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Introduction
CBF Chemical Constituents
Brine Handling and Personal Safety
Environmental Considerations: Brine Handling and Disposal
Agency Contact Information
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.

For a glossary of environmental terms, visit the EPA Web site at: www.epa.gov/OCEPAterms.

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.

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TABLE 46. NPDES Permit Effluent Limitations for Completion Fluids

NPDES Permit Effluent Limitations for Completion Fluids
Constituent Test Limit Frequency
Free Oil Static Sheen Test No free oil Daily, when discharging
Oil and Grease1 Oil and Grease Analysis <29 mg/l mo avg
<42 mg/l day max
Monthly, when discharging
Priority Pollutant (Zinc)   No discharge Prohibited
1The 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.

Drilling Fluids. A different set of requirements applies to reservoir drilling fluids. TETRA recommends that, in the case of drilling fluids, the standards regarding Free Oil should be based on the Static Sheen Test and the standards for Oil and Grease should be based on the HEM method as noted above. In addition, a toxicity test should be run to determine the LC50 rating.

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TABLE 47. NPDES Permit Effluent Limitations for Drilling Fluids

NPDES Permit Effluent Limitations for Drilling Fluids
Limitation Test Limit Frequency
Oil Based Fluids   No Discharge  
Oil Contaminated Drilling Fluids1   No Discharge  
Free Oil Static Sheen 58 12506 Number of days sheen observed Once per day
Toxicity Grab 96 hr LC50 using Mycidopsis Bahia 30,000 ppm daily minimum Once per month
Maximum Discharge Rate Estimate 1000 bbl/hr Once per hour
1EPA 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.

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TABLE 48. CBF RQ Information

Compound Formula RQ lb (Kg)1
Ammonium Chloride NH4Cl 5,000 (2,268)
Zinc Bromide ZnBr2 1,000 (454)
1RQ based on 49 CFR 172.101 Appendix A

 

Consult with your company’s environmental professionals regarding use of any regulated chemical.

Figure 17 shows how the reportable quantity in barrels of a three salt brine containing zinc bromide (ZnBr2) 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.

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FIGURE 17. Estimated RQs for Zinc Fluids
(in barrels for three salt fluids containing zinc at different densities) 

 Figure 17 Graphic

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.

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TABLE 49. TETRA Additive RQ Information

Additive Product Name TETRA Packaging RQ for Product1
  Unit lb gal
Acetic Acid 55 gal   570
Ammonium Chloride Dry Salt 50 lb 5,000  
Caustic Soda (Sodium Hydroxide) 50 lb 1,000  
Caustic Potash (Potassium Hydroxide) 50 lb 1,000  
CORSAF SF 5 gal, 55 gal   11,000
Hydrochloric Acid 55 gal   510
OxBan 5 gal   790
TETRAHib 5 gal, 55 gal   940
TETRAHib Plus 5 gal, 55 gal   250
TETRAVis Breaker 5 gal, 55 gal   75
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:

Any person in charge of a vessel or an offshore or onshore facility shall, as soon as he has knowledge of any release (other than a permitted release) of a hazardous substance from the facility in a quantity equal to or exceeding the reportable quantity (RQ) in any 24 hour period, notify the National Response Center at 800.424.8802.

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.

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