The Federal Agency on the Supervision of the Use of Natural Resources has published a clarification on handling steel used oil and gas pipes.
The Agency explained that the Federal Classification Waste Catalogue (FKKO) includes a group of wastes called “used steel oil and gas pipes”. Therefore, such used pipes are considered as “wastes” and their handling is regulated by the Federal Law on Industrial and Consumer Wastes No. 89-FZ.
If, during disassembly of these wastes an organisation prepares them for further recycling/utilisation, including their sorting, cleaning and preparation, these activities are considered “waste treatment” and therefore, this organisation will require a waste management licence.
If a technology that is used for disassembly of oil and gas pipes is a new technology that is capable of impacting the environment and no state environmental expert assessment has been issued fort his technology, the project involving disassembly of oil and gas pipes must be submitted (by the project owner) to the RosPrirodNadzor (the Russian environmental authority) for the state environmental expert assessment. The project owner will be allowed to commence the implementation of the project if a positive result on the environmental expert assessment has been obtained.