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Planning for Environmental Protection 149

1993; Tan and Hartog, 1991; Jennett, 1991; Whitehead, 1991; and
Crump and O'Gorman, 1991).

5.2 WASTE MANAGEMENT PLANS

Waste management plans identify exactly how each waste stream
should be managed. They ensure that appropriate engineering controls,
proper waste management options, adequate recordkeeping and report-
ing systems, and ongoing employee training are in place. The informa-
tion obtained from environmental audits can be used in developing a
waste management plan.
One of the first steps in developing a waste management plan is to
identify the region and scope to be covered. All materials generated
within the region must be identified, quantified, and characterized.
These data must include chemical toxicological, health, fire, explosive,
and reactivity information. They should also include first aid proce-
dures to be used in the event of human exposure to the material.
Material Safety Data Sheets (MSDS) provide much of this information
and can be obtained from chemical suppliers.
The potential for a material to migrate from a site must also be
considered when determining the best way to manage it. Factors like
topography, hydrology, geology, soil conditions, and the presence of
sources of usable water must be evaluated. Historical rainfall and
distribution data are also needed to determine soil loading conditions,
to predict net evaporation rates, to determine how quickly reserves pits
will dry, and to evaluate overtopping potential of open tanks and pits
during storms. Other factors that must be considered are the special
needs of environmentally sensitive areas such as wetlands, rain forests,
arctic tundra, arctic icepack, areas where subsidence during production
may occur, urban areas, historical sites, archaeological sites, protected
habitats, and sites providing habitats for endangered species.
A critical factor that must also be considered in developing waste
management plans is the regulatory status of each material at a site. One
way to classify wastes in the United States is according to the Resource
Conservation and Recovery Act (RCRA) categories of exempt and nonexempt
wastes (Stilwell, 1991). Nonexempt wastes can be further classified as
hazardous, nonhazardous, or special wastes, as discussed below:
« Exempt wastes are directly associated with drilling of an oil or
gas well or generated from the exploration and production of oil