Compendium of Regulatory Requirements Governing Underground Injection of Drilling Wastes Page: 3 of 14
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ELGs - ELGs are national technology-based minimum discharge requirements. These standards
are developed by the U.S. Environmental Protection Agency (EPA) on an industry-by-industry
basis and represent the greatest pollutant reductions that are economically achievable for an
industry sector or portion of the industry. Selection of ELGs involves consideration of
technologies that have already been demonstrated in industrial applications, costs and economic
impacts, and non-water-quality environmental impacts. The ELGs are applied uniformly to
every facility within the industrial sector, regardless of where in the country the facility is located
or the condition of the water body receiving the discharge. Existing facilities must meet a level
of performance known as best available technology (BAT), while new facilities must meet new
source performance standards (NSPS).
The EPA has developed ELGs for most major industrial categories. For the oil and gas industry,
the EPA developed separate ELGs for onshore activities in 1979, offshore activities in 1993, and
coastal activities in 1996. Special provisions for discharges from offshore wells drilled using
synthetic-based drilling fluids were added in 2000. These ELGs are compiled into the Code of
Federal Regulations as 40 CFR Part 435.
This paper is concerned only with onshore CBM activities. Three subcategories of Part 435,
which covers the oil and gas industry, deal with onshore activities. The first is Subpart C, the
onshore subcategory. The requirements for produced water in this section are very clear: no
discharges are permitted. The other two subcategories provide exceptions to the onshore
subcategory. Subpart E is the agricultural and wildlife water use subcategory, which applies to
facilities located in the continental United States west of the 98th meridian, for which produced
water is clean enough to be used for wildlife and livestock watering or other agricultural uses.
The 98th meridian extends from near the eastern edge of the Dakotas through central Nebraska,
Kansas, Oklahoma, and Texas. Produced water with a maximum oil and grease limit of 35 mg/L
may be discharged from such sites. One caveat to this subcategory is that the produced water
must be of good enough quality to be used for wildlife or livestock watering or other agricultural
uses and must actually be put to such use during periods of discharge.
The second subcategory that permits onshore discharges is Subpart F, the stripper subcategory
(40 CFR 435.60). This subcategory applies to facilities that produce 10 barrels per day or less of
crude oil. The EPA has published no national discharge standards for this subcategory,
effectively leaving any regulatory controls to states or EPA regional offices, depending on which
has NPDES primacy. The EPA's decision to provide an exception for small oil wells reflects
the economic burden that an across-the-board zero discharge standard would impose. The
stripper subcategory is inconsistent in that it applies only to small oil wells and not to small
(marginal) gas wells (typically 60 thousand cubic feet [MCF] per day or less). In the absence of
any regulatory exception for marginal gas well discharges, such discharges are prohibited by the
general onshore standards.
Permit writers may face situations in which no ELGs have been developed for entire industries,
industry segments, or particular waste streams. In these circumstances, the permit writers must2
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Puder, Markus G.; Bryson, Bill & Veil, John A. Compendium of Regulatory Requirements Governing Underground Injection of Drilling Wastes, report, March 3, 2003; Tulsa, Oklahoma. (https://digital.library.unt.edu/ark:/67531/metadc737411/m1/3/: accessed April 19, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.