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BP Pakistan Exploration & Production, Inc.

WASTE MANAGEMENT PROCEDURE

Rev. No. 0

BP Pakistan Exploration & Production, Inc.


WASTE MANAGEMENT PROCEDURE

Document No.: PRO/ENV/003 Sponsored by:

Rev. No.: 0 Endorsed by:

Issue Date: May 10, 2002 Approved by:

Amjad Shaikh Sr. Environmental Engineer

S. H. Nensey HSE Manager

David Knox Business Unit Leader

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PRO/ENV/003

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DOCUMENT CONTROL
Revision Record Revision Revision Date No. 0 May 10, 2001 Section / Page Description & Reason for amendment First Edition

DISTRIBUTION LIST
1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. Badin Performance Unit Leader Mehran Performance Unit Leader HSE Manager North Delivery Unit Leader South Delivery Unit Leader Central Delivery Unit Leader Mehran Delivery Unit Leader Qadirpur Delivery Unit Leader Field Support Team Leader Export Operations Manager Subsurface Operations Team Leader North Production Team Leader South Production Team Leader Central Production Team Leader Construction Team Leader Maintenance Team Leader Planning and Assurance Team Leader Camp Administrator CBWH Materials Administrator Surface Engineering Team Leader Well Works Team Leader Environmental Coordinator- North Delivery Unit Environmental Coordinator- Central Delivery Unit Environmental Coordinator- South Delivery Unit Environmental Coordinator- Subsurface Team Environmental Coordinator- Well Works Team Environmental Coordinator- Exploration Environmental Coordinator- Support Services Senior Environmental Engineer (Original)

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TABLE OF CONTENTS
Page No. 4 5 5 5 6 6 6 6 7 7 8 8 9 12

List of Acronyms 1.0 2.0 3.0 4.0 4.1 4.2 4.3 4.4 4.5 4.6 4.7 5.0 6.0 Purpose of Waste Management Scope Definitions Procedure Waste Minimization Waste Categorization Segregation / Labeling Storage and Handling Recycling Treatment Disposal Waste Management Options Recording and Reporting

Table 1: Table 2: Annexure I:

Summary of Waste Management Options Waste Tracking Form Waste Data Sheets - Detailed Guidelines for Waste Management

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List of Acronyms
ACM CO2 E&P EPA H2S HAP kg L R mg mm MSDS NORM PPE ppm TDS TEG TPH Asbestos-Containing Materials Carbon Dioxide Exploration and Production Environmental Protection Agency Hydrogen Sulfide Hazardous Air Pollutant Kilograms Liter Microroentgens per hour milligrams millimeters Material Safety Data Sheet Naturally Occurring Radioactive Material Personal Protective Equipment parts per million Total Dissolved Solids Triethylene Glycol Total Petroleum Hydrocarbons

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1.0

Purpose of Waste Management

The purpose of this procedure to provide guidelines and simplify the process of categorizing, quantifying, managing, and disposing of wastes. Waste management is a critical component of BPPs operating policies. Waste management includes the proper handling, accumulation, storage, manifesting, transportation, and disposal/recycling of the waste generated. The procedure is designed to assist in a company wide effort to provide protection for the environment and to comply with BPs corporate requirement, environmental laws and regulations regarding proper waste management.

2.0

Scope

Waste streams generated as part of drilling and production operations and from field camps shall be managed as per this procedure. Guidelines for proper handling, categorization, recording, minimization, recycling and disposal of all types of waste associated with BPP operations and projects are part of this procedure. This procedure shall be followed at all BPP sites by all BPP personnel and contractors working for BPP.

3.0

Definitions

(i) Waste: Any material for which no further use is intended, is considered a waste. It can be solid, semi solid or liquid. Additionally, abandoned materials and materials intended to be recycled are considered wastes. It is very important to understand this concept, because even though something is going to be recycled, it must be managed as a waste until it is actually recycled. (ii) Hazardous Waste: Waste is categorized as a hazardous waste if it has one or more of the following properties: Ignitability (flash point less than 60 0 C); Corrosivity (pH less than or equal to 2.0, or greater than or equal to 12.5); Reactivity (inherently unstable under ordinary conditions or when exposed to water); Toxicity (may present an unreasonable risk of injury to health or the environment.)

(iii) Non-hazardous Waste: The wastes are categorized as Non-hazardous wastes, if they do not possess any of the hazardous characteristics as defined above. However, non-hazardous waste may still present hazards to employees who handle them. All recommended safety and handling practices must be followed.

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4.0

Procedure

Priorities to manage the waste are listed below:


!"Eliminate

waste production. Use the material for its intended purpose on site, if

possible.
!"Minimize waste production. !"Reuse. !"Recycle waste on site. !"Dispose of waste in a proper waste disposal

facility.

4.1 Waste Minimization To minimize waste, the following steps shall be taken by all personnel working on BPP sites: Only the needed amount of materials shall be ordered. Before purchasing hazardous material, all alternatives for non-hazardous material should be explored. Prior consideration shall be given to the sizes of containers available when ordering products that could potentially generate waste. The intent is to avoid unused products and/or their containers from becoming wastes that require special handling.

4.2 Waste Categorization All wastes generated at BPP facilities shall be categorized in two major categories (i.e. Hazardous wastes and Non-hazardous wastes) as per the definitions in Section 3.0. Each category has different types of requirement for handling, storage and disposal. Table 1 shows the categories of most of the waste generated at our sites/ facilities/ camps. 4.3 Segregation / Labeling Waste management becomes very complicated if different types of waste are mixed together. A small amount of hazardous waste, mixed with a non-hazardous waste or recyclable material, can make the whole mixture a hazardous waste. Disposal costs and liabilities for hazardous waste are very high, so it is extremely important to identify wastes and keep them segregated. The scheme of segregation is as follow: (i) All hazardous waste shall be segregated from other types of hazardous wastes as well as non-hazardous wastes. At all facilities, following types of containers, with colour coding for easy identification, shall be kept to collect and segregate common wastes:
PRO/ENV/003 Page 6 of 46

(ii)

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(iii) (iv)

Glass (blue); Metals (green); Plastic (white); Oily rags (black); Used oil (red); General trash (yellow).

Food waste shall be collected in separate containers. All containers must be properly and clearly labeled. The label must clearly mention the name or type of waste. Also, if the waste is hazardous, it should be clearly labeled on the container along with its hazardous characteristics (e.g. flammable, toxic, radioactive, etc.). This is important to workers and to emergency response teams, who need to know what they are dealing with. Missing or unreadable labels must be replaced.

4.4 Storage and Handling (i) Waste, that will be sent for recycling or off-site disposal, shall be temporarily stored at waste storage facilities available at different sites such as Junkyard, Scrap yard, pits, etc. The oily sludge, contaminated soil and other hazardous liquid waste (e.g. rinsate, chemicals, etc.) shall be stored in lined pits with HDPE liner. Liner shall be of sufficient thickness (at least 20 mil) and strength to be resistant to tears and punctures. All other wastes awaiting disposal shall be kept in closed containers separately. Care must be taken to prevent wastes giving rise to secondary environmental problems, such as odors or soil and groundwater pollution through rainwater leaching. All stored wastes must be clearly labeled with type of waste and warning signs. (For guidance on each type of waste refer Annexure I). All workers handling wastes shall use proper PPE.

(ii)

(iii)

(iv) (v)

4.5 Recycling Recycling and reuse minimizes the quantity of waste requiring disposal. Some of the wastes can be reused within our facilities while others can only be recycled at off-site recycling centers. For example, recycling of used oil is possible in some of the Lube Oil Recycling companies; batteries may be sent back to manufacturer or distributor for recycling. Waste shall not be sold to the unauthorized contractors/companies, who may not have proper recycling facilities, to avoid misuse and to reduce associated liabilities. The possibilities of recycling of each waste are discussed in Annexure I.

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4.6 Treatment Some of the wastes, such as wastewater from camps, oily wastewater from process, etc., require proper treatment before disposal. The treated water should comply with National Environmental Quality Standards (NEQS). 4.7 Disposal Disposal becomes the only available alternatives, if reuse and recycling options are exhausted. A material should be classified as a waste for disposal only if no other useful purpose can be identified and if the material cannot be beneficially reused or recycled. The choice of a suitable disposal option for any waste depends on both environmental and economic considerations. The final disposal can be either at on-site disposal facilities or at off-site disposal facilities. (i) On-site Disposal Facilities !" Burial Pits Only segregated food waste shall be buried in burial pits. Buried waste should be covered with a thin layer of soil to reduce the environmental problems, such as odour from decaying of waste, spreading of waste into other areas due to wind, etc. !" Reserve pits These pits are used to temporarily store drilling waste, chemical waste, oily sludge and contaminated soil. The pits should be properly designed and lined to avoid soil, groundwater and surface water contamination. !" Incineration Open design incinerators are available at three locations in Badin operations. As these are not properly designed incinerators, so they can only be used for burning trash. Before burning the trash, plastics, metal, glass and any other items that is not to be burned, should be segregated first. Ash of the incinerator shall be buried in the lined landfill as it may contain heavy metals. !" Evaporation Ponds The evaporation ponds are used to dispose of produced water at some facilities by evaporation. All evaporation ponds should be lined. !" Injection and Disposal Wells These wells are primarily used for re-injection or disposal of produced water. However, some of the wells could be chosen to dispose drill cutting, oily sludge and other hazardous liquids. Tubing and casing integrity of such disposal wells should be verified as per international standards. !" Lined Landfills At the moment there is no properly designed landfill available in Badin for the disposal of such wastes which cannot be reused or recycled or sold to third part contractors because of its
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hazardous characteristics, BPP intends to construct a controlled landfill where all such waste could be disposed of. For the time being, two options are available with BPP, i.e. either temporarily store all those wastes or dispose of through contractors at off-site disposal facilities. (ii) Off-site Disposal Facilities: In Pakistan, properly designed and well-operated commercial waste disposal facilities are very limited. All such facilities are being explored and evaluated for possible future use.

5.0

Waste Management Options

Waste management options for each type of waste are listed in the following Table (Table 1) along with the category of waste. Detailed data sheets for each type of wastes are attached as Annexure I.

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Table 1 Summary of Waste Management Options


S. No. Waste Type Category Disposal Options Ownership/ Responsibility
Camp Admin. FST CBWH CBWH Concerned PTLs Field Medic Construction Team Leader

1 2 3 4 5 6 7

Aerosol Cans (Empty) Asbestos Batteries (Dry) Batteries (Lead Acid) Charcoal from Amine Plant Clinical Waste Construction / Demolition Debris including Scrap Crude Oil / Condensate Waste Descaling Acids Diethanolamine (DEA) Drilling Fluids / Solids

Non-hazardous Hazardous Hazardous Hazardous Non-hazardous Hazardous Non-hazardous

Empty canisters can be recycled though contractor. Lined landfill (HSE will advise suitable location). Recycle batteries with the distributor or manufacturer or contractor. Recycle batteries with the distributor or manufacturer. 1. Incinerate at off-site incinerator. 2. Dispose in a lined landfill. Incinerate at off-site incinerator. Recycle, reuse or sell to third party contractor.

Hazardous

Return crude oil liquid and condensate to the appropriate production stream. 1. 2. 1. 2. Reuse when possible. Dispose of in disposal / injection well. Dispose of in disposal / injection well. Controlled incineration at off site incinerator.

PTLs

9 10

Hazardous Non-hazardous

11

Hazardous

12

13

Drums and Containers (Empty) Filters

Non-hazardous

Non-hazardous

14

Fluorescent Light Tubes Food Waste Glycols Laboratory Wastes NORM Containing Waste (Tubulars / Equipment / Scale / Sludge)

15 16 17 18

Hazardous (if contain mercury) Non-hazardous Non-hazardous Hazardous Hazardous

1. Dispose of drilling wastes (fluids and solids) in the lined reserve pit. 2. Reuse water-based mud whenever possible. 3. Reuse waste drilling mud for upcoming well spudding or plugging operations. 4. Encapsulate surplus additives to avoid mixing with other environmental mediums. 1. Cleans drums at drum draining pit. 2. Return to the vendor or recycle through contractor. 3. Drums that are not empty should not be disposed of. 1. After draining oil, recycle drained oil as used engine oil. (Refer disposal options for Used Engine Oil.) 2. Recycle drained liquids (chemicals) back into production stream. 3. Sell the drained filters through approved contractor. 4. Send filters free of liquid to off-site incinerator. 1. Send fluorescent tubes to manufacturer. 2. Dispose of mercury-free lamps in a landfill. Bury in burial pits. 1. Reuse if viable. 2. Return to vendor for recycling. 1. Sell or exchange excess unused chemicals. 2. Incinerate at off-site incinerator. 1. Use concrete or properly designed lined tanks to temporarily hold the sludge or other liquid waste with NORM. 2. Reinject, if viable. 3. Incinerate sludge at off-site incinerator. 4. Immobilize scale by mixing with cement / concrete.

Well Works Team Leader PTLs / Well Works Team Leader Sub Surface Team Leader

CBWH

Maintenance Team Leader / CBWH

Camp Admin.

Camp Admin. PTLs / CBWH Corrosion Manager PTLs / P&ATL/ Well Works TL

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S. No.

Waste Type

Category

Disposal Options

Ownership/ Responsibility
Concerned Team Leaders Maintenance Team Leader / Concerned Team Leaders CBWH

19

20

Oil Contaminated Soil Oily Rags (Used)

Hazardous

1. 2.

Recover free liquids and recycle in production streams. Incinerate at off-site incinerator.

Non-hazardous

Incinerate at off-site incinerator.

21

22 23

Paint Waste (Waste Paint, Drums and Rollers/ Brushes) Paraffins Pigging Wastes

Hazardous

Incinerate at off-site incinerator.

Hazardous Hazardous

24

Plant Wastewater Produced Water

Non-hazardous

1. 2. 1. 2. 3. 1. 2. 1. 2.

25

Non-hazardous

Return to production stream. Incinerate at off-site incinerator. Reuse pigs whenever possible. Recycle paraffins and hydrocarbons whenever possible. Incinerate at off-site incinerator. Recycle free oil back into production stream. Dispose water into skim pits and / or lined evaporation ponds. Inject produced water in disposal or injection wells. Use produced water for hydro-testing pipelines, equipment, tanks, well killing and / or drilling mud preparation.

PTLs PTLs

PTLs

26

Rigwash

Non-hazardous

27 28

Rinsate Sanitary Wastewater

Hazardous Nonhazardous

29

Scale (Pipe and Equipment)

Non-hazardous

30

Sludge

Hazardous

31

Trash

Non-hazardous

32

Used Engine Oil

Hazardous

Collect and reuse for subsequent rig washdowns or for first stage washing of equipment. 2. Dispose of rigwash in the lined reserve pit. Dispose rinsate into skim pits and / or lined evaporation ponds. 1. Treat wastewater in Redfox or septic tanks before disposal. 2. Bury sludge removed during cleaning of Redfox or septic tank in burial pits. 1. Recover all free oils and return back in production stream. 2. Immobilize scale by mixing with cement / concrete. (For NORM containing scale refer S. No. 18 NORM Containing Waste.) 1. Reinject, if viable. 2. Incinerate at off-site incinerator. (For NORM containing sludge refer S. No. 18 NORM Containing Waste.) 1. Segregate glass, metal, plastic from trash. 2. Recycle all recyclable items. 3. Burn remaining trash in incinerators. 4. Bury ash from incinerators in a properly designed lined landfill. 1. Process through Lube Oil Purifier. 2. Recycle used engine oil through the approved recycling organizations.

1.

PTLs / Subsurface Operation Team Leader / Well Works TL Sub Surface Team Leader Concerned Team Leaders Camp Admin / PTLs

Sub Surface Engr. / Wellworks TL

PTLs / P&ATL

Camp Admin.

CBWH

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6.0

Recording & Reporting

BPP has to record the information about source, composition, quantity, and final disposition of the waste. This information is needed for regulatory compliance, risk assessment and setting reduction targets and objectives as well as Corporate statistics. The Waste Tracking Form, as shown in the following page shall be used to record this information by all BPP teams, while waste is being dispatched outside facility or BPP controlled location. It is the responsibility of the Team Leader to assign a suitable person (such as Lead Operator at all manned fields) to sign off the Waste Tracking Form, before the waste is dispatched outside.

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Table 2 Waste Tracking Form


Location of Generation: Reporting Team: Submitted by (Name): Submitted on (Date): Waste
Aerosol Cans (Empty) Asbestos Batteries (Dry) Batteries (Lead Acid) Charcoal from Turk Amine Plant Clinical Waste Construction Waste Crude Oil or Condensate Waste Descaling Acids Diethanolamine (DEA) Drilling Fluids/Solids Drums and Containers (Empty) Filters Fluorescent Light Tubes Food Waste Glycols Laboratory Wastes NORM Containing Waste Oil Contaminated Soil Oily Rags (Used) Paint Waste Pigging Wastes Plant Wastewater Produced Water Rinsate Sanitary Wastewater Scale (Pipe and Equipment) Sludge Trash (i) Glass (ii) Metal (iii) Plastic (iv) General Trash Used Engine Oil

________________________________ ________________________________ ________________________________ ________________________________ Approx. Quantity Unit Disposal Location

Checked and Signed:

__________________________ dated: _______________________

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Annexure I
Waste Data Sheets - Guidelines for Waste Management

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Aerosol Cans
Description Components Waste Category
Container used for spraying various substances with pressurized gas as propellant. #" Container #" Paints, starter fluids, oils, insecticides, etc. #" Canister shall be considered hazardous waste if not empty or still pressurized. #" Aerosol cans are non-hazardous if there is no propellant or product inside. No laboratory analysis required. Identify the components by referring label and/or Material Safety Data Sheet (MSDS). Camp Administrator Empty the contents of canister, if any, into a labeled bucket that is empty or that contains the same material as that of the aerosol can (e.g. paint, oil, starter fluid, etc.). Bucket must be correctly marked with contents of the can. Once bucket is full, send the bucket for proper disposal. Store empty can in recycling bin for metals (make sure it is a non-burnable trash). #" Use all of the contents. #" Order only the quantity needed. #"Empty canister can be recycled through contractor. #" For contents of aerosol can, refer appropriate sheet.

Analysis Ownership / Responsibility Accumulation/ Storage

Waste Reduction Disposal Options

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Asbestos
Synonyms: actinolite, chrysotile, tremolite Description Components
White, or greenish-blue, or gray green fibrous, odorless solid. #" Polytetrafluoroethylene Teflon. #" All the asbestiform varieties of serpentinite (chrysotile), riebeckit (crocidolite), cummingtonite-granerite, anthophyllite, and actinolitetremolite. Hazardous Waste No analysis is required. Field Support Team #" Store in rigid, leak-tight containers, such as metal, plastic or fiber drums, or bags or non-rigid containers that are dust and sift-proof. #" Asbestos storage containers must be marked with the following: CAUTION; HAZADOUS WASTE CONTAINS ASBESTOS FIBERS; AVOID CREATING DUST #" If asbestos or asbestos-containing materials (ACMs) are spilled, then the following actions must be completed: Sweep all spilled substance into sealable containers (if appropriate, moisten first to prevent dust formation); and Carefully transfer to a safe place for storage. #" Asbestos is a human carcinogenic substance, so use the proper personal protective equipment (PPE) when handling. #" Prevent dispersion of dust; #" Avoid contact; #" Wear protective clothing; #" If clothes become contaminated, rinse with plenty of water; #" Wear a self-contained full face respirator or air-purifying full face respirator with a high-efficiency particulate filter; and #" Wash hands thoroughly after handling. #" Purchase asbestos-free products and equipment. #" Conduct routine maintenance on ACMs to prevent exposure of asbestos. ACMs to be removed by trained personnel and disposed in a lined landfill.

Waste Category Analysis Ownership / Responsibility Accumulation/ Storage

Waste Handling

Waste Reduction Disposal Options

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Batteries (Dry)
Synonyms: Nickel, Cadmium, Mercury, Lithium, Silver-oxide batteries Description Components Waste Category
#" A dry electrical storage battery. #" Used in consumer goods; some are rechargeable. Nickel, cadmium, mercury, lithium, silver/silver oxide. #"Dry cell batteries containing hazardous components (i.e., nickel, cadmium, mercury, lithium, silver oxide, etc.) are hazardous waste. #"Some dry cell batteries used in consumer goods (e.g., AA, D, C, etc.) do not contain hazardous components (i.e., they are free of nickel, cadmium, mercury, etc.) and therefore considered as non-hazardous waste. If unsure about the battery components, consult the original package to see if there is any hazardous component in the battery. No analysis is required. CBWH Hazardous batteries must be accumulated/stored as follows: Label each container with Hazardous Waste Battery(ies); Label containers with the date on which the first battery became a waste; Do not accumulate waste batteries for more than one year. Place damaged, ruptured, or leaking batteries in a closed, structurally sound, and compatible container to prevent releases to the environment; Pack batteries without other materials in container or package; Protect batteries in order to prevent short circuits. Insulate at least one terminal of each battery with electrical tape to prevent short circuits and possible fire; and Do not use battery terminals to support any weight. Handle batteries in the following manner to prevent exposure: Wear impervious gloves if handling broken units; and Wear safety glasses, face shield, or goggles when handling damaged batteries. #" Use rechargeable batteries wherever possible. #" Arrange for battery exchange or credit from dealer. Recycle batteries with the distributor or manufacturer or through contractor.

Analysis Ownership / Responsibility Accumulation/ Storage

Waste Handling

Waste Reduction Disposal Options

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Batteries (Lead Acid)


Synonyms: wet cell battery, electric storage battery Description Components Waste Category Analysis Ownership / Responsibility Accumulation/ Storage
#" Liquid-filled or gel-filled lead acid batteries. #" Used in vehicle engine starting and uninterrupted power supply systems. #" Lead/lead oxide. #" Sulfuric acid. Hazardous waste. No analysis is required. CBWH Batteries waste must be accumulated/stored as per following instructions: Label each container with Hazardous Waste Battery(ies); Label all containers storing several batteries with the date on which the first battery became a waste; Label all batteries stored individually with the date on which the battery became a waste; Do not accumulate for more than one year; Damaged, ruptured, or leaking batteries must be placed in a closed, structurally sound, and compatible container to prevent releases to the environment; Pack batteries without other materials in the container or package; Protect batteries in order to prevent short circuits. Insulate at least one terminal of each battery with electrical tape to prevent short circuits and possible fire; Do not use battery terminals to support any weight; and Do not drain the electrolyte from the batteries. Used batteries should be handled in a manner to prevent exposure to skin and inhalation: Wear impervious gloves if handling broken units; Wear safety glasses, face shield, or goggles for handling damaged product; and Wear respirator with an acid-mist cartridge if there is a risk of acid release. Arrange for battery exchange or credit from dealer. Recycle batteries with the distributor or manufacturer.

Waste Handling

Waste Reduction Disposal Options

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Charcoal from Amine plant


Description Components Waste Category Analysis Ownership / Responsibility Accumulation/ Storage Waste Handling Waste Reduction Disposal Options
Carbon bed generated from rich amine carbon filter. Carbon Non-Hazardous waste No laboratory analysis is required. Concerned Production Team Leaders #" Store in a structurally sound and compatible container. #" Use appropriate PPE (e.g., gloves, boots, etc.) when handling charcoal waste. #" Recycle carbon bed #" Incinerate at off-site incinerator. #" Dispose in a lined landfill.

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Clinical Waste
Synonyms: Medical waste, hospital waste, infectious waste, expired medicines Description Components Waste Category Ownership / Responsibility Analysis Accumulation/ Storage Waste Reduction Disposal Options
Waste generated from filed clinics. Used cotton and bandages, expired medicines, used syringes, etc. Hazardous Field Medic No analysis is required. Collect and seal in polythene bags Do not mix with other wastes (such as paper) Incinerate at off-site incinerator.

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Rev. No. 0

Construction / Demolition Debris


Synonyms: metal scrap, wood scrap, spoil, vegetation Description Components Waste Category Ownership / Responsibility Analysis
Scrap metal, wood, or other materials from a construction or demolition site. Components depend on the material. Construction and demolition debris that is not contaminated by chemicals, asbestos, oil, or NORM is a non-hazardous waste. Construction Team Leader If material is suspected of NORM contamination, measure the contamination level (count/sec) with contamination monitors. If the readings are twice or above the background levels then refer the Waste Data Sheet on NORM for more details. If the construction or demolition debris is not contaminated with other substances (i.e., chemicals, oils, NORM, etc.), it doesnt need any special handling. However care must be taken so that the dust emanating from the debris is well under control. Recycle material when possible. If construction and demolition debris is not contaminated with other substances, the following disposal options are applicable: Recycling, reusing or selling to a third party contractor; and Disposal in a landfill.

Accumulation/ Storage Waste Reduction Disposal Options

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PRO/ENV/003

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Crude Oil and Condensate Waste


Description Components Waste Category Analysis Ownership / Responsibility Accumulation/ Storage
Crude oil and natural gas condensate waste generated due to spills, leaks. Hydrocarbons. Hazardous waste No laboratory analysis is required. Production Team Leaders #" Return crude oil and condensate to the production system. #" Label each storage container with the name of the material in the container and the appropriate hazard warnings (Flammable). #" Store crude oil and condensate in a structurally sound and compatible container. #" Use appropriate PPE (e.g., gloves, boots, etc.) when handling crude oil and condensate. #" Prevent leaks or spills by carrying out regular inspection and maintenance of all surface lines and facilities. #" Return crude oil liquid and condensate to the appropriate production stream. #" Return crude oil liquid and condensate to the appropriate production stream. #" If crude oil is not being recycled to the production stream due to excessive water content, separate the water and crude through any appropriate separation mode and recycle the crude oil.

Waste Handling Waste Reduction

Disposal Options

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PRO/ENV/003

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Descaling Acids
Description Components Waste Category Analysis Ownership / Responsibility Accumulation/ Storage
#" Liquid. #" Used for pipe and vessel descaling, cleaning agent for laboratory equipment. Depends on the type of acid and contaminants. Hazardous waste (Corrosive) No analysis is required. Well Works Team Leader #" Store in sealed containers, which are compatible with acids. #" Store in containers that are properly constructed and do not contain leaks, corrosion, gouges, bulges, or creases. #" Store in a cool, dry, ventilated storage area with acid resistant floors and good drainage. #" Protect from physical damage. #" Keep out of direct sunlight and away from heat, water, and incompatible materials. #" Do not wash out container and do not use for other purposes. #" When diluting, always add acid slowly to water and in small amounts; never use hot water and never add water to acid. #" Label each container with the name of the material in the container and the Hazardous Waste. #" Consult the MSDS for the proper personal protective equipment (PPE) required when handling this chemical. #" Use non-sparking tools when opening metal containers. #" Wear rubber or neoprene gloves, impervious boots, apron, or coveralls to prevent skin contact. #" Use chemical safety goggles and/or a full-face shield when there is a possibility of splash. #" Maintain eyewash fountains and quick-drench facilities in work area. #" Neutralize prior to disposal. #" Neutralize acids in pipe cleaning process. #" Do not order more than needed. #" Reuse as pH control whenever possible. #" Use for neutralization of caustic wastes. #" Reuse when possible. #" Dispose of in disposal / injection well.

Waste Handling

Waste Reduction

Disposal Options

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PRO/ENV/003

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Diethanolamine (DEA)
Synonyms: diolamine, 2,2-dihydroxydiethylamine, 2,2-iminodiethanol Description Components Waste Category Analysis Ownership / Responsibility Accumulation/ Storage
#" Liquid with an ammonia-like smell. #" Used in acid gas (H2S and CO2) removal from gas stream. #" Diethanolamine/water mix. #" Contaminants include hydrocarbons, H2S, and other materials from the process gas stream. Hazardous waste No analysis required. Production Team Leaders / Well Works Team Leader #" Waste DEA should be stored in leak-proof containers or tanks. #" Label each storage container with DEA -Hazardous waste. #" Keep waste DEA containers tightly closed and protect containers of from physical damage. #" Store waste DEA containers in a cool, dry, ventilated area away from heat, ignition sources, moisture, and incompatibilities. #" Avoid spilling DEA. However, if DEA is spilled, clean it up immediately to avoid soil and groundwater contamination. #" Do not mix DEA with other waste. #" When handling this material, following must be observed: Wear impervious clothing, including boots and gloves, to prevent skin contact; Use chemical safety goggles and/or a full face shield where splashing is possible; Wear an appropriate protective respirator; Maintain an eyewash fountain and quick-drench facilities; and Immediately wash contaminated skin and remove clothing that becomes wet or contaminated. #" Proper operation of amine system will extend life. #" Return waste DEA to a chemical distributor for redistillation. #" If disposal is necessary, Dispose of in disposal / injection well or controlled incineration at off-site incinerator.

Waste Handling

Waste Reduction Disposal Options

Document No.:

PRO/ENV/003

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Drilling Fluids/Solids
Description
#" Water or oil-based mud returned from downhole; #" Cuttings from downhole removed when reconditioning returned mud; #" Mud rinsate; #" Unused drilling chemicals. #" Muds and solids. #" Cement returns. #" Saltwater. #" Oil. #" Formation cuttings. Hazardous waste No analysis is required. Sub Surface Team Leader #" Store drilling fluids in the reserve pit. #" Store lubricating oil separately from drilling fluids #" Store chemicals separately from drilling fluids in leak-proof containers and label each container with the name of the material in the container and the appropriate hazard warnings. #" Segregate lubricating oil and chemicals for disposal so that they do not enter the reserve pit. Wear protective clothing and avoid eye or skin contact. #" Prevent spills and leaks. #" Optimize solids control equipment. #" Substitute less toxic products and additives. #" Use a closed-loop mud system whenever possible to reduce volumes of drilling fluid wastes. #" Minimize use of oil-based drilling fluids. #" Use inventory control and careful planning to avoid accumulating unused materials. #" Minimize water usage and excess chemical and additives. #" Transfer unused additives for use at other sites. #" Dispose of drilling wastes (fluids and solids) in the lined reserve pit. #" Reuse water-based mud whenever possible. #" Reuse waste drilling mud for upcoming well spudding or plugging operations. #" Encapsulate surplus additives and oil-based mud to avoid it mixing with other environmental mediums.

Components

Waste Category Analysis Ownership / Responsibility Accumulation/ Storage

Waste Handling Waste Reduction

Disposal Options

Document No.:

PRO/ENV/003

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Drums and Containers


Description Components Waste Category
Drums and containers either empty or having some residue. Packaging components and residue. #" Drums and containers containing hazardous material would only be considered empty, if no more than 1 inch of residue remains in the container. #" Empty drums and containers after cleaning are considered as nonhazardous waste. No analysis is required. CBWH #" Drums / containers should be checked to verify that they are empty. #" All drums that are not empty must be marked with legible labels. #" Store drums on pallets, racks, or other structures to keep them from direct contact with the soil. #" Cleans drums at drum draining pit. #" Take proper pre-cautions when handling & emptying the drums or containers that contain hazardous material. #" Consult relevant MSDS for PPE when emptying drums of hazardous material. #" For disposal of rinsate refer Rinsate Data Sheet. #" Switch to purchase of materials and chemicals in bulk containers, reducing the amount of drums requiring handling. Additionally, less drum handling reduces the chance of spills and releases requiring cleanup. #" Purchase materials in returnable or recyclable drums / containers. #" Reuse uncontaminated drums for other purposes (e.g., storage and transfer of non-hazardous waste). #" Return undamaged drums and containers to the vendor or send them to a drum reconditioner or recycler. #" Send damaged, uncontaminated drums to a metal recycler. #" Drums that are not empty should not be disposed of.

Analysis Ownership / Responsibility Accumulation/ Storage Waste Handling

Waste Reduction

Disposal Options

Document No.:

PRO/ENV/003

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Filters
Description
#" Used oil filters from gasoline, diesel, vehicle, and generator engines. #" Fuel oil filters. #" Glycol filters. #" Production filters. #" Chemical filters. #" Filter media. #" Residue from waste stream. Used oil filters are considered non-hazardous waste, if the filter is punctured at the filter anti-drain back valve or the filter dome end and hot drained for 12 hours at least. No analysis is required. Maintenance Team Leader / CBWH #" All filters must be punctured, drained, and free of any liquids prior to accumulation and disposal. #" Drained oil from filters is handled as used oil. #" Place drained filters in a labeled and closed container. #" Label each storage container with the name of the material in the container and Hazardous Waste. #" Place drained fuel and oil filters in a labeled and closed container for recycling. #" Do not mix drained liquids from filters with other materials. #" When handling filters, take care to prevent oil spillage and the contamination of soil. #" Change filters only when necessary; use differential pressure as an indicator of needed change. #" Use stainless steel, reusable filters. #" After draining oil, dispose of oil as used engine oil. (Refer Data sheet for Used Engine Oil.) #" Recycle drained liquids (chemicals) back into production stream. #" Sell the drained filters through approve contractor. #" Send filters free of liquid to off-site incinerator.

Components Waste Category Analysis Ownership / Responsibility Accumulation/ Storage

Waste Handling Waste Reduction

Disposal Options

Document No.:

PRO/ENV/003

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Fluorescent Light Tubes


Description Components Waste Category Analysis Ownership / Responsibility Accumulation/ Storage
Light tubes or ballasts. #" Glass. #" Chemicals associated with fluorescent tube; may contain mercury. #"Fluorescent light tubes containing mercury are hazardous waste. #"Mercury-free fluorescent light tubes are non-hazardous. No analysis is required. Camp Administrator #" Do not accumulate wastes for more than one year after the generation; #" Contain unbroken lamps in closed packages that minimize breakage during normal handling conditions; and #" Contain broken lamps in packaging that minimize releases of lamp fragments and residues. #" Cleanup and place any broken light tubes in a structurally sound container that will prevent escape of any material into the environment. #" Use mercury-free light tubes whenever possible. #" Send fluorescent tubes to a lamp recycler or manufacturer. #" Dispose of mercury-free lamps in a landfill.

Waste Handling Waste Reduction Disposal Options

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PRO/ENV/003

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Food Waste
Description Components Waste Category Analysis Ownership / Responsibility Accumulation/ Storage Waste Reduction Disposal Options
Waste generated from Kitchen. Non-recyclable food waste Non-hazardous waste. No analysis is required. Camp Admin #" Store separately. #" Do not mix with trash. Segregate all recyclable items e.g. plastic bottles, glass bottles. Bury in burial pits.

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PRO/ENV/003

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Glycols
Synonyms: ethylene glycol, propylene glycol, triethylene glycol (TEG) Description
#" Colorless, odorless liquid. #" Ethylene glycol or propylene glycol are used as antifreezing agent in heat exchange operations. #" Triethylene glycol is used for dehydration of natural gas. #" Constituents depend on the glycol material being used. #" Waste glycols may be contaminated with light hydrocarbons and salts. Non-hazardous waste. No analysis is required. Production Team Leaders / CBWH #" Do not mix waste glycols, because each glycol must be recycled separately. #" Store glycols in a structurally sound and compatible container. #" Label each storage container with the name of the material in the container. #" Observe the following requirements when handling this material: Wear protective gloves and coverall; Use chemical safety goggles; and Maintain eyewash fountain and quick-drench facilities in work area. #" Properly maintain and operate dehydration units to minimize waste and emissions (e.g., flow rates and temperatures). #" Regenerate waste glycols for reuse. #" Return to vendor for recycling.

Components Waste Category Analysis Ownership / Responsibility Accumulation/ Storage

Waste Handling

Waste Reduction Disposal Options

Document No.:

PRO/ENV/003

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Laboratory Waste
Synonyms: lab chemicals Description Components Waste Category Analysis Ownership / Responsibility Accumulation/ Storage
Waste resulting from sample testing. Depends on sample tested and chemicals used. Hazardous waste Refer MSDS to determine the characteristics of chemical and materials tested. Corrosion Manager #" Do not mix waste chemicals. #" Store wastes in appropriate containers (e.g., non-metal containers for corrosive substances). #" Label each storage container with the name of the material in the container and the appropriate hazard warnings. Consult the appropriate MSDS for personal protection and safety requirements when handling specific chemicals. #" Buy only the required amount. #" Minimize testing by conducting analysis of only required samples. #" Use test methods that generate less or no waste. #" Sell or exchange excess unused chemicals. #" Incinerate at off-site incinerator.

Waste Handling Waste Reduction Disposal Options

Document No.:

PRO/ENV/003

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NORM Containing Waste


(Tubulars, Equipment, Scale, Sludge, etc.) Description
NORM (Naturally Occurring Radioactive Materials) may be present in oil and gas operations at some locations. NORM can be found in downhole tubing, produced water, aboveground processing equipment, contaminated soils (well workovers, tank cleaning, and saltwater leaks), pipe cleaning, and other associated operations. Radioactive material generally consists of radionuclides: uranium, thorium, and radium (radium-226 and radium-228). Hazardous Waste Production Team Leaders Planning and Assurance Team Leader Well Works Team Leader Measure the contamination level (count/minutes) using contamination monitors. If the readings are twice or above the background levels then composite sample shall be collected for radio-chemical analysis. #" All NORM-contaminated equipment, whether in service or not, should be labeled. #" All out-of-service NORM contaminated equipment should be segregated and labeled. #" Use concrete or properly designed lined tanks to temporarily hold the sludge or other liquid waste with NORM. It is recommended that concerned supervisor maintain records of types, volumes, analytical data, destinations, and transportation mechanism of NORM wastes and report the same to HSE Team. Proper industrial hygiene and necessary precautions and equipment are required. Consult the BPP NORM procedure for health and safety requirements. #" Do not accept any used equipment that contains NORM. #" Use scale inhibitors where NORM scale accumulates. #" NORM wastes can be reinjected in abandoned wells. #" Contaminated soil and sludge can be incinerated at off-site incinerator. #" Immobile scale by mixing with cement / concrete.

Components Waste Category Ownership / Responsibility Analysis Accumulation/ Storage

Reporting Requirement Waste Handling Waste Reduction Disposal Options

Document No.:

PRO/ENV/003

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Oil Contaminated Soil


Description Components Waste Category Analysis Ownership / Responsibility Accumulation/ Storage
Soils that have been contaminated due to a release of oily compounds or products (i.e., condensate, produced water, hydrocarbons, etc.). #" Soil. #" Hydrocarbons Hazardous waste. Not required Concerned Team Leaders #" Contaminated soil must be stockpiled in a bermed area that is lined. #" Contaminated soil may be temporarily stored at the point of generation while final management options are being arranged, if all of the following conditions are met: Public access to the storage unit is controlled; The storage unit is bermed, lined, and covered with an impermeable material that has a nominal thickness of 6-mm (a cover is not required if run-off is controlled and odor problems are not reported); and The storage unit is posted with a sign: Caution Oil Contaminated Soils No Smoking. Prevent skin contact with contaminated soil by wearing impervious clothing, gloves, and boots. #" Prevent soil contamination by: Properly maintaining equipment and pipes to prevent leaks and spills; and Using containment devices in chemical storage areas. Using good quality transport bowsers. #" Use impervious secondary containment (i.e., double-walled tanks and liners). #" Use leak detection equipment. #" Use appropriate measures to stop and contain spill or leak if one occurs. #" Pick up free liquids or solids spilled as soon as possible after the spill is contained and recycle. #" Recover free liquids and recycle in production streams. #" Incinerate at off-site incinerator.

Waste Handling Waste Reduction

Disposal Options

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PRO/ENV/003

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Oily Rags
Synonymous: absorbent pads Description Components Waste Category Analysis Ownership / Responsibility Accumulation/ Storage Waste Handling
Oily rags or absorbent pads are used to clean up: Crankcase oil; Crude oil; Diesel fuel; Hydraulic fluid; and Other petroleum products. #" Hydrocarbons. #" Rag or absorbent material. Non-hazardous waste. No analysis required. Maintenance Team Leader Concerned Team Leaders #" Place oily rags in a closed container and keep the drum closed unless materials are being added or removed. #" Add enough absorbent at the time of packing to soak up free liquid. #" Label each storage container with the Oily Rags. #" Return liquid to the crude oil stream if it is crude oil, crankcase oil, diesel fuel, hydraulic fluid, or other non-hazardous petroleum distillates. #" Do not return halogenated solvents (e.g., chloro, flouro, or bromo in the name on the MSDS) to the crude oil stream. #" Prevent skin contact with oily rags and if skin contact should occur, wash skin. #" When possible, use absorbents that can be wrung out and reused. This reduces the volume of waste pads. #" If possible, return free liquids to the production stream. #" Send for off-site incineration.

Waste Reduction Disposal Options

Document No.:

PRO/ENV/003

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Paint
Synonymous: Used/spent paint, paint cans, thinner Description Components Waste Category Analysis Ownership / Responsibility Accumulation/ Storage Waste Handling Waste Reduction Disposal Options
Paints, paint thinner, cans, waste brushes and rollers. Constituents depend on the type of paint. Hazardous waste No analysis is required. CBWH Store in closed drums or containers. Consult MSDS for handling precautions. #" Consume all of product. Paint other objects if necessary. #" Return unused, unopened product to the manufacturer, when possible. #" Incinerate at off-site incineration.

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PRO/ENV/003

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Paraffins
Description Components Waste Category Analysis Ownership / Responsibility Accumulation/ Storage
#" Component of crude oil, which can be shipped to a refinery by drum as crude oil if not suitable for pipeline. #" Accumulate in pumps, tubing, surface equipment, and tank bottoms. Oily waste Hazardous No analysis required. Production Team Leaders #" Store paraffins in a structurally sound and compatible container to prevent releases into the environment. #" If the paraffin has thickened, thin the paraffin by mixing with a solvent and recycle in the production stream. #" Label each storage container with the name of the material in the container and the appropriate hazard warnings. Wear protective clothing and avoid eye and skin contact. #" Recycle by adding to the production streams. #" Minimize overuse or excessive usage. #" Use hot-oil treatment to dissolve paraffin in well and flow lines; send to production. #" Use paraffin inhibitor chemicals. #" Return to production stream. #" Incinerate at off-site incinerator.

Waste Handling Waste Reduction

Disposal Options

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PRO/ENV/003

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Pigging Wastes
Description Components Waste Category Analysis
#" Waste, mainly consisting of paraffin and scale build-up, generated during pigging of flow lines. #" Paraffin and other oil compounds. #" Scale Pigging waste is considered a hazardous waste. If NORM contamination is suspected, use a contamination monitor to measure the contamination level (count/sec). If the readings are twice or above the background levels then composite sample shall be collected for radio-chemical analysis. (See the Waste Data Sheet on NORM for more details.) Production Team Leaders. #" Store pigging wastes in a structurally sound and compatible container to prevent releases to the environment. For example, store wastes in tanks or lined pits to protect soil, groundwater, and surface water. #" Label each storage container with the name of the material in the container and the appropriate hazard warnings. #" Wear protective clothing and avoid eye and skin contact. #" Minimize paraffin accumulation by adding appropriate chemical agents. #" Reduce accumulation of hydrates. #" Reduce accumulation of scale. #" Reuse pigs whenever possible. #" Recycle paraffins and hydrocarbons whenever possible. #" If it is contaminated with NORM, refer sheet on NORM for disposal. #" It can be sent to offsite incinerator.

Ownership / Responsibility Accumulation

Waste Handling Waste Reduction Disposal Options

Document No.:

PRO/ENV/003

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Plant Wastewater
Description Components Waste Category Analysis Ownership / Responsibility Accumulation/ Storage Waste Handling Waste Reduction Disposal Options
#" General water from washings, etc. #" Water. #" Total Dissolved Solids (TDS) and total suspended solids #" Oil Non-hazardous Refer Monitoring procedure for analysis requirements (PRO/ENV/02). Production Team Leaders Stored in lined ponds or storage tanks till proper disposal. When handling plant wastewater, protect yourself from direct contact by using appropriate personal protective equipment. #" Reduce water use. #" Recycle free oil back into the production stream. #" Dispose water into lined evaporation ponds or skim pits #" Oily water from yards should be treated in oil/water separator.

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PRO/ENV/003

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Produced Water
Description Components
Water brought up from the hydrocarbon-bearing strata during the extraction process. #" Formation water. #" Injected water. #" TDS. #" Petroleum hydrocarbons. #" Naturally occurring metals. #" Additive chemicals. Non-hazardous Refer Monitoring procedure for analysis requirements (PRO/ENV/02). Production Team Leaders / Subsurface Operation Team Leader / Well Works Team Leader #" Use rock plugging with gel slugs to block off water production in completions where there is a separation of the oil and water zones. #" Dually complete the oil zone and water zone to allow water to be produced simultaneously but separately from oil and allow control of water coning. #" Carefully plan well completions. #" Reperforate well to reduce water production. #" Drill wells to minimize water production. #" Optimize production rate to minimize influx of water. #" Inject produced water into disposal or injection wells. #" Reuse produced water whenever possible. #" Use produced water for hydro-testing pipelines, equipment, tanks, well killing and or drilling mud preparation.

Waste Category Analysis Ownership / Responsibility Waste Reduction

Disposal Options

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PRO/ENV/003

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Rigwash
Description Components Waste Category Analysis Ownership / Responsibility Accumulation/ Storage Waste Handling Waste Reduction
Water used to wash down the rig floor. #" Water. #" Detergents. Non-hazardous if it doesnt contain spilled chemicals and oils. No analysis required. Sub Surface Team Leader #" Collect rigwash in the reserve pit. #" Collect oily layer through absorbent pads. #" Store any segregated used oil appropriately (see Used Oil data sheet). #" When handling rig wash, avoid eye and skin contact. #" Segregate any used oil and paint solids before disposing of rigwash in the reserve pit. #" Use water wisely in rig maintenance. #" Use high-pressure, low-volume hose nozzles with automatic cutoffs. #" Set up a regular maintenance program for water systems to reduce leaks and drips. #" Reduce rigwash use by sweeping or other dry cleaning when feasible. #" Collect and reuse rigwash for subsequent rig washdowns or for first stage washing of equipment. #" Use as make-up water in drilling and completion operations. #" Dispose of rigwash in the lined reserve pit.

Disposal Options

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PRO/ENV/003

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Rinsate
Description Components Waste Category
Water used to rinse out emptied drums and containers. Drums that contained acute hazardous waste must be triple rinsed. Water and residue from drum. #" Rinsate from drums that contained an acute hazardous material is hazardous waste. #" Rinsate from drums that contained non-acute hazardous waste can be considered as non-hazardous and treated as plant wastewater, if it does not exhibit hazardous waste characteristics (e.g., toxicity, ignitability, corrosivity, etc.). No analysis is required. Concerned Team Leaders #" Hazardous rinsate must be contained in rigid, leak-proof, and covered containers and may not be mixed with other rinsate. #" Label each storage container with the name of the material in the container and the appropriate hazard warnings. #" Non-hazardous rinsate may be added to plant wastewater for future disposal in the injection well. #" Appropriate personal protection is required when handling rinsate from drums that contained hazardous wastes. Consult the applicable MSDS for protection requirements. #" Avoid splashing rinsate on clothes or skin. Gloves and boots can protect skin from splashes and spills. #" Avoid spilling any rinsate on soil. #" Avoid using excess water for rinsing out drums and containers. #" Do not mix any other rinsate with a rinsate from a drum that contained any hazardous material. #" Rinsate containing hazardous materials can also be disposed in a disposal or injection well. #" Non-hazardous rinsate can be disposed in skim pits or lined evaporation ponds with plant wastewater.

Analysis Ownership / Responsibility Accumulation/ Storage

Waste Handling

Waste Reduction Disposal Options

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PRO/ENV/003

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Sanitary Wastewater
Description Waste Category Analysis Ownership / Responsibility Waste Handling Waste Reduction Disposal Options
Wastewater from camps. Non-hazardous Refer Monitoring procedure for analysis requirements (PRO/ENV/02). Camp Administrator / PTLs When handling sanitary wastewater/ sludge, protect yourself from direct contact by using appropriate personal protective equipment. Reduce water use. #" Treat wastewater in Redfox or in septic tanks before disposal. #" Sludge removed from Redfox or septic tank during cleaning should be buried in burial pits.

Document No.:

PRO/ENV/003

Page 42 of 46

PAPER COPIES ARE UNCONTROLLED. Prior to referring a printed copy, please check the controlled version on the intranet at http://pakistan.bpweb.bp.com/HSEam/index.htm to ensure that current revision is being used.

BP Pakistan Exploration & Production, Inc.

WASTE MANAGEMENT PROCEDURE

Rev. No. 0

Scale (Pipe and Equipment)


Description Components
Formed during the production process within wellbores and production equipment due to temperature and pressure changes. #" Barium sulfate. #" Iron sulfide. #" Calcium carbonate. #" Other inert materials. #" Some may contain NORM. Non-hazardous unless it exhibits hazardous waste characteristics. If material is questionable for NORM contamination, measure the contamination level (count/sec) using contamination monitors. If the readings are twice or above the background levels then composite sample shall be collected for radio-chemical analysis. (See the Waste Data Sheet on NORM for more details.) Subsurface Team Leader #" Store scale in a structurally sound and compatible container to prevent releases to the environment. #" Label each storage container with the name of the material in the container and the appropriate hazard warnings. Wear protective clothing and avoid eye and skin contact. #" Use scale inhibitors. #" Avoid mixing incompatible produced waters that can result in scale formation. #" Design facility to reduce locations prone to scale formation (i.e., avoid large pressure drops and unnecessary pipe elbows). #" Reduce the volume of water produced. #" Coat material surfaces with chemicals at critical points in the production system to reduce the availability of nucleation points for scale formation. #" Recover all free oils and return back into production stream. #" Immobilize scale by mixing with cement / concrete. #" For NORM contaminated scale, refer sheet on NORM Containing Waste.

Waste Category Analysis

Ownership / Responsibility Accumulation/ Storage Waste Handling Waste Reduction

Disposal Options

Document No.:

PRO/ENV/003

Page 43 of 46

PAPER COPIES ARE UNCONTROLLED. Prior to referring a printed copy, please check the controlled version on the intranet at http://pakistan.bpweb.bp.com/HSEam/index.htm to ensure that current revision is being used.

BP Pakistan Exploration & Production, Inc.

WASTE MANAGEMENT PROCEDURE

Rev. No. 0

Sludge
Description Components
Material (sediment and water) originally from downhole or that gathers on the bottom of treatment and storage tanks (i.e., production separator fluid treating vessels). #" Sands. #" Oils. #" Solids. #" Emulsions. Hazardous Waste #" Test a material that may contain NORM in the following manner: Measure the contamination level (count/sec) using contamination monitors. If the readings are twice or above the background levels then composite sample shall be collected for radio-chemical analysis. Production Team Leaders / P&A Team Leader #" Reprocess material if possible: Return free oil to process stream; and Dispose of water as produced water. #" Material that cannot be reprocessed must be contained in drums, tanks, or containers or in properly lined pits. #" Label each storage container with Oily Sludge Hazardous waste. #" Do not mix NORM containing sands or solids with other produced sand. #" Separate solids and liquids to minimize volumes #" Design perforations in completion operations to minimize sand production. #" Modify process to reduce waste (e.g., tank bottom accumulation). #" Reinject, if viable. #" Send for offsite incineration. #" For NORM contaminated sludge, refer sheet on NORM Containing Waste.

Waste Category Analysis

Ownership / Responsibility Accumulation/ Storage

Waste Handling Waste Reduction

Disposal Options

Document No.:

PRO/ENV/003

Page 44 of 46

PAPER COPIES ARE UNCONTROLLED. Prior to referring a printed copy, please check the controlled version on the intranet at http://pakistan.bpweb.bp.com/HSEam/index.htm to ensure that current revision is being used.

BP Pakistan Exploration & Production, Inc.

WASTE MANAGEMENT PROCEDURE

Rev. No. 0

Trash
Synonyms: domestic, office, warehouse, maintenance trash Description Components Waste Category Analysis Ownership / Responsibility Accumulation/ Storage Waste Handling Waste Reduction Disposal Options
Trash and paper products. Constituents depend on the item. Non-hazardous waste. No analysis is required. Camp Administrator Segregate and store trash in the drums or covered bins. Use caution to avoid splinters, cuts, and general harm. #" Recycle. #" Limit use of styrofoam and/or paper. #" Segregate glass, metal, plastic from trash. #" Recycle all recyclable items. #" Burn reaming trash in incinerators. #" Bury ash from incinerators in a properly designed lined landfill.

Document No.:

PRO/ENV/003

Page 45 of 46

PAPER COPIES ARE UNCONTROLLED. Prior to referring a printed copy, please check the controlled version on the intranet at http://pakistan.bpweb.bp.com/HSEam/index.htm to ensure that current revision is being used.

BP Pakistan Exploration & Production, Inc.

WASTE MANAGEMENT PROCEDURE

Rev. No. 0

Used Engine Oil


Synonyms: lube oil, engine oil, motor oil, lubricating oil Description Components Waste Category Analysis Ownership / Responsibility Accumulation Waste Handling Waste Reduction Disposal Options
Used oil generated when maintaining and lubricating production, drilling, workover, and gas plant equipment. #" Hydrocarbons. #" Process contaminants. Hazardous waste No analysis is required. CBWH

#" Collect and store in oil barrels /drums that are in good condition, and not
leaking. #" Label storage containers with the words Used Oil. Do not mix used oil with any other materials. #" #" Avoid contamination with other materials. #" Wear protective clothing and avoid eye and skin contact. #" Minimize volume of lube oil by extending its use and using high-grade oil. #" Use oil additives that improve oil performance. #" Process through Lube Oil Purifier. #" Sell to the approved recycling organizations for recycling.

Document No.:

PRO/ENV/003

Page 46 of 46

PAPER COPIES ARE UNCONTROLLED. Prior to referring a printed copy, please check the controlled version on the intranet at http://pakistan.bpweb.bp.com/HSEam/index.htm to ensure that current revision is being used.

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