; US Environmental Protection Agency SBF Effluent Limitation Guidelines
Documents
Resources
Learning Center
Upload
Plans & pricing Sign in
Sign Out
Your Federal Quarterly Tax Payments are due April 15th Get Help Now >>

US Environmental Protection Agency SBF Effluent Limitation Guidelines

VIEWS: 62 PAGES: 14

  • pg 1
									U.S. Environmental Protection Agency SBF Effluent Limitation Guidelines

Presented to the OCS Policy Committee October 25, 2000

Overview of SBF Rulemaking
• Since 1990, the oil and gas industry developed SBFs to provide the drilling performance of traditional oil-based fluids (OBFs) but with lower environmental impact and greater worker safety.

 In 1998, EPA initiated an expedited rulemaking to foster Industry development and use of SBFs as a pollution prevention technology while allowing the discharge of waste solids containing less toxic and persistent materials. A proposal was published in the Federal Register on February 3, 1999 (64 FR 5488) as was Notice of Data Availability on April 21, 2000 (65 FR 21548).  Since proposal, EPA has worked with Industry stakeholders to compile engineering, economic, and analytical data concerning use of SBFs and identify possible technology options.  EPA is required by a court order to complete its analyses and finalize the guidelines by December 2000.
October 25, 2000 OCS Policy Committee Meeting 2 of 14

SBF Rulemaking Participants
• Current SBF Rulemaking Participants include: EPA Office of Research (Gulf Breeze Lab, FL), EPA Regions 4,6,9, and 10 (GOM, California, Alaska), Department of Energy, Minerals Management Service, American Petroleum Institute, National Ocean Industries Association, Individual Stakeholder Companies Cook Inlet Keeper Cook Inlet Regional Citizens Advisory Council

October 25, 2000

OCS Policy Committee Meeting

3 of 14

SBF Rulemaking Participants
Industry Work Groups include:
• Analytical - Reverse Phase Extraction (offshore), GC/MS (onshore confirmatory) for formation oil contamination • Biodegradation - Solid Phase Test, Anaerobic Closed Bottle Test, Respirometer Test • Sediment Toxicity - Solid phase (sediment) test with amphipod, Leptocheirus plumulosus, Sediment-water inter-phase test with mysid shrimp • Seabed Survey (GOM) – Shallow and Deepwater SBF well sites • Technology Assessment - Best Management Practices (BMPs), Cuttings Retention Data
October 25, 2000 OCS Policy Committee Meeting 4 of 14

SBF Rulemaking Participants
Summary of Stakeholder Meetings since February 1999:
• • • • • • • • • • Proposal Public Meeting Stakeholder Meeting Stakeholder Meeting Industry Stakeholder Mtg. Stakeholder Meeting Stakeholder Meeting Draft NODA Review NODA Public Meeting Stakeholder Meeting Stakeholder Meeting
October 25, 2000

March 17, 1999 July 22, 1999 August 26, 1999 October 28, 1999 November 18, 1999 January 27, 2000 March 9-16,2000 April 25, 2000 July 20, 2000 October 12, 2000

Houston, TX Washington, DC Washington, DC New Orleans, LA Washington, DC Washington, DC Washington, DC New Orleans, LA Washington, DC Washington, DC
5 of 14

OCS Policy Committee Meeting

Final Rule Overview
• EPA divided the SBF discharges into two categories: - SBF discharges associated with cuttings (large volume) - All other SBF discharges (small volumes, mostly spills)

•

EPA evaluated three technology options for SBF-cuttings wastes: (1) Use of advanced solids control equipment and allow controlled discharges; (2) same as (1) but with some of the cuttings wastes (fines) captured for no discharge; and (3) no discharge of any cuttings wastes. EPA evaluated two technology options for all other SBF wastes: (1) no discharge; and (2) use of best management practices (BMPs) to control SBF discharges.

•

October 25, 2000

OCS Policy Committee Meeting

6 of 14

Final Rule Overview
SBF-Cuttings Technology Options
Well SBF Returned to Active System

SBF and all cuttings

Primary S.S. SBF and smaller cuttings Secondary S.S. SBF and fines Wet Cuttings Cuttings Dryer * SBF and fines

Fines Removal **

* Mud10, Vertical Centrifuge, Squeeze Press Centrifuge ** Mud Cleaner or Centrifuge

"Dried Cuttings" Discharge (approx. < 5%)

Fines Discharge (approx. >10%)

October 25, 2000

OCS Policy Committee Meeting

7 of 14

Final Rule Overview
• EPA rejected the zero discharge option for SBF-cuttings in all Offshore waters based on the increase of discharged pollutants and non-water quality environmental impacts (NWQIs) due to more anticipated use of WBFs and OBFs.



NWQIs include air emissions, fuel usage, land disposal requirements, worker safety, spills, and environmental justice issues. Under the zero discharge option for SBF-cuttings a majority of operators would switch from using SBFs to WBFs or OBFs: Switching from SBFs to WBFs would generally lead to more WBF development wells and more discharges to the ocean as WBF operations produce more waste per well than SBF wells WBF and OBF operations are slower than SBF operations and some wastes are hauled to shore which result in more air emissions and fuel usage Due to technical demands, operators will most often use SBF or OBF in the deepwater areas. An inadvertent release of whole OBF is substantially more deleterious and long-lasting than SBF which are less toxic and more biodegradable
OCS Policy Committee Meeting 8 of 14



-

October 25, 2000

Final Rule Overview
 EPA selected the controlled discharge option which would result in the least pollutant loadings to the ocean, air, and land.

 EPA did, however, select the zero discharge with exclusions for operators in Coastal Cook Inlet based on the limited number of wells and the ability of most Coastal Cook Inlet operators to re-inject their cuttings waste drilling fluids.

October 25, 2000

OCS Policy Committee Meeting

9 of 14

Final Rule Overview
 EPA selected various stock and discharge limitations to select those SBFs with the best environmental performance (i.e., fluids with environmental performances better than the internal olefins).

 Stock limitations include: Mercury, Cadmium, PAH, sediment toxicity, and biodegradation  Discharge limitations include: diesel oil discharge prohibition, aqueous toxicity, sediment toxicity, and formation oil contamination, base fluid retained on cuttings.  Bulk or neat SBFs are prohibited from discharge.

October 25, 2000

OCS Policy Committee Meeting

10 of 14

Final Rule Overview
 Cook Inlet, Alaska, operators are currently barred from discharging OBFs, SBFs, and enhanced mineral oil based drilling fluids under the Cook Inlet NPDES general permit (64 FR 11889).
 EPA identified that many Cook Inlet operators in Coastal waters are using cuttings re-injection to comply with zero discharge disposal requirements for OBFs and OBF-cuttings.

 The State regulatory agency, AOGCC, stated that there should be enough formation re-injection disposal capacity for the small number of NAF wells (< 510 well per year) being drilled in Cook Inlet Coastal waters.

October 25, 2000

OCS Policy Committee Meeting

11 of 14

Final Rule Overview
 AOGCC stated, however, that case specific limitations should be considered when evaluating disposal options.  Coastal Cook Inlet operators will be allowed to discharge their SBF-cuttings (at the same level of control as Offshore operators) provided that the following conditions are met:  inability to establish formation injection in wells that were initially considered for annular or dedicated disposal;  inability to prove to AOGCC’s satisfaction that the waste will be confined to the formation disposal interval; or  inability to handle drilling waste for exploration drilling with mobile rigs (i.e., limited storage or room for cuttings transfer).
 If Coastal Cook Inlet operators are technically prohibited from re-injecting their SBF-wastes then they will be allowed to discharge SBF-cuttings at the same level of control as Offshore operators.
October 25, 2000 OCS Policy Committee Meeting 12 of 14

Rule Schedule
 EPA is planning to complete internal EPA workgroup review by first week in November 2000.  SBF Stakeholder review will shortly follow this EPA review.

 OMB has indicated to EPA that they would also like to review the final rule.
 EPA is still required to complete the rulemaking by the end of December 2000.

October 25, 2000

OCS Policy Committee Meeting

13 of 14

For More Information…
Electronic copies of EPA supporting analyses and Federal Register notices can be found at: http://www.epa.gov/ost/guide/sbf/ EPA SBF Team contacts are:
Name
Marvin Rubin
Carey Johnston Ron Kirby James Covington Charles Tamulonis Chuck White Khouane Ditthavong Mary Ellen Levine

Position
Engineer, Branch Chief
Engineer, Team Leader Engineer Economist Environmental Assessor Statistician Analytical Methods Attorney

Phone
(202) 260 3028
(202) 260 7186 (202) 260 7168 (202) 260 5132 (202) 260 7049 (202) 260 5411 (202) 260 6115 (202) 564 5487

E-mail
rubin.marvin@epa.gov
johnston.carey@epa.gov kirby.ronald@epa.gov covington.james@epa.gov tamulonis.charles@epa.gov white.charles-e@epa.gov ditthavong.khouane@epa.gov levine.maryellen@epa.gov

October 25, 2000

OCS Policy Committee Meeting

14 of 14


								
To top