1. Environmental Compliance and Engineering for Oil & Gas E&P Activities
Mark Shemaria
Freemont AP Environmental
December 2007

2. Why do we need Environmental ?
Business today has a Triple Bottom Line:
Economic performance;
Social performance;
Environmental performance.

3. Sustainable Development
“meeting the needs of the present without compromising the ability of future generations to meet their own needs”

4. Environmental for E&P Activities
You must have:
Strong Leadership & Management Commitment;
Engage staff from across all disciplines;
Focus on practical & understandable;
Recognize that much is already done;
Share experiences & Learn;
Take it step by step.

5. Characterization
Environmental Aspects: How do we impact the environment?
How/what do we Generate?
How do we Manage?

6. Environmental?
Doing what we do
Right!

7. Air Permitting Title V = paper work Tanks & Process Systems
Combustion Devices
Large Sources - 4 or 10 tons per year
Timing – weeks/months
Title V = paper work

8. Table 1 – COMMON E&P INDUSTRY AIR EMISSIONS
Emissions Type of Generating Activity
VOC Fugitive emissions, product storage, process venting, combustion
H2S Well-casing gas venting, flaring, process venting
SOx Sour-gas combustion
NOx Combustion (flaring, IC)
CO Combustion (flaring, IC)
PM Combustion, dust (construction, roads)

9. Water Permits Spill Plans Class II Wells – Title 14 CCR Division 2
NPDES/Storm Water
Spill Plans
OSPR Title 14 CCR Division 1 SD 4
SPCC – 40 CFR 112 (Feb 06)

10. Table 2 – COMMON E&P INDUSTRY WATER DISCHARGES
Discharge Type of Generating Activity
Produced water Production Operations
Completion fluids Well completions
Well-treatment fluids Well workovers
Rig Wash Drilling operations
Hydro test water Pipeline, flowline testing
Storm water Runoff from drilling, production sites
Sewage All operations

11. Waste Hazardous 40 CFR & Title 22 CCR Non-Hazardous
Designated – oily waste (crude)
Debris/trash
Special (electrical stuff)

12. Table 3a – COMMON E&P INDUSTRY SOLID WASTES
Solid Waste Type of Generating Activity
Oily soil Leaks and spills
Tank bottoms/Scale Crude oil storage and maintenance
Solvents/chemicals Cleaning, analysis & operations
Lube fluids/filters Vehicle, equipment maintenance
Acid & caustic Well Treatment, Scrubber operations
Cement Drilling and completion operations, construction
Drill fluids/cuttings Drilling operations a

13. Table 3b – COMMON E&P INDUSTRY SOLID WASTES
Solid Waste Type of Generating Activity
NORM Production maintenance, well workovers
H2S & VOC scrubber Scrubber operations/Activated carbon
Paint waste Drilling and production maintenance
Empty containers Drilling and production operations
Batteries Vehicle, equipment maintenance Trash/rags All operations
Radioactive tracers Drilling operations
Concrete, steel Facility & pipeline abandonment

14. Table 4 –SOURCE REDUCTION THROUGH PURCHASING PRACTICES
Solid Waste Type of Generating Activity
Solvents Purchase low-toxicity/hazard/VOC solvents and purchase only amount needed; return unused portion.
Containers Purchase supplies in bulk containers; include requirement in contract that containers must be returned to vendor.
Chemicals Purchase only amount needed; return unused portion.
Lubricants Avoid ones containing chlorinated solvents and purchase only amount needed; return unused portion.
Packaging Require minimal or recyclable packaging.
Thread protectors Add requirement in contract that protectors must be returned to vendor.

15. Table 5 – Source Reduction Through Storage/Distribution Procedures
Pollutant Storage/Distribution Procedure
Contaminated soil Pipeline operating & maintenance procedures. Protect containers, store with secondary containment, and properly secure during transportation.
Chemicals Keep container labels from weathering to ensure contents can be identified. Use safe lifting procedures to prevent leaks.
Storm Water Cover storage area to prevent contact.

16. Table 6 – SOURCE REDUCTION THROUGH PRODUCT/MATERIAL SUBSTITUTION
Pollutant Product/material Substitution Procedure
Solvents Use nonhazardous solvents.
Paint Use minimal-hazard paint products and thinners.
Pipe dope Use heavy-metal-free dope.
Antifreeze Use minimal-hazard antifreeze (propylene glycol).
SOx emissions Use low-sulfur fuels.
Refrigerants Use non-CFC refrigerants.
Oil-based drill
fluids Use synthetic drilling fluids.
Laboratory waste Use minimal-hazard lab materials.
Aerosol cans Purchase materials in nonaerosol form.

17. Table 7 – SOURCE REDUCTION THROUGH EQUIPMENT/PROCESS MODIFICATION
Pollutant Equipment/Process Modification
Tank bottoms Design completions for lower solids production; keep solids suspended in tanks with mechanical agitation;
Solvents Use high-pressure wash system instead of solvents for cleaning.
NORM Segregate processing of noncompatible produced waters and minimize pressure drops to minimize precipitation.
Produced Water Design completions for lower water production.
Nox, CO emissions Use low-Nox burner; use electric instead of i-c engines; use natural gas instead of diesel engines

18. Table 8 – SOURCE REDUCTION WITH CONTROL SYSTEMS
Pollutant Control System
Tank bottoms Control with chemical treatment in process.
Scale Control with chemical treatment.
VOC emissions Install vapor-recovery.
SOx scrubber waste Automate control system to increase scrubber efficiency.
NORM Control with chemical treatment.
H2S, scrubber waste Automate control system to increase scrubber efficiency.
NOx, CO emissions Install electronic ignition and air/fuel ratio controllers/ install catalytic converters.

19. Table 9 – SOURCE REDUCTION THROUGH MAINTENANCE, INSPECTION AND REPAIR
Pollutant Maintenance and Repair Activity
VOC emissions Maintain connections/seals/hatches to minimize fugitives.
Contaminated groundwater Conduct regular mechanical-integrity tests on well tubulars.
Contaminated soil Perform routine maintenance/testing and repair leaks.

20. Table 10 – SOURCE REDUCTION THROUGH CLEANING/HOUSEKEEPING
Pollutant Cleaning/Housekeeping Procedure
Rig wash Sweep up solids before washing; use a high- pressure, low-volume wash unit.
Storm Water Keep equipment and process areas clean; cover process and storage areas.

21. Table 11 – SOURCE REDUCTION THROUGH CONTAINMENT
Pollutant Containment Measure
Contaminated soil Provide containment (e.g., drip pans) around equipment with the potential to leak (e.g., valves and flanges); provide containment around process areas, storage areas, tanks, wellheads, and loading racks.
Storm Water Contain spills to prevent contamination of storm water; provide containment for storm water.

22. Table 12 – SOURCE REDUCTION THROUGH SEGREGATION
Pollutant Segregation Procedure
Oily rags Separate from trash so they can be cleaned and reused.
Storm Water Divert from contaminated areas.
Filters Segregate filters that can be recycled.
Trash, refuse Segregate recyclable materials (aluminum, paper, glass).

23. Table 13 – SOURCE REDUCTION THROUGH SAMPLING PROCEDURES
Pollutant Sampling Procedure
Sample wastes Use in-line analyzers instead of performing shake-our tests.
Laboratory wastes Collect only amount needed for analysis.

24. Table 14 – REUSE THROUGH REGENERATION
Pollutant Regeneration Practice
Solvents Send to solvent reclaimer.
Pumps, valves Send to reconditioner.
Activated carbon Send to regenerator.
Batteries Use rechargeable batteries.

25. Pollutant Containment Measure
Table 15 – REUSE
Pollutant Containment Measure
Produced Water Inject for enhanced recovery
Drilling Fluids Closed-loop mud system, return to vendor.
Empty Containers Return to vendor.
Lube Oil Put in production.

26. Pollutant Recycling Measure
Table 16 – RECYCLE
Pollutant Recycling Measure
Oily Soil Use as asphalt for roads or berms
Tank Bottoms Use as asphalt for roads or berms, process in coker, commercial recycler
Empty Containers Recycle for scrap-metal
Trash Segregate and recycle

27. Table 17 – RECYCLE THROUGH EXCHANGE/SUBSTITUTION
Pollutant Exchange Substitution Measure
Drilling Fluids Use as spud mud on next well.
Acids Use for neutralization.
Produced Water Use for agricultural/other beneficial use