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Drilling waste management is ever evolving as new drilling fluid systems get developed, and regulatory guidelines change over time.

By working closely with your environmental services company during the planning stages of your drilling fluids program, we can help you identify potential disposal issues that could result in increased costs, and we can offer you suggestions that can help you meet your fluid performance objectives while helping your company develop the most cost efficient disposal program.

The drilling fluids system that you select will directly affect the options that you have for disposing of the drilling waste generated from all sections of your well.

Drilling Waste Disposal Planning

Having a thorough drilling waste management plan is essential for communicating drilling waste disposal options to all parties involved in drilling operations. When properly developed and executed, a drilling waste management plan will save you time and money.

Our comprehensive drilling waste management plans include:

• Determination of disposal options for the selected drilling fluid system to comply with regulatory guidelines for the province of operation.

• Conduct sump suitability assessments and above ground earthen bermed storage areas assessments when required.

• Preparation of a detailed step by step plan for managing each unique drilling waste component (fluids, solids, and cement).

• Preparation and submission of written notifications to appropriate regulatory bodies before disposal of drilling waste.

• Preparation and submission of drilling waste management facility waste disposal applications.

• Contingency planning if weather conditions or drilling conditions dictate a deviation from the original drilling waste management plan.

• If requested, arrange services including vacuum trucks, storage tanks, mixing and storage bins, sawdust delivery, and trucking services for waste transport to an approved waste management facility.

Drilling Waste Disposal Options

Currently, the most common disposal options for drilling waste are:

• Landspray While Drilling (LWD) – A cost effective solution for the disposal of water-based drilling waste that eliminates the associated costs of selecting and constructing drilling sumps. Disposal of drilling waste typically occurs on agricultural lands.  This method involves spraying fluid or total waste onto topsoil, sometimes with incorporation. LWD is limited to water-based nontoxic waste and can be done without prior storage. Land selected for these methods must have a slope of less than 5% for summer operations or less than 3% for winter operations. Spray rates are calculated based on the waste analysis. Maximum spray rates are 40 m³/ha for summer and 20 m³/ha for winter operations. Sodium loading should not exceed 250 kg/ha, and nitrogen loading must not exceed rates in Table 10 of Directive 050. Solids application on vegetated land must not exceed 6 t/ha. Post-disposal sampling is required if certain predisposal testing outcomes occurred. For LWD, disposal operations must occur within 48 hours of rig release, with limited exceptions for storage in tanks.  In May of 2012, the Alberta Energy Regulator released the Directive 50: Drilling Waste Management (2012) disposal guide. New criteria for drilling sump construction were included that could result in much higher costs for the acquisition of suitable land and construction of sumps.

• Disposal Onto Forested Public Lands (DFPL) – This method is limited to applying drilling waste from nontoxic water-based mud systems onto forested public lands, typically in winter. It is used on specific dispositions under the Public Lands Act. DFPL allows higher application rates than landspray/LWD. Application methods include vacuum trucks, terragators, or wagons. The waste must have a pH between 6 and 10.5, an EC not exceeding 10 dS/m, no visible hydrocarbons, and metal concentrations below endpoint values. Sodium loading should not exceed 250 kg/ha, and nitrogen loading must not exceed specified rates. Solids application on vegetated land must not exceed 6 t/ha. Post-disposal sampling is required if certain parameters exceeded thresholds in the drilling waste.

• Mix Bury and Cover (MBC)/Residual Solids Disposal (RSD) – This method involves mixing nonhydrocarbon-based drilling waste solids or total waste with subsoils on the well site, a disturbed pipeline right-of-way (if the waste is from that pipeline’s construction), or a remote site where the waste was stored. Hydrocarbon-based mud systems cannot be managed using MBC unless the waste has undergone biodegradation. Specific soil-waste mix ratios are required, at least three parts subsoil to one part drilling waste, with predictive lab mixes needed for waste with high EC or Na concentrations or for disposal on fair-rated soils. Once the drilling waste is mixed with receiving soil, we create a consistent mass of material that is then covered by clean fill to complete the disposal. Most often, this method is used to manage segregated drill cuttings or in conjunction with a pump off disposal option.

• Landspread On Lease (LOL) – Similar to MBC, this method involves spreading water-based drilling waste onto the shallow subsoil of a well site, disturbed pipeline right-of-way, or remote site and incorporating it. Only water-based drilling waste that passes a toxicity test can be landspread. The pH must be between 6 and 10.5. Post-disposal analysis is required if metal or hydrocarbon concentrations in the drilling waste exceeded specified values. A nitrogen loading rate limit of 300 kg/ha applies, prorated to the total area.

• Pump Off – Disposal of the clear fluid portion of drilling waste onto typically vegetated land. Often used in conjunction with another option for the disposal of drilling waste solids such as mix, bury, and cover. Pump Off Disposal is a cost effective way to reduce the volume of waste before mixing off the remaining sump liquids and solids. Pump-offs can also be used for water collected in cement return storage systems if specific criteria are met. Post-disposal sampling is required if sodium loading exceeded 150 kg/ha or nitrogen loading exceeded 20 kg/ha.

• Approved Waste Management Facility – There are times when the only feasible solution to dealing with drilling waste is to use a drilling waste management facility. Drilling waste can be sent to approved oilfield waste management facilities (OWMFs) regulated by Directive 058. Information on using such facilities must be kept in the well or pipeline file and used to support reclamation certification applications. Required characterization, classification, and analyses must be completed before adding sorbent material. Drilling waste must not be sent to registered landfills or landfills operating under a Public Health permit unless it qualifies for acceptance and specific criteria are met. Waste classified as solid non-dangerous oilfield waste (non-DOW) and inert can be sent to approved Class III landfills. Dangerous oilfield waste (DOW) can only be sent to Class I landfills if it passes the paint filter test and meets acceptance criteria set out in Directive 058. Sending drilling waste to compost facilities or dedicated land treatment facilities for refined hydrocarbons is prohibited.  We provide comprehensive waste characterization, analytical data review, acquisition of waste management facility approvals and tracking of wastes on your behalf to ensure fast turnaround times and cost effective disposal solutions.

• Biodegradation – This involves reducing organic constituents by microbial processes. One-time on-site biodegradation of waste is an activity that does not require specific approval under Directive 058 but has documentation requirements. Permanent biodegradation facilities (used more than once or for over five years) require approval as an OWMF. Biodegradation may be used to treat hydrocarbon-based drilling waste before using MBC or landspread. Approval from the AER is required for biodegradation as a disposal method or for using a non-prescribed treatment method.

• Thermal Treatment: Using mobile thermal treatment units is an option, with requirements specified in Directive 058. A 30-day notification to the AER is required before starting thermal treatment operations. Permanent thermal treatment facilities require approval as an OWMF.

• Remixing Former Disposals: For older sites, remixing a former drilling waste disposal is an option. Licensees must notify the AER at least 30 days prior and the local AER field centre at least 48 hours prior to starting this activity.

Drilling Waste Tracking & Manifesting

Combined with an appropriate drilling waste management plan, tracking of drilling wastes generated from drilling projects is key in ensuring that waste streams are segregated, and the location of wastes is known at all times. Improper tracking or integration of incompatible drilling wastes can result in thousands of dollars in additional disposal and clean-up costs.

Keneco Environmental Offers:

Field supervision of drilling waste disposal activities and ongoing inspection of drilling waste containment areas to ensure no cross contamination of drilling wastes has occurred.

• Detailed record keeping of drilling activities including the acquisition of drilling fluid usage reports.

• Preparation of site schematics and imagery indicating the location of waste storage systems and the wastes that contributed to each storage system. Detailed record keeping of drilling activities including the acquisition of drilling fluid usage reports.

• Sampling and analysis of drilling waste to determine the most appropriate and cost effective method for disposal of drilling waste at the completion of the project.

• Full manifesting and tracking of waste volumes transported to an approved drilling waste management facility.

Drilling Waste Management in Alberta

Drilling waste, which consists of mud and cuttings generated from drilling wells (including oil sands exploration, geothermal, and brine-hosted mineral) and directional drilling for pipeline construction, is a significant aspect of upstream petroleum industry operations. The management of drilling waste in Alberta is primarily governed by Alberta Energy Regulator (AER) Directive 050: Drilling Waste Management. This directive sets out requirements for the treatment and disposal of this waste to protect the environment and enable the restoration of drilling waste sites to equivalent land capability. Drilling waste management is also linked to the broader requirements outlined in Directive 058: Oilfield Waste Management Requirements for the Upstream Petroleum Industry.

A fundamental principle for wells undergoing reclamation is that drilling waste and other oilfield wastes must be properly disposed of according to AER directives. All contamination must be remediated prior to applying for certification. Reclamation criteria for well sites, including cultivated lands, forested lands, and native grasslands, state that drilling waste and other oilfield wastes must be properly disposed of according to AER Directives. Specific criteria for contaminant assessment and remediation, such as for salts, metals, sterilants, and organic chemicals, are addressed by Alberta Environment Tier 1 and 2 guidelines. Soil endpoints for drilling waste land disposal methods are aligned with the latest edition of the Government of Alberta’s Alberta Tier 1 Soil and Groundwater Remediation Guidelines. However, Directive 050 details specific options for drilling waste disposal, including dilution by mixing, which is not generally permissible under the Tier 1 guidelines.

Before disposal, the drilling waste must be characterized and classified. Waste characterization involves assessing the physical, chemical, and toxicological characteristics. The classification determines transportation dangers and appropriate management options. Toxicity testing, specifically the luminescent bacteria toxicity test, is required to evaluate drilling waste toxicity. If the test result is below the pass threshold (75 per cent for an EC50(15)), further testing after charcoal treatment or in-field treatment is required. Hydrocarbon content analysis is required for drilling waste samples, and hydrocarbon flags (indicators like horizontal oil well, diesel pill addition, or visible hydrocarbons) necessitate hydrocarbon testing to inform disposal decisions. Waste classification must be completed before adding any amendment or sorbent materials. Diluting oilfield waste to avoid regulatory requirements is prohibited.

Assessment of receiving soils is necessary to determine the suitability of a specific land disposal method. Soil endpoint requirements for salts, hydrocarbons, and metals for soils that have received drilling waste are set out in tables within Directive 050, adopted from the latest edition of Alberta Tier 1 Soil and Groundwater Remediation Guidelines. Assessment and remediation criteria for contaminants in general are addressed by Alberta Environment Tier 1 and 2 guidelines. D50 Equivalent Salinity Guidelines are used for assessing and remediating drilling waste disposal areas for reclamation certification.

Cement returns must be segregated from drilling waste and managed separately. Options for managing cement returns include allowing them to harden in aboveground synthetically lined walled storage systems (AWSS), or placing them in cells that are part of an approved landfill (subject to approval processes). Alternative management or recycling methods require application for approval from the AER. Soil sampling is required after removing unhardened cement returns from pits, unless specific conditions are met (e.g., sump meeting certain requirements or an earthen pit lined with a synthetic liner). AWSSs should be located on an active AER-licensed well or facility or AER-approved OWMF. Water collected in AWSS should not be discharged into any watercourse unless allowed by an Environmental Protection and Enhancement Act (EPEA) approval.

Drilling waste can be stored on the well site, pipeline right-of-way, or at a remote site. Storage systems include sumps, earthen-bermed structures, and aboveground tanks. It is prohibited to mix camp sewage or other oilfield wastes with drilling waste in a storage system. Storage areas must be kept clean and secured. Waste from directional drilling for pipelines must be stored separately from well drilling waste. Surface water must be prevented from entering or exiting the storage system, and a minimum freeboard of 0.5 m must be maintained. Drilling waste must be removed from storage systems within 18 months of rig release of the first well that contributed waste or within 12 months of the first receipt of pipeline drilling waste. Setbacks apply to storage systems from features like on-site rig water wells, off-site water wells, and water bodies. Liquid hydrocarbon-based drilling waste must be stored in tanks. Licensees intending to recycle or reuse drilling waste for a subsequent well can temporarily store it on that well site for up to three months in aboveground tanks without designating it a remote site.

Obtaining written consent from the landowner, department, or agency managing the land is required for accessing the land for drilling activities. Additional consent is needed for managing drilling waste outside the well site or pipeline right-of-way, using landspray, LWD, DFPL, or pump-off methods off site, storing, MBC, landspreading, or using an alternative method on a remote site, or placing cement returns in pits exceeding four square metres on private land. Licensees must provide landowners with a document titled “Information for Landowners on Consent for the Disposal, Treatment, or Storage of Drilling Wastes”. Consent requirements vary depending on the land type, such as private land (landowner agreement), public lands (AER through disposition), First Nations lands (IOGC or Indian and Northern Affairs Canada approval), and Canadian Forces Base lands (Department of National Defence consent).

Post-disposal information must be submitted electronically through the AER’s DDS system. Well licensees must submit a Directive 050 Drilling Waste Management Disposal form within 24 months of rig release. Pipeline licensees must submit a Directive 050 Pipeline Drilling Waste Disposal form within 12 months of each directional drilling activity. Licensees must also notify the AER via email if post-disposal or cement pit sample results exceed soil endpoints, including a plan to remedy the exceedance.

Other waste management and disposal options mentioned in the sources include managing naturally occurring radioactive materials (NORMs) and minimizing waste production through reduction, reuse, recycling, and recovery strategies. Non-oilfield waste, such as garbage and domestic waste, cellulose material, and inert debris like concrete, should ideally be disposed of at existing facilities like municipal landfills. Companies are encouraged to minimize volume through reuse, recycling, and recovery.

Drilling Waste Management in Saskatchewan

In Saskatchewan, the management of drilling wastes is governed by specific guidelines to protect the environment. The primary document outlining comprehensive methods and criteria for handling and disposal is the Saskatchewan Drilling Waste Management Guidelines, Information Guideline GL 99-01.
The Ministry of Energy and Resources (ER) emphasizes that drilling wastes must be managed to protect the environment from adverse impacts and allow the disposal site to return to equivalent land capability. Operators are ultimately responsible for the proper disposal of their wastes. Most wells use a liquid system which becomes contaminated with formation material, resulting in significant liquid and solid waste. Reusing or recycling fluids is encouraged.

Drilling fluids must be contained to protect the environment. Earthen sumps may be used for freshwater drilling fluids if separated from groundwater by at least one meter of continuous impermeable subsoil. Sumps shall not be used for salt or hydrocarbon based systems. Sump use on Crown lands may be prohibited.

Drilling fluids should be disposed of in a timely manner upon drilling completion. Earthen pits or sumps must be filled in and the surface restored. Sump closure must be completed within 12 months of drilling rig release, unless permission is obtained from ER. Placing hazardous wastes, waste dangerous goods (like used oil and antifreeze), or garbage in drilling sumps/tanks is prohibited. Certain drilling wastes may be regulated as dangerous goods if pH is less than 2.0 or greater than 12.5; pH adjustment is recommended if pH is less than 4 or greater than 11.

Information requirements, including pre-drilling, pre-disposal, and post-disposal details, must be submitted to ER. For certain methods like Landspraying While Drilling, pre-drilling notification and post-disposal notification (Form A-1 with specific data) are required. For Land Treatment, an Application For Land Treat of Hydrocarbon Contaminated Drilling Wastes with detailed information is required, and operator must receive written approval from ER.

Sampling and testing of all drilling wastes intended for disposal (fluids, solids, total waste) are generally required for parameters listed in Table 2.2.1, with exceptions for landspraying while drilling and disposal at approved waste processing facilities. Pre-disturbance receiving soil characterization is also required for pH, EC, major ions (sodium, calcium, magnesium, potassium, chloride, sulphate), and SAR (and hydrocarbon if multiple applications).

Environmental Site Assessments (ESAs), specifically Phase I and Phase II, are required upon well abandonment (cut and capped) or facility decommissioning. These assessments must meet the standards set by Directive PNG033 and CSA standards (Z768-01 for Phase I, Z769-00 for Phase II). If a Phase I ESA does not provide evidence that drilling waste was handled compliantly with GL 99-01, a Phase II ESA is required. The Phase II Directive PNG033 addresses environmental site assessment for spills, incidents, and historical contamination from wells, facilities, and flowlines. It outlines requirements for characterizing impacted sites. Investigation Derived Waste generated during assessment should be addressed at the time of site remediation.

Waste management is a key consideration in the environmental review process for oil and gas development projects. Project proponents must handle all waste according to appropriate legislation and describe how project wastes will be managed in their Oil and Gas Project Proposal (OGP). Constituents of predicted waste streams should be provided in the OGP.

Earthen structures or excavations are generally not to be used for storing oil, condensate, refined chemicals, oil and gas waste, or non-oil-and-gas substances. However, earthen pits can be used for oily and salt water storage in case of an emergency, following GL 97-01 requirements for Oily Byproduct Storage Structures. Flare pits are strictly prohibited as storage receptacles. Wastes from tanks or wells must be drained into proper receptacles.

Disposal of oil-and-gas wastes, including drilling fluids and waste oil or refuse from tanks or wells, must be into a subsurface formation unless approved by the minister. Even with approval, operators cannot allow wastes to hazard public health/safety or contaminate fresh water or arable land.

Legacy oil and gas-related linear features, such as roads and seismic lines, may require enhanced reclamation.
These guidelines and regulations aim to ensure environmentally safe and responsible management of the significant volume of waste generated by drilling operations in Saskatchewan.