Corporate Strategy to Tackle Offshore Drilling Discharge Regulation

This paper provides an overview of the main efforts that are being endeavored by Petrobras in order to contribute for developing a Brazilian regulation for use and discharge of drilling fluids and cuttings from offshore oil and gas operation, based on operational safety, well integrity and environmental aspects. In early 2018, the Brazilian Environmental Agency launched a Normative Instruction (IN 01/2018) addressing some new conditions for use and discharge of fluids and cuttings from offshore drilling rigs. This regulation is based on the EPA rules, although some relevant points deviate from it, such as the prohibition for discharging drilling fluids and cuttings associated with hydrocarbon reservoir sections. Additionally, this regulation mentions a potential zero discharge by 2022. Due to the challenges for meeting these new requirements and some uncertainty about the real environmental benefits, Petrobras has been developing fundamental and applied studies, research development and protocols in this area. Petrobras settled an innovative governance model to deal with the new regulation, its consequences and interfaces. It works as a multidisciplinary committee coordinated by an executive manager. It involves a law support for environmental issues and four work fronts, such as (1) linking between internal and external organization (2) guarantee of providing the required infrastructure (3) economical and operational impacts (4) technologies (research, development, studies and protocols) dedicated for related matters. Concerning the forth front, seven important initiatives were initially addressed and cover topics such as operational safety, well integrity – including offshore wells dedicated to cuttings disposal, laboratory protocols and environmental issues. Some relevant studies are those concerning LCA (life cycle analysis), options for avoiding landfill as final cutting disposal onshore and the quantification of oil compounds in drilling fluids and cuttings from the pay zone well section. The lack of knowledge about the whole impact for onshore destination as drilling waste management strategy, the improvements that still have to be established in order to achieve better operational practices and the comprehension of the input of oil from drilling discharges are the main drivers of this paper. The results help to clarify cloudy topics and, consequently, contribute to create a new basis for building or revisiting some aspects of the present regulation.