Environmental Considerations - Brine Handling and Disposal

Certain environmental regulations apply to completion/workover fluids as well as to some of the additive products used when working with these fluids. A listing of TETRA's brine fluids and additive products with established EPA reportable quantities (RQs) are found in Table 48 and Table 49.

A few definitions are provided to help you understand the applicable rules and regulations.

Hazardous Substances

Hazardous substances are:

1. Any elements, compounds, mixtures, solutions, or substances specially designated by the EPA under Section 311 of the Clean Water Act (CWA) (40CFR 116.4) or under Section 102 of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) (40CFR 302.4);
2. Any toxic pollutants listed under Section 307(a) of the CWA;
3. Any hazardous substances regulated under Section 311(b)(2)(A) of the CWA;
4. Any listed or characteristic Resource Conservation and Recovery Act (RCRA) hazardous wastes;
5. Any hazardous air pollutants listed under Section 112 of the Clean Air Act (CAA); or
6. Any imminently hazardous chemical substances or mixtures regulated under Section 7 of the Toxic Substances Control Act (TSCA).

Discharges

A discharge is any flow of surface water in a stream or canal or the outflow of ground water from a flowing artesian well, ditch, or spring. It can also apply to the discharge of liquid effluent from a facility or to chemical emissions into the air through designated venting mechanisms.

Permitted Discharges

Completion Fluids. Under the regulations of the National Pollutant Discharge Elimination System (NPDES), a discharge of clear brine fluid may be permitted as long as it does not have an RQ designation and passes certain tests. Permit effluent limitations pertinent to completion, well treatment, and workover fluids are listed in Table 46.

TABLE 46. NPDES Permit Effluent Limitations for Completion Fluids

The analytical method for Oil and Grease determination should be specified as EPA Method 1664, Revision A, N-Hexane Extractable Material (HEM: Oil and Grease), a liquid/liquid extraction gravimetric procedure.

TABLE 47. NPDES Permit Effluent Limitations for Drilling Fluids

EPA Method 1664 Revision A: N-Hexane Extractable Material (HEM: Oil and Grease)

Releases

A release is any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing of a hazardous or toxic chemical or extremely hazardous substance into the environment.

Reportable Quantities (RQs)

A reportable quantity (RQ) is the amount of a hazardous substance which, when released to the environment, must be reported to the National Response Center (NRC). Reportable quantities are action levels that may trigger an appropriate response to a release under provisions of the CWA, the CERCLA, or the Emergency Planning & Community-Right-To-Know Act (EPCRA).

CBF RQs

The following table outlines the RQ information for ammonium chloride (NH4Cl) and zinc bromide (ZnBr2), which are the only brine salts that have established EPA reportable quantities.

TABLE 48. CBF RQ Information

RQ based on 49 CFR 172.101 Appendix A

Figure 17 shows how the reportable quantity in barrels of a three salt brine containing zinc bromide (ZnBr

) varies as the density goes up. As can be seen in Figure 17, a release of as little as 10 bbl constitutes a reportable release for all zinc containing brines with densities greater than 16.0 lb/gal. This quantity decreases to approximately two bbl at a density of 19.2 lb/gal.

FIGURE 17. Estimated RQs for Zinc Fluids

Additive RQs

The following table provides a list of TETRA additive products containing at least one ingredient with an established EPA reportable quantity. Keep in mind that TETRA is continually developing new additives aimed at solving corrosion, fluid loss, and production impairment issues. While Table 49 provides a complete list of TETRA additives containing at least one ingredient with an established EPA reportable quantity as of this guide's publication, the list may become outdated as new products are introduced to the marketplace. Consult your TETRA representative regarding reportable quantity information for the particular additive package you select for your well.

TABLE 49. TETRA Additive RQ Information

¹RQ for products are approximate and are based on 49 CFR 172.101 Appendix A

Releases to the Environment and Notification Requirements

Releases are spills or unplanned discharges. They are regulated by the Clean Water Act (CWA) and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). Notification of a release in excess of the Reportable Quantity is required. Notification requirements (for releases) 40CFR 302.6 reads as follows:

Other agencies to be notified:

U.S. Federal Agencies

• U.S. Coast Guard
• U.S. Department of Interior Minerals Management Service (MMS)

Louisiana Agencies

• Department of Environmental Quality-Water Resources Control Division
• Department of Public Safety

Texas Agencies

• The Railroad Commission of Texas (operations and waste)
• Texas Commission on Environmental Quality
• Texas General Land Office (Oil Spill Response)

Addresses and phone numbers for some, but not all, regulatory agencies are included in the following section.

Due to the number of involved agencies, many of which have overlapping boundaries or authorities, as well as differing interpretations of regulations, most companies working in oil and gas development have departments established specifically to deal with environmental compliance issues.