You know how we’re told that all that drilling waste is supposed to be safe enough to spread on our farmland, and leave lying around in pits for cattle to drink and to run off into our streams? Well, it seems the Texas Railroad Commission admits that it’s not really all that safe after all.
In January of 2003, a flash fire killed three and seriously burned four workers at a commercial oil and gas waste disposal facility. The U. S. Chemical Safety and Hazard Investigation Board (CSB) (website at www.chemsafety.gov) investigated the accident and concluded that neither the waste generator nor the waste hauler
recognized the potential flammability hazard of oil and gas waste.
The accident involved two vehicles operated by employees of an authorized oil and gas waste hauler who were transporting basic sediment and water (BS&W) in 50-barrel vacuum trucks from gas leases to an authorized commercial disposal facility. Apparently the BS&W contained a significant amount of gas well condensate. The drivers discharged wastes by opening the drain valves at the rear of the vacuum trucks allowing the BS&W to drain into a concrete pit. This method of drainage released sufficient hydrocarbon vapors to form a combustible mixture in air. The drivers left the engines of the vacuum trucks running and the CSB concluded that intake of flammable vapors caused the diesel engine to initially race and then backfire, igniting the vapor cloud to cause the flash fire.
The Railroad Commission is providing this notice to waste haulers and operators of disposal and producing wells to remind them of the importance of educating their employees about the potential hazards of oil and gas wastes. The U. S. Department of Transportation hazardous materials regulations apply to (a) each person who offers hazardous materials for transportation (oil and gas operator) and (b) each carrier who transports a hazardous material (oil and gas waste transporter). The Railroad Commission advises all authorized waste haulers and operators who generate
oil and gas waste of their responsibility to determine the hazards of any oil and gas waste that they offer for transport or that they accept for transport and to comply with applicable regulations regarding worker safety and safe transportation of materials. Where appropriate, operators may need to provide multilingual notice to employers and contractors.
- The haulers didn’t know that they were hauling dangerous drilling waste. (It seems pretty basic that the haulers should know how dangerous their load is. Reckless endangerment of waste haulers!)
- The material they were hauling was determined to have “significant” gas well condensate. (Why wasn’t the condensate stripped off before disposal at one of those very safe salt water disposal wells? Who tested this waste and determined it should go to a disposal well? Are they the same ones who test the sludge pit waste and the landfarm waste and…)
- Who is responsible for determining how dangerous the waste is? ANSWER: haulers and operators who generate oil and gas waste.
- The people responsible for determining how to handle this
safe enough for farmlanddangerous waste might not be able to read the directions.