ENVIRONMENTAL RULES MAKE SCRUTINY OF RIG WORK PRACTICES A MUST
John Candler
M-1 Drilling Fluids Co.
Houston
Mention environmental regulations and visions of big chemical plants come to mind. The words "hazardous waste" bring images of 55-gal drums brimming with noxious chemicals.
These terms also apply to oil field rig site operations, but not in such obvious manners.
Some common oil field practices are illegal according to existing environmental regulations. On the surface some of these regulatory violations seem minor, but they can lead to serious trouble for an operator or the drilling foreman on location.
By understanding how environmental regulations affect operations, a company can stay out of trouble while continuing to operate and meet business goals.
Most presentations concerning regulatory affairs start by discussing a major federal regulation like the Resource Conservation and Recovery Act (RCRA) and then give examples of how the regulation might apply to a particular field operation. Such presentations may not adequately address common situations on a rig site.
The people who conduct day-to-day activities in the field are faced with the direct responsibility of maintaining compliance, often with little or no knowledge about environmental regulations. In the field, environmental regulatory issues do not come neatly packaged as solid waste problems covered under RCRA.
Many industry people readily acknowledge that environmental regulations are confusing and often overwhelming. Unfortunately, this does not relieve the responsibility of compliance. Environmental programs must address everyday practices in the field and give field personnel a means to answer environmental questions quickly and effectively.
Here are some common and typical questions about environmental regulations and some day-to-day practices that have been standard operating procedures for many years.
BURNING PIT
You relieve a drilling foreman in a remote south Texas location where the crew has been burning household trash in an open pit. In addition to waste from the living quarters, you notice rig site personnel are also burning other waste generated at the rig, such as empty paper sacks from drilling fluid products, used oil, and empty plastic buckets.
Based on the regulations in Texas, what should you do?
(A) Stop all open burning at the rig site, and haul all waste to the nearest landfill which is 30 miles away.
(B) Continue burning household garbage, but haul the other wastes to the landfill.
(C) Continue the practice without changing anything.
Texas Regulation I controls the open burning of waste. In the first paragraph of the regulation there is a general prohibition of outdoor burning, but the rest of the regulation is devoted to outlining the exceptions to the prohibition.1
If you answered "A," then you have clearly met the regulations. According to the state headquarters of the Texas Air Control Board (TACB), the only material allowed for open burning at the rig site is dry vegetation cleared from the location during construction.2
If you answered "B," then you still have met the regulatory requirements in south Texas. A local TACB inspector stated that he has seen open burning in the oil field done legally in some cases and illegally in other cases; the determining factor was the type of material being burned. The burning of household waste is acceptable; however, burning industrial waste such as asphaltic materials is not acceptable and has earned at least one operator a citation.3
If you answered "C," then you were in violation of Texas regulations unless you received permission from the local TACB office before you began the operation.
This situation demonstrates the difficulty with applying pollution regulations to actual day-to-day operations.
DISPOSAL IN RESERVE PIT
A deep well reached total depth and was found to be a dry hole. After plugging the well, rig-down operations began. The drilling fluid company picked up all of the unused drilling fluid products except for a few broken sacks of chrome lignite and chrome lignosulfonate. The rig hands then threw the broken sacks of material into the reserve pit while they cleaned up the rig site.
Did this disposal practice violate any state or federal disposal regulations?
Yes, according to RCRA. Only certain types of oil field wastes are exempt from hazardous waste laws. Some of these exempt wastes include drilling mud and cuttings, whereas other wastes not exempt from hazardous waste laws include spilled chemicals and contaminated products. Therefore, broken sacks of chemicals are not exempt from the hazardous waste law RCRA.
Another alternative to dumping into the reserve pit, the sacks could have been disposed of as hazardous waste; however, this option can become expensive. The most efficient disposal method for the broken sacks would have been to try to properly use the chemicals in the mud system while the well was drilled. Most importantly, the sacks could have been better protected to ensure that they would not be damaged prior to use.
UNANNOUNCED INSPECTION
In the previous example, one of the rig crew is run off because he failed a drug test. The employee becomes angry and complains to the state about the disposal of products thrown into the reserve pit. An inspector shows up at the location the next day and observes the rig hands throwing broken sacks of products into the reserve pit.
Which of the following options is available to the inspector?
(A) He can instantly declare the area an environmental disaster zone and start criminal proceedings.
(B) He can sample all of the waste in the reserve pit and have it classified as hazardous waste if it exceeds the Toxic Characteristic Leachate Procedure (TCLP) limits.
(C) He can sample only the broken sacks of products and have them classified as hazardous waste.
(D) He has no authority to enter your location.
"B" is the correct answer. The relatively small problem of a few sacks of hazardous waste has become a much bigger problem involving the entire reserve pit. According to an American Petroleum Institute (API) environmental guidance document, deliberately commingling nonexempt waste with exempt waste could result in the entire waste stream losing its exempt status. Therefore, the entire reserve pit should be tested according to TCLP guidelines. If the reserve pit exceeds the hazardous waste limitations, the entire reserve pit might have to be disposed of as hazardous waste.4
Obviously, as the volume of hazardous waste becomes larger, the cost and difficulty of disposal increases. A good course of action is to determine which fluid additives on location can be classified as hazardous waste and then to take steps to segregate these materials from the nonhazardous waste.
USED MOTOR OIL
You are using a diesel oilbased mud to drill a deep well in western Oklahoma, and the cuttings are solidified on site using a new fixation process. During the course of the well, used oil from the diesel engines on the rig is poured into the mud system. In addition, used cleaning solvents and used hydraulic fluids are also added to the mud system.
Are the cuttings generated at this drilling operation exempt from the hazardous waste laws?
No. Nonexempt wastes (used oil, solvents, hydraulic oil) mixed with exempt waste (mud and cuttings) can cause mud and cuttings to lose their exemption and be considered hazardous waste under subtitle C of RCRA. Additionally, the cuttings solidification process could be considered unpermitted treatment of hazardous waste, and where the solidified waste material is placed on the ground could be considered an unpermitted hazardous waste landfill. Just because the waste lost its exemption, it does not necessarily become hazardous waste. However, the waste must be analyzed to determine if it exceeds any of the characteristic hazardous waste limits of corrosivity, flammability, reactivity, or toxicity according to TCLP.4
Alternatively, you can protect the RCRA exemption for the drilling fluid and cuttings by possibly recycling used oils and solvents instead of disposing them into the mud pit. Otherwise the nonexempt oil field waste must be treated as potentially hazardous waste and analyzed and disposed of according to state and federal regulations.
SUPERFUND INVESTIGATION OF PIT
Once again you are drilling a well in western Oklahoma using an oil-based mud. Having learned your lesson in the last example, you carefully protect the RCRA exemption and make sure that only oil mud products are added to the mud system.
After completing the well, you close the solidified waste pit according to current state regulations. Two years later the state receives a complaint about drinking water in the area.
The Environmental Protection Agency (EPA) determines that your reserve pit is the most likely cause of the problem and starts a Comprehensive Environmental Responses, Compensation, and Liability Act, or Superfund, site investigation.
Is your company responsible for paying for the investigation and remediation of this location?
Yes. Complying with current state and federal disposal laws does not protect you from Superfund liability. The average Superfund cleanup is estimated to cost $50 million. When making decisions about waste disposal, it is important to consider the long-term liability as well as the short-term cost of a particular disposal method.'
Alternatively, consider a disposal technology that will destroy or recycle the waste. Furthermore, use the least toxic products available so that the waste you generate will not become a health hazard.
RIG WASH WATER
During a long, involved fishing operation, several round trips are made at a depth of 13,000 ft. After finally retrieving the fish, drilling resumes. The tool pusher tells the driller that the rig needs to be washed down.
The rig hands get to work and soon rig wash water is flowing into the reserve pit.
The wash water contains some oil and grease from the machinery on the rig.
Do you have to analyze the pit to see if it exceeds RCRA limitations for hazardous waste because it may have lost its RCRA exemption?
No. Rig wash water is an exempt waste under the RCRA hazardous waste law. Therefore, its addition to the reserve pit does not cause the reserve pit to lose its exempt status.4
CHOOSE THE PROPER AGENCY
Once again you are drilling in Oklahoma. This time, however, you are sure you have learned your lesson from previous examples. You are ready to dispose of a small quantity of hazardous waste generated at the rig site.
Which governmental agency should you call to ask about the disposal of this hazardous waste in Oklahoma?
(A) The Oklahoma Corporation Commission
(B) The Oklahoma State Department of Health
(C) The Environmental Protection Agency.
The correct answer is "A." In Oklahoma, the regulation of hazardous and nonhazardous waste generated at the well site is the responsibility of the Oklahoma Corporation Commission.6
In Texas, hazardous waste is the responsibility of the Texas Water Commission, and nonhazardous waste is handled by the Texas Railroad Commission.7
In Louisiana, hazardous waste is handled by the Department of Environmental Quality, and nonhazardous waste is controlled by the Department of Natural Resources/Office of Conservation.8 Many environmental regulations are written in vague terms and need interpretation.
Sometimes the interpretation of the regulation differs from area to area even within a state or region.
The best approach to solve this problem is to read the regulation and then consult with the local regulatory office to determine how the regulation applies to your operation.
STORM WATER RUNOFF
You are planning to spud a well in south Louisiana on Nov. 19, 1991. Because your company is concerned about the long-term liability, it has decided to remove all of the mud and cuttings from the location for treatment and disposal. It has also decided to collect and treat rig wash and other contaminated water from the location. However, the location will be very large and you expect uncontaminated storm water to be discharged while the well is drilled.
Do you need a permit to discharge uncontaminated storm water?
Probably yes. Louisiana is in the process of completing state regulations concerning waste water generated at the rig site. One of the provisions of the new regulations requires that all storm water discharges from a location have a water permit.9 After Nov. 18, 1991, the new federal storm water regulation will cover all drilling and production operations in the U.S.10
Another option in this situation is to collect the storm water and dispose of it off site in an injection well or at a waste water treatment plant.
HAULING BROKEN SACKS
You have just finished drilling a well in east Texas. The mud company has picked up the unused materials and left a few broken sacks of chrome lignosulfonate at the rig site.
You call up the mud company and tell them to come pick up the rest of the material, but the mud company explains that they cannot accept hazardous waste generated at the rig site because they are not licensed to handle or treat hazardous waste.
If you are going to dispose of hazardous waste generated at the rig site, do you need to obtain a hazardous waste generator number?
Yes. EPA generator numbers are site specific; thus, you need to obtain one if you are going to dispose of hazardous waste from the rig site. Contractors and service companies do not need generator identification numbers for their rig site operations because the EPA does not issue "traveling" generator numbers."
An alternative course of action for the drilling foreman is to require service companies to operate in a manner that will minimize or eliminate hazardous waste generation. This includes careful handling of chemicals during loading and off-loading. The materials can be stored in a weatherproof mud house to prevent damage to hazardous drilling fluid additives.
If a damaged or contaminated product can be recycled by the drilling fluids company, the material can be taken back by the service company.
Making service companies remove hazardous waste generated at the rig site is illegal unless the service company is a licensed waste hauler.
WASTE STRATEGY
After attending a big conference on environmental issues you return to your operation and calculate the costs associated with strict compliance with environmental regulations. You inform your boss of your findings and ask him what to do. He tells you that the company policy states that you must comply with all the applicable environmental regulations, but you cannot have any additional personnel to work on compliance due to a hiring freeze.
How do you comply with a maze of environmental regulations covering drilling operations and continue to operate a profitable company?
One successful approach concerning waste generated at the rig site is called an area waste-management plan.
An outline of a typical plan, as written by C. T. Stilwell, can be found in Table 1.12 The best method to deal with regulatory problems is to use these guidelines to develop your own system of waste management and regulatory compliance specifically suited to your needs. Such a plan can eliminate some of the regulatory confusion for personnel at the rig site.
REFERENCES
- "Texas regulation 1: Control of air pollution from visible emissions and particulate matter," Texas Administrative Code, Title 31, Part III, amended effective Feb. 7, 1990, Chapter 111.
- Phone conversation with Dave Hendrichs, Texas Air Control Board, Austin, January 1991.
- Phone conversation with Felix Zapata, Texas Air Control Board, Region 4, January 1991.
- "Onshore solid waste management in exploration and production operations," API Environmental Guidance Document, 1st edition, Jan. 15, 1989.
- Zagata, Michael D., "The RCRA exemption for oil and gas: Panacea or time bomb," Petroleum Independent, August 1989, p. 18.
- Phone conversation with Bob Slaby, Oklahoma Corporation Commission, Oklahoma City, January 1991.
- Phone conversation with Lori Wrotenbery, Texas Railroad Commission, Austin, January 1991.
- Phone conversation with Carrol Wascomb, Louisiana Department of Natural Resources/Office of Conservation, Baton Rouge, January 1991.
- "Proposed rule: Exploration for and production of oil and natural gas," Title 33: Environmental quality, Part IX, Dec. 20, 1990, Chapter 7, Section 708.
- "National pollutant discharge elimination system permit application regulations for storm water discharges-final rule," Federal Register, Vol. 55, No. 222, Nov. 16, 1990, p. 47990.
- "Notification of hazardous waste activity," EPA form 8700-12, October 1988.
- Stilwell, C.T., "Area waste-management plans for drilling and production operations," Journal of Petroleum Technology, January 1991, p. 67.
Copyright 1991 Oil & Gas Journal. All Rights Reserved.