Page 163 - Environmental Control in Petroleum Engineering

150 Environmental Control in Petroleum Engineering

and gas. Most wastes in the upstream petroleum industry fall into
this classification.
• Nonexempt nonhazardous wastes are not directly associated with
drilling and production activities for oil and gas and are not con-
sidered hazardous under RCRA, Subtitle C. Nonhazardous wastes are
those that are not specifically listed as hazardous or that do not fail
the hazardous criteria of reactivity, corrosivity, ignitability, or toxicity.
These criteria are discussed in Appendix A.
• Nonexempt hazardous wastes are either listed or fail the hazardous
criteria of reactivity, corrosivity, ignitability, or toxicity. An
example of these wastes are solvents used to clean production
equipment. Solvents generally fail the ignitability criterion.
• Nonexempt special wastes are covered under special statutes and
regulations. Examples of wastes in this classification are asbestos,
naturally occurring radioactive materials (NORM), polychlorinated
biphenyls (PCBs), and pesticides.

A critical step in developing waste management plans is to identify
a specific action plan for handling each and every material at all sites
covered by the waste management plan. These action plans should be
based on the "Hierarchy of Waste Management Principles" that were
promulgated in the Pollution Prevention Act of 1990 and further
defined by the U.S. Environmental Protection Agency's "Memorandum
on Pollution Prevention" (Habicht, 1992). This hierarchy of waste
management principles defines the preferred order for actions related
to managing wastes.
The first and most important action in the waste management
hierarchy is to reduce the volume of wastes generated. The next action
is to reuse the wastes or materials in the wastes. Only after those
actions have been completed should the remaining wastes be treated
and disposed. By following this hierarchy, both the volume of waste
to be disposed and the ultimate disposal cost will be minimized.
Possible actions for managing each material at a site can be identi-
fied by evaluating current practices in that area, current practices in
other areas, current practices for other types of wastes, practices used
by other companies or industries for similar wastes, and new practices
that may be described at trade shows or in the literature. Examples
of waste management actions within the Hierarchy of Waste Manage-
ment Principles are given in the following section.