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

Drilling Waste 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

Contaminants in Drilling Waste • Metals • Salts • Arsenic • Chlorides • Barium • SAR • Cadmium • Organics • Chromium • Hydrocarbons • Lead • Benzene • Mercury • pH • Selenium • NORM/TENORM • Silver • Proprietary / • Zinc 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% of tap water samples exceed the action level, water systems must take additional steps. For lead, the action level is 0.015 mg/L 10 .

EPA’s Waste Management Hierarchy Source Reduction Recycling/Composting Energy Recovery Treatment & Disposal

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

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 Tons Percent Produced Recycled Recycled Coal Combustion Products Fly Ash 37,817,327 22,634,497 59.85% Bottom Ash 10,135,360 3,775,480 37.25% Boiler Slag 2,188,298 1,310,959 59.91% FGD 32,006,516 18,372,663 57.40% Gypsum in 2016 FGD 9,556,694 896,141 9.38% 56.01% Material Wet FGD 1,488,752 310,607 21.44% Material Dry FGD Other 7,508 0 0.00% FBC Ash 14,267,412 12,869,437 90.20% 2014 Drilled 55,000,000 < 405,000 < 1.00% < 1.00% Cuttings

The Best Drilled Cuttings Recycling Program 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 •

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

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

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

Recommended Performance Specifications for Recycling Methods Method Physical Chemical Legal Requirements Performance Performance Specifications Specifications • • • Composting N/A Toxicity testing Third-party • Totals (mg/Kg) for testing • salts, metals, TPH, Quarterly other mud reporting to State additives • • • Soil Amendment N/A Toxicity testing Third-party • Totals (mg/Kg) for testing • salts, metals, TPH, Quarterly other mud reporting to State additives • • • S/S Unconfined Leachate testing Third-party compressive (mg/L) for salts, testing • strength metals, TPH, and Quarterly • Hydraulic other mud reporting to State conductivity additives

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 No current rules in place NDDH)

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 on-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 on 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 of 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.”