remedy selection for solid drilling waste
TRANSCRIPT
Remedy Selection for Solid Drilling Waste
Jeffrey Tyson, P.E., M.ASCE,Scott Environmental Services, Inc.
Remedy Selection for Solid Drilling Waste
Jeffrey Tyson, P.E.Scott Environmental Services, Inc.
Oil and Gas Environmental ConferenceDecember 2015
• What is Solid Drilling Waste?
• Regulation of Solid Drilling Waste
• Waste Management Methodologies
• Summary and Questions
What is Solid Drilling Waste?
According to API, drilling waste is the rock cuttings and fluids that are produced from drilling a new wellbore into the subsurface.1
1http://www.api.org/~/media/files/ehs/environmental_performance/icf-waste-survey-of-eandp-wastes-2000.pdf?la=en
• 1.21 barrels of drilling waste are generated for every foot drilled1
• In Scott’s Experience, one-half of this is solid drilling waste
• Over 196,000,000 barrels of solid drilling waste estimated from U.S. land drilling during 2014
1http://www.api.org/~/media/files/ehs/environmental_performance/icf-waste-survey-of-eandp-wastes-2000.pdf?la=en
• 2014’s solid waste alone would fill AT&T Stadium over 10 time
http://attstadium.com/
Constituents of Potential Concern (COPCs)• Salts• Heavy Metals• Hydrocarbons• VOCs• Sodium• High/Low pH• Sulfates/Sulfides• TENORM
Variability of COPCs• The characteristics of the waste can vary
drastically from well to well, and;• The characteristics of the waste can vary
drastically throughout a single well• Proper sampling and analysis of the waste are
required to maximize the efficiency and reliability of selecting an appropriate remedy
Regulation of Solid Drilling Waste
1976 19891976 1978 1980 1982 1984 1986 1988
EPA publishes proposed waste management standards; temporarily exempts E&P wastes from Subtitle C pending further analysis12/18/1978 EPA submits reports to
congress for E&P wastes1,2,3
12/1/1987
Resource Conservation and Recovery Act10/21/1976
Congress enacts Solid Waste Disposal Act with Bentsen Amendment.
10/12/1980
EPA issues its regulatory determination for E&P wastes4
7/6/1988
1. http://www3.epa.gov/epawaste/nonhaz/industrial/special/oil/530sw88003a.pdf2. http://www3.epa.gov/epawaste/nonhaz/industrial/special/oil/530sw88003b.pdf
3. http://www3.epa.gov/epawaste/nonhaz/industrial/special/oil/530sw88003c.pdf4. http://www3.epa.gov/epawaste/nonhaz/industrial/special/oil/og88wp.pdf
• Solid drilling waste is exempt from RCRA Subtitle C –Hazardous Waste regulations
• Solid drilling waste is subject to regulation under the Clean Air Act (CAA), Clean Water Act (CWA), Safe Drinking Water Act (SDWA), Oil Pollution Act of 1990 (OPA), and many other State and Federal requirements
1. http://www3.epa.gov/epawaste/nonhaz/industrial/special/oil/oil-gas.pdf
“Certain exempt wastes, while excluded from RCRA Subtitle C hazardous wastes control, might still be harmful to human health and the environment if not properly managed…”1
Drilling Waste Management
1. http://www3.epa.gov/epawaste/nonhaz/industrial/special/oil/oil-gas.pdf
“Prudent waste management decisions, even for nonhazardous wastes, should be based on the inherent nature of the waste. Not all waste management options are appropriate for every waste.”1
http://www2.epa.gov/sites/production/files/2015-07/documents/rom.pdf
http://www2.epa.gov/sites/production/files/2015-07/documents/rom.pdf
Source Reduction
• Reduces or eliminates the generation of waste at the source and refers to any practice that reduces the use of hazardous materials in production processes.
Source Reduction• Reduce generated volume via well design• Reduce COPCs via mud design• Implement rigorous solids control plan
http://www.drillingcontractor.org/monobores_can_save_money_upfront_but_life_cycle_costs_must_be_considered-875
http://gnsolidscontrol.com/video/vertical-cuttings-dryer-water-based-mud-drilling-waste
http://www.derrickequipment.com/webmodules/catCatalog/dtl_Product.aspx?ID=6
Source Reduction• When evaluating source reduction and re-use
techniques, be sure to view the entire system as a whole to account for total impacts as well as total costs and liability. Often times a change in one part of the system will affect something else within that system.
http://www2.epa.gov/sites/production/files/2015-07/documents/rom.pdf
Recycling• Recycling involves processing a material into a new
product• Various forms of recycling exist for solid drilling
waste
Recycling• Embankment/Fill Material• Road Base• Dust/Erosion Control• Engineered Load-Bearing
Structures
http://www.usroads.com/journals/rmej/9806/rm980604.htmhttp://onlinemanuals.txdot.gov/txdotmanuals/pdm/images/figure_2.1.gif
Recycling“[T]here are some cases in which individuals or companies mayattempt to circumvent legitimate waste management regulations orlaws by "sham recycling" in order to avoid costly waste managementrequirements (e.g., some wastes are recycled for end uses with littlevalue solely to avoid complex and expensive hazardous wastemanagement rules).1”
- Drilling Waste Management Information System
1. http://web.ead.anl.gov/dwm/techdesc/reuse/index.cfm
• What is the initial physical and chemical composition of the waste?
• What will the end product be used for?• Where will the end product be used?• What specifications will be followed
during processing?• What Quality Control Procedures will
be used during processing?• Does the end product have value?• Is the end product appropriate for the
intended use?• Who are the end users?• Will my waste be mixed with other
wastes?• What will the final volume be in
relation to the initial volume?
• What are the overall land impacts associated with the treatment technique?
• How will success of the treatment technique be evaluated?– What parameters will be tested?– What test methods will be used?– What are the regulatory/permit
requirements? • If the process is not successful, how
will the waste be managed from that point?
• How does this affect liability?• What are the overall costs? • Does this method protect human
health and the environment?
Recycling
Composting
• Composting is a form of bioremediation designed such that the end result, called compost, can be used as a soil conditioner
• Generally limited to organic constituents
http://www.earthday.org/takeaction/images/compost1.jpghttp://www2.vermeer.com/vermeer/images/1/6008/floating/CT718_Bell%20County%20TX_Action3_Final.jpg
• What is the initial physical and chemical composition of the waste?
• What will the end product be used for?
• Where will the end product be used?
• Are there inorganic constituents of concern present in the waste, and how will they be managed?
• Will my waste be comingled with other wastes?
• What specifications will be followed during the process?
• What Quality Control Procedures will be used during processing?
• How will success of the process be evaluated?
• If the process is not successful, how will the waste be managed from that point?
• How does this affect my liability?• What are the overall costs?• Does this method protect human
health and the environment?
Composting
http://www2.epa.gov/sites/production/files/2015-07/documents/rom.pdf
Energy Recovery
“Energy recovery from waste is the conversion of non-recyclable waste materials into useable heat, electricity, or fuel through a variety of processes, including combustion, gasification, pyrolization, anaerobic digestion, and landfill gas (LFG) recovery.1”
1. http://www3.epa.gov/epawaste/nonhaz/municipal/wte/
Energy Recovery• Thermal Desorption evaporates organic constituents from
the waste for recovery and re-use
http://www.heat-inc.com/Heating_Industry_Applications/ThermalDesorption.html
Energy Recovery• Incineration
– Waste is used as fuel, organic constituents are destroyed
http://www.sswm.info/sites/default/files/toolbox/EISENMANN%20%20and%20GEC%20ny%20Fluidised%20Bed%20Incinerators.jpg
• What is the energy input required?• What potential air emissions are
involved?• What specifications will be followed?• What Quality Control procedures
will be followed?• How will the recovered material or
energy be used?• What is the value of the recovered
energy or material?• What concentration of other
constituents will remain?
• What secondary management technique will be used on the remaining material?
• How will success be evaluated? • How does this affect my liability?• What are the overall costs?• Does this method protect human
health and the environment?
Energy Recovery
http://www2.epa.gov/sites/production/files/2015-07/documents/rom.pdf
Treatment and Disposal“Treatment involves changing a waste’s physical, chemical, or biological character or composition through designed techniques or processes.”
http://www3.epa.gov/epawaste/nonhaz/industrial/special/oil/og88wp.pdf
Treatment and Disposal“Land disposal means placement in or on the land[…] and includes, but is not limited to, placement in a landfill, surface impoundment, waste pile, injection well, land treatment facility, salt dome formation, salt bed formation, underground mine or cave, or placement in a concrete vault, or bunker intended for disposal purposes.”
http://www3.epa.gov/epawaste/nonhaz/industrial/special/oil/og88wp.pdf
• What is the initial physical and chemical composition of the waste?
• Will the waste be processed prior to burial?• What is the geography of the surrounding soils?• How will groundwater be affected?• What specification will be followed during burial?• What quality control procedures will be followed?• What will the area above the pit be used for in the
future?• How does this affect my liability?• What are the overall costs?• Does this method protect human health and the
environment?
On-site Burial
• What is the initial physical and chemical composition of the waste?
• What are the current and future uses for the land?
• How will groundwater be affected?• How will soil properties be affected?• What specification will be followed?• What quality control procedures will be
followed?• What test methods and procedures will be
used?• Who owns the land?• How does this affect my liability?• What are the overall costs?
• Does this method protect human health and the environment?
Land Application
http://gangsterenterprises.com/Users/gschlachter/Sites/Gangster%20Web/_Media/fieldlandsreadingvacuumtruc_med_hr.jpeg
• Where is the closest landfill in regards to where the waste is generated?
• Can the landfill accept industrial waste?
• Does the landfill have a history of compliance issues?
• How will the waste be transported from the generating site to the landfill?
• Will the waste require any treatment prior to disposal at a landfill?
• What affects will trucking have on the community?
• Will my waste be comingled with other wastes?
• How will my waste be tracked within
the landfill?• What are the closure and post-closure
requirements of the landfill?• What is the financial assurance of the
landfill? • How does this affect my liability?• What are the overall costs?• Does this method protect human
health and the environment?
Landfill Disposal
http://dev.akkuarios.com/demos/cetco1/CCS/images/Applications/ACUA%203.JPG
• Drilling waste is generated in extremely large volumes• Physical and chemical characteristics can vary drastically for
different waste streams and within a single waste stream• Proper characterization is a fundamental step in remedy selection• Appropriate remedies should:
– Meet all applicable regulations and, – Protect human health and the environment
• Not all remedies are appropriate for all wastes
