During site closure the operator should prepare a waste management plan that identifies the waste streams that will be generated, how the waste will be characterized, any treatment that may be required, storage specifications and identifying disposal facilities. The waste management plan should follow state/provincial and local waste management regulatory requirements. It should also include an evaluation of opportunities for reuse and recycling and include a specific section that addresses naturally occurring radioactive materials (NORM) and technically enhanced naturally occurring materials (TENORM). In many cases the oil and gas company, either due to regulatory requirements, or attention to good environmental practices will have a company or area specific waste management plan that can provide guidance and information to develop a site-specific plan.
The plan should also include a record keeping process that will track equipment removal and waste management. Records of equipment removal and dispensation, the type and volume of waste generated, the transporter and the name and location of any treatment or disposal sites should be maintained on file for the length of time designated by regulatory requirements and/or company policy.
