Area Waste-Management Plans for Drilling and Production Operations
Authors: Stilwell C.T. 
Published: December 2007

This paper details a process for identifying appropriate waste-managementstrategies in a specific area of operation. These strategies consider currentregulatory requirements, company policies, and economic and practical factors. Management practices covered include minimization, storage, handling, anddisposal. The strategies developed are communicated to field operations througha document specifically designed for effective use by field drilling andproduction personnel. The plan's objectives, development, content, and possiblealternative applications are presented, and examples from the development of anactual plan are given. presented, and examples from the development of anactual plan are given.

Introduction

One environmental issue receiving significant attention in recent yearswithin the oil and gas E and P industry is the handling and disposal of wastes. Heightened interest within the public and the regulatory agencies towardenvironmental issues has been an impetus for the industry to scrutinize itswastes and how they are managed. From a private company's perspective, properwaste management is an important part of business. A company must be concernedabout complying with applicable waste regulations, minimizing the impact of wastes on the environment, and reducing the disposed-of waste. All these mustbe done within certain economic boundaries. Also, eliminating or minimizingwaste generation is becoming more critical, both environmentally andeconomically, as a means of reducing waste-related liabilities and costs. Thispaper reviews the concept of the area waste-management plan as a means ofimproving the management of wastes generated by a company's drilling and production operations. The development and use of area waste-management plans allow a company to identify and communicate sound waste-management strategies effectively. The strategies are based on regulatory, environmental, technical, and economic criteria applicable to a specific geographic area of operation.

Waste-Management Concerns

A cursory review of Arco Oil and Gas Co.'s drilling and production operations identified several concerns regarding the handling and disposal ofcertain wastes generated by its operations. Production operations were viewed from a broad scope of operating facilities, including oil production (primaryand secondary), gas production, and gas processing. Drilling operationsobserved included drilling, workover, and completion. These field operationsoccurred in a variety of environmental and regulatory settings. Waste-management concerns generally focused on inconsistent minimization, handling, and disposal practices. Reviews of the operations and interviews withpersonnel revealed the specific reasons for these concerns. The primary reasonfor the concerns was an inadequate understanding of the wastes and themanagement options available. This misunderstanding was the result of severalfactors, including complex and changing regulations, unclear guidance on theenvironmental aspects of field operations, and the perception of competingenvironmental and economic goals.

Regulatory Climate. Most state oil and gas agencies began regulating wastefrom drilling and production operations before the U.S. government started topass environmental statutes in the early 1970's. Historically, regulation of oilfield wastes has focused on drilling fluids and produced water. Since theearly 1970's, a number of federal and state environmental statutes andregulations have been passed that affect the management of oil and gas waste. Each state has developed regulations to control these wastes as specified inthe federal laws and as specified in the state's own environmental statutes. Though adequate, states' requirements for oil and gas waste management varysignificantly, reflecting the diverse geological and environmental conditionsin each state. Because of the historical emphasis on drilling fluid andproduced water, the regulations often are not specific on a waste-by-wastebasis. For operations on federal lands, companies must comply with separate.sometimes overlapping, regulations administered by different federal agencies(e.g., U.S. Bureau of Land Management and the U.S. Forest Service) in additionto the state's requirements. Also, the regulations have been amended frequentlyover the last 10 years. This complex regulatory climate, which changes withtime and geopolitical boundaries, contributes significantly to the lack ofunderstanding of requirements affecting waste management in the oil field.

JPT

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