A review of oil and gas drilling and producing activities and analysis of the wastes generated, demonstrated reserve pit solids are not hazardous, dangerous or toxic, (EPA, 1987). These conclusions confirm the industry's own research efforts and study results. By comparing regulations with a demonstrated lack of harmful wastes, EPA concluded E&P activities have little adverse impact on the environment. However, one state, Louisiana (Rule 29-B, 2000), mandates waste treatment protocol and demonstration of treatment effectiveness by comparing postclosure analyses to Louisiana regulatory clean closure values.

In our opinion, most oil and gas wastes require some form of management to preclude adverse impact to land resources, land use or water resources. Hydrocarbons, salts and the dispersed nature of waste solids (lack ofphysical structure) are the principal problems associated with oil field wastes. Some wastes contain elevated hydrocarbon levels, while others are high in salts. Many oil and gas producing States require reserve pit management and pit closure in an attempt to minimize the potential for an adverse impact. However, the state regulations vary substantially in their requirements and for the most part are ineffective.