Recycling Drilled Cuttings Current Rules and Approaches May 7, - - PowerPoint PPT Presentation

Recycling Drilled Cuttings – Current Rules and Approaches

May 7, 2018 Oklahoma City, OK

• Rock cuttings and fluids that

are produced during drilling

• 1.2 barrels of waste

generated per foot drilled

• Average 50% solids / 50%

liquids

• 392,000,000 bbls generated

in 2014

• Enough to fill 25,000

Olympic-size swimming pools

• Approximately 55,000,000

tons of solid drilling waste

2

Drilling Waste

Contaminants in Drilling Waste

• Metals
• Arsenic
• Barium
• Cadmium
• Chromium
• Lead
• Mercury
• Selenium
• Silver
• Zinc
• Salts
• Chlorides
• SAR
• Organics
• Hydrocarbons
• Benzene
• pH
• NORM/TENORM
• Proprietary /

Uncertain additives

Constituents and Parameters

a: USEPA National Primary Drinking Water Standards https://www.epa.gov/ground-water-and-drinking-water/table-regulated- drinking-water-contaminants b: USEPA National Secondary Drinking Water Standards https://www.epa.gov/dwstandardsregulations/secondary-drinking- water-standards-guidance-nuisance-chemicals c: Lead is regulated by a treatment technique that requires systems to control the corrosiveness of their water. If more than 10%

• f tap water samples exceed the action level, water systems must take additional steps. For lead, the action level is

0.015 mg/L10.

Source Reduction Recycling/Composting Energy Recovery

Treatment & Disposal

EPA’s Waste Management Hierarchy

• Landfilling
• Land Spreading/ Land Farming
• Road Spreading (Road Application)
• On-site Burial

Traditional Disposal Methods

Legitimate Recycling – U.S. EPA

• Provides a useful contribution to the recycling process or to

a product or intermediate of the recycling process

• Produces a valuable product or intermediate
• Managed as a valuable commodity and in a manner

consistent with the management of the raw material

• Must be comparable to a legitimate product or intermediate
• Must meet widely recognized commodity

standards and specifications

Drilling Cuttings Compared to CCP

Product Tons Produced Tons Recycled Percent Recycled

Coal Combustion Products in 2016

Fly Ash 37,817,327 22,634,497 59.85% 56.01% Bottom Ash 10,135,360 3,775,480 37.25% Boiler Slag 2,188,298 1,310,959 59.91% FGD Gypsum 32,006,516 18,372,663 57.40% FGD Material Wet 9,556,694 896,141 9.38% FGD Material Dry 1,488,752 310,607 21.44% FGD Other 7,508 0.00% FBC Ash 14,267,412 12,869,437 90.20% 2014 Drilled Cuttings 55,000,000 < 405,000 < 1.00% < 1.00%

• Saves money and creates value
• Performance specifications are clearly defined
• Routine, representative sampling to manage variability
• Physical and chemical analyses using appropriate test methods
• Bench-scale testing prior to processing
• No significant increase in volume
• Creates a valuable asset
• Protects human health and the environment

The Best Drilled Cuttings Recycling Program

Cost Evaluation Example

• Construction Recycling

Model

• Sampling and Testing
• Trucking
• Processing
• QA/QC
• Construction
• Typical Model
• Disposal
• Box Rental
• Trucking
• Solidification
• Disposal
• Washout
• Equipment and personnel
• Construction
• Labor
• Equipment
• Materials

Drilled Cuttings Pre-Treatment Before Final Management

Method Type of Drilled Cuttings Used On Effect on Contaminants Contaminants Left Dewatering WBC Reduces Mud Contaminants TPH, salts, metals Chemical Drying WBC, OBC Some Dilution TPH, salts, metals Mechanical Separation OBC Reduces Mud Contaminants TPH, salts, metals, proprietary additives Thermal Desorption OBC Dramatically Reduces TPH and Water Salts and metals Bioremediation OBC Reduces TPH TPH, salts, metals

• Create Growing Medium
• Compost
• Soil Amendment
• Create Construction Material Using

Stabilization and Solidification (S/S)

• Fill Material
• Aggregate
• Direct Load-Bearing Material

Drilled Cuttings Recycling Methods

Drilled Cuttings Recycling Methods

Method Type of Drilled Cuttings Used On Effect on Contaminants Contaminants Remaining Issues Composting OBC Reduces TPH Salts and metals Can create issues with plants Soil Amendment WBC (freshwater) N/A Usually none Unknown S/S WBC Sequestration TPH, salts and metals Very few if done properly S/S OBC Sequestration TPH, salts and metals Very few if done properly

Recommended Performance Specifications for Recycling Methods

Method Physical Performance Specifications Chemical Performance Specifications Legal Requirements Composting

• N/A
• Toxicity testing
• Totals (mg/Kg) for

salts, metals, TPH,

• ther mud

additives

• Third-party

testing

• Quarterly

reporting to State Soil Amendment

• N/A
• Toxicity testing
• Totals (mg/Kg) for

salts, metals, TPH,

• ther mud

additives

• Third-party

testing

• Quarterly

reporting to State S/S

• Unconfined

compressive strength

• Hydraulic

conductivity

• Leachate testing

(mg/L) for salts, metals, TPH, and

• ther mud

additives

• Third-party

testing

• Quarterly

reporting to State

Solidification/Stabilization

Selected States’ Rules Overviews for Drilled Cuttings

State Rule Texas (RRC)

• TAC Title 16, Part 1,

Chapter 3.8 Water Protection and Chapter 4, Subchapter B, Commercial Recycling Oklahoma (OCC)

• OAC 165: 10-9-4
• OAC 165: 10-8-1
• OAC 165: 10-7-24

Louisiana (LDNR)

• LAC 43.XIX.313.G
• LAC 43.XIX.565

North Dakota (NDIC and NDDH)

• No current rules in place

Texas

From RRC Website for Chapter 4, Subchapter B “Solids Recycling: Division 2, Division 3 and Division 4 Division 2: On-Lease solid waste recycling for reuse as roadbase is limited to any

• n-lease location for a maximum of one year. Information must be submitted for

application of a permit, including but not limited to a typical layout of the facility, processing information, storage and liner information. The roadbase must meet specific limitations on leachability concentrations of metals, chloride and TPH must be met, in addition to a minimum compressive strength. Division 3: Off-Lease or Centralized solid waste recycling for reuse as roadbase is limited to any location for a maximum of two years. The requirements for permit of an Off-Lease facility include those of Division 2, and also require site specific environmental and property information because the facility will be at one location longer than one year. The applicant will have to provide notice to the surface owner

• n which the facility is to be located and adjacent landowners. The permit will also

require monitor wells and financial security. Division 4: Stationary solid waste recycling facilities are permitted for one location for up to five years. After five years, a request for renewal of the permit may be

• requested. The requirements for permit of a Stationary Recycling facility include

those of Division 2 and Division 3, and also require notice be published in accordance with HB480. To apply for a permit follow each Rule in the applicable Division. Each Division is written as a permitting guide.”

Texas

“ALTERNATIVE BENEFICIAL USES FOR TREATED OIL AND GAS SOLID WASTE Environmental Permitting staff has received numerous proposals for alternative uses of treated oil and gas waste solids other than for reuse as roadbase

• material. Proposed alternative uses include non-load bearing fill material for

construction and bulking agents for cement and treated aggregate for landfill components or cover and capping material. Current rules under 16 Texas Administrative Code (TAC), Chapter 4, Subchapter B define engineering and environmental standards for recyclable products resulting from the treatment of solid oil and gas waste that will be used as "roadbase or other similar uses." These rules allow the RRC to establish the appropriate engineering and environmental standards for recyclable products that will be beneficially reused for other purposes, depending on the purpose and location of use. Permits issued for these purposes limit the reuse of recyclable product to commercial and industrial use as fill material or treated aggregate with additional limitations including end use locations, production volumes, and time constraints. The guidance document for a Permit Application for Reusable Product follows the same rules found in Chapter 4, Subchapter B for solids recycling with the exception

• f different testing requirements for the end product.”

Oklahoma

From OAC 165: 10-8-1 “PART 1. HYDROCARBON RECYCLING/RECLAIMING FACILITIES 165:10-8-1. Scope This Part shall cover the permitting, construction, operation, and closure requirements for any recycling/reclaiming facility.”

Oklahoma

From OAC 165: 10-9-4 “Commercial recycling facilities

(a)

Scope. This Section shall cover the permitting, construction, operation, and closure requirements for commercial recycling facilities. A commercial recycling facility is a facility which is authorized by Commission

• rder

to recycle materials defined as "deleterious substances" in OAC 165:10-1-2. Such substances must undergo at least

• ne treatment process and must be recycled into a marketable product for

resale and/or have some beneficial use. This definition does not include the reuse of drilling mud (plug mud) which was previously utilized in drilling or plugging operations. This Section does not cover hydrocarbon recycling/reclaiming facilities (see OAC 165:10-8-1 through 165:10-8-11).”

Louisiana

LAC 43.XIX.313.G. “Onsite Land Development. Reserve pits containing E and P Waste may be closed by processing the waste material with Department of Environmental Quality approved stabilizing additives and using the mixture onsite to develop lease roads, drilling and production locations, etc. provided the following conditions have been met: E and P Waste shall not be processed in an unlined reserve pit with a bottom that extends to a depth deeper than 5 feet above the seasonal high water table;

• the processed waste material meets the following analytical criteria:
• pH range of the mixture: 6-12;
• electrical conductivity (EC): < 8 mmhos/cm;
• il and grease content: < 1 percent by weight;
• total metals content meeting the criteria of §313.C.2 above;
• leachate testing** for chloride concentration:

< 500 mg/L; and,

• NORM concentrations do not exceed applicable DEQ criteria or limits;”

Louisiana

LAC 43.XIX.565. “Resource Conservation and Recovery of Exploration and Production Waste

• A. In order to encourage the conservation and recovery of resources

in the oilfield industry, the processing of E and P Waste into reusable materials or FSR fluid, in addition to or beyond extraction and separation methods which reclaim raw materials such as crude oil, diesel oil, etc., is recognized as a viable alternative to other methods

• f disposal.”

Louisiana

Parameter Limitation

Parameter Limitation Moisture Content < 50% (by weight) or zero free moisture pH* 6.5 - 9.0 Electrical Conductivity (EC) 8 mmhos/cm Sodium Adsorption Ratio (SAR) 12 Exchangeable Sodium Percentage (ESP) 15% Total Barium: Reuse at Location

• ther than Commercial

facility 40,000 ppm Leachate Testing** for: TPH Chlorides 10.0 mg/l 500.0 mg/l TCLP Benzene 0.5 mg/l Leachate Testing**: Arsenic Barium Cadmium Chromium Copper Lead Mercury Molybdenum Nickel Selenium Silver Zinc 0.5 mg/l 10.0 mg/l 0.1 mg/l 0.5 mg/l 0.5 mg/l 0.5 mg/l 0.02 mg/l 0.5 mg/l 0.5 mg/l 0.1 mg/l 0.5 mg/l 5.0 mg/l NORM Not to exceed Applicable DEQ Criteria/Limits

F.Testing Criteria for Reusable Material

Sham Recycling – U.S. EPA

“Sham recycling may include situations when a secondary material is ineffective or only marginally effective for the claimed use; used in excess of the amount necessary; or handled in a manner inconsistent with its use as a raw material or commercial product substitute.”

Sham Recycling

• Using incorrect testing methods e.g. TCLP analysis

with incorrect closure limits and without physical tests

• Dilution with high volume additions e.g. one part

cuttings to two parts soil

• Using fake laboratories to create fake samples for

testing

• Using centralized facilities to receive wastes without

recycling

• Testing material without it being in the final state for

reuse

• Not testing for all potentially harmful chemicals in

drilling mud

Sham Recycling

Insufficient or non-existent specifications Little to no value created

Sham Recycling

Leaching from cuttings

• History of recycling with proof
• Passes EPA’s definition of recycling
• Scientific basis for methodology
• Review of EPA documentation of recycling method
• Examples of cost savings using real examples
• Use of professional engineers
• Reports stamped by professional engineers
• Bench-scale

testing

• n

each job to demonstrate competency

Determination of Legitimate Recycler

About Scott

• J. Blake Scott

Scott Energy Technologies LLC www.scottenergy.com 903-663-4635 jbscott@scottenergy.com