Since the introduction of synthetic-based mud (SBM) technology in the Gulf of Mexico, stakeholders have worked toward realization of the pollution-prevention aspects of SBM technology without losing the benefits of enhanced drilling performance. In addressing the issues of SBM in the Coastal Effluent Limitation Guidelines, the U.S. Environmental Protection Agency (EPA) recognized the pollution-prevention potential for SBM technology, but also determined that the exiting test protocols needed to be improved to measure environmental performance. In response to the Coastal Effluent Limitation Guidelines, industry work groups, including EPA scientists and engineers, took on the specific tasks of identifying and modifying test protocols that would allow continued positive development of SBM technology. The resulting test protocols for biodegradation, toxicity and analytical chemistry as described in the Effluent Limitation Guidelines for SBM technology will form the structure for usage of existing non-aqueous fluids and development of new fluids and fluid blends. This paper details the process of protocol and regulatory development, which is a success story applicable to other regulatory arenas and other issues in the U.S. The resulting regulatory framework and technology will lead to U.S. offshore operations becoming the hot bed of pollution prevention in the global offshore drilling community. The authors will show how continued use of SBM technology in the Gulf of Mexico will allow successful development of deepwater petroleum resources in an environmentally responsible manner. Introduction Synthetic-based muds (SBMs), pollution prevention, and zero discharge are all concepts that have become part of the dialog in discussions of offshore drilling. Recent completion of the Effluent Limitation Guidelines (ELG) for SBMs and other non-aqueous fluids (NAFs) has outlined the framework for usage of SBMs and discharge of SBM cuttings in the U.S. Outer Continental Shelf (OCS).1 These new guidelines impact both current operations and the development of future drilling fluids and solids-control technology. The introduction of new permit requirements and limitations can signal the end of some older technologies and open the door for opportunities for both existing and yet-to-be-developed technologies. By understanding the history, development, testing requirements and regulatory drivers, the continued opportunities for development and use of SBM technology as pollution-prevention technology becomes apparent. Background Water-based drilling fluids or muds (WBMs) use water or brine as the continuous or external phase with the critical functions (density, viscosity, filtration, lubricity, etc.) achieved with the addition of various materials. Non-aqueous systems use non-water-soluble base fluids as the continuous phase with water (or brine) emulsified and dispersed in the base fluid. Non-aqueous drilling fluids (NAFs) include diesel, mineral oils, enhanced mineral oils (EMOs), and synthetic base fluids (SBFs). Studies in the North Sea and elsewhere in the 1980s raised concerns about the environmental effects of the original, high-aromatic diesels that drove the introduction of EMOs and, in the 1990s the development of synthetic-based muds (SBMs). The SBMs were developed to deliver the same performance as oil-based muds (OBMs), but with lower environmental impact and enhanced worker safety through lower toxicity, elimination of Polycyclic Aromatic Hydrocarbons (PAHs), faster biodegradability, and lower bioaccumulation potential.

Acute benthic toxicity tests can be a useful tool for screening nonaqueous base fluids used in drilling fluids. These toxicity tests were originally designed to evaluate dredged spoil, and were adapted and introduced as a standard benthic test, using field sediments for approval of nonaqueous ( ) drilling fluids, by the Oslo & Paris Commission OSPAR in the North Sea in 1994. In the US, development of a standard benthic test for regulatory approval of nonaqueous drilling fluids and screening new base fluids is continuing. There is now some concern that the variability and nature of field sediments can cause effects in addition to the toxicity of the test material. Use of formulated sediment to replace natural sediment may greatly decrease this variability, and allow for greater interlaboratory comparisons. The formulated sediment developed and refined in this study consisted of 30% sand, 20% silt, 48% clay, 1% organic material, and 1% calcium carbonate. This formulation ( ) produced acceptable control survival )90% in ten toxicity tests using Leptocheirus plumulosus. The results of five diesel toxicity tests and five C1618 internal olefins toxicity tests produced coefficient of variations of 16.0 and 28.9, respectively, indicating the formulation can produce consistent test results.

TX 75083-3836, U.S.A., fax 01-972-952-9435. AbstractThe inability to consistently discriminate biodegradation performance inhibits the development and use of Synthetic-Based Muds ( SBMs) and other non-aqueous base fluids. Government regulators and industry representatives are discussing and seeking to improve the repeatability, discriminatory power and environmental relevance of the current bottle and simulated seabed biodegradation tests. To date, the existing protocols and procedures are only moderately successful in discriminating the performance of various base fluids. This study provides information on the modification and development of an existing freshwater anaerobic test (ISO/DIS 11734) 1 for use as a marine sediment anaerobic biodegradation test. This paper reviews and compares the repeatability, discriminatory power, practicality and ecological relevance of the modified test relative to the performance of other biodegradation tests and field data.

TX 75083-3836, U.S.A., fax 01-972-952-9435. AbstractThe inability to consistently discriminate biodegradation performance inhibits the development and use of Synthetic-Based Muds ( SBMs) and other non-aqueous base fluids. Government regulators and industry representatives are discussing and seeking to improve the repeatability, discriminatory power and environmental relevance of the current bottle and simulated seabed biodegradation tests. To date, the existing protocols and procedures are only moderately successful in discriminating the performance of various base fluids. This study provides information on the modification and development of an existing freshwater anaerobic test (ISO/DIS 11734) 1 for use as a marine sediment anaerobic biodegradation test. This paper reviews and compares the repeatability, discriminatory power, practicality and ecological relevance of the modified test relative to the performance of other biodegradation tests and field data.

Environmental and health issues are frequently nettlesome and often costly if left unaddressed. Within the last 40 years many industrialized countries have developed laws for protecting citizen's health and the environment. These laws have helped in the development of regulations minimizing the impact of environmental and occupational health issues. Translated to the workplace, these regulations drive companies to develop programs with a structured and consistent approach that will protect its workers, minimize its impact on the environment, and protect communities in which it does business. The implementation of a management system provides both governances in an easy-to-use fashion. This constructive means of facilitating, fostering and encouraging performance has shown very dramatic results throughout an oilfield service company. In 2000, the firm developed a health, safety and environmental management system that included standards to which company operations would adhere. Since the company operates in a number of countries, the standards were written in a general nature to allow for incorporation of local requirements. Each company location throughout the world was charged with implementing the requirements of the management system and making the changes necessary to conform to the corporate management system and the local regulations. Within a year of implementing the management system, audits were scheduled and performed at company facilities to confirm implementation and provide suggestions for further improvement to the management system. A scoring system was used to compare progress made by different sites within the same geographical area as well as progress made by locations throughout the company. This paper examines the cultural shift, attitudinal redirection and resultant changes in the company's business activities in the occupational health and environmental sectors. This includes the integration of risk assessments and job safety analyses, emergency response planning and training, and annual auditing as tools to improve performance with the results from more than 50 countries over seven years charted. Introduction In many instances, the regulated community relies on indicators that follow an event, commonly referred to as lagging indicators, to assess and manage health, safety, and environmental (HSE) performance. The thought process has been that no matter how careful or diligent workers are regarding HSE matters, incidents will simply "just happen". However, previous industry experience shows that leading indicators, events or actions that can aid in the prevention of an incident, can be used for HSE matters. Many root causes for HSE incidents are related to behavior and a development and implementation of an HSE Management System (MS) can help to reinforce positive behavior to assist in avoiding and preventing incidents. Often there is no correlation between behavior (leading indicators) and consequences (lagging indicators). For a management system to be successful and provide information that can yield positive results, it must be coupled with a method of documenting incidents. It is important to note that all incidents, whether they are reportable or non-reportable to a regulatory agency, must be reported and documented. In addition, a system must capture not only major incidents, but small minor incidents, whether reportable or non-reportable. The most efficient way to manage such data collection is to automate it, making it easy to input information and retrieve data. The amount of data that a system can maintain and the ease in which such a system can be searched may mean the difference between a recordkeeping matter and a major violation.