BCI
Memo to Our Clients
Louisiana Environmental Law & Regulatory
Update
May 29, 2011
Regular Session, 2011, House Bills 563 &
564 and Senate Bill 146
Note to
the Reader: The following is a summary based on the synthesis of regulatory
review both federal and state, published news articles, blogs, interviews and
firsthand knowledge of the implications for both sides on the issue of “Legacy”
or “Legacy Oil Field Sites” or formerly used exploration or production sites
(E&P). Feel free to comment as this
subject is a moving target. We do our best to check facts and relish in
updating the action on this subject. In
this memo we refer to the Louisiana Department of Natural Resources as the LDNR
and this can be substituted for the Louisiana Legislatures reference to Office
of Conservation or “OOC”.
This year in the regular session of Louisiana Legislature,
three bills were set out, two in the House (HB 563 & 564) and one in the
Senate (SB 146). The House Bills 563 & 564 were voted down (deferred) in
committee in a 10-7 vote on May 18,
2011, thus killing the bills for this regular session. The sister Bill 146 in the Senate is still
alive as of this writing, but is probably dead for this session.
Proponents of these bills presented fairly
bold language as compared to past attempts at regulating what the oil industry
believes are frivolous claims that are impacting mainly smaller operators from
speculation, exploration and production. HB 563[i] and SB 146 present
“primary jurisdiction” for the LDNR that would cover any claims of
environmental damages resulting from oil and gas exploration and production on
Louisiana land based operations. HB 564[ii] makes “specific performance”
the “preferred remedy” for environmental claims under the Louisiana Oil Field
Restoration Law. It appears that these bills are attempting to eliminate stakeholders
and landowners rights to file suit to recover damages for environmental impact claims
by broadening the LDNRs power over these matters like a separate court, specifically for the oil and gas operators
that engage, or have engaged, in both exploration and production. Opponents to the bills make many claims, but
the most salient one is that the foundation and spirit of these bills are
unconstitutional. This battle does not seem to have a sunset. We believe it should be settled at the
federal level by reassessing the applicability of the exemptions and exclusions
that exist for this industry. LDNR
remained neutral throughout the hearings and this frustrated numerous
representatives of both sides. The goal of the proponents was to give LDNR more
power and thus reduce litigation time.
Opponents said it should do just the opposite.
This recent effort injected some new language that warrants
attention. In particular, the proposal
of authorizing the Louisiana Department of Natural Resources to have primary
jurisdiction for ALL demands arising as a result of actual or potential
impacts, damages, or injury to environmental media caused by impacts from oil
field operators of exploration and production.
It also attempted to advance that all monies recovered would be placed
in the Oil Site Restoration Fund[iii]. According to the Daily Comet, May 19,
2011[Jeremy Alford - Capitol Correspondent] paraphrasing…..“Members
of the House Natural Resources Committee said they were concerned about passing
a bill with enormous complexities, while state officials wavered on the
question of whether the Louisiana Department of Natural Resources could take
the specialized claims process from the courts”.
These bills bring up issues
on constitutionality by granting the LDNR the authority to adjudicate
claims as opposed to the courts.
Property rights could also be thwarted as opposed to increased
protection with 312. Another major concern by the opposition is that this would
apply retroactively to current claims pending in the courts.
The opponents to this bill
say that there is inadequate funding for the expansion of the responsibilities
of the LDNR, to include all the required testing, monitoring, and regulatory
hearings that be expected to overwhelm the capabilities of the LDNR. They
also claim that there is no budget that can cover these additional functions
that the bills present. In essence, the LDNR would be promoting the oil
and gas industry and also be the agency for cleanup. Opponents believe Act 312
keeps the LDNR in the loop to protect the stakeholders and the people of the
state without shifting this new financial burden to the state.
The typical discovery
process is also said to be negated by the LDNR if these bills come to fruition.
This could prevent full disclosure from ever happening. On non-oil field sites like a solid or
hazardous waste site “deed recordations” are sometimes required, and certainly
full disclosure must occur prior to a transaction of that property where the
activity took place. Determination of who is liable typically happens before
the LDNR gets involved under 312.
The process that would
result from these bills would also require that verification of every operator
be conducted at a hearing to determine the PRPs for that specific claim. It also seems that these bills would delay
the cleanup and increase soft costs that have nothing to do with
remediation.
Proponents are saying that
these bills will promote stability for operators going into new E&P
projects. The oil and gas industry
claims that there has been too much uncertainty with potential liability to
risk start up activities in Louisiana.
Proponents of these bills
say that 312 and the possibility of false claims against current and past
operators has decreased activity in this market, however, more independent operator permits have been issued in recent
years. Opponents say the bills also fail
to provide any answers towards better accountability before any litigation
issues arise. There should be more attention made to operator’s responsibility
to notify LDNR and land owners prior to vacating sites. The lack of communication with landowners
creates a chiasm of distrust.
Here is an excerpt from Capitol
Correspondent Jeremy Alford published in the Daily Comet:
David
Russell, president of McGowan Working Partners, said he deserves protections,
too:
“Obtaining
proper insurance ... for oilfield operations is not difficult to get,” Russell
said. “It’s impossible. After 15 years of providing coverage, my company’s
provider declined pollution liability insurance coverage simply due to the
legacy-lawsuit issues in the state. Developments like this are going to shut
this industry down, as far as Louisiana is concerned.”
Regardless
of Wednesday’s outcome, opponents and proponents both agreed the program has
faults.
Of
the 250 cases recognized by the state, only two have been cleaned up since the
latest law went into effect five years ago and another 16 cases are working
through the system, according to Natural Resources attorney Blake Canfield.
Back Story:
During the 2006 Louisiana Legislative
Session, Act 312 was successfully enacted.
This was viewed by many as a sound compromise for Big Oil and landowners
and their advocates. This was done to reform the procedure in litigation
claiming environmental damages. These
claims are commonly known as “legacy litigation”. BCI is keenly aware of our clients/stakeholders
desire to monitor ongoing bills or policy changes at LDNR or LDEQ that can
affect ongoing claims. Act 312 will continue to be challenged based on
constitutionality. District and
appellate courts continue to address issues that should have been vetted by now
as compared to other contaminated site litigation under CERCLA. Example issues are: 1) When to defer to LDNR
on actual remediation plan approvals (we believe is best suited for LDEQ), 2)How
to apply provisions of the Act 312, 3) Who should decide who the PRPs
(principle responsible parties) are, and a host of other issues key to
navigating or fighting any claim in state court.
This is a nationwide issue and
originates back to the RCRA Oil Field Wastes Exemption and CERLCA Petroleum
Exclusion [See excerpt from LDNR Website at the bottom of this memo on Exempt
and Non-Exempt Wastes[iv]]. E&P wastes have remained exempt (meeting
discreet definitions and proof of “mixed wastes”) from Subtitle C based on the
notion that “special wastes” are lower in toxicity as compared to other
materials generated upstream from E&P.
The reader should not confuse this with OPA 1990 or LDEQ/EPA UST
provisions. The CERCLA Notification Form promulgated in 1981 contained
instructions which clearly excluded E&P wastes from regulation as CERCLA
hazardous substances. Wastes not subject
to notification under Section 103(c) of Superfund (solid wastes not presently
regulated as “hazardous waste” under RCRA) are generally drilling fluids,
produced waters, and other wastes associated with the exploration, development,
or production of crude oil, natural gas, or geothermal energy. Therefore, even
the EPA notification form acknowledged the CERCLA E&P Exclusion.
Both sides agree that the
system needs serious improvement. Hundreds of sites remain to be cleaned up and
there seems to be little serious talk or better ideas of actual streamlining
the process. If the system is
streamlined for both sides and clean-up is routine, it will inevitably be more
conducive for exploration and production to take place. Restitution for restoration through the
courts is incredibly slow and the cleanup is often delayed or marginalized.
[i] The following are the key points of each
bill that originated from the House as it was presented in committee:
HB No.
563
Abstract: Provides that the
jurisdiction of the office of conservation includes claims for certain
environmental damages resulting from oil and gas activity and authorizes the
secretary of the Dept. of Natural Resources to take legal action to meet the
purpose of the La. Oilfield Site Restoration Law.
Proposed law provides that the
office of conservation shall have primary jurisdiction for all demands arising
as a result of any actual or potential impact, damage, or injury to
environmental media caused by contamination resulting from activities
associated with oilfield sites or exploration and production sites.
Proposed law requires that all
judicial demands which have been filed or amended as of July 1, 2011, and which
the office has not approved a plan to evaluate or remediate the environmental
damage be stayed and referred to the office for approval of a plan.
Present law provides for the
proper and timely cleanup, closure, and restoration of orphaned oilfield sites
and creates the Oilfield Site Restoration Fund (fund) for that purpose.
Proposed law provides that monies
recovered from activities conducted pursuant to the La. Oilfield Site
Restoration Law shall be placed in the fund.
Proposed law authorizes the
secretary of the Dept. of Natural Resources to take legal action to meet the
purpose of the La. Oilfield Site Restoration Law.
Abstract: Authorizes the
secretary of the Dept. of Natural Resources to take legal action to meet the
purpose of the La. Oilfield Site Restoration Law and provides that specific
performance is the preferred remedy in a case of failure to restore the
property subject to a mineral lease or mineral servitude.
Present law provides for the
proper and timely cleanup, closure, and restoration of orphaned oilfield sites
and creates the Oilfield Site Restoration Fund (fund) for that purpose.
Proposed law provides that monies
recovered from activities conducted pursuant to the La. Oilfield Site
Restoration Law shall be placed in the fund.
Proposed law authorizes the
secretary of the Dept. of Natural Resources to take legal action to meet the
purpose of the La. Oilfield Site Restoration Law.
Proposed law provides that
specific performance is the preferred remedy in a case of failure to restore
the property subject to a mineral lease or mineral servitude.
Proposed law requires notice be
sent to the lessor or grantee and a reasonable opportunity to respond and
perform.
Background
The Louisiana Oilfield Site Restoration Program was created in
1993 within the Department of Natural Resources to address the growing problem
of unrestored orphaned oilfield sites across the State. Orphan wells are
abandoned oil and gas wells for which no viable responsible party can be
located, or such party has failed to maintain the wellsite in accordance with
State rules and regulations. The specific focus of the Oilfield Site
Restoration Program is to properly plug and abandon orphan wells and to restore
sites to approximate pre-wellsite conditions suitable for redevelopment.
Oilfield site restoration projects range in size and scope from
the repair of small wellhead leaks and the removal of exploration and
production related trash and debris to the plugging of wells and removal of
associated facilities and structures. Orphan wells are found throughout
the State in all areas where there has been historic oil and gas
activity. These sites deteriorate over time due to neglect from the
operator of record and therefore become susceptible to releasing oil, gas, and
saltwater to the surrounding area. The Program has addressed sites near
schools and public buildings, in sensitive coastal wetland areas, and near
residential areas.
Orphan wellsites are prioritized to direct available funding to
those sites that pose the greatest threat to public safety and
environment. However, in order to also economically decrease the total
number of orphaned wells in the State, lower priority sites located near a
proposed project area are often included in the project scope of work to
increase cost-effectiveness by lowering overall individual well plugging
costs. Project design and oversight is handled by in-house petroleum
engineering staff while all other restoration-specific tasks are contracted to
approved oilfield contractors. Project bids are solicited in accordance
with the State bid law and projects are awarded to the lowest qualified bidder.
Revenue for the Program is entirely generated from a fee on oil
and gas production in the State of Louisiana which is paid quarterly by
Louisiana oil and gas operators. These flat-rate fees are deposited to
the oilfield site restoration fund (Fund) which is dedicated by statute to fund
the operation of the Program. No tax-payer dollars are utilized.
The fee consists of one and one-half cents ($.015) for every barrel of oil and
condensate produced, and three-tenths of one cent ($.003) for every thousand
cubic feet of gas produced. This currently equates to roughly $4 million
dollars a year to be utilized by the Program for orphan oilfield site
restoration projects.
Recovery
of Restoration Costs
The operator of record for an orphan wellsite is in all cases
the primary party required to restore an oilfield site once it becomes
unusable. This responsibility remains whether or not a site specific
trust account has been established for this purpose. Should a site be
restored using monies from the Fund, and a site specific trust account has not
been created for the site, former operators and their working interest owners
may then also have some liability in addition to the responsible party for
repayment of the monies spent from the Fund.
The process of recovery of site restoration costs of orphaned
oilfield sites from the responsible party and others who may share in this
liability is addressed in LSA-R.S. 30:93. The Secretary of the Department
of Natural Resources is empowered by law to recover all costs incurred by the
Program resulting from orphan site restoration operations. The procedures
to be utilized in this matter are dependent on the specific cost of site
restoration activity and whether or not a site specific trust account has been
established for the site restored. For a site without a site specific
trust account, the Secretary is authorized to collect only from the responsible
party (i.e. the last operator of record and his working interest owners) unless
the cost of the site restoration exceeds $250,000.00, at which time all former
operators and working interest owners become liable for the entire restoration
cost in inverse chronological order.
Site
Specific Trust Accounts
In accordance with the provisions of the Oilfield Site
Restoration Law (LSA R.S. 30:80 et seq), when a transfer of ownership interest
of an oilfield site occurs, either party of the transfer can elect to file an
application to establish a site specific trust account (SSTA) to cover future
site restoration costs. To the extent permitted under the law, once
established and fully funded, a SSTA will release from liability the Transferor
and all prior responsible parties for site restoration costs for the
transferred oilfield site. Thereafter, the Transferee will be considered
the responsible party for the purposes of site restoration. For more
information, please see the document entitled 'Establishing a Site Specific Trust Account (SSTA)' or contact Program staff. The following forms related to
SSTAs are also available:
· FORM 9604 -
Site Specific Trust Account
·
FORM 9604-1 - Site Specific Trust Account Reassessment (MS Word, PDF).
The Oilfield Site
Restoration Commission
The
Program is domiciled within the Engineering Division of the Office of
Conservation of the Department of Natural Resources. Program oversight is
provided by an Oilfield Site Restoration Commission which consists of ten
members. The Secretary of the Department of Natural Resources serves as
chairman of the Commission, while the Commissioner of the Office of Conservation
serves as vice-chairman. The remaining eight members of the Commission
are appointed by the Governor from a list of nominees submitted by various
industry and environmental groups. The Commission meets quarterly in
Baton Rouge.
Oilfield
Site Restoration Commission
Scott A. Angelle, Chairman, Secretary of DNR
James
H. Welsh, Vice-Chairman, Commissioner of Conservation
Paul
Frey, Louisiana Land Association
Don
Briggs, Louisiana Oil & Gas Association
Wilfred
Fruge, Louisiana Oil & Gas Association
Karen Gautreaux,
Nature Conservancy
Randy
Lanctot, LWF, Sierra & Audubon Societies
James
Maranto, At Large
Michael
Lyons, Mid-Continent Oil & Gas Association
Troy
Vickers, Mid-Continent Oil & Gas Association
*Source-EPA
document EPA530-K-95-003, May 1995
In December, 1978, the Environmental
Protection Agency (EPA) proposed hazardous waste management
standards that included reduced requirements for several types of large volume
wastes. Generally, EPA believed these large volume "special wastes"
are lower in toxicity than other wastes being regulated as hazardous waste
under RCRA. Subsequently, Congress exempted these wastes from the RCRA Subtitle
C hazardous waste regulations pending a study and regulatory determination by
EPA. In 1988, EPA issued a regulatory determination stating that control of
exploration and production (E&P) wastes under RCRA Subtitle D was not
warranted. Hence, E&P waste have remained exempt from Subtitle C
regulations. This exemption, however, did not preclude these wastes from
control under state regulations, under the less stringent RCRA Subtitle D solid
waste regulations, or under other federal regulations. In addition, although
they are relieved from regulation as hazardous wastes, the exemption does not
mean these wastes could not present a hazard to human health and the
environment if improperly managed. Statewide Order No 29-B provides guidelines
for environmentally sound management of these exempt wastes.
In the 1988 regulatory determination, EPA published lists of
wastes regarded as exempt and non-exempt. The lists were provided as examples
of wastes regarded as exempt or non-exempt; the lists were not to be considered
comprehensive. The E&P waste wastes listed in this brochure closely track
the exempt listing of the 1988 regulatory determination. Examples of non-exempt
wastes are as follows:
- Gas
plant cooling tower cleaning wastes;
- Painting
wastes and waste solvents;
- Refinery
wastes;
- Used
equipment lubricating oils;
- Waste
compressor oil, filters, and blowdown;
- Used hydraulic fluids.
[1] The following are the key points of each
bill that originated from the House as it was presented in committee:
HB No.
563
Abstract: Provides that the
jurisdiction of the office of conservation includes claims for certain
environmental damages resulting from oil and gas activity and authorizes the
secretary of the Dept. of Natural Resources to take legal action to meet the
purpose of the La. Oilfield Site Restoration Law.
Proposed law provides that the
office of conservation shall have primary jurisdiction for all demands arising
as a result of any actual or potential impact, damage, or injury to
environmental media caused by contamination resulting from activities
associated with oilfield sites or exploration and production sites.
Proposed law requires that all
judicial demands which have been filed or amended as of July 1, 2011, and which
the office has not approved a plan to evaluate or remediate the environmental
damage be stayed and referred to the office for approval of a plan.
Present law provides for the
proper and timely cleanup, closure, and restoration of orphaned oilfield sites
and creates the Oilfield Site Restoration Fund (fund) for that purpose.
Proposed law provides that monies
recovered from activities conducted pursuant to the La. Oilfield Site
Restoration Law shall be placed in the fund.
Proposed law authorizes the
secretary of the Dept. of Natural Resources to take legal action to meet the
purpose of the La. Oilfield Site Restoration Law.
[1]
HB No. 564
Abstract: Authorizes the
secretary of the Dept. of Natural Resources to take legal action to meet the
purpose of the La. Oilfield Site Restoration Law and provides that specific
performance is the preferred remedy in a case of failure to restore the
property subject to a mineral lease or mineral servitude.
Present law provides for the
proper and timely cleanup, closure, and restoration of orphaned oilfield sites
and creates the Oilfield Site Restoration Fund (fund) for that purpose.
Proposed law provides that monies
recovered from activities conducted pursuant to the La. Oilfield Site
Restoration Law shall be placed in the fund.
Proposed law authorizes the
secretary of the Dept. of Natural Resources to take legal action to meet the
purpose of the La. Oilfield Site Restoration Law.
Proposed law provides that
specific performance is the preferred remedy in a case of failure to restore
the property subject to a mineral lease or mineral servitude.
Proposed law requires notice be
sent to the lessor or grantee and a reasonable opportunity to respond and
perform.
Background
The Louisiana Oilfield Site Restoration Program was created in
1993 within the Department of Natural Resources to address the growing problem
of unrestored orphaned oilfield sites across the State. Orphan wells are
abandoned oil and gas wells for which no viable responsible party can be
located, or such party has failed to maintain the wellsite in accordance with
State rules and regulations. The specific focus of the Oilfield Site
Restoration Program is to properly plug and abandon orphan wells and to restore
sites to approximate pre-wellsite conditions suitable for redevelopment.
Oilfield site restoration projects range in size and scope from
the repair of small wellhead leaks and the removal of exploration and
production related trash and debris to the plugging of wells and removal of
associated facilities and structures. Orphan wells are found throughout
the State in all areas where there has been historic oil and gas
activity. These sites deteriorate over time due to neglect from the
operator of record and therefore become susceptible to releasing oil, gas, and
saltwater to the surrounding area. The Program has addressed sites near
schools and public buildings, in sensitive coastal wetland areas, and near
residential areas.
Orphan wellsites are prioritized to direct available funding to
those sites that pose the greatest threat to public safety and
environment. However, in order to also economically decrease the total
number of orphaned wells in the State, lower priority sites located near a
proposed project area are often included in the project scope of work to
increase cost-effectiveness by lowering overall individual well plugging
costs. Project design and oversight is handled by in-house petroleum
engineering staff while all other restoration-specific tasks are contracted to
approved oilfield contractors. Project bids are solicited in accordance
with the State bid law and projects are awarded to the lowest qualified bidder.
Revenue for the Program is entirely generated from a fee on oil
and gas production in the State of Louisiana which is paid quarterly by
Louisiana oil and gas operators. These flat-rate fees are deposited to
the oilfield site restoration fund (Fund) which is dedicated by statute to fund
the operation of the Program. No tax-payer dollars are utilized.
The fee consists of one and one-half cents ($.015) for every barrel of oil and
condensate produced, and three-tenths of one cent ($.003) for every thousand
cubic feet of gas produced. This currently equates to roughly $4 million
dollars a year to be utilized by the Program for orphan oilfield site
restoration projects.
Recovery
of Restoration Costs
The operator of record for an orphan wellsite is in all cases
the primary party required to restore an oilfield site once it becomes
unusable. This responsibility remains whether or not a site specific
trust account has been established for this purpose. Should a site be
restored using monies from the Fund, and a site specific trust account has not
been created for the site, former operators and their working interest owners
may then also have some liability in addition to the responsible party for
repayment of the monies spent from the Fund.
The process of recovery of site restoration costs of orphaned
oilfield sites from the responsible party and others who may share in this
liability is addressed in LSA-R.S. 30:93. The Secretary of the Department
of Natural Resources is empowered by law to recover all costs incurred by the
Program resulting from orphan site restoration operations. The procedures
to be utilized in this matter are dependent on the specific cost of site
restoration activity and whether or not a site specific trust account has been
established for the site restored. For a site without a site specific
trust account, the Secretary is authorized to collect only from the responsible
party (i.e. the last operator of record and his working interest owners) unless
the cost of the site restoration exceeds $250,000.00, at which time all former
operators and working interest owners become liable for the entire restoration
cost in inverse chronological order.
Site
Specific Trust Accounts
In accordance with the provisions of the Oilfield Site
Restoration Law (LSA R.S. 30:80 et seq), when a transfer of ownership interest
of an oilfield site occurs, either party of the transfer can elect to file an
application to establish a site specific trust account (SSTA) to cover future
site restoration costs. To the extent permitted under the law, once
established and fully funded, a SSTA will release from liability the Transferor
and all prior responsible parties for site restoration costs for the
transferred oilfield site. Thereafter, the Transferee will be considered
the responsible party for the purposes of site restoration. For more
information, please see the document entitled 'Establishing a Site Specific Trust Account (SSTA)' or contact Program staff. The following forms related to
SSTAs are also available:
· FORM 9604 -
Site Specific Trust Account
·
FORM 9604-1 - Site Specific Trust Account Reassessment (MS Word, PDF).
The Oilfield Site
Restoration Commission
The
Program is domiciled within the Engineering Division of the Office of
Conservation of the Department of Natural Resources. Program oversight is
provided by an Oilfield Site Restoration Commission which consists of ten
members. The Secretary of the Department of Natural Resources serves as
chairman of the Commission, while the Commissioner of the Office of Conservation
serves as vice-chairman. The remaining eight members of the Commission
are appointed by the Governor from a list of nominees submitted by various
industry and environmental groups. The Commission meets quarterly in
Baton Rouge.
Oilfield
Site Restoration Commission
Scott A. Angelle, Chairman, Secretary of DNR
James
H. Welsh, Vice-Chairman, Commissioner of Conservation
Paul
Frey, Louisiana Land Association
Don
Briggs, Louisiana Oil & Gas Association
Wilfred
Fruge, Louisiana Oil & Gas Association
Karen Gautreaux,
Nature Conservancy
Randy
Lanctot, LWF, Sierra & Audubon Societies
James
Maranto, At Large
Michael
Lyons, Mid-Continent Oil & Gas Association
Troy
Vickers, Mid-Continent Oil & Gas Association
[1]LDNR
WEBSITE
*Source-EPA
document EPA530-K-95-003, May 1995
In December, 1978, the Environmental
Protection Agency (EPA) proposed hazardous waste management
standards that included reduced requirements for several types of large volume
wastes. Generally, EPA believed these large volume "special wastes"
are lower in toxicity than other wastes being regulated as hazardous waste
under RCRA. Subsequently, Congress exempted these wastes from the RCRA Subtitle
C hazardous waste regulations pending a study and regulatory determination by
EPA. In 1988, EPA issued a regulatory determination stating that control of
exploration and production (E&P) wastes under RCRA Subtitle D was not
warranted. Hence, E&P waste have remained exempt from Subtitle C
regulations. This exemption, however, did not preclude these wastes from
control under state regulations, under the less stringent RCRA Subtitle D solid
waste regulations, or under other federal regulations. In addition, although
they are relieved from regulation as hazardous wastes, the exemption does not
mean these wastes could not present a hazard to human health and the
environment if improperly managed. Statewide Order No 29-B provides guidelines
for environmentally sound management of these exempt wastes.
In the 1988 regulatory determination, EPA published lists of
wastes regarded as exempt and non-exempt. The lists were provided as examples
of wastes regarded as exempt or non-exempt; the lists were not to be considered
comprehensive. The E&P waste wastes listed in this brochure closely track
the exempt listing of the 1988 regulatory determination. Examples of non-exempt
wastes are as follows:
- Gas
plant cooling tower cleaning wastes;
- Painting
wastes and waste solvents;
- Refinery
wastes;
- Used
equipment lubricating oils;
- Waste
compressor oil, filters, and blowdown;
- Used hydraulic fluids.
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