Traditionally, pollution prevention (waste minimization, source reduction, etc.) has best been represented through a hierarchy in the shape of a pyramid (below). The information contained in this topic hub essentially follows this hierarchy when alternatives are derived. However, in some instances, the hierarchy will not be followed, as treatment and disposal alternatives may be the only cost-effective options available.

Waste Management Hierarchy

 

Source Reduction

Source reduction is given the highest priority in the waste management hierarchy because avoiding waste generation altogether, or generating the least toxic waste possible, minimizes the problems associated with waste management. Waste that is not generated need not be managed. Waste that is generated, but is of the lowest possible volume and/or toxicity, can be managed most cost-effectively. Source reduction includes, but is not limited to, material substitution, process substitution, and process elimination. Examples of some source reduction opportunities are described below.

Material Substitution

Materials that will result in less toxic wastes can be substituted for materials that are currently being used. Examples include the following:

• The substitution of less toxic drilling fluid additives will result in less toxic drilling

           wastes.

• Shifting from solvent-based paints to water-based paints reduces the toxicity of paint wastes.

Process Substitution or Elimination

Processes that result in less waste and increased efficiency can be substituted for processes that are currently being used. Also, entire processes can be eliminated if pollution prevention is implemented. Examples are use of the following:

• Well designs and drilling methods that reduce the volume of cuttings generated,
• Improved transportation methods that reduce the risk of spills and leaks,
• Improved separation techniques at the well that eliminate the need for several gas processing steps.

Good Housekeeping and Equipment Maintenance

Good housekeeping and equipment maintenance are two best management practices that are often low-cost/high-benefit approaches to pollution prevention. A common example of good housekeeping practices involves the use of drip pans to catch leaks or drips from equipment. Equipment maintenance is important for two distinctly different reasons: 1) routine maintenance will reduce the occurrence of leaks and drips, and 2) routine maintenance will extend the lifetime of the equipment. When thinking about pollution prevention, it is important to consider that when equipment comes to the end of its life it also becomes a waste!

Water Conservation

Water conservation is another best management practice which, if successful, will greatly reduce the waste volume from oil and gas operations. Examples include

the following:

• Low solids, non-dispersed drilling fluid systems may replace dispersed systems that typically require large volumes of water,
• Careful use of water during equipment cleanup and efficient operations of cooling towers may result in reduced water volumes,
• Increased use of ?smart? pigs or ultrasonic devices to test wall thickness or detect weak spots can enable better targeting of pipeline sections requiring pressure testing or replacement. More efficient pigging and pre-cleaning of pipelines prior to hydrostatic pressure testing will result in greatly reduced volume and toxicity of waste hydrostatic test water.

Pollution Prevention in Design and Planning

Designing or planning for a new process or operation is the best time to address pollution prevention considerations. With an existing process, implementing pollution prevention can require some possible down time due to either equipment reengineering or technician training. This will greatly add to the cost and, therefore, reduce the economic benefit of the particular pollution prevention approach. In the design and planning phase, there is no status quo and, therefore, no down time and associated costs.

Training and Awareness

Training and awareness programs are critical to ensuring that pollution prevention is realized to its fullest potential. The best ideas will come from persons who work with machines, use materials, and generate waste. These persons must be aware that often there are alternatives and that they constantly need to be thinking about ways to

improve operations, efficiency, etc. It is always more effective to provide pollution prevention training to persons with process know-ledge (often, the implementers and stakeholders) than to provide ?pollution prevention experts? with process knowledge to develop a pollution prevention plan.

Life-Cycle Analysis

Pollution prevention often utilizes a principle known as ?life-cycle analysis? to address all associated costs and possible solutions associated with a particular process or waste. Life-cycle analysis, sometimes referred to as ?cradle-to-grave? analysis, is often used to

track a particular material from its inception to its ultimate demise. This tracking usually requires documentation from other companies (both vendors and customers) in the material chain. In material substitution, for example, a possible material alternative that would drastically reduce a particular waste stream may require a process change by

the vendor first. Also, a positive pollution prevention approach implemented by a particular company could have negative impacts to its customers or contractors. For these reasons, it is helpful to include vendors, customers, and contractors as part of the pollution prevention team!

Inventory Control

Inventory control addresses the effective use of data and information to track the procurement, use, and management of materials throughout the operation. Inventory control practices include the following:

         ?Just-in-Time? procurement. Only purchase what is needed in the amounts needed. This is extremely important for chemicals or materials that have relatively short shelf-lives and have to be disposed if not used in a timely manner.

         Affirmative Procurement. Only purchase materials that have been or can be recycled. Purchase non-hazardous chemicals and materials whenever possible.

         Barcoding. Use barcodes to track material usage throughout the facility. This is extremely helpful in limiting the amount of material purchased if it is known how much of that material may be already stored at the facility. Through a chemical or material exchange program, chemicals and materials can be obtained from operations within the facility instead of having to purchase the materials.

Recycling

Unfortunately, in some cases reduction at the source will not yet be technically possible or economically feasible. Therefore, recycling opportunities should be investigated for all wastes that are unavoidably generated. Recycling involves reclaiming useful constituents of a waste material, or removing contaminants from a waste so that it can be reused. Recycling may also involve the use or reuse of a waste as a substitute for a commercial product, or as feedstock in an industrial process. Recycling helps to preserve raw materials and reduces the amount of material that requires disposal.

Treatment

Treatment should be investigated for any waste that is unavoidably generated and that cannot be recycled in its current form. Treatment is any method, technique, or process that changes the physical, chemical, or biological character of a waste. Treatment renders the waste less hazardous and, therefore, recyclable or safer to transport, store, and dispose. Note that treatment does not prevent the creation of pollutants. Treatment involves changing the nature of the waste or reducing or eliminating the pollutants in a waste.

Waste treatment is usually the third option after source reduction and recycling opportunities have been exhausted. Treatment includes techniques such as precipitation, neutralization, stabilization, and incineration. For the purposes of this hub, waste segregation is also considered as a treatment alternative. In many cases, waste treatment is performed off-site by a contracting organization. The waste generating organization must maintain very careful records regarding the contents of the waste so the proper waste management procedures can be carried out. In many cases, information regarding the process that generated the waste is maintained with the waste information. This information is helpful in demonstrating an understanding of how

(and why) the waste was generated, and it lessens the risk to the contracting organization that may be treating wastes it may otherwise not be permitted to treat.

Waste segregation is an environmental best management practice designed to reduce costs through storing incompatible wastes separately, including separating hazardous from non-hazardous wastes, or regulated from non-regulated wastes. In many circumstances, mixing regulated with non-regulated wastes renders the entire waste contents regulated and unnecessarily increases waste management costs.

Disposal

Waste disposal generally is the discharge, deposition, injection, dumping, spilling, leaking, or placing of any waste into or on land, water, or air. In the waste management hierarchy, disposal is the least preferred waste management option. Disposal also involves the greatest potential liability.

Energy Efficiency

In most instances, energy efficiency opportunities are most prevalent in heating, ventilation, and air conditioning systems (e.g., insulation) and in lighting. Many of the energy efficiency best management practices address good housekeeping principles, such as the following:

         Use small lamps to direct light onto areas where you are working.

         Use dimmer switches to keep lighting down to the level necessary.

         Use outdoor lighting only when necessary. If you do use lighting, use fluorescent globes for lights left on for extended periods.

         Keep equipment well oiled to reduce wear and maintain energy efficiency.

         Use timers or motion detectors.

         User timers on thermostats.

         User energy management systems in buildings.

        

The U.S. Environmental Protection Agency?s (EPA?s) A Guide to Implementing the Natural Gas STAR Program reports a number of energy-efficient best management practices for reducing methane emissions. The STAR Program reports that companies involved in the program have reduced methane emissions by over 26 billion ft 3 . The

best management practices described in the EPA guide are listed under two categories: 1) transmission and distribution companies, and 2) production companies.

For more information on the EPA?s Natural Gas STAR Program

EnergyStar? Website

Hotline: 1-888-STAR-YES (782-7937)