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

34 API RECOMMENDED PRACTICE 51R
8.6 Waste and Residual Management
8.6.1 General
Waste and residual management practices for production operations should be conducted consistent with lease and
landowner obligations. This should include solid wastes and residuals, such as tank bottoms, drilling fluids and
cuttings, liquid wastes and residuals, such as produced water and used oil, and gaseous wastes, such as
hydrocarbons and carbon dioxide. A sound waste management plan is important to protect human health and the
environment and minimize long-term liabilities to the operator.
A waste or residual management plan should utilize one or all of the options listed below, in order of preference, to
protect human health and the environment.
a) Source Reduction—Minimize or eliminate the volume and/or toxicity of the waste generated.
b) Recycling—Reclaim or reuse the maximum amount of waste possible.
c) Treatment—Utilize techniques to minimize the amount and the toxicity of waste after it is generated, thereby
minimizing the amount that has to be disposed.
d) Disposal—Employ environmentally sound and approved methods to properly dispose of generated wastes.
8.6.2 Source Reduction
Source reduction involves decreasing the volume or toxicity of wastes or other residuals that are generated. Product
substitution is an example of source reduction. Production and workover chemicals should be evaluated to
determine if less toxic substitutes are available that meet the performance and economic criteria of the operator.
Reviewing common-sense housekeeping practices can be effective in reducing waste or other residual generation.
Installing drip pans, as an example, on valves and fittings allows the collection of leaked oil before it contacts the soil
and becomes a waste.
8.6.3 Recycling and Reclaiming
After all reduction options are considered, recycling or reclaiming the residual material should be evaluated.
Examples of recycling and reclaiming are recovering waste oil, hydraulic oil, and oily sump water by reintroduction
into the oil stream or transportation to a refinery. Drums, batteries, and scrap metal can be sold or returned to the
vendor, where possible. Tank bottoms and sludges can be sold to reclaimers, where feasible.
8.6.4 Treatment
Following reduction and recycling efforts, treatment of waste should be considered to minimize the waste volume
and the toxicity of the waste.