Unlock Regulatory Requirements for Drill Cuttings Waste Utilisation Pilot

Drill cuttings waste was recycled into new use and pilot project to utilize drill cutting waste in road and construction application were carried out. This work describes strategy and best practice to engage regulator in order to unlock regulatory requirements for the pilot on drill cutting waste utilization. Characterization of drill cuttings waste was carried out and its regulatory requirements as indicated in waste management plan and EIA were investigated in parallel to the study on technical feasibility to utilize drill cuttings waste. Equally important is investigation on the rule and regulation relevant to areas and/or industries that the drill cuttings waste will be used for. These regulatory requirements must be clearly identified in an early stage of the pilot project as it will indicate necessary analytical tests to be carried out and will provide information for designing of an environmental impact assessment and monitoring program. Drill cuttings waste is classified into two groups based on type of drilling mud used. Drill cuttings from upper section of well contaminated with water-based mud, called top-hole drill cuttings, is classified as non-hazardous waste while drill cuttings from lower section of well contaminated with synthetic-based mud, called bottom-hole drill cuttings, is classified as hazardous-minor waste. Physical properties of the drill cuttings waste such as pH, conductivity, salinity, chemical properties on chloride contents as well as heavy metal contents must be analyzed and identified to be within the standard limit. These analytical results provide necessary technical information for regulator to make decision based upon in order to support the drill cuttings waste utilization pilot. Based on characteristic of road usage and potential wear and tear of the pilot recycled drill cuttings road, environmental impact assessment and monitoring program on soil, surface water, and subsurface water on areas closed to the pilot site were performed prior and after construction of the pilot road. This environmental impact assessment and monitoring program provides track record of technical analytical data which is essential supporting information for regulator's consideration and endorsement on the future modification of EIA's regulatory requirements. This work demonstrates that good understanding on classification of the drill cuttings waste, its regulatory requirements, characteristic of application the drill cuttings waste will be used for, and its relevant legislations are essential. This information indicates necessary technical analyses required to be performed in order to obtain important technical data to unlock regulatory requirements. Drill cuttings waste utilization not only save waste management cost, but also reduce environmental footprint. This approach can be applied to utilization of other type of waste as well.