TCEQ also promotes waste compliance and provides assistance to businesses and local governments to adhere to environmental regulations.
| Characteristics | Values |
|---|---|
| Regulatory Bodies | Railroad Commission of Texas (RRC), Texas Commission on Environmental Quality (TCEQ) |
| RRC Waste Disposal | Allowed under specific circumstances stated in an MSW Landfill's permit |
| TCEQ Waste Management | Regulated by the Industrial and Hazardous Waste Rules and Regulations for Small-Quantity Generators |
| Used Oil | Management guidelines available, recycling encouraged |
| NORM (Naturally Occurring Radioactive Material) | Requires special permits and disposal methods, must be identified with "NORM" tags |
| Waste Minimization | Techniques available for gas treating and processing operations, product substitution recommended |
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What You'll Learn
Hazardous and non-hazardous waste
The TCEQ provides a step-by-step guide to the registration, operation, and reporting requirements for transporting sludge wastes in Texas. It also offers free, confidential help to small businesses and local governments working to follow state environmental regulations.
The TCEQ's Used Oil Recycling Program aims to increase the participation of public and private sector organizations and companies as used oil collection centers, as well as increase the number of collection centers and the amount of oil collected. The program also provides education and technical guidance to the regulated community and the public.
The TCEQ also provides a Household Hazardous Waste (HHW) program, which includes guidance on what constitutes HHW, what to do with it, and who can accept it. HHW includes leftover or used household products that contain chemicals that can be unsafe if not managed properly, such as corrosive cleaners. While these materials are not required to be handled as hazardous waste and can be placed in regular trash, many communities in Texas have HHW drop-off facilities or hold HHW collection events.
The RRC has adopted revisions to the Texas Administrative Code (TAC) Chapter 4, Subchapter B, relating to Commercial Recycling, and new TAC Chapter 4, Subchapter A, relating to Oil and Gas Waste Management. The official document will be available on the Secretary of State's website from July 1, 2025. The RRC also provides information on environmental permit types for hazardous waste and an Annual Hazardous Oil and Gas Waste Report package.
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NORM (Naturally Occurring Radioactive Material)
NORM, or Naturally Occurring Radioactive Material, is a radioactive element found in the environment that occurs naturally. It primarily contains uranium, thorium, radium, and sometimes potassium. Despite being natural, uranium and thorium are defined as source materials and are regulated as such. NORM is often found as a byproduct of industrial processes, including oil and gas production, phosphate fertilizer production, mineral extraction, metal recycling, waste management, and water treatment.
In the context of oil and gas waste in Texas, NORM waste is defined as any solid, liquid, or gaseous material, or combination of materials (excluding source material, special nuclear material, and byproduct material) that spontaneously emits radiation in its natural state, is discarded or unwanted, and exceeds specific exemption criteria. Oil and gas operations can result in NORM-contaminated equipment, soils, and waste, which must be identified with the letters "NORM" through clearly visible tags or markings.
NORM wastes contain radionuclides like radium, thorium, or uranium, which can become concentrated through human activity, leading to radioactive hazards through potential ingestion or direct radiation exposure. Some NORM radionuclides are heavy metals that can be toxic, such as uranium, which can damage the kidneys. The regulation of NORM waste in Texas falls under the Texas Radiation Control Act, with exemption requests evaluated on a case-by-case basis by the Texas Commission on Environmental Quality (TCEQ).
Permits are required for the disposal of oil and gas NORM waste, with specific rules for underground injection (Rule 9) and surface disposal (Rule 8). NORM-contaminated solids, such as pipe scale, may be disposed of without a permit on the site where they were generated, through burial or landfarming, as long as radioactivity concentrations do not exceed exemption levels. Facilities with oil and gas surface waste disposal permits that require financial security must conduct a NORM screening survey when submitting a closure cost estimate (CCE) for permit renewal. If NORM is detected above the screening level, the CCE must include additional costs for the disposal of NORM-contaminated equipment, soils, or waste.
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Wastewater permits
In Texas, the Railroad Commission (RRC) regulates the transport of hazardous oil and gas waste. The Texas Commission on Environmental Quality (TCEQ) regulates waste that is not overseen by the RRC.
The TCEQ has issued permits for oil and gas wastewater, including a new Oil and Gas Extraction TPDES General Permit, effective January 10, 2024. This permit authorises the discharge of wastes associated with oil and gas extraction activities from OCS facilities located between 3.0 and 10.357 statute miles from the coastline in the Gulf of Mexico. For discharges beyond this distance, the TCEQ has issued a separate Oil and Gas Outer Continental Shelf (OCS) General Permit, also effective from January 10, 2024.
To obtain permit authorisation, facilities must submit a notice of intent (NOI) through the State of Texas Environmental Electronic Reporting System (STEERS). If a facility cannot meet the requirements of the general permit, an individual permit may be required.
The TCEQ also offers a Used Oil Recycling Program, which aims to increase the collection and recycling of used oil by establishing more collection centres. The program provides education and technical guidance to the public and the regulated community.
The RRC has implemented rules and regulations for the management of hazardous oil and gas waste, including the Waste Hauler Permit. This permit is not required for the hauling of inert waste, but the transport of hazardous waste is subject to Statewide Rule 98. The RRC also invites interested parties to participate in the implementation of new rules and regulations related to oil and gas waste management.
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Used oil recycling
In Texas, the Texas Commission on Environmental Quality (TCEQ) regulates the disposal and recycling of oil and gas waste. Oil and gas waste includes hazardous and non-hazardous waste associated with the exploration, development, and production of oil and gas.
Used oil is a specific category of oil and gas waste that is managed through the Used Oil Recycling Program. This program aims to increase the collection and recycling of used oil by establishing public and private sector organizations and companies as used oil collection centers (UOCCs). UOCCs are facilities that accept, store, and manage used oil collected from generators, as well as from household do-it-yourselfers in quantities of less than five gallons. These centers must register with the TCEQ within 30 days of operation and renew their registration every two years. They are also required to report the amount of used oil collected annually.
To encourage participation in the Used Oil Recycling Program, registered UOCCs can qualify for an exemption from the fees collected by the Comptroller of Public Accounts on the first sale of new automotive oil. Additionally, Texas law prohibits the dumping of used oil on land, into sewers or waterways, or its use as a dust suppressant. Used oil filters are also banned from landfills, and UOCCs are encouraged to remove as much free-flowing oil from these filters as possible.
The TCEQ provides educational resources and technical guidance to the public and the regulated community to promote proper used oil management and recycling. The commission offers a step-by-step guide to registration, operating, and reporting requirements for transporting sludge wastes in Texas, as well as specific information on used oil recycling in the Used Oil Recycling (RG 325) document.
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Waste minimisation techniques
Waste minimisation is any activity that results in a reduction of the quantity or toxicity of oil and gas waste that must be treated or disposed of. It is not specifically required by the Railroad Commission of Texas (RRC), but it is encouraged as it can reduce operating costs, improve efficiency, reduce regulatory compliance concerns, and reduce future potential liability. Waste minimisation can also improve the public image of a company and the oil and gas industry as a whole.
The RRC provides a publication called "Waste Minimization in the Oil Field", which offers a general overview of waste minimisation as a waste management practice. It also includes chapters on waste generation in oil and gas operations, identification of hazardous oil and gas waste, and the principles of waste minimisation. The RRC also provides documents that address waste minimisation for specific operations, such as waste minimisation in gas treating and processing operations, and waste minimisation in production and workover operations. These documents provide case histories of successful waste minimisation projects and a bibliography of useful technical references.
The Texas Commission on Environmental Quality (TCEQ) publishes two useful documents: "Recycle Texas" and "RENEW". "Recycle Texas" is a listing of companies that take various wastes, including those typical of oil and gas operations, for recycling. "RENEW" is a waste exchange that is published quarterly and lists companies that have generated wastes and are making them available for recycling, as well as companies that want certain wastes for recycling. Both documents are available free of charge from TCEQ.
Training is also a crucial aspect of waste minimisation. Operators' efforts to minimise waste will only be effective if the people in the field understand waste classification and the concept of waste minimisation. They should also be empowered to implement waste minimisation techniques as they are identified. Waste minimisation training is becoming more common, and oil and gas associations have begun publicising waste minimisation successes. Technical societies, such as the SPE, are publishing more and more papers on effective waste minimisation techniques.
There are many economically and technically feasible waste minimisation techniques that can be used in production and workover operations. For example, choosing feasible source reduction and recycling options can reduce or eliminate the generation of waste at the source or the release of a contaminant from a process. Another example is the substitution of alternative cleaning agents, such as citrus-based cleaning compounds and steam, for organic solvents. This can eliminate a hazardous waste stream and reduce associated waste management and regulatory compliance concerns.
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Frequently asked questions
NORM, or Naturally Occurring Radioactive Material, is any solid, liquid, or gaseous material that spontaneously emits radiation in its natural state, is discarded or unwanted, and is contained in or has contaminated oil and gas waste.
The Used Oil Recycling Program aims to increase the participation of public and private sector organizations as used oil collection centers, increase the collection of used oil, and provide education and technical guidance to the public.
The regulation of oil and gas activities in Texas falls primarily under the jurisdiction of the Railroad Commission of Texas (RRC). The Texas Commission on Environmental Quality (TCEQ) also plays an important role in waste management, air quality, surface water management, and water quality.
