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...