Worked In North Dakota, Now Looking Else Where?!?!

Do not need HAZ to haul production water.

 

there is a difference between production water, and flow back water... production water is a hazmat load.

The major constituents of interest in produced water are:

• Salt content: Salt content can be expressed as salinity, total dissolved solids, or electrical conductivity. The salt content in produced water varies widely, from nearly freshwater to salt levels up to ten times higher than seawater.
• Oil and grease: Oil and grease is not an individual chemical. Rather, the term "oil and grease" refers to a common test method that measures many types of organic chemicals that collectively lend an "oily" property to the water.
• Various inorganic and organic chemicals: These chemicals are found naturally in the formation, are transferred to the water through long-term contact with the hydrocarbon, or are chemical additives used during drilling and operation of the well. The presence of specific chemicals and the concentrations of those chemicals vary widely among different produced water samples.
• Naturally occurring radioactive material (NORM): Some of the formations holding oil and gas have small concentrations of natural radioactivity. Low levels of the radioactivity can be transferred into produced water. Generally, the radiation levels in produced water are very low and pose no risk. However, scale from pipes and sludge from tanks holding produced water can concentrate NORM.

• Produced water is mainly salty water trapped in the reservoir rock and brought up along with oil or gas during production. It can contain very minor amounts of chemicals added downhole during production. These waters exist under high pressures and temperatures, and usually contain oil and metals. Because of this, they must be treated.

 

all legal production water hauler requires hazmat for their drivers....

I haul a hazardous material that is diluted with water. Do I have to comply with HAZMAT regulations?
Generally the answer is yes.



Skilles Required
•Must have a Class “A” /or “B” Commercial Drivers License with tanker and hazmat endorsements
depending on the type of vehicle being

 

Where I run you don't have to have a Hazmat to haul PW. What regulations state you need a Hazmat to haul PW?

 

You are referring to a question on the NDDOT site that says "hauling hazmat with some water". Production water is primarily water with salt. Your definition above says it ..... Produced water is mainly salty water. I don't know of any companies in ND, MT, CO, WY that placard production water. I don't know any that placard flowback either for that matter.

[h=1]I haul a hazardous material that is diluted with water. Do I have to comply with HAZMAT regulations?[/h]

Generally the answer is yes, but your load must meet the definition of a hazardous material in 49 CFR Part 390.5. If you still have HAZMAT in the mixture which meets the rules in the HAZMAT regulations then you will still have to comply. If the state of the material is altered, the material may no longer pose a hazard and may not require compliance, but that decision must be made in accordance with federal regulations and cannot be decided solely because you diluted it.

 

FALSE.....

 

enjoy that huge ticket when you get fined for hauling hazmat with out the proper placards and endorsement.

Production water can be hazmat, due to the other chemicals mixed in.

 

I know of many water haulers in wyoming colorado that do placard their water haulers... A&Water service, Jims water service, Any company affiliated with Quality services.... They all require the Hazmat endorsement for their drivers also.

 

What placard are they using?

 

flammable.

It was determined due to this investigation from texas in 2003.

CSB Investigation

Because of the deaths and injuries caused by this incident, OSHA and the U.S. Chemical Safety and Hazard Investigation Board (CSB) conducted investigations. CSB's investigation sought to determine the root and contributing causes, and to issue recommendations to interested parties in an effort to prevent similar occurrences. (1)


In its investigation report, the CSB pointed out that "the oil and gas industry disposes of many thousands of barrels of E&P waste liquids annually, including potentially flammable BS&W." (1) "E&P wastes can have flammability characteristics that meet the definition of a flammable liquid in both OSHA and DOT regulations, thus posing a significant physical hazard to personnel." (1) The CSB found inconsistency within the oil and gas industry in managing the potential flammability hazard of BS&W. In some cases, the flammability hazard is not identified or recognized, and work practices are inadequate for safe handling of the potentially flammable liquid.



Contributing causes of the incident reported by the CSB are summarized below:

• The transport company did not understand the potential flammability hazard of BS&W in the product storage tanks, nor did they understand that inadvertent mixing of hydrocarbon product with waste liquid when filling the vacuum trucks' tanks most likely increased the flammability hazard of the trucks' contents (1),

Discussion of Standards

Based on the listed root causes of this incident, the following aspects of the incident and their associated OSHA standards are identified below.
Hazard Determination and MSDSs

• Drillers and producers must evaluate chemicals they produce to determine if they are hazardous, i.e., determine the potential flammability hazard associated with BS&W and other E&P waste liquids- 1910.1200(d).
• Drillers and producers must obtain or develop appropriate MSDSs for the hazardous materials they produce, i.e., BS&W - 1910.1200(g)(1).
• Drillers and producers must ensure that appropriate MSDSs are provided to downstream employers, e.g., the transport company, with their first shipments - 1910.1200(g)(6)(i).
• The transport company did not conduct a hazard determination or obtain an MSDS from the producer. The transport company is responsible for a hazard determination of the hazardous chemicals they deliver to downstream customers/ employers - 1910.1200(d)(1).

Vacuum Truck Operations
Vacuum truck owners must ensure that vacuum truck operators are trained and qualified for their work assignment. The following Standards address the issues necessary to provide appropriate training.

• 29 CFR 1910.1200, Hazard Communication,
• 29 CFR 1910.106, Flammable and Combustible Liquids,
• 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response,
• 29 CFR 1910.307, Hazardous (classified) Locations,
• 29 CFR 1910.1000, Air Contaminants, and
• 49 CFR, Parts 171, 172, 173, 178, 179, 382, 383 and 390-397, U.S. DOT "Motor Carrier Safety requirements for proper hazard classification and manifesting of flammable liquids, approved container design, and periodic testing.