General Mitigation Measures
General mitigation practices and principles that could apply to any or all phases of a hazmat incident include:
- Implement plans for hazardous materials management, waste management, spill prevention and response, stormwater management, and pesticide management. Train employees to promptly contain, report, and/or clean up any oil or hazardous material spill.
- Provide secondary containment for all on-site hazardous materials and waste storage, including fuel. (Fuel storage should be a temporary activity and fuel storage facilities should be removed immediately upon completion of the construction and decommissioning phases.)
- Containerize and periodically remove wastes for disposal at appropriate off-site permitted disposal facilities. The goal would be to minimize the amount of hazardous materials and waste onsite.
- Document accidental releases as to cause, corrective actions taken, and resulting environmental or health and safety impacts.
Project Phase-Specific Mitigation Measures
Mitigation measures specific to a particular phase of an oil and gas project include:
- Minimize the generation of both solid and liquid wastes (including produced water) from well drilling and well development operations that are potential environmental contaminants. Options to minimize waste include use of several different directional drilling techniques (which minimize the number of wells required and consequently, the amount of drill cuttings), drilling the smallest possible size well bore, use techniques that reduce the amount of drilling fluids requiring ultimate disposal, and consider the use of drilling fluids that generate fewer waste cuttings.
- Consider the use of drilling and fraccing fluids with the lowest potential for producing wastes and with potential to harm the environment and/or contaminate water resources. Employ drilling and recovery systems that recycle drilling fluids, and minimize the amount of final disposal of contaminated fluids and materials.
- Isolate surface reserve pits where drill mud and drill cuttings and produced water are stored, or where they are ultimately disposed of, from both surface and ground water resources (through use of appropriate top and bottom liners, and top soil and vegetative cover).
Production Controls and Guidelines
- Separate water produced along with oil or gas for storage, treatment, and/or ultimate disposal, and ensure that it is not released to contaminate either surface water resources or potable underground aquifers.
- Employ a long-term monitoring program to ensure that mitigation measures (e.g., closure of reserve pits) employed throughout the project are effective.
Information from Tribal Energy and Environmental Information Clearinghouse