Mr. Erik Milito - The House Committee on Natural Resources ...

12 API RECOMMENDED PRACTICE 51R
5.6.3 Restoration plans should be prepared in detail and should consider methods such as:
a) priority of stabilization and revegetation of disturbed areas,
b) use of native plant species,
c) stockpiling soils where reclamation would be enhanced,
d) use of agency approved designs and seed mixes.
6 Producing, Injection/Disposal Wells
6.1 Completion, Stimulation, and Workover Operations
6.1.1 Planning
For a new well site, an effective planning process should be carried out and should incorporate the latest guidelines
for waste management, pit location and construction, handling of water discharges, and waste disposal. <strong>The</strong> location
and size of new pits and pads for completion and workover equipment should be selected so as to minimize
disruption of the surface resources and retain the potential for reclamation of the site. Refer to API Environmental
Guidance Document: Onshore Solid Waste Management in Exploration and Production Operations for
environmental aspects of reserve pit construction, operation and closure.
For an existing well site, the planning process is just as important to provide for safe and environmentally acceptable
completion and workover operations. Existing facilities, such as pits and production equipment, should be reviewed
and assessed to determine whether the facility is suitable in its present condition for the intended well operations or
if modifications are required. For both new and existing well sites, a waste management plan for handling and
storing all waste materials generated during completion and workover activities should be developed. Refer to API
Environmental Guidance Document: Onshore Solid Waste Management in Exploration and Production Operations,
for information on how to develop such a plan. <strong>The</strong> waste management plan should address the specific wastes
which are expected to be produced by the particular operations being performed, as well as provide guidelines
concerning the actions to be taken in the event that unexpected waste materials, including hazardous materials, are
encountered during the operations. In addition to safe handling and storage of waste materials on the well site,
provisions should also be made for each type of waste to be disposed of. Refer to API 55 and API 49 for planning
and conducting operations involving hydrogen sulfide. Refer to API E2 for information regarding management of
naturally occurring radioactive materials (NORM).
Since much of the work on producing and injection wells is performed by contract or service company personnel, the
operating company should confirm that the contractor’s personnel have appropriate safety training, including hazard
communication training, and are aware of requirements of the site-specific waste management plan. Consideration
should also be given to requiring performance bonds, if appropriate. <strong>The</strong> operator should also confirm that the
contractor’s personnel are aware of all applicable safety and environmental requirements of the operator.