This paper was prepared for presentation at the SPE international conference on health, Safety and Environment in Oil and Gas Exploration and Production. This paper analyzes materials developed for cementing and stimulation operations. The challenge now is to develop environmentally friendly materials that do not sacrifice operational performance or significantly impact well economics.
This paper was prepared for presentation at the SPE international conference on health, Safety and Environment in Oil and Gas Exploration and Production. This paper analyzes materials developed for cementing and stimulation operations. The challenge now is to develop environmentally friendly materials that do not sacrifice operational performance or significantly impact well economics.
This paper was prepared for presentation at the SPE international conference on health, Safety and Environment in Oil and Gas Exploration and Production. This paper analyzes materials developed for cementing and stimulation operations. The challenge now is to develop environmentally friendly materials that do not sacrifice operational performance or significantly impact well economics.
Developing Environmentally Compliant Materials for Cementing and
Stimulation Operations J ulio Gomez, BJ Services Company Copyright 2010, Society of Petroleum Engineers
This paper was prepared for presentation at the SPE International Conference on Health, Safety and Environment in Oil and Gas Exploration and Production held in Rio de J aneiro, Brazil, 1214 April 2010.
This paper was selected for presentation by an SPE program committee following review of information contained in an abstract submitted by the author(s). Contents of the paper have not been reviewed by the Society of Petroleum Engineers and are subject to correction by the author(s). The material does not necessarily reflect any position of the Society of Petroleum Engineers, its officers, or members. Electronic reproduction, distribution, or storage of any part of this paper without the written consent of the Society of Petroleum Engineers is prohibited. Permission to reproduce in print is restricted to an abstract of not more than 300 words; illustrations may not be copied. The abstract must contain conspicuous acknowledgment of SPE copyright.
Abstract Several offshore oil and gas well drilling operations involve discharging fluids to the sea as part of normal operations. This can have a potential environmental impact on marine and aquatic ecosystems, depending on the characteristics of the components of these discharges.
Offshore drilling operations are carried out in many regions, worldwide, and different governments have enacted environmental regulations and requirements to control potential marine pollution. In addition, most of the companies that operate in these environments have their own internal environmental policies. All of those requirements must be met during offshore operations.
However, some chemicals traditionally used in the onshore operations pose risks in the marine environment. Therefore, as more environmentally sensitive operations arise (e.g. deepwater cementing, where the tophole cement returns are circulated to the sea), environmentally friendly alternative chemical products are being developed to replace those hazardous chemicals. The challenge now is to develop environmentally friendly materials that do not sacrifice operational performance or significantly impact well economics.
This paper analyzes materials developed for cementing and stimulation operations, comparing their environmental performance with the different environmental regulations requirements and considering their operational performance with traditional chemicals that pose more risks to marine environments.
Introduction Efforts to control and reduce the environmental impact of offshore oil and gas have resulted in several regulations, ranging from specific country legislation to multilateral agreements. In 1982, UNCLOS (United Nations Convention on the Law of the Sea), signed by 154 countries to-date, defined the rights and responsibilities of countries regarding the worlds oceans. Included is the fact that each country will be responsible for legally regulating and controlling the activity in waters under its exclusive economic zone. Thus, the implementation of these multilateral agreements has resulted in a country-by-country legal approach, and a single agreement has resulted in several different local regulations.
We will outline the general multilateral agreements, examples of local country regulations and we will then analyze how materials used for cementing and stimulating oil and gas wells have evolved to comply with regulations in the North Sea and in Brazil.
IMO (International Marine Organization), which is also a United Nations agency, with 168 member states, established MARPOL (International Convention for the Prevention of Pollution from Ships). All ships, including oil and gas well related vessels, are covered by MARPOL. Its focus is mainly prevention pollution from the ship operation itself, accidents and tank cleaning, but not the oil and gas well related activity. However, it is used as base for several local regulations, especially in the absence of other agreed guidelines. Regarding industrial offshore activity, MARPOL is very general and lacks detailed procedures, toxicity levels, classifications and is not specific for offshore oil and gas activity. 2 SPE 127196 North Sea Countries with waters in the North-East Atlantic have agreed in OSPAR (Oslo - Paris Conference for the Protection of the Marine Environment of the North-East Atlantic) a detailed and strict regulation to control the offshore environment, specifically applicable to oil and gas operations. For well cementing and stimulation operations the regulation is based in the OSPAR decision HMCS (Harmonized Mandatory Control System for the Use and Discharge of Offshore Chemicals) which requires that all offshore chemicals are subject to pre-screening against given criteria for acceptance. In order to comply with the pre-screening requirements, any materials used in offshore well fluids must pass a pre-screening process (figure 1), which includes specific test protocols on component levels (and not on product level):
Maximum toxicity levels on the mandatory marine species: 1. Skeletonema costatum (algae) 2. Acartia tonsa (crustacean) 3. Scophthalmus maximus juvenile or Cyprindon variegatus (fish) 4. Corophium volutator (sediment reworker)
Additional to the above, organic substances need to meet the minimum parameters on: Biodegradation (OECD 306) Bioaccumulation (OECD 117)
Based on the results of the tests above, the components will either pass or fail the pre-screening criteria. If one component in the product fails, then the whole product fails. There is an exemption list of substances where OSPAR has deemed the substances to be non-hazardous, and therefore do not require the testing as described above. This is the so-called PLONOR list, (Pose Little Or NO Risk), and these are mostly natural occurring, minerals and/or inert substances. On the other side, there is also a list with priority substances with hazardous substances, a "banned" list. Once all test data is available, the products are ranked according to their HQ (Hazard Quotient), based on their environmental profile, expected usage (dosage) and standardized factors for dilution/discharge.
Parallel to OSPAR, the EU (European Union) has approved new legislation covering both continental and offshore EU: REACH (Registration, Evaluation, Authorization and Restriction of Chemicals). For the North Sea, this regulation is mandatory further to the regulations that have risen from OSPAR, which means that even if a given material is cleared for use by OSPAR regulations, it is not automatically cleared by REACH, and therefore it needs to follow the REACH protocol to be registered and cleared.
REACH, which came into force in 2008, requires that all the substances that are part of the materials used in the EU have to be registered and cleared for use according to testing protocols that vary depending on the type of substance, and the utilization tonnage.
The tonnage bands for the testing and clearance process for pre registered components are: <1 tone per year - No test required >1 tone per year - Testing of pre-registered components required by 2018 >100 tone per year - Testing of pre-registered components required by 2013 >1000 tone per year - Testing of pre-registered components required by 2010
The testing includes not only environmental parameters, but also an assessment of risk for human beings and risk exposure.
Brazil Brazils water environment is controlled by IBAMA (Brazilian Institute for the Environment and Renewable Resources). The legislation issued in 2000 is mainly based on MARPOL and contains a classification of the discharges to sea based on their toxicity level. The legislation implementation is based on testing, approval and control on preparation basis, individual components of the preparations need not be tested and approved. The tests to approve the systems or blends used include: 1. Acute Toxicity, based on the Brazilian standard testing procedure CETESB LS250. To pass this test, the result needs to be a LC50 higher than 30,000 ppm at 96 hr. for Mysidopsis juniae (an indigenous shrimp). 2. Chronic Toxicity, based on the Brazilian standard testing procedure CETESB LS251. To pass this test, the result needs to be a VC(l) higher than 1,000 ppm at 24-28 hr. in embryos of Lytechinus variegatus (an indigenous type of SPE 127196 3 urchin). 3. Biodegradation, based on the procedure OECD 306 Both materials to be discharged offshore, and materials being transported for well operations, need to pass the above testing protocol as part of the clearance process prior to being used.
Effluents from Completion Operations Offshore oil and gas wells drilling and completion operations can produce four types of effluents, which potentially could pollute the sea, as follows:
1. Direct discharge to the sea:
2. Potential of leaks or accidents involving spills, when chemical products are stored in offshore vessels or platforms.
3. Tanks and vessels cleaning, surplus disposal
4. Well flow back effluents
Our analysis focuses on offshore cementing and stimulation operations, in the first and second group of effluents. For offshore cementing operations, we will analyze top hole cement slurries, for which the first type of effluent is involved. For stimulation operations we will analyze fracturing gels and acid blends, for which the second type of effluents will be analyzed.
Top Hole Cementing Operations in Deep Water Wells Deep water wells are drilled using a closed loop system. There is a riser attached to a cemented casing which provides a connection between the casing and the drilling rig. The drilling fluids are pumped from the rig through the drill pipe, the drilling bit and then they return to the rig through the annuli between the hole and drill pipe, the casing and drill pipe and the riser and drill pipe. This process does not discharge any fluids to the sea. However, when the first sections (top hole) of deep water wells are drilled, there is not any ability to circulate fluids from the hole back up to the rig, since a riser has not yet been installed. Thus, the drilling fluids, the formation cuttings and the cement returns are circulated directly to the sea, from the drill pipe to the hole and from the hole into the sea.
For this reason, this top hole section is usually drilled with sea water as drilling fluid, including sweeps of non-toxic polymers. The cement slurries also need to be non-polluting and must comply with environmental regulations in order to enable them to be circulated into the sea. At the same time, the cement sheath in the annulus needs to comply with certain minimum technical requirements both to guarantee the ability to continue drilling the well by supporting the casing and to isolate the sea from any formation fluids. Some of the most important of these technical requirements are: 1) a density between the pore and fracture pressure equivalent densities, 2) to achieve a minimum compressive strength, 3) to be mixable and pumpable and 4) to provide a suitable thickening time profile. Additionally, deep water wells may require slurries with special properties such as gas control or low transition time.
GENERAL ENVIRONMENTAL CONSIDERATIONS OF TOP HOLE CEMENT SLURRIES Top hole cement slurries are environmentally assessed whether at system level or at component level, depending on the applicable regulation. System-based evaluations are used following regulations in Brazil and other countries. In the case of Brazilian operations, the requirements, as explained before, are: 1. Acute toxicity, 2. Chronic toxicity and 3. Biodegradation. In the last eight years we have seen an evolution of these types of slurries both in environmental and operational performance. Currently, top hole cementing operations are performed with slurries showing environmental features much 4 SPE 127196 better than the Brazilian regulations require: Typically more than 50,000 ppm for LC50 at 96 hours (needs to be higher than 30,000 ppm for Mysidopsis Juniae), VC(l) of more than 10,000 ppm (required to be more than 1,000 ppm in Lytechinus Variegates) and they meet biodegradability requirements.
ENVIRONMENTAL EVALUATION OF THE COMPONENTS To meet the environmental cement slurry requirements, each component needs also to be analyzed. The regulations involve assessments, registration and authorizations to use materials on a substance basis (single component of each system) and to record the amount of each component used.
The OSPAR, regulated that each substance needs to be environmentally assessed using a protocol called Chemical Hazards Assessment and Risk Management (CHARM). If each single component (substance) is in the PLONOR (Pose Little or No Risk) list of materials, it is cleared for offshore use. Substances that are not on this list need to pass the OSPAR pre- screening process to be cleared for use 3 . A diagram is this pre-screening process is shown in figure 1.
Most of the components of cement slurries used for top hole sections are accepted by the current regulations. However, several of them were considered pollutants before 2004, when the OSPAR was started to be applied by the North Sea countries. New environmentally compliant materials were developed to replace those toxic substances. The following is the analysis per component of the typical top hole cement slurries, with focus on the components replaced due to environmental reasons, during the last five years:
Portland cement: This is the base of the cement slurry. The most widely used cement in offshore environments is API class G cement, which is in the list of PLONOR materials, thus environmental assessment and pre-screening process are not required. Other cements, including API Portland cement other than class G are not in the list of Plonor materials and would need to pass this pre-screening, registration and clearing process 1 .
Foam preventer: This additive is used to prevent operational problems that happen when the cement foams due to the turbulence created in the cement mixing devices. Before the 2000s, non biodegradable polypropylene glycol and silicon- based defoamers were widely used. Modern defoamers have evolved to vegetable oil type raw materials that pass the environmental requirements 1 . A foam preventer made with components solely from the PLONOR list has already been developed and current efforts are focused in achieving operational performance comparable to conventional defoamers.
Dispersant: High viscosity can make cement slurries very difficult or impossible to be mixed and pumped. Dispersants are added to reduce the viscosity when this happens. Commonly used materials are some types of sulfates and sulfonates classified as toxic materials. However, since 2005 a dispersant made with components from the PLONOR list was developed. It shows similar or better performance than the previous dispersants.
Fluid loss controller: These products are used to prevent the cement slurry from losing water to the formation, and thus dehydrating. Offshore additives are preferred to be liquid in order to be fed on the fly into the slurries and to avoid disposal of premixed residual volumes. Fluid loss controllers are powder polymers, in some cases non polluting PLONOR materials. However, in order to be used in a liquid form, these polymers need to be slurried in a non-aqueous phase. The most common base fluids are diesel or heavy naphthas, both heavily contaminant. Before 2004, liquid fluid loss controllers available were toxic. In 2006, a liquid fluid loss controller made using components from the PLONOR list was developed and it is currently in use.
Extenders: Extenders are additives used in order to reduce the density of a cement slurry and while maintaining minimum mechanical properties of the cement sheath. Glass or ceramic hollow microspheres are extenders commonly used for premium low weight cements. For other less-critical applications, sodium silicate or bentonite extenders are used for slurries which are not required to show high performance mechanical properties. All of these are PLONOR materials.
Accelerator / retarder: For top hole slurries, calcium chloride accelerator and lignosulfonate based retarders, which are PLONOR components, are commonly used.
SPE 127196 5 Table 2. Environmental evolution of the components of a typical cement slurry 1 , from fig. 7 of SPE 106644.
Stimulation Operations in Offshore Wells As explained above, stimulation fluids are not intended to be effluents to be dumped or circulated with discharge to the sea. They are injected into the formations that bear oil or gas to improve the production conditions. Then, they flow back along with the produced fluids to the production facilities or to special equipment for proper disposal. However, potential of leaks or spills exists and the environmental impact of these possible events would be high considering that fracturing gels and acid blends are used in large volumes to stimulate offshore wells. They are blended and stored in the tanks of stimulation vessels or in the completion platforms before the stimulation operations. For this reason, they are also subject to the environmental regulations and it is of worth analyzing the pollution potential and the regulation compliance of them.
We are analyzing the two most common stimulation fluids, fracturing gels and acidizing blends:
FRACTURING GELS: Hydraulic fracturing operations are very common treatments performed to increase oil or gas production. Fracturing pumps inject liquids into the reservoir at high pressure and rate to create a crack in the rock. The crack is an improved path for the reservoir fluids to be produced. In order to prevent it from closing, it is propped with a solid material. The fracturing fluids are used to create this crack and to transport the proppant inside it. In offshore wells, the most used fracturing fluids are high viscosity liquids usually blended with sea water. The gels are usually blended on the fly, as they are pumped down hole, by the addition of liquid chemical products to the sea water, as follows:
Typical Fracturing Gel Components and Environmental Considerations:
Gellant: They are mostly powdered guar, guar derivatives or similar polymers, which are dispersed in a hydrocarbon liquid in order make a slurry (liquid polymer concentrate). Since guar based polymers are not pollutants (and in fact most of them are in the PLONOR list), the environmental concern is the hydrocarbon and stabilizing additives used to prepare the slurry. The most commonly used carrier fluid was diesel due to low cost and availability, however it is not biodegradable. Currently, the industry has moved to the utilization of so-called green oils, which despite being hydrocarbons, show lower environmental impact than diesel. Since 2007, the most used slurried gellants are products environmentally accepted by most of the regulatory bodies, including the OSPAR convention, Brazilian and US regulations.
Crosslinkers: These are additives used to increase the viscosity of a hydrated polymer, to generate a viscous gel. Offshore operations normally use borate, zirconium and aluminum based crosslinkers. Some of the borate based crosslinkers pass successfully the OSPAR screening process and are registered to be able to be used. Metallic based crosslinkers are used for higher temperature or other special applications. Only a few of them are environmentally acceptable and some applications do not have yet a suitable crosslinker able to meet the environmental regulations.
Surfactants: These are additives used to improve the fracturing fluid recovery by preventing emulsions, reducing surface tension and promoting water wettability. Despite of the low concentrations used, (0.1 to 0.5% by volume), the chemical products used before 2004 were toxic. Low toxicity surfactants have been developed since then, and they are able to pass OSPAR environmental screening.
Breakers: These are additives used to degrade the gel viscosity after the treatment and thus allow the gel and formation fluids to be produced. The most common types are oxidative materials (such as peroxides, persulfates and perborates) and enzymes. From an environmental standpoint, the enzymes are less polluting than the oxidative materials and they are in the green PLONOR list of materials. Oxidative breakers in general, despite the fact that they are not in the PLONOR list, mostly pass the OSPAR screening process. They are non-organic low toxicity and environmentally acceptable chemicals.
Clay controllers and pH controllers: These are typically salts or buffer solutions added to the fracturing gels to prevent clay 6 SPE 127196 swelling or to adjust the system pH to a point for optimum viscosity. As inorganic materials, such as KCl, NH 4 Cl, NaOH and similar salts, most of them are PLONOR substances and they have low toxicity. In fact, several of them are part of the sea water.
In general, after the developments made regarding the polymer based fracturing gels, the fluids used today in offshore environments show low toxicity when they are analyzed as a system. High performance fracturing fluids and gels for very high temperature applications still include toxic chemicals, but since these additives are typically used at low concentrations (typically less than 1%) in the gel system, they are environmentally acceptable in a system-based analysis (e.g., for Brazilian or US regulations).
Two typical gels examples are shown bellow:
Table 3. Example of Fracturing gels: System environmental analysis as per Brazilian regulation:
Green Borate Guar Gel HTHP Frac Gel Brazilian Regulation LC50 (96h) - MJ * (ppm) 40,291 203,063 >30,000 ppm CV (l) - LV** (ppm) 31,225 176,777 >1,000 ppm Biodegradable Yes Yes Yes * Lethal Concentration for 50% of population at 96 hour for Mysidopsis Juniae ** Chronic Toxicity Value Test 24-28 hr. for Lytechinus Variegatus embryo
However, in a component-based analysis, there are still some materials used in the high performance gels, despite the low concentrations required, that are not considered acceptable under a the component analysis. The challenge, thus, is to develop substitute materials able to show comparable performance to the ones currently used, to be able to pass the environmental screening process. On the other hand, as the offshore oil industry expands its frontiers to deeper and hotter reservoirs, and as improved performance materials are developed, the low toxicity gels could not perform under the new conditions, where the old toxic systems do. Therefore, current developments are focused on addressing the requirements of these new frontiers of oil and gas industry with non polluting fracturing fluids.
ACIDIZING BLENDS: Acid stimulation is also a widely used technique to increase oil and gas well production. Acidizing treatments are based in the fact that certain acids are able to chemically dissolve either the formation rock components, the solids plugging the hydrocarbons flow in the porous media or the scales plugging the well tubulars. The most common acid types used for well stimulation are hydrochloric (HCl), hydrofluoric (HF), acetic (HOAc) and formic (HCOOH). Several additives are added to the base acids to prepare the stimulation acid blends in order to improve the treatment results and to avoid undesirable reactions, such as tubular corrosion or iron reprecipitation in the porous media.
Typical Components of Acid Blends and Environmental Considerations
Base Acid: Depending on the formation type and reservoir / well properties, one or several of the above mentioned acids are blended with water to adjust the strength for optimum stimulation performance. Acid concentration typically ranges from 5 to 20 % HCl, from 0.5 to 3%, from 10 to 13% HOAc and from 9 to 10% HCOOH 2 . Acids are chemical compounds that, when diluted in water, generate a solution with hydrogen ion activity. Since this activity depends on the acid concentration, in the event of a spill or a leak, the environmental potential pollution in offshore operations will exist only for a limited period of time (while the acid is diluted by the sea water to a non dangerous concentration). In fact, the OSPAR convention classifies the acids listed above as PLONOR materials. Typical acid solutions are low toxicity systems, with LC50 concentrations within the range to be considered as non-toxic for all the offshore regulations.
Corrosion inhibitors: Unfortunately acids cause corrosion in all well tubular metallurgies. Since oil and gas wells are assets that need to be productive for several years, corrosion needs to be controlled to guarantee long term production. For this reason, stimulation acid blends are treated with additives that inhibit corrosion. As bottom hole temperatures are higher, stronger corrosion inhibitors and higher loadings are required to protect the tubular. Known materials that prevent corrosion from acid are very poisonous and strongly polluting. Table 3 shows an example of the environmental evolution where some progress has been made in reducing the components toxicity in the corrosion inhibitors used offshore. However, acceptable environmental alternatives to control corrosion in typical acidizing operations have not been found. This is one of the main environmental challenges of stimulation fluids at this time.
SPE 127196 7 The following table shows an example of acid corrosion inhibitors toxicity progress:
Table 3: Acid corrosion inhibitors toxicity examples. Substance-based (pure component) testing as per OSPAR convention:
Values for the worst component Acid Inhibitor 2 (before 2008) Acid Inhibitor 3 Regulation** LC50*, ppm 0.3 1.4 >10 Biodegradation (28 days), % 39 56 >60 Bioaccumulation, Log Pow 3.82 3.02 <3 * Lethal Concentration for 50% of population. Test for 4 different organisms, the table shows the worst case. ** Passing the OSPAR screening requires to pass two out of these three criteria for this type of materials.
Iron controllers: Acids dissolve iron and rust from the well tubulars. When acid laden with this dissolved iron reacts with the formation components and spends, it would eventually precipitate this iron in the porous media, plugging the oil or gas flow. For this reason, additives that keep this iron in solution are used. There are several materials able to do this job. The most used is the citric acid, which is found in fruits and it does not pollute the sea environment. Among other materials used for this purpose, some are low toxicity materials, cleared for offshore use, and others are toxic and not environmentally acceptable. For most of the current acidizing applications, the environmentally acceptable materials show suitable technical performance.
Gellants: It is a successful and common practice to stimulate certain types of formations with viscosified HCl acid. There are two types of materials able to increase the viscosity this acid, 1. Polymers like acrylamides or hydroxyethyl cellulose (HEC); or 2. Viscoelastic surfactants. The first type, the polymers, are low contaminant products, most of them present in the list of PLONOR materials or classified as low toxicity materials. However, for the second type, the surfactants used to viscosify acids are do not pass the OSPAR pre-screening process. In a product by product analysis, such materials could be considered toxic, while in a system-based analysis, like in Brazilian regulations, some systems could be acceptable, depending on the concentration of the gallant used in the system.
Acid blends can also include additives from a broader range of materials, depending on each specific application, such as the surfactants, which were analyzed in the fracturing gels section.
In general, typical acid systems are low polluting systems, except for the fact that they include corrosion inhibitors. The main challenge currently is to find low toxicity materials able to control tubular corrosion from acids. In fact, as shown in Table 3, North Sea regulations classify the currently-used corrosion inhibitors as not passing the OSPAR pre-screening process since they are very toxic. The use of corrosion inhibitors has been limited by these regulations on a case by case basis analysis and due to the fact that there is not a viable alternative to date. There is a commitment to develop environmentally acceptable corrosion inhibitors and this is the main challenge to meet environmentally acceptable stimulation fluids today.
Conclusions 1. The environmental regulations covering offshore oil and gas industry have important variations from country-to-country and from one area to another. Some standardization efforts have been made, but this is still an area for improvement. The lack of worldwide standards results in both higher costs to develop environmentally safe materials and in a non-efficient sea pollution reduction and control. 2. There are important differences in the environmental regulations for offshore operations. One major difference is that the regulations in some areas, such as the North Sea, consider a substance- or component-based analysis, while other areas, such as Brazilian regulations, consider a system-based analysis. This leads to differences in each area in terms of what is environmentally acceptable or not. 3. The cementing and the stimulation fluids have evolved from an environmental point of view, over the past five years. Most of the materials used today are environmentally friendly and meet the expectations of both North Sea and Brazilian environmental regulations. 4. It is currently possible to perform oil and gas wells stimulation operations with low pollution, low toxicity and environmentally compliant materials. 5. One important exception to the above, and thus a challenge that is still outstanding, is to develop environmentally acceptable corrosion inhibitor for acid stimulation, something which is not currently available. 6. As offshore wells reach into deeper and hotter environments, and new high technology performance materials are developed, the oil industry faces new challenges to develop materials able to perform both technically and in an environmentally safe manner, to address these extreme conditions. 8 SPE 127196 Nomenclature
ft x 3.048* E 01 =m F(F-32)/1.8 =C in. x 2.54* E +00 =cm psi x 6.894 757 E +00 =kPa gal x 3.785 412 E 03 =m 3 mile x 1.069 E +00 =km MW x 2.39085 E-5=cal/sec
Acknowledgements The authors thank BJ Services Company for permission to present this paper.
References 1. Haheim, S., Scoggins, C., Lebo, S. and Pedersen, R. Meeting the Environmental Challenges in Cementing., SPE 106644, SPE E&P Environmental and Safety Conference, Galveston, Tx, March 2007 2. Kalfayan, L. Production Enhancement with Acid Stimulation. BJ Edition, Pennwell, 2008. 3. OSPAR Convention for the Protection of the Marine Environment in the North East Atlantic, Annex 16. Copenhagen, J une 2000. 4. Garland, E., Prunier, A., Aqueous Discharges From E&P Installations: Current Technical and Regulatory Challenges From an Operators Point of View. SPE 102900, ATCE, San Antonio, Tx., September 2006 5. Gilbert, Y., Pessala, P., Vaahtera, A., Raivio, T., Formate Fluids and Environmental Regulations: A Global View of Benefits and Challenges. SPE 110891. ATCE Anahaim, Ca. November, 2007
SPE 127196 9
Figure 1. The Harmonised Pre-Screening Scheme (shaded) as Part of the Whole Harmonised Mandatory Control System for Offshore Substances set out in the applicable OSPAR Decision 3
Is substance on Annex 2 of the OSPAR Strategy with regard to Hazardous Substances or considered by authorities to be of equivalent concern for the marine environment ? Is substance on the PLONOR list? F u l l
H O C N F
n e e d e d
Is the substance inorganic? Is biodegradation of substance <20% in 28 days ? Is LC 50 or EC 50 < 1mg/l ? I s
s u b s t i t u t e
a v a i l a b l e ?
A. Permission D. Refusal of Permission Ranking B. Substitution (CHARM may be used as a decision supporting tool + expert judgement) C. Temporary Permission or D. Refusal of Permission (CHARM may be used as a decision supporting tool + expert judgement) Expert judgement positive? * Start yes yes yes yes yes yes yes yes no no no no no no no Develop new product no Does the substance meet 2 of the 3 following criteria: biodegradation <70 % in 28 days (OECD 301A, 301E) or <60 % in 28 days (OECD 301B, 301C, 301F, 306) bioaccumulation log Pow 3 or is BCF>100 and considering molecular weight toxicity LC 50 or EC 50 <10mg/l ** Management decision based on the outcome of the ranking