IBP44900 OFFSHORE DISCHARGE OF DRILLING FLUIDS AND CUTTINGS -A SCIENTIFIC PERSPECTIVE ON PUBLIC POLICY H. R. Melton1, J. P. Smith1, C. R. Martin1, T. J.

Nedwed1, H.L. Mairs1, D. L. Raught1

Copyright 2000, Brazilian Petroleum Institute - IBP
This paper was prepared for presentation at the Rio Oil & Gas Conference held in Rio de Janeiro, Brazil, 16-19 October, 2000 This paper was selected for presentation by the Event Technical Committee following review of information contained in an abstract submitted by the author(s). Contents of the paper, as presented, have not been reviewed by the IBP. Organizers will neither translate nor correct texts received. The material, as presented, does not necessarily reflect any position of the Brazilian Petroleum Institute, its officers, or members.

Abstract The most effective regulations or public policies are developed cooperatively by government and industry based on sound scientific understanding of the potential impacts, risk considerations, and evaluation of the costs and benefits of alternative approaches. This paper reviews the scientific framework that helped achieve general regulatory acceptance of the discharge of water-based drilling fluids and cuttings and discusses information being considered in current efforts to develop policies for the discharge of cuttings drilled with non-aqueous fluids (NAF). Development of effective policies for discharges depends on consideration of the specific local environmental conditions that govern the fate of discharge materials, the scientific basis for assessing the potential for effects in that environment, and balanced consideration of the environmental effects and relative costs of discharge versus other disposal options. This approach can lead to policies that provide for environmental protection and encourage adoption of mitigation measures that provide benefits commensurate with their cost. 1. Introduction

Scientific research provides a basis for development of effective policies governing discharge of drilling fluids and cuttings. This paper discusses the results of research on the effects of the discharge of drilling fluids and cuttings, the consideration of site-specific information in the environmental assessment of discharges, and the comparative evaluation of alternative drilling fluids and cuttings disposal options. This information has provided a framework for achieving general regulatory acceptance of the discharge of water-based fluids and cuttings and is providing useful information for current efforts aimed at developing policies for the discharge of cuttings drilled with NAF. The balanced consideration of research results, local environmental conditions, and the costs and benefits of disposal alternatives offers the most cost-effective way of achieving demonstrable environmental benefits. 2. Scientific Evaluation of Environmental Aspects of Drilling Wastes

During the past twenty years, a scientific framework has been developed to evaluate the fate and effects of discharges into the marine environment. The key elements of this framework include
_____________________________ 1 PHD, Chemical Engineering - ExxonMobil Upstream Research Company 2 PHD, Physical Chemistry - ExxonMobil Upstream Research Company 3 BS, Chemical Engineering, Business Administration - ExxonMobil Upstream Research Company 4 PHD, Environmental Engineering - ExxonMobil Upstream Research Company 5 MS, Ocean Engineering - ExxonMobil Production Company 6 BS, Civil and Environmental Engineering - ExxonMobil Upstream Development Company

IBP44900 characterization of effluent composition and volume, assessment of potential for effects of discharges, and field monitoring. Selected examples of results from this effort are discussed below to provide the key information about the composition and environmental effects of discharged drilling wastes. 2.1 Characterization of Drilling Waste Volume and Composition

Drilling wastes comprise drilling fluids and drill cuttings. There are two basic types of drilling fluids: water-based fluids (WBFs) and non-aqueous fluids (NAFs). WBFs have either fresh water or salt water as the primary fluid phase, while NAFs have either refined oil or synthetic materials as the primary fluid phase. For many wells, drilling conditions (e.g. deviated or horizontal wells, active shales) often require the use of NAFs instead of WBFs for efficient, cost-effective operations. In most cases, both WBFs and NAFs are used in drilling the same well, with WBFs used to drill the shallow portion of the well. Drill cuttings are pieces of the formation being drilled that are returned to the surface with drilling fluid. Solids control equipment separates the cuttings from the drilling fluids so that the drilling fluid can be reused. The cuttings then become a waste stream from the drilling process. A thin coating of drilling fluid adheres to the cuttings. Cuttings volumes depend on the type of fluid used, the depth of the well, and the size of the borehole. Estimated volumes per well range from 130 to 560 m3 per well (Hinwood, et al., 1994, USEPA, 1993). WBF may be discharged intermittently during the drilling process in batches of about 20 to 30 m3 volume or in larger volumes (approximately 200 m3) at the end of the drilling process or when the fluid system is changed out. The estimated volume of WBF discharges per well ranges from 500 to 1700 m3 per well. When NAFs are used, only the fluid that adheres to the cuttings is discharged. The valuable fluid is recycled for further use. WBF consists of water, salts, barite, bentonite and other minor additives. WBF composition depends on the density of the fluid. An example WBF composition for a 1190 kg/m3 fluid is (in wt %) 76 wt% water, 15% barite, 7 % bentonite and 2% salts and other additives (National Research Council (US), 1983). The barium in barite, a sparingly soluble mineral used to increase drilling fluid density, dominates the heavy-metal content of wastes from drilling with either WBF or NAF. Other trace metals are present at much lower concentrations. Neff (1988) compared the ranges of concentrations of metals found in drilling fluids and marine sediments and found that drilling fluids had concentrations of barium and chromium that fell outside the observed range naturally occurring in marine sediments. NAF consists of an organic base fluid, barite, water or brine, and specialty additives. NAF composition depends on fluid density. The United States Environmental Protection Agency (USEPA) (1999a) presented an example NAF composition of (in wt%) 47% base fluid, 33% barite, and 20% water. This example does not reflect a 2-5% content of additives such as fluid loss agents and emulsifiers that would be used in a NAF. NAFs are classified according to the type of base fluid used. Base fluids are in turn classified by their source and polycyclic aromatic hydrocarbon (PAH) content. Base fluids include oil based fluid (1-2 % PAH), low toxicity mineral oil based fluid (0.001% < PAH < 0.35%), enhanced mineral oil based fluid (PAH <0.001%), and synthetic based fluid (SBF, PAH <0.001%). The oil-based fluid category includes diesel oil based fluid and mineral oil based fluid. The low toxicity mineral oil based fluid includes materials refined from crude oil. Enhanced mineral oil based fluids and SBF are derived from different base materials, but
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IBP44900 both have very low PAH contents. Enhanced mineral oil based fluid comprises materials refined from crude oil whereas SBF comprises material generated by chemical reactions of relatively pure compounds including synthetic hydrocarbons. Because the heavy metals in barite are the main influence on the metals content of drilling wastes, the heavy-metal content of NAF and NAF cuttings should be very similar to those of WBF drilling wastes. 2.2 Assessment of Potential for Effects from Discharges The potential for environmental effects from drilling fluids and cuttings discharges is assessed through laboratory studies of toxicity and evaluation of bioaccumulation. Toxicity testing is a measure of the relative potential for direct adverse effects on marine organisms. Evaluation of bioaccumulation addresses the potential for uptake of waste components into marine organisms. The results of toxicity and bioaccumulation evaluations are useful when assessing the potential for environmental exposures with site-specific numerical modeling studies. 2.2.1 Toxicity Bioassay testing of drilling fluids focuses on the toxicity of whole drilling fluid or of individual drilling fluid components added to a base drilling fluid. Bioassays of whole drilling fluids permit the assessment of potential effects of materials actually discharged from drilling operations. Research has shown that bioassay test results for individual components might be considerably different from bioassay test results obtained on those same components in an actual drilling fluid (Sprague and Logan, 1979). Species for regulatory testing were chosen after assessing the sensitivity of a wide range of organisms. By 1983, the toxicity of water-based drilling fluids to 62 different species of marine animals from the Atlantic and Pacific Oceans, the Gulf of Mexico, and the Beaufort Sea (National Research Council (US), 1983) had been determined. USEPA chose one of the more sensitive crustacean species, Mysidopis bahia, as the standard organism for drilling fluid bioassays as part of its implementation of a toxicity limit on drilling fluid discharged to United States waters. US experience shows that discharged WBF will be low in toxicity. Toxicity values are reported as the 96-hour LC50, the concentration causing mortality of 50% of the test organisms during a 96-hour exposure, for the suspended particulate phase (SPP), a 1:9 mixture of drilling fluid and seawater. USEPA data showed that 99.9% of 10,397 Gulf of Mexico drilling fluid LC50s were in excess of 30,000 ppm (Science Applications International, Inc., 1992), the US regulatory limit on drilling fluid toxicity. This limit is met routinely in drilling operations. Due to rapid dilution, an organism entrained in a drilling fluid plume would be exposed to concentrations in excess of 30,000 ppm SPP (corresponding to approximately 0.3% whole drilling fluid) for only about 30 seconds. Thus, the 96-hour exposure used in the regulatory toxicity test is a very conservative exposure scenario. Industry has developed NAF systems that are lower in toxicity and environmental persistence than the original diesel based fluids while maintaining similar drilling performance. Toxicity testing shows that modern NAFs have low aquatic toxicity (Vik, et al., 1996 and USEPA, 1999b) as might be expected from materials with low water solubility and low aromatic content. NAF cuttings settle very rapidly out of the water column (Brandsma, 1996), further reducing possible environmental exposures of organisms. The tendency of NAF cuttings to settle to the seabed has focused attention on the toxicity of NAF to benthic (i.e., sediment-dwelling) species. Vik, et al., (1996) examined the aquatic and benthic toxicity of a range of SBF and found that they would not be considered toxic according to Norwegian government standards. Current efforts to determine the acceptability of discharge of NAF cuttings have motivated the development of new testing protocols for sediment
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IBP44900 toxicity. The results of this work will provide a more complete assessment of the sediment toxicity of the whole spectrum of NAF fluids. 2.2.2 Bioaccumulation of Drilling Discharge Components by Marine Organisms Laboratory studies of bioaccumulation of drilling fluid metals in marine organisms have found a small degree of barium and chromium uptake and little or no accumulation of other metals (Neff et al., 1988a and 1988b). When bioaccumulation has been observed, it has not been high enough to be harmful to the accumulating animals or predators. Studies of the bioaccumulation of mercury, cadmium, copper, lead, and arsenic from pure and impure barite (Neff, 1988b) concluded that the metals associated with drilling fluid barite are virtually non-available for bioaccumulation by marine organisms that might come in contact with discharged drilling fluid solids. Neff's results with barite have been confirmed by laboratory measurements which show that benthic organisms (Bowmer et al., 1996) and bottom-feeding fish (Stagg and McIntosh, 1996) do not bioaccumulate metals from actual NAF drill cuttings. Laboratory studies have shown that heavy metals in drilling fluids do not biomagnify in marine food webs (Neff et al., 1988a and 1988b). Similar results have been found in studies of biomagnification of heavy metals from sources other than drilling fluids. With the exception of organomercury compounds, which are not found in drilling waste discharges, concentrations of most metals in natural marine food webs show either no relation or an inverse relation to trophic level, indicating that food chain biomagnification of inorganic metals does not occur (Kay, 1984; Bascom, 1983; Amiard et al., 1980; Young and Mearns, 1979 and Schafer et al., 1982). Concerns over bioaccumulation of hydrocarbons associated with drilling wastes have centered around PAHs. Fortunately, all vertebrates have enzyme systems that enable the oxidation and expulsion of aromatics from the organism. For all species, the very low PAH content of modern NAFs effectively mitigates this concern. Consequently, bioaccumulation of hydrocarbons from NAF drilling fluid discharge is not expected to be a significant issue. An accepted measure of bioaccumulation potential for organic compounds is the octanol-water partition coefficient (log Pow). Studies have shown that substances with log Pow greater than 3 and a molecular weight less than 600 have a tendency to accumulate. However, most experts agree that a substance with a log Pow greater than 7 will not bioaccumulate in aquatic species through the gills because the molecules of such substances will be too large to move past the aqueous diffusion layer which is present at the water/gill interface (Rand, 1995). The limited bioaccumulation data available indicate that for most SBFs, log Pow coefficients are outside the range that would suggest significant bioaccumulation potential (Vik et al, 1996). The available laboratory test data indicates limited to no uptake of synthetics, with rapid depuration. 2.2.3 Field Monitoring and Evaluation Field monitoring provides a direct means of assessing the fate and effects of drilling fluids and cuttings discharged into the marine environment. Because drilling waste effluents are low in toxicity and rapidly disperse in the water column, monitoring studies have focused on assessment of effects on the seabed rather than in the water column. The results of these studies show that, for discharges of both WBF and NAF drilling wastes, local environmental conditions play a major role in determining the severity and extent, both temporal and areal, of seabed effects from drilling discharges. Results from selected monitoring studies are discussed below, with emphasis on the importance of local environmental conditions in determining the extent of effects.
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IBP44900 Field observations following discharge of WBFs and cuttings generally have shown very limited observable impact associated with drilling. These studies indicate (National Research Council (US), 1983) that the energy of the water column and seafloor environment is very important in determining the extent and duration of environmental effects. In environments with relatively high bottom currents (e.g. more than 35 cm/sec), no observable effects on the biota were seen although elevated barium concentrations were observed (Lees and Houghton, 1980; Houghton et al., 1980a and Houghton et al., 1980b, Neff et al., 1989 and Bothner et al., 1985). At a site in 120 meters of water with very low bottom currents (maximum bottom current of 19 cm/sec) elevated barium concentrations were found along with decreases in the abundance of megabenthic organisms (demersal fish and crabs) immediately following drilling (Ayers et al., 1980; Menzie et al., 1980; EG&G, 1982 and Gillmor et al., 1985). One year after drilling, only minor biological effects were observed. A decreased density of echinoderms (brittle starfish) was observed at a cluster of sampling stations within 100 meters of the well. This area of reduced density was small. The observation that the highest density of echinoderms was reported within 50 meters of the area of low density indicates that any effects of drilling fluid solids was limited in extent. The abundance of macrofauna in the post drilling study area exhibited only weak spatial trends and had no correlation with barium concentrations. The discharge of NAF cuttings causes initial adverse biological effects in the first few hundred meters around a discharge site (Davies et al., 1988). Recovery of sediment biological communities begins after a few years with the rate of recovery dependent on specific local conditions. For example, a study of a site where low toxicity mineral oil based fluid was used to drill one well offshore Australia in 80 meters water depth indicated that three years after drilling, no evidence of acute impact on species abundance or richness was noted and measurable differences in species richness were restricted to within 100 meters of the cuttings discharge point (Oliver and Fisher, 1999). In contrast, a study of an oil based mud discharge site in the Dutch sector of the North Sea in 40 meters depth (Dann and Mulder, 1995) found that eight years after drilling, recovery was underway but biological effects could still be clearly detected at stations less than 100 meters from the discharge site and less significant effects could be detected at distances of 250 meters. More recent studies of enhanced mineral oil based fluid and SBF discharge sites show evidence of relatively less severe effects and more rapid recovery. At an Australian site where enhanced mineral oil based fluid cuttings were discharged in 78 meters of water, Oliver and Fisher (1999) reported that elevated hydrocarbon and barium concentrations were observed at 200 meters from the discharge site. One year after drilling, sediment samples showed only trace amounts of hydrocarbons and background levels of barium. Terrens et al., (1998) monitored the discharge of SBF cuttings from 7 development wells in the Bass Strait (70 meters depth) and concluded that impacts on benthic infauna were not substantial and were localized in area and duration. Eleven months after drilling, SBF was not detected in sediments. Studies of SBF discharge from a single well in the North Sea (67 meters depth) conducted by Smith and May (1991) determined that immediately following drilling, faunal communities were impacted within 100 meters of the drill site, as evidenced by low species diversity and abundance, but after one year, there were substantial signs of faunal recovery. A study of SBF discharge from one exploratory well in the Gulf of Mexico (39 meters depth, Candler et al., 1995) indicated that two years after drilling, macrofaunal impacts (reduced species richness, diversity relative to reference) were limited to within 50 meters of the drill site and that in the presence of SBF levels up to 1000 mg/kg, macrofaunal indices were similar to background indices. A consortium of operators and US government agencies is sponsoring a comprehensive seabed survey of Gulf of Mexico NAF discharge sites in the 20005

IBP44900 2001 time frame. This study will examine 8 sites, including 3 deepwater sites, where NAF cuttings were discharged. This survey should add substantially to the current base of information. 2.3 Consideration of Site-specific Conditions in Environmental Assessments Site-specific information plays an important role in the environmental assessment of discharges. Discharges may be inappropriate at sites located in waters where mixing is limited, or where there are especially sensitive environmental features such as coral reefs or mangroves. For other areas, site-specific oceanographic conditions should be considered in decisions about the acceptability of discharges. For both water-based and NAF materials, scientific studies indicate that local conditions of current, depth, temperature, and amount of material discharged all play a role in determining the severity and extent, both areal and temporal, of effects on seabed biological communities. Numerical models are useful in predicting the fate of discharges using site-specific environmental conditions. Model predictions can be helpful in providing a perspective on the extent of elevated water column concentrations of discharged components or on the areal extent of accumulations of solids on the seabed. For this paper, the Offshore Operators Committee Mud and Produced Water Discharge Model (OOC model) was used to predict water column solids concentrations and seafloor solids loading resulting from WBF, WBF cuttings, and NAF cuttings discharged from drilling a single, deepwater (1200 meters) exploration well. Current and hydrographic data used for modeling were taken from field measurements. The OOC Model is a computer program that predicts the initial fate of drilling fluid, drill cuttings, and produced water discharged into the marine environment (Brandsma et al., 1992). The predictions of this model have been used in the development of regulations in the United States (Avanti Corporation, 1993) and incorporated in the CHARM (Chemical Hazard Assessment / Risk Management) model developed for use in the North Sea (Karman and Vik, 1996). The OOC Model's predictions have been validated by comparison to the results of field (O'Reilly et al., 1988) and laboratory (Brandsma, et al., 1992) observations of plume behavior. Model predictions illustrate how the rapid dilution of drilling discharges eliminates the potential for adverse effects on organisms in the water column. For a discharge of WBF solids at a rate of 16 m3/hr into a current of 7.2 cm/s, predicted WBF solids concentration dropped from 121,000 mg/l at the source to approximately 25 mg/l at 100 meters and 8 mg/l at 250 meters from the discharge point (Figure 1). The concentration of WBF solids in the water column drops below the US minimum 96-hour LC50 (corresponding to approximately 0.3% whole drilling fluid) within 9 meters of the source. A planktonic organism that drifts with the current and passes directly under the discharge pipe during the discharge would be exposed to a concentration as high as the minimum US 96-hour LC50 for less than 30 seconds. Due to faster fall velocities, the predicted concentrations for WBF cuttings and especially NAF cuttings decrease more rapidly than the corresponding concentrations of WBF solids. This analysis shows that drilling discharges pose a minimal risk of adverse effects to organisms in the water column.

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Figure 1. Model-predicted maximum water column solids concentrations from drilling discharges. The distance shown on the x-axis is the horizontal distance from the discharge point. Effluent solids concentrations are 121,000 mg/l, 1,000,000 mg/l, and 1,000,000 mg/l for the WBF solids, WBF cuttings, and NAF cuttings discharges, respectively. The line marking 0.3% of initial concentration approximates the minimum 96-hour LC50 for drilling fluids allowed under US regulations. The OOC Model was used to predict seabed solids loading caused by drilling discharges using two scenarios. In the first scenario, a 4,000 m well drilled with WBF only was simulated to release 703 m3 of WBF solids (e.g., bentonite and barite) and 623 m3 of WBF cuttings into 1200 meters of water. In the second scenario, NAF was used in place of WBF to drill all hole intervals below the conductor. In this scenario, the release of 498 m3 (less hole washout was assumed) of NAF cuttings was simulated. The average current speed decreased from 17 cm/s near the surface to 6 cm/s near the seabed. The model predicted the seabed loading caused by discharges made near the sea surface. The modeling did not account for the discharge of WBF cuttings from the first section of the well that will occur near the seafloor. These seafloor discharges can cause significant cuttings accumulations near the well site. NAF cuttings fall through the water column more rapidly than WBF cuttings and this results in a higher predicted seabed loading for NAF cuttings (greater thickness, smaller area) than for WBF cuttings. The predicted maximum cuttings accumulation depths are 0.19 cm for the WBF cuttings/solids and 1.3 cm NAF cuttings. Cuttings loadings decrease rapidly with distance from the discharge point. For the NAF discharge, seabed cuttings loadings decrease by more than an order of magnitude less than 200 meters from the discharge point. The low deposition density and limited areal extent of solids accumulation predicted for both scenarios should cause minimal initial effects (e.g., smothering) and allow for rapid natural recovery.

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Figure 2a. Seabed loading contours from the discharge of WBF solids and cuttings into 1200 m of water. Contour lines show the predicted depth of cuttings accumulations; cross marks the discharge point. 3.

Figure 2b. Seabed loading contours from the discharge of NAF cuttings into 1200 m of water. Contour lines show the predicted depth of cuttings accumulations; cross marks the discharge point.

Evaluation of Alternative Drilling Fluids and Cuttings Disposal Options

The potential for effects of discharges on the marine environment must be considered alongside the environmental effects and incremental costs of alternative disposal options in the process of identifying the best overall environmental solution. Alternatives to discharge all involve additional incremental costs and have their own set of environmental consequences. Considering that the discharge of water-based fluids and cuttings is widely accepted, the following discussion centers on alternatives to the marine discharge of wastes from drilling with NAF. Alternatives to marine discharge of NAF wastes include drilling a larger fraction of the total depth with water-based drilling fluids, onshore disposal of NAF drilling wastes, and injection of NAF drilling wastes. Some drilling situations (e.g., high temperatures, sensitive formations, extended reach drilling) require NAF usage, so WBF can be substituted for NAF only to a limited extent. Increasing the use of WBF involves environmental tradeoffs including longer drilling time which increases air emissions, increased energy use, and workplace hazard exposures. Drilling with WBF will also increase the volume of drilling waste compared to drilling with NAF, since wellbores drilled with WBF tend to be larger due to more formation solids sloughing off the borehole wall. Onshore disposal of NAF wastes will result in greater air emissions and energy use due to the need to transport cuttings ashore and transport them to a final treatment and disposal site. Onshore NAF cuttings disposal will take up land area, and energy and financial resources will be required to manage the facility properly. NAF cuttings can be injected into some subsurface formations. Injection results in greater energy use and air emissions relative to discharge. Incremental costs are incurred for the injection facilities and for any downtime of the injection plant, during which drilling operations must cease unless cuttings can be discharged. More importantly, injection from floating drilling rigs is an experimental technology (Ferguson, et al., 1993) which is not be practical under most conditions.

4.

The Role of Science in Regulatory Decisions

In summary, there is a scientific framework for evaluating potential impacts from discharging drilling wastes. In many environmental settings, these discharges will not cause significant environmental harm. Discharges are permitted in major petroleum producing provinces such as Australia, the United States and the North Sea where regulatory agencies found drilling discharges acceptable. Currently, industry is working with the USEPA to develop criteria for acceptable NAF cuttings discharge by providing information on test methods, environmental effects and the performance of treatment technology. The program includes development of laboratory protocols for testing fluids, and a field survey to examine several sites where NAF cuttings were discharged in the past. By ensuring that all available data are considered, such a cooperative approach, involving industry expertise and regulators, can serve as a good model for developing effective public policy elsewhere. It is our view that all data, including available field surveys to understand how laboratory testing relates to actual field performance, should be considered. By using sound science, industry and government agencies can prioritize issues and quantify potential environmental effects from different management options. This helps to ensure prudent investment in mitigation measures that result in real environmental benefits while avoiding measures that result in little or no positive environmental return. Through mutual cooperation, government agencies and industry can refine and develop regulations based on sound scientific principles that allow industry to conduct business in a cost-effective manner while responsibly protecting the surrounding environment. References Amiard, J.C., Amiard-Triquet, C., Metayer, C., Marchand, J., and Ferre, R. (1980). Etude du Transfer de Cd, Pb, Cu, et Zn dans les Chaines Trophiques Neritiques et Estuariennes. I. Etat dans L'estuuaire Interne de la Loire (France) au cours de l'ete 1978. Water Res. 14:665-673. Avanti Corporation (1993), "Ocean Discharge Criteria Evaluation for the NPDES General Permit for the Western Gulf of Mexico OCS" EPA Contract No. 68-C9-0009 Work Assignment S-4-49(P), Task 161, prepared for USEPA Region 6, Dallas TX Dated August 9, 1993. Ayers, R.C., Jr., Meek, R.P., Sauer, T.C., Jr., and Stuebner, D.O. (1980a), "An Environmental Study to Assess the Effect of Drilling Fluids on Water Quality Parameters During High Rate, High Volume Discharges to the Ocean." Proceedings of Symposium, Research on Environmental Fate and Effects of Drilling Fluids and Cuttings, January 21-24, 1980, Lake Beuna Vista, Florida, Vol. I, pp. 351-379. Ayers, R.C., Jr., Sauer, T.C., Jr., Meek, R.P., and Bowers, G. (1980b), "An Environmental Study to Assess the Impact of Drilling Discharges in the Mid-Atlantic. I. Quantity and Fate of Discharges." Proceedings of Symposium, Research on Environmental Fate and Effects of Drilling Fluids and Cuttings, January 21-24, 1980, Lake Buena Vista, Florida. Vol. I, pp. 382-418. Bascom, W. (1983), The Non-Toxicity of Metals in the Sea. MTS Journal 17: 59-66. Bothner, M.H., Rendigs, R.R., Campbell, E.Y., Doughton, M.W., Parmenter, C.M., O'Dell, C.H., Dilisio, G.P., Johnson, R.G., Gillison, J.R. and Rait, N. (1985), "The Georges Bank Monitoring Program: Analysis of Trace Metals in bottom Sediments during the Third Year of Monitoring", Final Report submitted to the US Minerals Management Service. Prepared by the US Geological Survey, Woods Hole, MA. 99p. Bowmer, C.T., Gimeno, S., Foekema, E.M., Kaag, N.H.B.M. (1993); "An Environmental Evaluation of Cleaned Drill Cuttings Using a Long Term Model Ecosystem Bioassay" Paper 6 in

E&P Forum Joint Study - The Physical and Biological Effects of Processed Oily Drill Cuttings (Summary Report), E&P Forum Report No. 2.61/202 April 1996. Brandsma, M.G., Davis, L.R., Ayers, R.C., Jr., and Sauer, T.C., Jr.(1980). " A Computer Model to Predict the Short-Term Fate of Drilling Discharges in the Marine Environment", Proc. Symp. on Research on Environmental Fate and Effects of Drilling Fluids and Cuttings, January 21-24, 1980, Lake Buena Vista, Florida. Volume 1, pp. 588 - 608. Brandsma, M.G. and Sauer, T.C., Jr., 1983a, "The OOC Model: Prediction of Short Term fate of Drilling fluid in the Ocean. Part 1: Model Description". Proceedings of MMS Workshop on An Evaluation of Effluent Dispersion and Fate Models for OCS Platforms, February 7-10, 1983, Santa Barbara, California, Minerals Management Service, Contract No. 14-21-0001-29122, pp. 58-84. Brandsma, M.G. and Sauer, T.C., Jr., 1983b, "The OOC Model: Prediction of Short Term fate of Drilling fluid in the Ocean. Part 2: Model Results". Proceedings of MMS Workshop on An Evaluation of Effluent Dispersion and Fate Models for OCS Platforms, February 7-10, 1983, Santa Barbara, California, Minerals Management Service, Contract No. 14-21-0001-29122, pp. 86-106. Brandsma, M.G., Smith, J.P., O'Reilly, J.E., Ayers, R.C., Jr., Holmquist, A.L. (1992), "Modeling Offshore Discharges of Produced Water" in Produced Water: Technological/Environmental Issues and Solutions, Ray, J.P. and Englehardt, R. eds. Plenum Press , NY, pp 59-71.; PDOX Brandsma, M.G. (1996); "Computer Simulations of Oil-Based Mud Cuttings Discharged in the North Sea " pp 25 - 39 in E&P Forum (1996) OBM Study E&P Forum (1996); "E&P Forum Joint Study - The Physical and Biological Effects of Processed Oily Drill Cuttings (Summary Report)" E&P Forum Report No. 2.61/202 April 1996. Candler, JE, Hoskin, S. Churan, M. Cui Wei Lai, Freeman M. (1995). Seafloor Monitoring for Synthetic Based Mud Discharged in the Western Gulf of Mexico. SPE Paper 29694. Crippen, R.W., Hodd S.L. and Greene, G. (1980), "Metal Levels in Sediment and Benthos Resulting from a Drilling fluid discharge into the Beaufort Sea", Proceedings of Symposium, Research on Environmental Fate and Effects of Drilling Fluids and Cuttings, January 21-24, 1980, Lake Buena Vista, Florida. Vol. I, pp. 636-669. Dann, R., and M. Mulder (1995); "Long Term Effects of OBM Cutting Discharges in the Sedimentation Area of the Dutch Continental Shelf " NIOZ Rapport 1995 - 11 Davies, J., Bedborough, D., Blackman, R.A.A., Addy, J., Appelbee, J., Grogan, W., Parker, J.G., Whitehead, A. (1988), "The Environmental Effects of Oil Based Mud Drilling in the North Sea", in Drilling Wastes, The Proceedings of the 1988; International Conference on Drilling Wastes, Calgary, Alberta,; Canada 4/5-8/88,Engelhardt, F.R., Ray, J.P., Gillam, A.H., eds. pp 59-89. EG&G Environmental Consultants. (1982), "A Study of Environmental Effects of Exploratory Drilling on the Mid-Atlantic Outer Continental Shelf", Final Report of the Mid-Atlantic Monitoring Program. EG&G, Waltham Mass. Offshore Operators Committee, Environmental Subcommittee, POB 50751, New Orleans, La 70150. Ferguson, G.C., Minton, R.C., Cow, S.,and Secoy, B.W. (1993), "Subsea Cuttings Injection Guide Base Trial", SPE Paper 26681 Presented at the Offshore Europe Conference , Aberdeen, 7-10 September 1993. Gillmor, R.B., Menzie, C.A., Mariani, G.M., Levin, D.R., Ayers, R.C., Jr., and Sauer, T.C., Jr., (1985), "Effects of Exploratory Drilling Discharges on the Benthos", Wastes in the Ocean, Volume 4: Energy Wastes in the Ocean. John Wylie & Sons, Inc. 1985, pp. 243-270.

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