Hazardous Materials and Waste Management Mitigation Measures
Mitigation measures to avoid or reduce impacts from hazardous materials and waste management associated with oil and gas production.
The following are examples of mitigation measures that could be applied to reduce hazardous materials and waste management impacts of a project depending upon site- and project-specific conditions. Hazardous materials and waste management impacts are related to the types and amount of equipment and machinery used for the project and the wastes they produce and material shipments and construction wastes. Many impacts can be reduced or avoided when considered during the siting and design phase.
Develop a final set of mitigation measures for any project in consultation with the appropriate federal resource management agencies and stakeholders. Conduct these consultations early in the project development process and preferably prior to final project siting and design.
Siting and Design Mitigation Measures
Siting and design considerations that mitigate impacts include:
Prepare a comprehensive list of all hazardous materials to be used, stored, transported, or disposed of during all phases of activity.
Develop a hazardous materials management plan addressing storage, use, transportation, and disposal (interim and final) for each item in the comprehensive list. The plan should identify specifics regarding local and federal emergency response.
Develop a waste management plan identifying anticipated solid and liquid waste streams and addressing determination, inspection and waste minimization procedures, storage locations, and waste-specific management and disposal requirements. Include a recycling strategy to be practiced by workers during all project phases.
Develop a spill prevention and response plan for addressing storage locations of hazardous wastes, spill prevention measures, training requirements, waste-specific spill response actions, spill response kits, and notifications to authorities.
Develop a stormwater management plan to ensure compliance with regulations and prevent off-site migration of contaminated stormwater or increased soil erosion.
General mitigation practices and principles that could apply to any or all phases of an oil and gas project include:
Implement plans for hazardous materials management, waste management, spill prevention and response, stormwater management, and pesticide management. Train employees to promptly contain, report, and/or clean up any oil or hazardous material spill.
Provide secondary containment for all on-site hazardous materials and waste storage, including fuel. (Fuels storage should be a temporary activity and fuel storage facilities should be removed immediately upon completion of the construction and decommissioning phases.)
Containerize and periodically remove wastes for disposal at appropriate off-site permitted disposal facilities. The goal would be to minimize the amount of hazardous materials and waste onsite.
Document accidental releases as to cause, corrective actions taken, and resulting environmental or health and safety impacts.
Project Phase-Specific Mitigation Measures
Mitigation measures specific to a particular phase of an oil and gas project include:
Minimize the generation of both solid and liquid wastes (including produced water) from well drilling and well development operations that are potential environmental contaminants. Options to minimize waste include use of several different directional drilling techniques (which minimize the number of wells required and consequently, the amount of drill cuttings), drilling the smallest possible size well bore, use techniques that reduce the amount of drilling fluids requiring ultimate disposal, and consider the use of drilling fluids that generate fewer waste cuttings.
Consider the use of drilling and fraccing fluids with the lowest potential for producing wastes and with potential to harm the environment and/or contaminate water resources. Employ drilling and recovery systems that recycle drilling fluids, and minimize the amount of final disposal of contaminated fluids and materials.
Isolate surface reserve pits where drill mud and drill cuttings and produced water are stored, or where they are ultimately disposed of, from both surface and ground water resources (through use of appropriate top and bottom liners, and top soil and vegetative cover).
Production Controls and Guidelines
Separate water produced along with oil or gas for storage, treatment, and/or ultimate disposal, and ensure that it is not released to contaminate either surface water resources or potable underground aquifers.
Employ a long-term monitoring program to ensure that mitigation measures (e.g., closure of reserve pits) employed throughout the project are effective.