Operations

Pre -Screening

M. B. Environmental Services, LLC (MBES) diligently screens wastes prior to offloading. We screen the generator, the Tanks geographic or waste stream origin, and the waste type. We cannot accept any material that is not adequately identified as non-hazardous oil and gas waste. First time clients, or those with un-documented waste streams, should contact our disposal facility for pre-screening.

Waste Offloading

We provide full offloading capabilities for most any waste vehicle or container. Commonly managed vehicles and containers include:

Vacuum trucks;
End dumps / dump trucks;
Barrels and Drums;
Cuttings and Roll off Boxes;
Supersacks; and
Barge access/ofloading. Contact us for details.

M. B. Environmental Accepted Wastes

M. B. Environmental Services can accept for disposal only (a) oil and gas wastes that (b) are considered non-hazardous.

Oil and Gas Wastes

In Texas, oil and gas wastes are broady defined to include:

Drilling, operation, and plugging of wells associated with the exploration, development, or production of oil and gas, including oil and gas wells, fluid injection wells used in enhanced recovery projects, and disposal wells;
Separation and treatment of produced fluids in the field or at natural gas processing plants;
Storage of crude oil before it enters a refinery;
Underground storage of hydrocarbons and natural gas;
Transportation of crude oil or natural gas by pipeline;
Solution mining of brine; and
Storage, hauling, disposal, or reclamation of wastes generated by these activities.

Categorizing Oil and Gas Waste as Non-Hazardous

An Oil and gas waste may be categorized as non-hazardous if it:

Meets the EPA hazardous waste exemption criterion; OR
Is characterized as non-hazardous based on sampling, analytics and/or process knowledge to determine that ignitibility, reactivity, corrosivity, and toxicity criterion are not exceeded; AND
The waste is not specifically listed as hazardous by the EPA.

EPA Exemption

Oil and gas wastes are considered non-hazardous, or exempt from hazardous status, if they are:

Uniquely associated with E & P operations; AND
Derived from primary field operations.

Both conditions are technical in nature and warrant further reading. See the below references or our Categorizing NOW summary for further details and guidance. Please read our Disclaimer.

Texas and the EPA have issued guidelines on exempt and non-exempt wastes. See the below lists and/or the references for further details.

Operators seeking to dispose of oil and gas waste that are not exempt, based on the above two criterion, must submit a Non-Hazardous Certification prior to waste offloading.

Charaterizing / Profiling Oil & Gas Waste as Non-Hazardous

An oil and gas waste can be characterized as non-hazardous if it is not specifically listed by the EPA as hazardous and the waste is profiled based on process knowledge or sampling and analysis. Operators seeking to dispose of oil and gas waste with M B Environmental Services whose waste is characterized as non-hazardous via process knowledge or testing, must submit a Non-Hazardous Certification prior to waste offloading.

References

Railroad Commission of Texas - Rule §3.8, Water Protection
Railroad Commission of Texas - Rule §3.9, Disposal Wells
Railroad Commission of Texas - Rule §3.9, Standards for Management of Hazardous Oil and Gas Waste
Railroad Commission of Texas, Waste Minimization in the Oilfield, July 2001
Railroad Commission of Texas, The Interim Guidance for Hazardous Waste Manual
EPA - Regulatory Determination for Oil and Gas andbGeothermal Exploration, Development and Production Wastes , July 1988
EPA - Clarification of the Regulatory Determination for Oil and Gas and Geothermal Exploration, Development and Production Wastes, March 1993
EPA - Exemption of Oil and Gas Exploration and Production Wastes from Federal Hazardous Waste Regulations, 2000

EPA & Texas 'Guidelines' for Exempt Wastes

The below list of oil and gas wastes are generally considered to be non-hazardous. The list is only a guideline, however. The exemption status of a specific waste should be evaluated by competent personnel, suchas the Railroad Commission, against regulatory criterion.

Activated charcoal filter media;
Basic sediment and water (BS&W);
Caustics, if used as drilling fluid additives or for gas treatment Condensate;
Cooling tower blowdown;
Debris, crude oil soaked or stained;
Piping and equipment deposits (i.e., pipe scale, hydrocarbon solids, hydrates, and other deposits);
Drilling cuttings/solids and fluids;
Gas dehydration wastes;
Gas plant sweetening wastes for sulfur removal:
Gases removed from the production stream (i.e.,H2S, CO2, and VOCs)
Liquid hydrocarbons removed from the production stream but not from oil refining
Liquid and solid wastes generated by crude oil and tank bottom reclaimers;
Pigging wastes from producer operated gathering lines;
Pit sludges and contaminated bottoms from storage or disposal of exempt wastes;
Produced sand and water;
Produced water constituents removed before disposal (injection or other disposal);
Rigwash;
Slop oil (waste crude oil from primary field operations and production);
Soils, crude oil-contaminated;
Sulfacheck/Chemsweet waste;
Tank bottoms and basic sediment and water (BS&W) from: storage facilities that hold product and exempt waste;
VOCs from exempt wastes in reserve pits or impoundments or production equipment;
Well completion, treatment, and stimulation, and packing fluids; and
Workover wastes.

EPA & Texas 'Guidelines' for Non-Exempt Wastes

The below list of wastes can not be considered 'exempt' and therefore are not non-hazardous oil and gas wastes. M. B. Environmental Services, LLC does not dispose of these wates.

Batteries: lead acid or nickel-cadmium;
Boiler cleaning wastes or refractory bricks;
Caustic or acid cleaners;
Chemicals, surplus or unusable;
Compressor oil, filters, and blowdown waste;
Debris, lube oil contaminated;
Drilling fluids, unused;
Drums/containers, containing chemicals or lube oil;
Gas plant cooling tower cleaning wastes;
Hydraulic fluids, used;
Incinerator ash;
Laboratory wastes;
Mercury;
Methanol, unused;
Oil, equipment lubricating (used);
Paint and paint wastes;
Pesticide and herbicide wastes;
Pipe dope, unused;
Radioactive tracer wastes;
Refinery wastes (e.g., unused frac fluids or acids);
Sandblast media;
Scrap metal;
Soil, chemical, lube-oil, or mercury contaminated;
Solvents, spent;
Thread protectors, pipe dope contaminated;
Vacuum truck rinsate (from tanks containing nonexempt waste);
Waste in transportation pipeline related pits; and
Well completion, treatment and stimulation fluids.

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