HSE Mgt in Drilling Operations

30
7/30/2019 HSE Mgt in Drilling Operations http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 1/30  Author: Peter Aird www.kingdomdrilling.co.uk  Ref: HSEM01 Health safety and environmental management in drilling operations  Rev: 1.0 15/04/01

Transcript of HSE Mgt in Drilling Operations

Page 1: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 1/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Health safety andenvironmental management

in drilling operations 

 Rev: 1.0 15/04/01

Page 2: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 2/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Health safety and environmentalmanagement in drilling operations

Objectives

The objectives of this document are:-

• Describe the principles of Health, Safety and Environmental (H,S&E)management in the offshore industry;

• Illustrate how principles are applied in practice, with special reference toenvironmental management in drilling operations.

Page 3: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 3/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Table of contents

HEALTH SAFETY AND ENVIRONMENTAL MANAGEMENT IN DRILLING

OPERATIONS ................................................................................................................................2 

Objectives......................................................................................................................................2

Table of contents ...........................................................................................................................3

Introduction ...................................................................................................................................4

Principles of quality management .................................................................................................5

THE E&P FORUM HSE MS.........................................................................................................7 

Leadership and Commitment ........................................................................................................8

Policy and Strategic Objectives ....................................................................................................8

Organisation, Resources and Documentation ...............................................................................9

Evaluation and Risk Management ..............................................................................................10

Planning and Procedures.............................................................................................................14

Implementation and Monitoring .................................................................................................15

Audit and Review........................................................................................................................15

APPLYING TO IN DRILLING OPERATIONS .......................................................................16 

Identifying Environmental Hazards ............................................................................................16

Assessing the Magnitude and Significance of Hazards ..............................................................20

IMPLEMENTING CONTROL TECHNIQUES TO ELIMINATE OR MINIMISE

HAZARDS .....................................................................................................................................22 

General ........................................................................................................................................22

The Waste Management Hierarchy.............................................................................................23

Treatment and Disposal of Drill Cuttings ...................................................................................25

Environmental Effects of Cuttings Discharges ...........................................................................26

The Regulatory Framework ........................................................................................................27

Future Options for Managing Discharges of Drill Cuttings........................................................29

RECOMMENDED FURTHER READING ...............................................................................30 

Page 4: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 4/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Introduction

The Piper Alpha disaster was a defining event in the history of the UK offshore industry.

The Cullen Report that resulted recommended sweeping changes for to manage safety,requiring a fundamental shift from prescriptive regulations to a goal setting regime. 

Operators were now required to demonstrate to the regulator  (i.e. the Health and Safety Executive) that safety hazards have been identified and the effective controls are in place to prevent accidents happening.

Safety management systems

The vehicle for implementing these changes was the development of SafetyManagement Systems (SMS).

SMS are based on the principles of quality management, as identified by:

• The International Standards Organisation (ISO) in their Quality Systemstandard ISO 9000.

Page 5: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 5/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Principles of quality management

The overriding objective of all quality management systems is however to achievecontinuous improvement in performance. The principles of quality management arestraightforward, and comprise the following basic steps:

1. Define Objectives 

2. Develop a plan to achieve these objectives, and resource accordingly 

3. Implement the plan; 

4. Monitor performance against the plan; 

5. Provide feedback to allow corrective action.

The success of the quality management approach in many areas of business activityincluding safety management, has encouraged its application in the broader area of H,S&E management.

 A key milestone in this process was the development of the British Standard BS 7750 – Specification for Environmental Management Systems  – which was published in

1992.

Since that time, the International Standards Organisation has developed the ISO 14000series on environmental management. This includes specific guidance onEnvironmental Management Systems (e.g. ISO 14004: Environmental Management Systems – general guidance on principles, systems and supporting techniques) and elements of thesesystems (e.g. ISO 14010: Guidelines for Environmental Auditing – General principles).

In developing these systems, the standards organisations implicitly – and probablyinadvertently – emphasised differences between managing the different elements of H,S&E.

Page 6: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 6/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

For companies that embraced the principles of quality management, the proliferation of management systems can create real and practical problems.

• Firstly, management systems need active effort and maintenance to be effective.Thus, the implementation and maintenance of growing numbers of managementsystems places an increasing burden on companies.

• Secondly, the development of separate management systems for H,S&E doesnot always recognise the inter-relationships of these elements in day-to-dayactivities.

These problems, coupled with growing recognition of the common elements in H,S&Emanagement, led the Oil Industry Exploration and Production Forum (the E&P Forum – 

the international association of oil companies and petroleum industry organisation) to developguidelines for integrated Health Safety and

Environmental Management Systems (HSE MS). This was published in 1994, andprovides a common standard for operators and service companies around the world.

Page 7: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 7/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

The E&P Forum HSE MS

The purpose of this section is to outline the E&P Forum HSE MS, highlighting key areas.Figure 1 illustrates the elements of the system, which can be described as follows:

Figure 1: HSE management system; leadership and commitment

Policy &strategic

objectives

Organisation, resources & documentation

Evaluation and risk management

Planning and procedures

Implementation

Audit

Management review

Corrective action

and improvement

Corrective actionand improvement

Monitoring

Corrective action

Page 8: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 8/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Leadership and Commitment

This is, perhaps, the most fundamental elements of the whole HSE MS. Senior management have to demonstrate clear leadership and commitment to H,S&E for thesystems to have any credibility. Visibility is the key. In practical terms, this means givingmanagement time to H,S&E (e.g. through site inspections) and making resources availableto implement the HSE MS.

Policy and Strategic Objectives

Most companies have H,S&E policies, which summarise corporate intentions andaspirations in these areas of the business. Policy statements tend to be high level, andneed to be communicated effectively throughout the organisation. This includesexplaining what the policy means in terms of the day-to-day business, and explaining theexpectations policy places on individuals within the organisation.

 As an example, this might include the commitment that H,S&E performance has equalpriority to other aspects of the business, with a clear understanding that work must stopwhen H,S&E performance is compromised.

The definition of strategic objectives in H,S&E complements policy developments. These

objectives have to be clear and unequivocal to be effective and – as with policycommunicated effectively throughout the organisation. Examples of objectives include:

• To eliminate occupational health hazards

• To prevent all accidents

• To prevent accidental discharges to the environment

These objectives effectively set the scene for H,S&E planning throughout theorganisation, as discussed in element 5 below.

Page 9: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 9/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Organisation, Resources and Documentation

H,S&E performance is a line responsibility, and this needs to be understood at all levelswithin the organisation. This requires the roles, responsibilities and accountabilities aredefined and communicated successfully. In many cases, it is necessary to allocateadditional, specialist resources to ensure that the HSE MS is implemented successfully.Examples include risk assessment specialists and safety engineers.

The emphasis on line responsibility for HS&E places a clear requirement onorganisations to define competence requirements in these areas, and ensure that staff achieve and maintain the required competencies to carry out their responsibilities inH,S&E. This is one of the more challenging aspects of implementing the HSE MS, while

it is relatively easy to define competence requirements, assessing and maintainingcompetence levels throughout the work force can quickly become an intenselybureaucratic and cumbersome process.

The development and maintenance of documentation can be another problematic areaof HSE MS. All management systems require some degree of documentation, but thiscan easily burgeon into unmanageable proportions. Focused attention is needed tostrike a balance between the need for documentation, and the practicality of updatingand maintaining documents.

Page 10: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 10/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Evaluation and Risk Management

Evaluation and Risk Management lies at the heart of HSE MS. The process can beoutlined as follows:

a. identify H,S&E hazards;

b. assess the magnitude and significance of hazards;

c. implement control techniques to eliminate or minimise the hazard;

d. develop plans and procedures to manage the consequences of exceptional

events.

Taking these in turn:

a) Identifying H,S&E hazards is typically based on:

• experience/judgement

• checklists

• codes of practice and standards

• structured review techniques, such as hazard and operability studies (HAZOPs), event or fault tree analysis, failure mode and effect analysis(FMEA) or Environmental Impact Assessment (EIA).

b)  Assessing the magnitude and significance of hazards involvesevaluating the risks associated with identified hazards. This needs to take fullaccount of probability of occurrence and severity of consequences for people, theenvironment and assets.

The concept of tolerable risk is central to this evaluation process. This concept is

based on the premise that risks can be allocated to one of the followingcategories:

1. Risks are sufficiently high to be intolerable

2. Risks are tolerable, but are actively managed to be As Low As ReasonablyPracticable (ALARP).

3. Risks are sufficiently low to be acceptable, with no action required toreduce further.

Page 11: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 11/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Figure 2 illustrates the approach.

Figure 2: Tolerability of risk

 A range of tools and techniques are available to aid decision-making:

• Expert judgement

• Codes of practice and standards

• Qualitative probability and consequence analysis

• Quantitative risk assessment

Expert judgement can be particularly useful in assessing environmental hazardsparticularly in providing focus on key issues, e.g. issues associated with cold water corals on the Atlantic Frontier.

Codes of practice and standards include regulatory guidance, such as Occupationalexposure Limits and standards for effluents and emissions.

Qualitative probability and consequences analysis can be particularly useful inhelping operations carry out their own risk assessments.

For example, Table 1, tables 2 and Fig. 3 shows probability , consequence andmatrix that can be used to assess the potential severity of incidents, integrating semi-quantitative elements into the assessment process.

Tolerable 

*

 Intolerable

* As low as

reasonably

practicable zone

Page 12: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 12/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Quantitative risk assessment (QRA) has been developed by safety practitioners as aformal and systematic tool for aiding decision-making and its practical value is wellestablished and understood throughout the industry. However, attempts to extend

the approach to environmental risk have been generally unsuccessful.

The product of this assessment process is a thorough understanding of H,S&Ehazards and their significance.

Probability.

Table 1: Probability metrics

Probability Weighting value Occurrence of event 

Negligible  1 Less than once every 500 wells

Low  2 Less than once every 100 wells

Moderate  3 Less than once every 10 wells

High  4 More than once every 10 wells

Consequences of events.

Table 2: Consequence metrics

Probability Weighting value Consequences for involved personnel,pollution & equipment 

Negligible  1 Minor lost time accident

Minor pollution

Limited material damage (less than $150,000)

Limited lost time (less than 1 day)

Moderate  2 Lost time accidents with no prolonged disability

Limited pollution to less than 10 cu. Meter oil or less than 1 dayduration gas blow out

Damage to equipment (less than $500,000).

Moderate time loss (less than 30 days)

Severe  3 Fatal injury to 1 single person, injury to personnel which may

cause prolonged disability for one person or more.Pollution in excess of 100 m3 or long duration gas blow out (lessthan 30 days)

Severe equipment damage (less than $15 mill.)

Severe lost time (less than 100days.) 

Catastrophic  4 Fatal injury to more than one person

Pollution out of control

Damage to installation which causes loss or partial loss of theunit

Page 13: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 13/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Figure 3: Example of a risk matrix

Risk estimate diagram

H 4 8 12 16

M 3 6 9 12

L 2 4 6 8

N 1 2 3 4   P  r  o   b  a   b   i   l   i   t  y

   ⇒   ⇒ 

N M S C

Consequence⇒⇒ 

c) Implementing control techniques to eliminate or minimise hazards involvesidentifying appropriate tools and techniques which can be used as risk reductionmeasures. These can include:

• Physical controls e.g. blow out preventers; personal protective equipment;pressure release systems; 

• Organisational controls e.g. intrinsically safe designs; Permit-to-work

systems, alcohol and drug use programmes. 

Measures are also required to mitigate or lessen adverse effects if one of thesecontrol measures fails. Examples include:

- ignition control systems

- gas/fire/smoke detection

- secondary tank containment

d) Development of plans and procedures to manage the consequences of exceptional events. This is contingency planning, and is described in the nextsection.

Page 14: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 14/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Planning and Procedures

H,S&E planning should be persuasive throughout the organisation. Corporate objectives(element 1, above) set the direction and basis for H,S&E planning throughout theorganisation.

H,S&E planning at all levels in the organisation should include:

• a clear description of objectives, with quantified targets;

• designation of responsibility for setting and achieving objectives and targets;

•the means by which they are to be achieved;

• mechanisms for evaluation and follow up.

In principle H,S&E planning at all levels in the organisation – whether definingdepartmental plans or setting tasks and targets for individuals – should reflect thedirection and intent of the corporate objectives.

Offshore work is heavily proceduralised, and procedures need to take full account of H,S&E considerations if they are to contribute to the HSE MS. Procedures thereforeneed to be reviewed to identify those that may be critical to H,S&E performance, and

revised accordingly. This is an onerous task, but can make a major contribution tooverall H,S&E performance.

Contingency and emergency planning is well established in the offshore industry. Plansshould be developed to cover all emergencies, and should include:

• organisation, responsibilities, authorities and procedures for emergencyresponse;

• systems and procedures for providing personnel refuge, evacuation, rescueand medical treatment;

• systems and procedures for preventing, mitigating and monitoringenvironmental effects of emergency actions;

• procedures for communicating with authorities, relatives and other relevantparties; systems and procedures for mobilising third party resources andemergency support;

• arrangements for training response teams and testing emergency systemsand procedures.

Page 15: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 15/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Implementation and Monitoring

Measuring performance is critical to any management system. From an H,S&Estandpoint, it comprises the following elements:

1. identify key performance indicators (KPIs) e.g. Lost Time InjuryFrequency (LTIF); incidence of occupational illness; surface losses of drilling muds;

2. Determine the frequency of measuring KPIs.

3. Record and communicate KPIs, focusing on performance

against plans and targets.

Incident reporting and investigation is another facet of monitoring performance. Thepurpose of all incident reporting and investigation is to identify underlying causes andthus prevent recurrence. In order to be effective, incident reporting needs to addresspotential consequences. Thus, a fall from scaffolding might have resulted in a brokenwrist, but could equally have resulted in a fatality and needs to be investigatedaccordingly.

Audit and Review

This is the final element in the HSE MS, and is designed to ensure that the effectivenessof the system is reviewed critically at appropriate intervals. Audits may take severalforms, from management inspections through to audits lasting for several weeks andinvolving dedicated teams. The effectiveness of audits depends largely on theidentification and follow up of action items – unless these are addressed, the audit hasbeen a wasted effort.

Management review is another aspect of audit, and involves periodic review by senior management of the HSE MS in helping to achieve corporate objectives, and in assessingwhether objectives and policy need to be revised.

Page 16: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 16/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Applying to in Drilling Operations

This section describes how the principles of the HSE MS are applied in practice toenvironmental management in drilling. The focus is on Evaluation and RiskManagement, which is the process of Environmental Impact Assessment. 

Identifying Environmental Hazards

This comprises of two elements:

identify the environmental hazards and effects associated with the drillingoperation;

• characterise the environment, and identify sensitivities in relation to drillingoperations

 Note: What, when and where it happens is important to the probability and consequencesin environmental management and adds a different dimension to that considered innormal HS&E issues.

Page 17: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 17/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Taking these in turn, the main environmental hazards associated with drilling are:

Environmental Hazard Possible Effect Physical presence of rig  • disturbance of sea bed

• interference with other users of the sea

• noise/visual effects

Drilling discharges (mud, cuttings)

• effects on seabed organisms

• organic enrichment of seabed

Rig discharges (drainage water, sewage)

• turbidity effects

• organic enrichment

Emissions to air (power generation, well testing)

• greenhouse effect

• acid rain

• ozone formation

Solid waste disposal  • onshore effects

Accidental spills 

(crude or diesel spills, fall out from well testing) 

Effects on:

• seabirds• fish and shellfish

• coastal resources

Page 18: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 18/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

The significance of such potential effects is determined by the environment in which theoperation is carried out.

In practical terms, offshore and coastal areas can be differentiated and the followingenvironmental factors need to be considered:

a) Offshore

Hazard Risks 

Oceanography  • bathymetry

• currents

• waves

Meteorology  • wind speed and direction

• climate

Seabed  • seabed features

• sediment type

Biology  • plankton/benthic communities

• rare/unique species

Fisheries  • fish spawning and nursery areas

• shellfish grounds

• commercial fisheries

Marine mammals  • whales, dolphins, porpoises andseals

Offshore Birds  • birds at sea

Other users of the sea  • shipping

• oil and gas activity

• cables

• a gravel extraction

Page 19: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 19/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

b) Coastal Areas

The major elements outlined above for offshore areas are equally relevant to coastal

operations. However, the following elements also need to be addressed:

Hazard Risks 

Coastal habitats  • salt marshes

• sand beaches

Conservation areas  • nationally/internationally designatedarea

• breeding colonies

feeding grounds• over wintering areas

Inshore fisheries and mariculture 

• migratory fish

• fish/shell fish farming

Amenity and recreational use  • tourist beaches

• water sports

Page 20: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 20/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Assessing the Magnitude and Significance of

HazardsThis activity focuses on assessing whether the environmental hazards associated withthe proposed drilling activity are significant and thus require control. As describedearlier, this is based on:

• expert judgement

• codes of practice and standards

• a qualitative probability and consequence analysis

• quantitative risk assessment

Examples are:

Expert judgement

Expert judgement is used routinely in the Environmental Assessment process. This maybe fairly straightforward. For example, atmospheric emissions from turbines may be judged to be insignificant when viewed against emissions from other sources, and

discounted at an early stage in the assessment process.

Other decisions can be more complex. For example, the possible effects of sub-seanoise on whale behaviour are not well understood. Expert judgement – drawing on theviews of recognised specialists – is required to guide decision making in suchcircumstances.

Page 21: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 21/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Codes of practice and standards

Codes of Practice and Standards are applied routinely in drilling operations. Examplesinclude:

• legislation covering cuttings discharge e.g. zero discharge of mineral oil based mud (OBM).

• Required standard for oil in water in drainage discharges

• No visible oil sheen during well testing

Other codes and standards can also be useful during the Environmental Assessment

process. For example, the significance of sewage and grey water discharges in near shore environments can be assessed using water quality standards for bacteria andturbidity.

Qualitative Probability and Consequence Analysis

Qualitative Probability and Consequence Analysis can be particularly useful in oil spillcontingency planning. For example, detailed plans may be neither appropriate nor necessary when drilling in a known gas province where there is an extremely low

probability of encountering oil, or in situations where there is a low probability of spilledoil stranding.

Quantitative Risk Assessment

Finally, Quantitative Risk Assessment has only found limited application in theenvironmental area, but the approach can be useful in oil spill contingency planning.The main strength of QRA lies in its use as a decision support tool to compare relative –rather than absolute risks.

Page 22: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 22/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Implementing Control Techniques toEliminate or Minimise Hazards

General

This section gives generic and specific examples of control techniques for managingenvironmental hazards.

The first example if the Waste Management Hierarchy, which provides a usefulframework for addressing waste management issues.

The second example describes controls on the treatment and disposal of cuttings coatedwith drilling mud, which is generally considered to be the major environmental hazardassociated with drilling. This is included to show how controls evolve, and to highlightthe role of regulation and legislation in this process.

Page 23: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 23/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

The Waste Management Hierarchy

The objective of the waste management hierarchy is to minimise quantities of wasterequiring disposal. The first step is to identify and segregate waste streams. Thehierarchy is then implemented as:

1. prevent waste being generated;

2. re-use wastes;

3. re-cycle wastes

Disposal is the final option, and is only carried out when all other opportunities havebeen exhausted.

The practical value of the waste management hierarchy has been demonstrated in manyindustries around the world, and it provides a sound basis for tackling wastemanagement in drilling.

Page 24: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 24/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Examples include:

Hierarchy Examples Prevent waste being generated: 

• replace single use chemical drums withreturnable bulk containers for drillingchemicals (fewer drums to land fill)

• reduce water volumes used in tankcleaning

Re-use waste:  • re-use wooden pallets

• use off-spec drilling cement in onshoreapplications

• use cleaned cuttings in engineering

applications e.g. road fill

Recycle waste:  • recycle used lube oils

It is important to understand that the waste management hierarchy is not applicable inevery situation. For example, there are instances where re-cycling plants are remotefrom where the wastes are generated.

In these cases, the environmental and safety issues associated with road journeysshould be taken into account, and there will be cases where local disposal is the

preferred approach. Nevertheless, the waste management hierarchy provides a usefulstarting point for all waste management planning.

Page 25: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 25/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Treatment and Disposal of Drill Cuttings

Controls on treating and disposing cuttings have been driven largely by regulation andlegislation, which has evolved in the light of increased understanding of theenvironmental issues associated with cuttings discharges.

Page 26: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 26/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Environmental Effects of Cuttings DischargesThe environmental effects of discharging cuttings to sea have been well investigated andare generally well understood. The primary impact is physical smothering of organismson the sea bed under and immediately around drilling locations. The practicalsignificance of such effects is determined by the nature and composition of contaminantsin the discharge, which determine the rate of which organisms are able to re-coloniseimpacted areas. For water based muds, re-colonisation typically proceeds rapidly –generally beginning when discharge has ceased.

Oil Based Mud (OBM) discharges have longer term effects, since elevatedconcentrations of hydrocarbons associated with cuttings and surrounding sedimentshave severe impacts on marine life – either by direct toxicity or by creating anoxicconditions. The rate at which the oil degrades determines the duration of effects.Degradation is typically slow under North Sea conditions, and effects can last fordecades.

Environmental concerns with synthetic muds (SMs) also focus on their persistence in themarine environment, and thus on the duration of environmental effects. The muds weredeveloped in response to increasing restrictions on the discharge of oil based mud(OBM) to sea, with their use and discharge supported by claims from mud companies

that their products degraded significantly faster in the marine environment than OBM.

Results from sea bed surveys and other environmental studies have provided increasingevidence SMs do not degrade rapidly under field conditions. This has been confirmed byresults of laboratory biodegradation tests, carried out by the Scottish Office Agriculture,Environmental and Fisheries Department (SOAEFD), which indicate that SM base oils(other than the ester, Petrofree) cannot be differentiated from mineral oils on grounds of persistence.

Page 27: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 27/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

The Regulatory Framework

General

The Department of Trade and Industry (DTI) regulates environmental aspects of the UKoffshore E&P industry. The Scottish Office Agriculture, Environment and FisheriesDepartment (SOAEFD) and The Centre for Environment, Fisheries and AquacultureScience (CERES – formerly part of the Ministry of Agriculture, Fisheries and Food)provides the DTI with specialist scientific support.

The UK is a Contracting Party to the Oslo and Paris Commission (OSPAR), whichregulates international aspects of offshore discharges to the North Sea and North East

 Atlantic. Regulations applied on the UKCS have to be compatible with OSPARDecisions and are thus greatly influenced by pressure from other Contracting Parties toOSPAR, such as the Netherlands, Norway, Denmark and Germany.

Regulations governing the discharge of cuttings to sea can be summarised as follows:

Water based mud’s

Water Based Mud’s (WBM): There are no specific controls on the discharge of WBM to

sea, although chemicals added to WBM are regulated under the Offshore ChemicalsNotification Scheme (OCNS).

Oil based mud’s

Oil Based Mud’s (OBM): The discharge of OBM to sea is regulated under exemptionsto the Prevention of Oil Pollution Act (1971). Discharges have been increasinglyrestricted, and an Oil on Cuttings (OOC) limit of 10g/kg now applies to all wells (effective01/01/97). This limit is not achievable using proven techniques and technologies. In

practical terms, the imposition of the 10 g/kg OOC limit can be taken as an effective banon the discharge of OBM cuttings.

This limit is not achievable using proven techniques and technologies. In practical terms,the imposition of the 10 g/kg OOC limit can be taken as an effective ban on thedischarge of OBM cuttings.

Page 28: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 28/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Synthetic based mud’s

Synthetic Mud’s (SM): are regulated under the Offshore Chemicals NotificationScheme (OCNS) – their discharge to sea is only permitted when mud’s are allocated tothe least hazardous category (Group E) of this scheme. Other controls on the dischargeof SMs have included:

•  An upper limit for OOC (as SM base oil) of 100 g/kg. This used to berequested “when achievable,” but is increasingly being required by the DTIas a condition of discharge.

• No discharges from larger hole sections (>16 ins), other than in exceptionalcircumstances (operators to justify such discharges to DTI);

• Operators are required to carry out sea bed surveys to investigate thefate and effects of discharges under field conditions. This is aconditional requirement depending on the availability of survey results.SOAEFD consider that results from five surveys provide a reasonable basisfor assessing the environmental properties of each SM. Requirements for sea bed surveys are increasingly applied only when using new mud’s.

However, the recent evidence that the environmental behaviour of most SMs is littledifferent to OBM has resulted in a fundamental re-appraisal of these muds. The DTI,working together with UKOOA, has therefore proposed the following controls on the

discharge of SMs to sea:

• Discharges of SMs above 1% oil on cuttings limit to be phased out over afour year period, beginning 01/01/97. This equates to zero discharge by2001.

• The different chemical groups of SM base oils will be subject to the samephase out programme, with the exception of esters;

• Pending further evidence from seabed surveys the use of ester based muds

will continue to be permitted.

Page 29: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 29/30

 

Author: Peter Aird  www.kingdomdrilling.co.uk  Ref: HSEM01

Future Options for Managing Discharges of Drill

CuttingsFaced with the phase out of SM discharges, the industry currently has the followingoptions for managing cuttings discharges:

1. Increase the use of water based muds (silicate based muds). This haslimited potential, since WBMs have inferior drilling performance to OBMand SMs, particularly in the areas of shale stability and lubricity whendrilling highly deviated or extended reach wells.

2. Continue using ester based SM. These muds are expensive and have

performance limitations, particularly when drilling under high pressure/ hightemperature conditions.

3. Use conventional oil based mud, implementing total containment to preventlosses at sea; (re-injection)

There are two basic approaches to total containment:

• Cuttings re-injection uses proven technology, and is practised by anumber of operators in the North Sea and elsewhere around the world. Its

main value lies in platform drilling – it is not readily adaptable to drillingfrom mobiles.

• Ship-to-shore. In this technique, cuttings are collected and transported toshore, where they can be cleaned using thermal desorption processes.The cleaned cuttings can then be used in engineering applications e.g.road fill. Ship-to-shore is practised in the Southern North Sea, with athermal treatment unit at Lowestoft. Opportunities for extending thisapproach into other sectors of the North Sea are currently beinginvestigated by operators and service companies. The main limitations onship-to-shore are likely to be logistic problems and down time due to

adverse weather.

Different operators can be expected to respond to the SM phase out in different ways,depending on factors such as the geographical location of operations and the nature of their drilling programmes. At the same time, the mud companies are actively working todevelop novel muds which combine the technical performance of OBM with theenvironmental properties of WBM.

Page 30: HSE Mgt in Drilling Operations

7/30/2019 HSE Mgt in Drilling Operations

http://slidepdf.com/reader/full/hse-mgt-in-drilling-operations 30/30

 

Recommended Further Reading

1. Guidelines for the Development and Application of Health, Safety and Environmental

Management Systems, E&P Forum, London, 1994.

2. Successful Health and Safety Management, Health and Safety Series booklet HS(G)65,

HMSO, London.

3. Environmental Management Systems – General guidelines on principles, systems and

supporting techniques. International Standard ISO 14004, 1996 (E).

4. Environmental Implications of Offshore Oil and Gas Development in Australia. Swan

J.M., Neff, J.M., Young, P.C. (Eds). ISBN 0 908277 17 2. Christopher Beck Books,

Queensland, 1994.