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Informational Letter IL 2001-3
August 28, 2001
| To: |
All Oil and Gas Operators
All Oil Sands Operators
All Drilling and Servicing Contractors |
MANAGEMENT OF DRILLING WASTES ASSOCIATED WITH ADVANCED GEL CHEMICAL SYSTEMS
Subsequent to the October 1996 release of Guide 50: Drilling Waste Management, the use of advanced gel chemical drilling fluids containing new mud formulations or additives has increased. This informational letter (IL) clarifies Alberta Energy and Utilities Board (EUB) requirements with respect to the appropriate management of drilling wastes generated from the use of such drilling fluids.
Advanced gel chemical drilling fluids are those water-based drilling fluids that have additives or components not addressed in the current version of Guide 50 (e.g., potassium sulphate, sodium and potassium silicates, potassium formate, potassium nitrate, ammonium nitrate, and potassium iodide tracers). It is the waste generator's responsibility to determine whether the drilling fluid system it is using constitutes an advanced gel chemical drilling fluid. The EUB Operations Group should be contacted if clarification is required.
Prior written approval from the EUB is required for any land application of advanced gel chemical drilling wastes. This includes both on-site and off-site land applications as described in Guide 50, sections 3 and 4. The waste generator must apply in writing to the EUB for such approval, detailing the type of advanced gel chemical drilling fluid to be used and the requested disposal option. Contact the EUB Operations Group to obtain a list of the information required as part of an application for the disposal of these advanced gel chemical drilling wastes.
Note that the EUB conducts drilling waste audits on an ongoing basis. If an audit or field inspection discloses that disposal of advanced gel chemical drilling wastes occurred without prior written approval, the EUB will take enforcement action in accordance with IL 99-4: EUB Enforcement Process, Generic Enforcement Ladder, and Field Surveillance Enforcement Ladder.
Disposal of these advanced gel chemical drilling fluids through an approved waste management facility, as referred to in Guide 50, Section 6, does not require prior approval from the EUB.
The EUB will be announcing a review of Guide 50 later this year. New management options for these advanced drilling fluids will be addressed through this review.
Please direct any questions to Jason Desilets, EUB Operations Group, at (403) 297-8178.
[Original signed by]
J. D. Dilay, P.Eng.
Board Member
