Melanie Clore
Conservation Program Manager

Contact
Information

phone (225) 342-4093
   FAX  (225) 342-2584

PHYSICAL ADDRESS
Office of Conservation
Engineering Division
LaSalle Building, 9th Floor
617 N. Third Street
Baton Rouge, Louisiana
70802

MAILING ADDRESS
Office of Conservation
Engineering Division
Post Office Box 94275
Baton Rouge, Louisiana
70804-9275

Report an INCIDENT 

• Use of Reclaimed Oilfield Waste (ROW) for Downhole Well Operations (LAC 43:XIX.301, 303, 311, 313, 501, 519 & 565) - (Effective 05/20/2023)

Form ENG-17 "Reclaimed Oilfield Waste (ROW) Transportation Ticket" ordering information is now available.

Reclaimed Oilfield Waste (ROW) Staging Location Registration Form (web-based) is now available.

This page provides guidance on the regulatory and reporting requirements for on-site storage, treatment and disposal of Exploration and Production (E&P) Wastes. The following definitions are used to determine applicability of these regulations:

"ON-SITE" means on the same lease or contiguous property owned by the lessor, or within the confines of a drilling unit established for a specific well or group of wells.

"EXPLORATION & PRODUCTION WASTES" are drilling wastes, salt water, and other wastes intrinsically derived from primary field operations associated with the exploration, development, or production of crude oil or natural gas wells which are exempt from the Louisiana Hazardous Waste Regulations and the Federal Resource Conservation and Recovery Act (RCRA).

E&P Wastes include, but are not limited to the following:

• Salt water (produced brine or produced water);
• Oil-base drilling wastes (mud, fluids and cuttings);
• Water-base drilling wastes (mud, fluids and cuttings);
• Completion, workover and stimulation fluids;
• Produced oily sands and solids;
• Produced formation fresh water;
• Crude oil spill clean-up waste;
• Rainwater from firewalls, ring levees and pits at drilling and production facilities.

If the waste material and/or disposal site do not meet the above definitions, the regulations and guidance provided in this document are not applicable.

Common wastes that are not classified as E&P Waste include:

• Unused fracturing fluids and acids;
• Engine oil and lubricating oils;
• Hydraulic fluids;
• Sanitary wastes;
• Pesticide and herbicide wastes;
• Painting wastes;
• Drilling fluids from pipeline boring operations.

DENR does not have jurisdiction over the storage, treatment or disposal of any waste not classified as an E&P Waste. Instead, these non-exempt wastes are subject to LDEQ/EPA regulations.

Additional information and resources regarding the E&P Waste exemption can be obtained from the EPA website and the EPA document entitled "Exemption of Oil and Gas Exploration and Production Wastes from Federal Hazardous Waste Regulations".

Contamination of a groundwater aquifer or a USDW with E&P Waste is strictly prohibited.  The discharge of produced water or other E&P Waste (including drilled solids) into manmade or natural drainage or directly into state waters is allowed only in conformance with any applicable state or federal discharge regulatory program.

E&P Wastes may be stored on-site in tanks (closed-loop storage systems) or within earthen impoundments or "pits".  Pits may be either lined or unlined depending on the intended purpose and the types of E&P waste being stored.  The Office of Conservation encourages the use of closed-loop systems for on-site E&P Waste storage.

For the purpose of these regulations, a "pit" is defined as a natural topographic depression or man-made excavation used to hold E&P Waste, produced water or hydrocarbon storage brine.  Lined sumps with a capacity less than 660 gallons or containment dikes, ring levees or firewalls constructed around oil/gas facilities are NOT considered pits under this definition.

Pits are divided into two main categories:

"Reserve Pits" - temporary earthen pits used to store only those materials used or generated in drilling and workover operations.

"Production Pits" - earthen or lined storage pits for collecting E&P Waste sediment periodically cleaned from tanks and other producing facilities, for storage of produced water or other exploration and production wastes produced from the operation of oil and gas facilities, or used in conjunction with hydrocarbon storage and solution mining operations.

Production Pits are further subdivided into the following nine categories:

• Produced Water;
• Onshore Terminal;
• Washout;
• Burn;
• Well Test;
• Emergency;
• Natural Gas Processing Plant;
• Compressor Station;
• Salt Dome Cavern.

Specific regulatory requirements for the construction and operation of pits are found in LAC 43:XIX.307.

Except for reserve pits, operators must notify the Office of Conservation of the intent to construct new pits at least ten (10) days prior to start of construction.  For reserve pits used in drilling and workover operations, notification requirements are satisfied by application for a drilling or work permit.

The required notification is to be provided on Form ENG-15 [word/PDF].  If a liner is required, liner specifications must accompany the notification form.

All Reserve pits must be emptied of fluids in a manner compatible with all applicable regulations, and closed in accordance with LAC 43:XIX.311 & 313 within six months of completion of drilling or work over operations.  The operator (generator) must also file Form ENG-16 [word/PDF] documenting proper disposition of all E&P wastes generated within six months of the completion of drilling or workover operations.   

Waste Characterization/Pre-Closure Analysis

For evaluation purposes prior to closure, E&P Waste must be analyzed for the following criteria:

• pH
• total metals content (arsenic, barium, cadmium, chromium, lead, mercury, selenium, silver, zinc)
• oil and grease (percent dry weight)
• soluble salts and cationic distributions (EC, SAR, ESP, CEC)
• radioisotopes if pit is located in the coastal area

Reserve pit fluids disposed of through subsurface injection or generated during drilling of a well to a depth of less than 5,000 feet with a freshwater "native" mud containing no more than 25 lbs/bbl bentonite, 0.5 lbs/bbl caustic soda or lime, and 50 lbs/bbl barite are exempt from the analytical testing requirements. 

All parameters are to be analyzed using standard soil testing procedures as presented in the DENR Laboratory Manual for the Analysis of Oilfield Waste by a LDEQ - LELAP accredited laboratory.

All pre and post closure analytical documentation must be maintained in operator's files for at least three (3) years after completion of closure activities and must be made available upon written request from OC.

On-site Disposal Methods

• Land Treatment (LAC 43:XIX.313.D)
• Burial / Trenching (313.E)
• Solidification (LAC 43:XIX.313.F)
• Onsite Land Development (LAC 43:XIX.313.G)
• Passive Closure (LAC 43:XIX.313.H)
• Subsurface Annular Injection (LAC 43:XIX.315)

Prior to conducting onsite pit closure activities, an operator must make a determination that the requirements and closure limits specified by LAC 43:XIX.313 are attainable.

Closure Limits for Onsite E&P Waste Disposal 

The criteria for land treatment, burial, solidification, or onsite land development applies to the disposal of any E&P waste remaining onsite. 

Other E&P Waste disposal methods include:

• Use of Reclaimed Oilfield Waste (ROW) for Downhole Well Operations (LAC 43:XIX.313.J)
• Class II or Community Injection (fluids only) 
• Offsite Commercial Disposal  

Additional information regarding injection well disposal or subsurface annular injection may be obtained from the Injection and Mining Division - Underground Injection Control (UIC) Section. 

Additional information regarding off-site or commercial disposal may be obtained from the Environmental Division - Exploration and Production Waste Management Section.

LAC 43:XIX Chapter 3  - Pollution Control-Onsite Storage, Treatment and Disposal of Exploration and Production Waste (E&P Waste) Generated from the Drilling and Production of Oil and Gas Wells (Oilfield Pit Regulations)

None at this time.

• Injection well disposal
• Annular disposal
• Offsite/commercial disposal