Regulatory Intelligence
Can existing tanks be used for Class Ib fluids without a waste approval?
Category:
Waste and Facilities
Research Basis
Archive Period
2015-2025
Records Reviewed
71
Primary Topics
D056; Directive 058; oilfield waste; Class Ib; tanks; facility authorization; waste storage
Current Reference
AER Directive 056; AER Directive 058; AER Manual 012
Common Question
Can existing tanks be used for Class Ib fluids without a waste approval?
Archive Findings
AER confirmed that a Directive 056 Class II facility receiving Class Ib fluids needs Directive 058 oilfield waste approval before receiving that waste. The response separated on-site runoff from oilfield waste brought to the site.
The issue was not whether tanks already existed. It was whether the facility was approved for the fluid class and activity.
Engineering Insight
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Before using existing tankage, confirm the source of the fluid, waste class, receiving activity, and approvals. Do not treat containment capacity as approval to receive waste.
Current Guidance
Use Directive 056 with Directive 058 and Manual 012 when a facility will receive, store, treat, or dispose of oilfield waste.