Summary A maze of U.S. regulations and regulatory agencies coupled with uncertainty in interpretation of environmental data and an evolving system of disposal engineering will require industry action to monitor the area and derive a solid engineering basis for disposal of spent drilling fluid. A set of disposal methods with approximate costs is presented to serve as an initial guide for disposal. Introduction In the past 10 years, regulatory practice for waste disposal has changed radically because of the imposition of environmental legislation at the federal level; the Clean Water Act (CWA), Resource Conservation and Recovery Act (RCRA), and the Toxic Substance Control Ant (TSCA) all bear on this new industrial problem. The drilling industry has been exempted temporarily from direct application of part of this regulatory action by the 1980 Solid Waste Disposal Act Amendments. This exemption may end in Oct. 1982, at which time the U.S. Environmental Protection Agency (EPA) administrator is to have determined whether hazardous waste classification is appropriate for any drilling fluids. Within 6 months, Congress would have to pass additional legislation to place the recommendations into appropriate actions. In spite of the federal moratorium on regulatory control, another phase of the RCRA is intended to transfer federal management of the hazardous waste program to state agencies. Following EPA approval, program to state agencies. Following EPA approval, the states will assume prime responsibility for RCRA management and enforcement. This transfer process and the degree to which it already has been accomplished has been reviewed in Ref. 1. This review includes a list of the states whose RCRA programs have been approved by EPA. Once its state plan is approved, each state becomes eligible for federal money that EPA has allocated to manage and implement RCRA. This amounts to $30 million in fiscal 1981; EPA has requested $41.7 million for fiscal 1982 for this state program. The state agencies, thus, are assuming the regulatory and enforcement procedures initiated by EPA and will have considerable autonomy in selection of EPA's guidelines for enforcement. Variations in state programs undoubtedly will complicate drilling operations, although local agencies will understand the local situations better than federal rule makers. This paper reviews the background of waste management for drilling fluid disposal. It presents a brief outline of suggested disposal methods, their approximate costs, rig safety and fluid management suggestions, and a suggestion to build an API data base on state agency waste management as it applies to drilling fluid disposal. Disposal methods considered are (1) fluid ejection, (2) pit and solids encapsulation, (3) injection into safe formations, (4) removal to disposal sites off location, (5) separation into clean solids and clean fluid, (6) incineration, (7) microorganism processing, (8) distillation, liquid extraction, and chemical fixation, and (9) traditional solids control. Discussion Laws Forming Basis of Regulatory Actions Federal. Federal laws include the CWA, RCRA, and TSCA. Miscellaneous State and Local Agency Laws. Currently, disposal of drilling fluids has been exempted from the direct application of the federal RCRA rules by the 1980 Solid Waste Disposal Act Amendments Some quotes from this amendment may help explain a continuing obligation of regulatory control that essentially has been transferred from the EPA to state agencies for enforcement. Sec. 7 of the 1980 amendment states, "Drilling fluids, produced waters, and other wastes associated with the exploration, development, or production of crude oil or natural gas or geothermal production of crude oil or natural gas or geothermal energy shall be subject only to existing State or Federal regulatory programs in lieu of subtitle C until at least 24 months after the date of enactment of the Solid Waste Disposal Act Amendments of 1980 and after promulgation of the regulations in accordance with subparagraphs (B) and (C) of this paragraph." paragraph." JPT P. 2377
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Sep 1, 1991
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