OPINION/
Energy Waste Management and the Carbon Agenda Opinion By Gabriel Rio, Milestone Environmental Services
D
espite the supply and demand cycles of our industry, and advances in the development of alternative energy sources, oil and gas remains – without question – the world’s most effective source of energy with unparalleled cost and reliability advantages. Supply models predict that fossil fuels will remain a major part of the global energy mix for decades to come, and when strong demand is coupled with concerns about climate change and other environmental impacts, it becomes all the more important that our industry continues to adapt and improve on its environmental performance. Over the past couple of years, most E&P companies have committed to net-zero or other measurable decarbonization goals. Most of the focus has been placed on reducing greenhouse gas (GHG) emissions downstream of the drilling rig, and while this work is to be applauded, the environmental impact of energy waste remains conspicuously absent from the carbon agenda.
Compliance Is Not Enough
The uncomfortable fact is that, in some states, regulation of energy waste is outdated and unaltered for the modern era of decarbonization. In Texas, for example, due to a ruling last revised in the 1980s, operators still routinely dispose of oilfield waste in earthen pits or spread it out on ranchland, even when environmentally responsible cost-effective alternatives exist. In this case, basic regulatory compliance is no longer enough to satisfy stakeholders and regain the social license our industry needs to continue operating long term. To better illustrate the problem, building a reserve pit involves excavating a hole about 12 feet deep and half the size of a football field at the drill site. Sometimes this has a plastic liner, although this is not always required by Texas regulation, and the pit is filled with oilfield waste as the well is drilled and completed. The waste is then buried with dirt sometime after, creating what has been coined a “waste burrito.” Spreading waste on ranchland—also known as landfarming—is no better. Drilling fluids and cuttings are tilled into the soil on the lease, 24
Well Servicing Magazine/March 2022
and petroleum hydrocarbons and other compounds either evaporate as volatile organic compounds (VOCs) or interact with organisms in the soil, which are eventually expelled as carbon dioxide (CO2). Clearly, these methods pose tangible environmental risks, as well as potential reputation risk to the operator and industry as a whole. Onsite disposal applies waste to the soil, assuring soil contamination and risking groundwater contamination from leachate, even with a liner present. Unlike professional disposal sites, neither reserve pits nor land application require longterm groundwater monitoring of the surrounding area. By design, onsite methods vent VOCs and CO2 to the atmosphere. And don’t forget that liability for pollution remains with the waste generator forever, unless it is transferred to professional disposal sites that carry pollution liability.
In Support of Business as Usual
The conventional argument in support of onsite disposal is the perception that it is the cheapest possible option. Indeed, this may have been the case when the alternative was too remote from location to be feasible. However, in recent years there has been prolific investment in disposal infrastructure, making it more accessible and affordable than ever before. Nowadays, in the Permian Basin, virtually every active lease is within a 30-minute drive of one or more professional disposal facilities. In most cases, this makes the cost of offsite disposal comparable with the cost of building and closing a reserve pit on location. Recent studies also show that if a premium does exist, it is negligible in the overall context of the well cost (less than 1% of the AFE). The other most common claim about dumping in reserve pits or landfarming is that the waste is only water-based and therefore harmless. The reality is, once used in a well, even water-based drilling fluids and cuttings generally include petroleum hydrocarbons, heavy metals, benzene and other contaminants which, although present in nature, are found in much higher concentrations in oilfield waste. Absent its exemption from the Resource Conservation
