Safety and the Environment
We begin with a brief reminder about the importance of safety and the environment when working with clear brine fluids and chemical additives. The field of safety and environmental protection is broad, constantly evolving, and is outside the realm of this document, which should only be viewed as a brief introduction. You have two primary resources in these areas. Your main resource should be the safety and environmental professionals within your company. The regulatory agencies themselves are a second valuable resource. There are many regulatory agencies in the oil and gas producing regions of the world. Information provided in this guide is applicable to the United States and associated offshore areas.
An overview of these topics is provided in Chapter 7, "U.S. Safety and Environmental Information," which should be read in its entirety before bringing a clear brine fluid (CBF) to any well location.
Personal Safety
An understanding of the nature of CBFs will reduce the risk of personal injury to those using these materials while conducting completion and workover operations.
Clear brine fluids are highly concentrated mixtures of inorganic salts, usually chlorides and bromides. These fluids have an affinity for water and will even absorb water from the air. Should concentrated brines come into contact with a person's skin, this same strong tendency to absorb water will cause drying of the skin and, in extreme cases, can even cause a burn-like reddening and blistering.
All precautions should be taken to prevent direct contact between clear brine fluids and the body, especially the eyes and mucous membranes. |
Safe work practices should be implemented to reduce worker exposure to CBFs. When engineering controls are not feasible to prevent exposure, a risk assessment should be conducted and administrative controls should be initiated that will reduce employee exposure to an acceptable level.
A properly completed Job Safety/Environmental Analysis (JSEA) will help to establish these conditions. |
Employees who work with or around clear brine fluids should participate in a safety meeting before any work begins. As previously noted, a more detailed discussion of safety precautions and appropriate equipment is provided in Chapter 7, "U.S. Safety and Environmental Information," later in the guide.
Environmental Considerations
The constituents of clear brine fluids are common salts and, except for those containing zinc bromide, can be rendered harmless to the environment with the addition of sufficient water. Offshore discharges of CBFs to the environment fall under the regulations of the National Pollutant Discharge Elimination System (NPDES). Zinc bromide is considered a priority pollutant under NPDES and cannot be legally discharged.
All precautions should be taken to ensure that fluids and additives are not lost to the environment in an uncontrolled manner. In the event that this does happen, immediate notification to the National Response Center and other regulatory authorities is required if the released fluid contains zinc bromide, ammonium chloride, or one of the TETRA additives listed in Table 49 in an amount greater than the established EPA reportable quantity (RQ). Because environmental regulations can change, always involve your company's environmental professionals when planning any completion or workover project.
Under EPA regulations, spills of completion fluids containing zinc bromide or ammonium chloride must be immediately reported to the National Response Center at 1.800.424.8802 if: * the quantity of zinc bromide in the spill exceeds the 1,000 lb RQ for zinc bromide, or * the quantity of ammonium chloride in the spill exceeds the 5,000 lb RQ for ammonium chloride. |