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Offshore Discharge of Drilling Fluids and Cuttings -A Scientific Perspective on Public Policy H

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Offshore Discharge of Drilling Fluids and Cuttings -A Scientific Perspective on Public Policy H IBP44900 OFFSHORE DISCHARGE OF DRILLING FLUIDS AND CUTTINGS -A SCIENTIFIC PERSPECTIVE ON PUBLIC POLICY H. R. Melton1, J. P. Smith1, C. R. Martin1, T. J. Nedwed1, H.L. Mairs1, D. L. Raught1 Copyright 2000, Brazilian Petroleum Institute - IBP This paper was prepared for presentation at the Rio Oil & Gas Conference held in Rio de Janeiro, Brazil, 16-19 October, 2000 This paper was selected for presentation by the Event Technical Committee following review of information contained in an abstract submitted by the author(s). Contents of the paper, as presented, have not been reviewed by the IBP. Organizers will neither translate nor correct texts received. The material, as presented, does not necessarily reflect any position of the Brazilian Petroleum Institute, its officers, or members. Abstract The most effective regulations or public policies are developed cooperatively by government and industry based on sound scientific understanding of the potential impacts, risk considerations, and evaluation of the costs and benefits of alternative approaches. This paper reviews the scientific framework that helped achieve general regulatory acceptance of the discharge of water-based drilling fluids and cuttings and discusses information being considered in current efforts to develop policies for the discharge of cuttings drilled with non-aqueous fluids (NAF). Development of effective policies for discharges depends on consideration of the specific local environmental conditions that govern the fate of discharge materials, the scientific basis for assessing the potential for effects in that environment, and balanced consideration of the environmental effects and relative costs of discharge versus other disposal options. This approach can lead to policies that provide for environmental protection and encourage adoption of mitigation measures that provide benefits commensurate with their cost. 1. Introduction Scientific research provides a basis for development of effective policies governing discharge of drilling fluids and cuttings. This paper discusses the results of research on the effects of the discharge of drilling fluids and cuttings, the consideration of site-specific information in the environmental assessment of discharges, and the comparative evaluation of alternative drilling fluids and cuttings disposal options. This information has provided a framework for achieving general regulatory acceptance of the discharge of water-based fluids and cuttings and is providing useful information for current efforts aimed at developing policies for the discharge of cuttings drilled with NAF. The balanced consideration of research results, local environmental conditions, and the costs and benefits of disposal alternatives offers the most cost-effective way of achieving demonstrable environmental benefits. 2. Scientific Evaluation of Environmental Aspects of Drilling Wastes During the past twenty years, a scientific framework has been developed to evaluate the fate and effects of discharges into the marine environment. The key elements of this framework include _____________________________ 1 PHD, Chemical Engineering - ExxonMobil Upstream Research Company 2 PHD, Physical Chemistry - ExxonMobil Upstream Research Company 3 BS, Chemical Engineering, Business Administration - ExxonMobil Upstream Research Company 4 PHD, Environmental Engineering - ExxonMobil Upstream Research Company 5 MS, Ocean Engineering - ExxonMobil Production Company 6 BS, Civil and Environmental Engineering - ExxonMobil Upstream Development Company IBP44900 characterization of effluent composition and volume, assessment of potential for effects of discharges, and field monitoring. Selected examples of results from this effort are discussed below to provide the key information about the composition and environmental effects of discharged drilling wastes. 2.1 Characterization of Drilling Waste Volume and Composition Drilling wastes comprise drilling fluids and drill cuttings. There are two basic types of drilling fluids: water-based fluids (WBFs) and non-aqueous fluids (NAFs). WBFs have either fresh water or salt water as the primary fluid phase, while NAFs have either refined oil or synthetic materials as the primary fluid phase. For many wells, drilling conditions (e.g. deviated or horizontal wells, active shales) often require the use of NAFs instead of WBFs for efficient, cost-effective operations. In most cases, both WBFs and NAFs are used in drilling the same well, with WBFs used to drill the shallow portion of the well. Drill cuttings are pieces of the formation being drilled that are returned to the surface with drilling fluid. Solids control equipment separates the cuttings from the drilling fluids so that the drilling fluid can be reused. The cuttings then become a waste stream from the drilling process. A thin coating of drilling fluid adheres to the cuttings. Cuttings volumes depend on the type of fluid used, the depth of the well, and the size of the borehole. Estimated volumes per well range from 130 to 560 m3 per well (Hinwood, et al., 1994, USEPA, 1993). WBF may be discharged intermittently during the drilling process in batches of about 20 to 30 m3 volume or in larger volumes (approximately 200 m3) at the end of the drilling process or when the fluid system is changed out. The estimated volume of WBF discharges per well ranges from 500 to 1700 m3 per well. When NAFs are used, only the fluid that adheres to the cuttings is discharged. The valuable fluid is recycled for further use. WBF consists of water, salts, barite, bentonite and other minor additives. WBF composition depends on the density of the fluid. An example WBF composition for a 1190 kg/m3 fluid is (in wt %) 76 wt% water, 15% barite, 7 % bentonite and 2% salts and other additives (National Research Council (US), 1983). The barium in barite, a sparingly soluble mineral used to increase drilling fluid density, dominates the heavy-metal content of wastes from drilling with either WBF or NAF. Other trace metals are present at much lower concentrations. Neff (1988) compared the ranges of concentrations of metals found in drilling fluids and marine sediments and found that drilling fluids had concentrations of barium and chromium that fell outside the observed range naturally occurring in marine sediments. NAF consists of an organic base fluid, barite, water or brine, and specialty additives. NAF composition depends on fluid density. The United States Environmental Protection Agency (USEPA) (1999a) presented an example NAF composition of (in wt%) 47% base fluid, 33% barite, and 20% water. This example does not reflect a 2-5% content of additives such as fluid loss agents and emulsifiers that would be used in a NAF. NAFs are classified according to the type of base fluid used. Base fluids are in turn classified by their source and polycyclic aromatic hydrocarbon (PAH) content. Base fluids include oil based fluid (1-2 % PAH), low toxicity mineral oil based fluid (0.001% < PAH < 0.35%), enhanced mineral oil based fluid (PAH <0.001%), and synthetic based fluid (SBF, PAH <0.001%). The oil-based fluid category includes diesel oil based fluid and mineral oil based fluid. The low toxicity mineral oil based fluid includes materials refined from crude oil. Enhanced mineral oil based fluids and SBF are derived from different base materials, but 2 IBP44900 both have very low PAH contents. Enhanced mineral oil based fluid comprises materials refined from crude oil whereas SBF comprises material generated by chemical reactions of relatively pure compounds including synthetic hydrocarbons. Because the heavy metals in barite are the main influence on the metals content of drilling wastes, the heavy-metal content of NAF and NAF cuttings should be very similar to those of WBF drilling wastes. 2.2 Assessment of Potential for Effects from Discharges The potential for environmental effects from drilling fluids and cuttings discharges is assessed through laboratory studies of toxicity and evaluation of bioaccumulation. Toxicity testing is a measure of the relative potential for direct adverse effects on marine organisms. Evaluation of bioaccumulation addresses the potential for uptake of waste components into marine organisms. The results of toxicity and bioaccumulation evaluations are useful when assessing the potential for environmental exposures with site-specific numerical modeling studies. 2.2.1 Toxicity Bioassay testing of drilling fluids focuses on the toxicity of whole drilling fluid or of individual drilling fluid components added to a base drilling fluid. Bioassays of whole drilling fluids permit the assessment of potential effects of materials actually discharged from drilling operations. Research has shown that bioassay test results for individual components might be considerably different from bioassay test results obtained on those same components in an actual drilling fluid (Sprague and Logan, 1979). Species for regulatory testing were chosen after assessing the sensitivity of a wide range of organisms. By 1983, the toxicity of water-based drilling fluids to 62 different species of marine animals from the Atlantic and Pacific Oceans, the Gulf of Mexico, and the Beaufort Sea (National Research Council (US), 1983) had been determined. USEPA chose one of the more sensitive crustacean species, Mysidopis bahia, as the standard organism for drilling fluid bioassays as part of its implementation of a toxicity limit on drilling fluid discharged to United States waters. US experience shows that discharged WBF will
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