To avoid unnecessary efforts and mitigate risks, all phases throughout the design and implementation of large capital projects should incorporate comprehensive planning for waste management
Proper waste-management planning and execution during all phases of a large capital project in the chemical process industries (CPI) can contribute greatly to a project’s success. How well waste management is integrated into a project is often an indicator of the project’s overall risk management.
This article provides guidance on how to integrate waste-management planning and execution into the entire lifecycle of capital projects to reduce risk, manage costs and maintain schedules. This lifecycle approach takes the process from project scoping and early design through startup, operations and decommissioning. The article also identifies specific approaches and mechanisms that can be integrated into a company’s existing project-development and execution tools, and provides approaches to move waste-management programs forward within and between all stages of a capital project.
An area of waste-management planning found most frequently to be challenging is integrating and managing the ever-expanding contractor activities into the operator’s waste-management strategy and philosophy. Contractor-management approaches, such as auditing programs and third-party contract requirements, are often not addressed until the project is well into design and construction, resulting in confusion, delays, higher costs and increased liability for the project owner. Construction wastes are usually high-volume streams, such as used oils, used filters, used tires, solvents, scrap metal and wood, waste cement and so on (Figure 1). Although many of these waste streams are not hazardous, the high volume can be a problem for disposal, especially if local handling capacities are exceeded. Particularly in greenfield areas outside the U.S., implementing proper waste-handling procedures is critical, because low waste-handling capacity, poor, potentially high-risk transportation routes and local regulations can often prove to be problematic.
Most companies have developed a basic waste-management philosophy and strategy based on good practices and home-country standards and regulations, as well as internal operating and management systems. References 1–7 give more details on specific waste-management standards and regulations.
Based on the company’s international presence, these internal guidelines are often the first stage and foundation of a capital-project waste-management program. For companies that are expanding into international areas for the first time, the first step to a sound waste-management approach is often to review these corporate guidelines and expand them if necessary to include issues that will impact a capital-project program. Some issues of concern may include the following:
Expanded and more restrictive country regulations (for example, those related to wastewater-discharge standards, hazardous-waste definitions and final handling, treatment and disposal requirements) Local-country third-party contractor requirements related to waste management Infrastructure limitations Engineering, procurement and construction (EPC) contractor programs
Another important aspect of a company’s program during international expansion is to ensure that its overall operational excellence/operational integrity management (OE/OIM) system is robust enough to handle international considerations and capital projects. Waste is only one aspect of this overall OE/OIM system, but if the OE/OIM system is not structured well, then all of the management programs will be hampered, including waste management. Once these foundational issues have been addressed, the focus can be shifted to the specific capital project in question.
Capital project structure
Successfully planning for and integrating waste management into a capital project requires both planned and free-flowing communication between project sub-teams that are simultaneously executing different project work scopes. As with all aspects of a project, the extent to which sub-teams are “siloed” increases the risk that waste-management planning will be inadequately integrated into project development. Specific approaches that can encourage more disciplined integration earlier in the project-development process are detailed in the sections below.
Establish a collaborative project culture.Companies have come to recognize the importance of fully integrating personnel from all project scopes, including facilities development, design and construction, as well as auxiliary operations, such as housing, wastewater-treatment, solid-waste management, spill response, pipeline operations and so on. Personnel involved with all project phases (including personnel from operations) should also be integrated into project development and execution. However, environmental planning functions are often not integrated into project planning.
Environmental, social and health-impact assessment (ESHIA) preparation is typically conducted by an environmental team (in many instances, a third-party contractor). At this point, the core environmental team is in a non-collaborative role, such as gathering information from other team members instead of having an active role in the planning and execution of the project. If ESHIA preparation is a company’s sole mechanism for waste-management planning during the early project phases, and if the personnel preparing the ESHIA are not fully integrated into the project, the common outcome is that waste-management planning will be inadequate and untimely.
Include waste management in the project development, design and execution. All project planning evolves from the initial project’s philosophy, objectives, plans and basis of design (BOD). Ensuring waste management is included in the original project philosophy and BOD will help to ensure its timely consideration in the subsequent plans for environmental management, contractor management, construction management and other programs that follow.
Consider waste management as necessary infrastructure.Civil engineers were the original waste-management engineers. Over the last 30 years, waste management has shifted to being an environmental discipline, and is no longer specifically covered by a core engineering discipline during project development. As a result, planning for waste-management infrastructure is often conducted separately from other infrastructure planning — and often lags behind other infrastructure planning. Ensuring that the waste-management infrastructure scope is covered by the project’s overall infrastructure development will ensure waste-management planning is in step with the overall project development. Waste-management planning should take place in parallel with plans for power distribution, roads and water- supply infrastructure.
Project infrastructure planning
Large capital projects in remote locations or countries with poor infrastructure typically require an infrastructure to be established in order to support the project. The infrastructure is usually established in phases, with multiple and sequential developmental projects required to establish basic infrastructure before full construction of the capital project itself can be initiated. Waste-management planning in such situations is quite challenging, as the infrastructure projects, in many instances, have to be advanced faster than the capital project itself.
It must be understood that waste-management methods will change as infrastructure develops. Waste-management methods likely need to be unique for different project phases — and a specific waste stream may have more than one solution at different points in time. As a result, blanket management requirements (for instance, the refusal to ship waste out of a region because it is cost prohibitive, or that waste cannot be sent to a certain facility because the facility’s throughput will not be adequate) can be detrimental to project development and execution. Instead, a company may recognize that a solution or combination of solutions may be costly but necessary in the short term. In the meantime, it can develop more economical, localized facilities to support later project phases. Writing off a legally and logistically viable management method in the short term often results in stockpiled wastes. These stockpiled wastes will frequently require continued investment to maintain stability while a permanent solution is developed or awaits government approval. Often, the stabilization method increases the waste volume, and the low-cost solution that was originally envisioned ends up not being viable.
Also crucial to develop is a philosophy that dictates waste-management infrastructure development be nested within and integral to the overall capital project. The greatest challenge with waste-management infrastructure planning is the “chicken-and-egg” scenario — finalizing the waste-management infrastructure BOD, when the capital project facility BOD scope and front-end engineering design (FEED) are not yet finalized. Ensuring that the waste-management infrastructure work is fully integrated within the capital-project design will provide the foundation for the waste-management infrastructure and ensure that the projects advance on time and within the capital project budgets.
The company must also work with and demonstrate great competence to stakeholders at planning and executing the early project phases, in order to ensure that the project stays on schedule, and that stakeholders continue to be aligned with the project. Planning project development phases requires project team integration for all functions as detailed below.
Early works and camp.The early-works scope consists of the infrastructure required to enable the capital-project construction contractor to mobilize and establish a construction camp at the site. An early camp will often be required, along with associated waste and wastewater-treatment facilities. The early-works contractor should consider building out from earlier camps, depending on conditions and location. The waste-management infrastructure requirements may then be a simple expansion of these camp structures. Alternatively, a new camp may be required. From a waste-management perspective, this would typically still include a package wastewater-treatment plant, one or more incinerators and perhaps other solid-waste-management facilities, such as storage facilities, initial treatment facilities and possibly the beginning of a limited landfill. Waste recycling opportunities should be considered for certain waste streams, such as scrap wood, scrap metal and used oil.
Full construction camp and activities.The construction contractor will construct and initiate the use of some permanent waste-management facilities, such as a landfill and a waste-storage and transfer station. Other waste-management facilities will be part of the permanent-camp project and will not be used until the operations personnel arrive onsite. Depending on the size and complexity of the project, multiple sites may be developed, each with varying levels of waste-management facilities. Construction may also continue well after operations startup, resulting in overlapping needs and requirements that will need to be considered in the design, as well as the management of facilities.
Operations camp.While a project landfill may have been in operation during early project construction, new permanent waste-management facilities will often need to be brought online roughly when the capital-project facility starts up. Typically, dedicated waste equipment, such as incinerators and domestic waste-treatment facilities, are brought online with operational startup. However, construction facilities may be kept on location for future expansion work, resulting in multiple waste facilities. Remote camps may also be constructed away from the primary facility, such as those associated with pipeline booster stations and coastal loading and offloading facilities. These camps may or may not have separate waste facilities, but will surely have waste generation that will have to be managed.
Integrated waste-management planning that considers each of the above phases as possibilities will be required, in order to ensure that the waste-management infrastructure is sized appropriately and brought online at the right time. The following planning items require consideration:
It is imperative that all aspects of wastes from the construction and operations phase be considered when sizing waste-management facilities. If not integrated into the permanent camp, early-works camps may need to be demolished or abandoned. The construction and demolition (C&D) waste from these camps’ removal will need to be captured by the construction or permanent-camp waste-management planning, or handled by a third-party contractor separately from operations. These added waste streams need to be incorporated into the design of the waste facilities (in particular the landfill). Figure 2 shows an example of a master-planned landfill that can incorporate industrial waste streams. Another item to consider is whether any of the early-works waste-management facilities will be or should be used by the construction contractor All project-development camps (all camps except for the facility operating camp) will need to be decommissioned and abandoned at some point in time. A camp closure plan is required for each camp to establish the expected camp end-of-service timing and closure vision. Plans for these wastes and facilities must be accounted for In general, the construction contractor will be advised to arrange for suppliers to remove any unused materials, shipping containers and packaging. Deviations from this expectation need to be understood and planned for In some cases, unused construction materials, shipping containers and packaging, and other items may be used for community engagement and improvement. Advance planning with legal, candidate contractors, and stakeholder-engagement personnel is required in order to plan appropriately for these wastes Once operations start up, will the operator manage residual and future construction project wastes or will the contractor be required to take care of its own wastes based on company restrictions? Determine how this will be managed Domestic wastewater-treatment-plant discharges for the construction and operations camps need to be modeled in conjunction with industrial discharges. In many cases, the initial ESHIA covers only the first few project phases. Longer-term modeling and planning for varying discharge scenarios is required in order to understand and mitigate for this scenario, even if the ESHIA does not yet consider the intermediate and final build-out plans. Careful consideration of how discharge locations may shift as the project develops is required for this modeling
Managing phase transitions
Transitioning between the early-works, full-construction and operation phases is typically a time of overlapping contracts, with many contractors concurrently onsite. The overlap, particularly in the case of full construction and operation, may take place over several years. Minimizing project disruption and properly preparing contractors ultimately results in lower project costs, as clear expectations reduce execution risk. Some considerations to help reduce cost and risk are as follows:
Contractors coming onsite must have reviewed and incorporated the company’s waste philosophy and BOD with regard to waste into their scope of work and work expectations. Thus, the company must include such requirements into the invitation to tender (ITT) package for each contractor, with clear understandings of how waste will be managed onsite and by whom. Before final pricing of any phase, the contractors whose onsite presence will overlap should have an opportunity to develop a coordinated transition plan that will address all areas of transition — including waste management. The plan development must also include waste generators that are not specifically involved in the transition, so that all parties understand their roles, expectations and impacts What are the interdependencies between the extent to which the onsite contractor completes its scope and the ability of the next contractor to mobilize onsite? Careful consideration of the onsite contractor’s schedule will show the point at which construction is sufficiently complete for the next contractor to mobilize — and take over waste-management tasks. This vision of how these will likely look needs to be clearly outlined and “frozen” for bidding. Also important to include is a transition risk review of waste management to make sure everyone is aware and knows what to do
Some of the activity-specific “nuts and bolts” to consider for each phase of a capital project are detailed in the following sections.
During new venture reviews, several key activities, along with planning, need to be conducted prior to beginning field operations. These include understanding both the regulatory and social conditions for the environment and infrastructure of the area. How difficult will it be to obtain permission to operate? What will be the cost in time and equipment to support project activities? These are key questions that need to be answered in the initial evaluation of a new venture. Can these risks be reduced to manageable levels or will the costs be too high?
In some cases, a local office in the country will be arranged for workers to start the process of introduction of the company to the local government and get a realtime understanding of the issues that can arise. Although often of limited size and scope, this office complex will typically be the first activity the company will have related to waste management within the country of operation, and can provide insight into future problems. From a waste perspective, Table 1 describes some of the actions that should be taken.
FEED activities relate to the BOD and the beginning engineering of the project facilities and pipelines, as well as baseline studies as needed, and a full-project ESHIA program if required. Accordingly, the project often has an increased demand for rooms and lodging, increased travel in and out of the country and various contractors arriving for both short and long assignments to collect information and conduct research. Typically, the FEED contractor will manage a large part of the baseline work from an engineering standpoint, including evaluating soil types, water levels, weather and land data and so on. The company will manage other studies, such as the full-project ESHIA work and increased regulatory and social efforts, to make sure the project moves forward. Table 2 provides some considerations for FEED-level waste management.
The initial activity involves developing an ITT package for contractor bids for pre-FEED and FEED items and for the development of a BOD document. Environmental considerations, including waste management, need to be included in the development of these bid packages and BOD documents.
During the construction phase, the largest expansion of personnel usually occurs, and the volume of waste generated is often at its maximum. The types of waste that must be handled will expand to include remaining waste streams from the completion of work on early-phase infrastructures, and now full-blown construction waste streams, as well as domestic waste streams. Large volumes of used oils, lubricants, waste filters and used tires, as well as scrap wood, plastic and concrete are generated. Although the volume of hazardous waste increases, the main types of waste streams are still common ones (for instance, used oils). The principal waste problem now becomes one of logistics, movement and handling. Table 3 addresses some items that must be accounted for during the construction phase.
Operation of the facility usually results in demobilizing the construction facilities and consolidating residual waste streams into the permanent waste facility during closeout. Some residual construction may continue with a reduced construction camp. The camp and associated equipment may remain onsite with the anticipation of expansion needs or may be removed completely, depending on operator strategy. The volume of waste will be reduced considerably; however, with the startup of operations, other waste streams will come online that may be more hazardous (process wastewater streams, solvents, tank bottoms and so on) that may require additional third-party contractors and possibly expanded recycling and or treatment facilities. Table 4 explains of the waste-management concerns that arise once the capital project becomes operational.
Planning for capital-project decommissioning (including asset retirement) has historically been done to meet facility operating requirements, often in response to a sudden need for the facility to ratchet down its operating parameters to accommodate production decreases. The industry has recently begun to initiate asset retirement in a more planned and proactive fashion. As a result, wastes related to decommissioning and asset retirement require more advanced planning and earlier management, while the waste-generation rate peaks at a lower rate. Table 5 lists some considerations related to decommissioning.
Waste management is generally not viewed as a “make or break” item for capital projects. However, if not managed correctly, it can be a major frustration and distraction to the team leads, resulting in lost time and efforts to correct problems that arise. Waste management can also create a loss in value to the project, and in many instances can be a very costly liability, if not managed correctly. Risk assessment, and transitioning lessons learned from one phase to another can reduce this liability. A well-structured and communicated waste-management philosophy can go a long way toward reducing risk and costs.
Understanding local laws and requirements, and coordinating contractors through detailed BOD and ITT packages can also be a risk reducer. Understanding the local area infrastructure abilities and planning well in advance for treatment and disposal options can, in the long run, save time and expenses when dealing with waste generation.
Finally, demobilization is a key factor in a project’s overall waste strategy. A large volume of waste, with large volumes of hazardous waste, can result from demobilization of facilities once construction is finished. Making sure these waste streams are accounted for in the design of the waste program can reduce liability and overall risk once the project is completed. ■
Edited by Mary Page Bailey
1. American Petroleum Institute (API), Environmental Guidance Document: Waste Management in Exploration and Production Operations, Publication No. API E5, 2nd Ed., Exploration and Production Department, American Petroleum Institute, Washington, D.C., Feb. 1997.
2. IPIECA, Petroleum Refining Water/Wastewater Use and Management, Operations Best Practice Series, 2010.
3. Environmental Protection Agency (EPA), Final Standards Promulgated for Petroleum Refining Waste, EPA 530-F-98-014, 1998.
4. API, Manual of Disposal of Refinery Wastes, Volume on Solid Waste Refinery Department, 1980.
5. API, Manual of Disposal of Refinery Waste Volumes on Liquid Wastes, Publ. 931 C18, 1975.
6. API, The Generation and Management of Wastes and Secondary Materials in the Petroleum Refining Industry, API Pub No. 4530, 1991.
7. International Finance Corp. (IFC), Environmental, Health and Safety Guidelines for Petroleum Refining, World Bank Guidelines, 2007.
Frederick V. Jones is a technical director with Environmental Resources Management (ERM; 840 West Sam Houston Parkway North, Suite 600, Houston, TX, 77024; Phone: (832) 730-4381; Email: email@example.com). Jones works with companies to develop HSE management systems, capital projects, regulatory compliance, ESHIA, waste- and water-management programs, and environmental support of projects and production operations to achieve lower corporate exposure and liability, reduce costs and achieve regulatory compliance. Jones has 35 years of experience in oil and gas drilling, production and project development and operations.
Susan Rankin is a senior consultant with ERM (same address as above; Phone: (832) 209-8827; Email: firstname.lastname@example.org). Rankin has over 20 years of experience in the environmental industry, both as consultant and as client in industry and government. Rankin has extensive experience with industrial and municipal waste management, including: initial project scoping; waste-stream identification; characterization and inventory development; facility siting and permitting; project development and FEED; and as project engineer during construction, commissioning and operations oversight.
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