Echnical Eport: Drill Cuttings JIP

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TECHNICAL REPORT

Drill Cuttings JIP

Phase I Summary Report

Revision 2: 20th January 2000


DNV Order Number: 29003500
(p:\a9\atc\0001-0050\003500\r2\003.doc)

20 January 2000
Sponsors of the Drill Cuttings JIP
Phase I Summary Report (Rev 2)

Client:

Client Contract No:

Title of Report:

Phase I Summary Report

Indexing Terms:

Drill cuttings, JIP, environment, impact, BEP, BAT

Summary:

This report summarises all the research work done under Phase I of
the Drill Cuttings JIP
Louis Backwell, Susan Stephens, Amy Annand, M Stewart
(support), Andy Bolsover
Prepared by:
Approved by:

Work Carried Out By:


ATC Order No.

29003500

L Backwell

A. J. Bolsover

Document Revision Record


Rev No
0
1
2

Issue Date
7th Jan00
17 Jan00
20 Jan00

Reason for Issue


Issued for discussion
Incorporating Client Comments
Final Report

Aberdeen Technical Consultancy

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Prepared by
LBACK
LBACK
LBACK

Approved by
SMS
AJB
AJB

20 January 2000
Drill Cuttings JIP
Phase I Summary Report (Rev 2)

CONTENTS
Page
EXECUTIVE SUMMARY (2 Pages)

1.0 INTRODUCTION

2.0 OVERVIEW OF PHASE 1 RESEARCH AREA REPORTS

3.0 OVERALL DISCUSSION AND CONCLUSIONS


3.1 Summary of Findings
3.2 Outstanding Issues
3.3 Further Comments

4.0 REFERENCES

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20 January 2000
Drill Cuttings JIP
Phase I Summary Report (Rev 2)

EXECUTIVE SUMMARY.
The 1998 OSPAR meeting in Sintra led to the regulation of the decommissioning of
offshore installations. At that time there was little information on:
the means to avoid or minimise the disturbance of associated drill cuttings,
the effect of releasing the contents,
the effects of different disposal methods for cuttings pile materials.
As a result a Joint Industry Project (JIP) commissioned a 1 million research
programme to establish the best ways of dealing with these issues.
The 15 research areas funded by the JIP were targeted towards three key areas. These
are problem definition, potential solutions and developing a framework for evaluation
of management options. The key findings are as follows.
Problem definition.
An improved knowledge on volumes and composition of cuttings piles and the lack of
any correlation between these and well history was determined. There is little toxicity
information available other than for hydrocarbon content where a no-effect
concentration of 10 mg/kg has been suggested. Recolonisation begins 1-2 years after
discharge cessation by opportunistic species and the rate increases relative to distance
from the pile centre. A rapid rate of organic matter decomposition has been identified
and precipitation of metal sulphides within a pile (reducing bioavailability) and low
exchange rates with overlying seawater was observed. A wide range of contaminants
has the potential to be naturally biodegraded, but time scales are likely to be long and
vary between and within piles. Erosion is likely to be of greater significance than
sedimentation. Non-validated, but pragmatic disturbance mechanism data were input
into an existing mathematical model, and examples of contamination dispersion have
been produced based on identified mechanisms and natural events.
Potential solutions.
Degradation by both anaerobic and aerobic means is likely, but limited by availability
of electron acceptors e.g. oxygen, and strategies have been developed for acceleration
of degradation. Containment is reasonably practicable, but contained aquatic disposal
would cause significant environmental impact during construction and a cover would
slow degradation. Recovery systems are potentially capable of accessing the majority
of cuttings and achieve > 90 % recovery. Substantial dilution with seawater is likely,
however, in most techniques. The impacts from these systems have been assessed. It is
suggested their impacts are more dependent on pile characteristics than on the removal
techniques employed, and will probably be within the area effected by original drilling
operations. Most will use the same amount of power. On-shore processing capacity in
the UK and Norway is sufficient and typical energy consumption is reported. Landfill
capacity is available except for untreated oily waste, but limited to England, requiring
long distance transportation. Treatment and disposal costs are reported. Re-use
opportunities are limited and would require processing. Re-injection is currently the
only established technique for processing cuttings offshore, but if no suitable formation
is available, on-shore processing is currently the only technique to satisfy existing
regulations. Techniques reviewed are limited by weight/space demands and emerging
technologies could become viable in the future.
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Evaluation framework.
A three-tier framework has been suggested encompassing
(i) preliminary site assessment; (ii) generic quantitative assessment of specific
chemical, physical and biological data, risk assessment, including modelling of cuttings
dispersion scenarios and assessment of the potential that any disturbance may affect the
local ecosystem; and (iii) an assessment of the management options to aid decision
making in the determination of BEP and BAT for the remediation of any specific pile.
While all research areas have been completed on time, the conclusions identified above
have in some cases been developed against a background of data limitations that have
qualified the results. Such limitations and other gaps in the research areas of Phase I
are identified in the report. As a result of the uncertainties remaining there is a
requirement for more work in addition to and associated with field trials in Phase II.

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Drill Cuttings JIP
Phase I Summary Report (Rev 2)

1.0

INTRODUCTION
DNV has been requested by the sponsors of the Drill Cuttings Joint Industry Project
(JIP), supported by UKOOA, to prepare an overall summary of the results of the
research activities undertaken in Phase I of the programme. While all research areas
have been completed on time, the conclusions have in some cases been developed
against a background of data limitations that have qualified the results. As a result of
the uncertainties remaining there is a requirement for more work. Recommendations
for such work to be carried out in Phase II will be formulated and prioritised at a second
stakeholder meeting to be held in February 2000. Phase II is intended to further
knowledge about cuttings piles and investigate a set of potential options, based on the
results and feedback from Phase I, by conducting further research and field trials.
The R&D, Phase I programme of the JIP, developed from the Drill Cuttings Initiative,
was established by UKOOA in collaboration with the E&P Forum (now the
International Association of Oil and Gas Producers) and supported by the Norwegian
Offshore Association, in June 1998. It was further refined during the stakeholder
workshop held in November 1998, when additional priorities were identified. Details
of this workshop can be obtained from the Environmental Council web-site www.theenvironment-council .org.uk.
The objective of the programme is to identify the Best Environmental Practice (BEP)
and Best Available Technology (BAT) (Reference1) 1 for dealing with drill cuttings
piles in the North Sea, in accordance with the principles set out by the OSPAR
Convention.
The first phase of the JIP programme mainly comprised desktop studies with the
objectives to:
establish the current state of knowledge
investigate various solutions for the management of cuttings piles encompassing
the complete range of options from leaving in place to their removal.
The process of achieving the deliverables of Phase I, the research areas identified and
the details of the R&D groups awarded the work, can be found on the UKOOA website, www.ukooa.co.uk. Details of the Scientific Review Group and their function to
add independent quality assurance to the science can also be found at this site.
The work conducted in Phase I have fallen into three main areas:
Problem Definition
Potential Solutions
Evaluation Framework
Problem Definition
In order to advance an acceptable methodology and allow for improved assessment, it
has been necessary to establish the current state of knowledge of the problem issues,
namely:

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20 January 2000
Drill Cuttings JIP
Phase I Summary Report (Rev 2)

cuttings accumulation content, the characteristics of toxicity and contaminant


leaching,
colonisation,
identification of potential disturbance mechanisms and quantification of the likely
extent of disturbance, in terms of probability and volume of material disturbed ,
mathematical modelling capability for predicting dispersal of cuttings pile material
The last two points assist with problem definition and also encompass impact prediction
and assessment.
Potential Solutions
In order to decide what potential solutions could be trialed under Phase II, solutions
have been identified and their advantages and disadvantages assessed.
The potential solutions fall into two possible categories, namely,
In-Situ:
leave in place to allow natural degradation and recovery
bioremediation - acceleration of natural degradation
covering and confined aquatic disposal
Removal:
lifting, followed by
onshore disposal
offshore disposal
Consideration of potential solutions has to also include an Environmental Impact
Assessment.
Evaluation Framework
A consistent framework for evaluating the possible management options for a particular
drill cuttings pile is required.

Table 1.1: Summary List of Research Areas in Phase I


Ref
Research area
Problem Definition
1.1
Cuttings pile Contents

1.2

Cuttings pile Toxicity

2.1

In-Situ Environmental
Impact
In-Situ Environmental
Impact

2.2

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Title
Determination of the physical characteristics of
cuttings piles, using existing survey data and
drilling information
Determination of the toxicity characteristics of
cuttings piles, using existing survey data and
drilling information
Faunal colonisation of cuttings piles based on
literature review and field studies
Contaminant leaching from drill cuttings piles
based on literature review and field studies.
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2.3

In-Situ Environmental
Impact

3.1

Environmental Effects
from Disturbance
3.2
Environmental Effects
from disturbance
Potential Solutions
4.1
Bioremediation
Solutions
5.1
Covering Solutions
6.1

Removal solutions

6.2

Removal Solutions

6.3

Removal Solutions

7.1

Onshore Disposal
Solutions
Offshore Disposal
Solutions
New Technology

7.2
8.1

Evaluation of Options
9.1
Cuttings Pile
Acceptance Criteria

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Natural degradation and estimated recovery


timescales based on literature review and field
studies
Identification and quantification of potential
disturbance of in-situ piles
Mathematical model of pile dispersal following
disturbance
Acceleration of natural degradation
Study into the practicality of covering cuttings
piles in-situ
Identification and effectiveness of drill cuttings
removal methods
Proposed methods of lifting drill cuttings for
treatment/disposal (incorporated into 6.1)
Determination of environmental effects of
removal solutions
Study into the impact of onshore disposal of
recovered pile contents
Study into the impact of offshore disposal of
recovered pile contents
To encourage invention and development of new
technology and assess the benefits and difficulties
of such new technology (Incorporated into all
solution research areas)
Determination of an evaluation framework for
cuttings piles management.

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Drill Cuttings JIP
Phase I Summary Report (Rev 2)

2.0

OVERVIEW OF PHASE 1 RESEARCH AREA REPORTS


This section gives a short summary of the work done under each of the research areas as
detailed in Table 1.1. It highlights the original aims of the work and whether they have
been achieved. In each case the full details of the work are given in a separate report.
See section 4.0 for the detailed reference list.

2.1

Research Area 1.1 Cuttings Pile Contents.


Aim

Achievements

Gaps

To determine the range of physical characteristics from existing


survey data and drilling information and quantify overall
deposition in both dimension and composition
1. The volume of existing cuttings is now estimated to be larger
than previously estimated
2. Improved knowledge of pile composition
3. There is no identified pattern for any correlation between pile
composition and well history of contaminant accumulation
except for cadmium and poly-aromatic hydrocarbon
concentrations (non-significantly).
Detailed data on the majority of piles has yet to be determined
Data that was provided was limited and of variable quality.

Short Summary of the work


Available data on existing drill cuttings piles were collected, principally from operators,
SCOPEC International Ltd and previous studies. Of the 124 identified multi-well
installations in the central and northern North Sea information for the following pile
numbers was provided. In some cases full data was received for individual piles:
mapped pile dimensions for 44
full or partial data for discharged cuttings for 63
full or partial data for discharged mud for 22
chemical discharge data for 18.
Using the derived equations and mapped pile volume data it was estimated that there
are approximately 700,000m 3 of in-situ cuttings in the central North Sea and 500,000m 3
in the northern North Sea. These combined volumes are almost double those previously
estimated by the ODCP report in 1998 (Reference 2).
Compositional data were received from fifteen multi-well sites. The various data
reported were not uniformly collected among installations, but total hydrocarbons and
polycyclic aromatic hydrocarbon (PAH) were reported for most of the sites. Data on
metals content were less comprehensive but were reported for some installations. There
was little or no information available on contaminants in cuttings piles such as naturally
occurring radioactive material (NORM) and endocrine disrupters and site specific
concentrations were not reported.
For sites where full datasets were received, correlation and regression co-efficients for
discharge volume, discharge weight, water depth and caisson height above sea bed were
derived in order to see whether there were any relationships. Mean data at each depth
through each pile were examined to try and identify distribution patterns.
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Correlation analysis showed that all the examined parameters vary without any obvious
pattern of, or, through the piles. Therefore no conclusions can be drawn indicating a
relationship between accumulation composition and the other factors considered. The
only exception to this is an indication that cadmium concentrations are higher and polyaromatic hydrocarbon concentrations are lower towards the pile surface although the
reason for this is uncertain
The difficulty in determining distribution patterns could be due to reasons such as
disturbance by other operational factors, the low number of pile sampling studies
performed, the variable characteristics of sampling devices and locations, or the
inherent heterogeneity of the piles.

2.2

Research Area 1.2 Cuttings Pile Toxicity


Aim
Achievements

Gaps

To determine from existing information the likely toxicity of pile


material in sediment and water column.
1. Little information on the toxicity of the piles is available
except for the hydrocarbon content
2. Acute effects may be expected in the region of 100 mg/kg
3. Chronic effects may be expected to occur above concentrations
in the region of 10mg/kg
1. Information on chronic and sublethal toxicity of the whole
material
2. Information on bioavailability of components of the waste
3. Potential extent of bioaccumulation and the consequent effects

Short Summary of the work


The project considered the available information on composition and toxicity of
cuttings, the toxicity of drilling mud components, petroleum hydrocarbons, metals and
other possible organic contaminants. It also considered the relevance, applicability and
precision of the available toxicity data and ancillary information on toxicokinetics of
some key components.
For total hydrocarbons it was difficult to draw firm or quantitative conclusions
although it has been determined, with some caution, that there is an order of magnitude
convergence of data derived from relevant studies. These suggest that acute toxicity
effects are frequently detectable at concentrations in the region of 100g/kg, and above,
oil in sediment. This indication is consistent with results of laboratory tests on drilling
base fluids, suggesting that acute effects are an expression of nonpolar narcosis. The
corollary of this observation is that chronic toxic effects may be expected to occur
above concentrations in the region of 10mg/kg, and above, oil in sediment.
For the pile contents as a whole there is a limited amount of information, especially
recent information, on toxicity levels, which prevents any other definitive conclusions.
The three main gaps are:
information on chronic and sublethal toxicity of the whole material
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Phase I Summary Report (Rev 2)

information on bioavailability of components of the waste


potential extent of bioaccumulation and the consequent effects
On being made aware of these information gaps the sponsors of Phase I approved a
variation to the scope of work under this area to allow some additional toxicity studies
to be conducted.

2.3

Research Area 2.1 In-Situ Environmental Impact


Aim
Achievements

Gaps

To review existing information on patterns of species colonisation


of piles and relate to models of benthic succession
Confirmation that recolonisation begins 1 2 years after cuttings
discharge cessation initially by bristle worms during the first 5
years and that recolonisation rates increase in relation to distance
from centre of pile.
1. There is a lack of base data for representative (deeper) pile
thickness and sample methods were inconsistent.
2. Effect of pile composition and modelling of understanding of
processes is not covered possibly due to lack of data.

Short Summary of the work


The research area workscope included:
To undertake a literature review and ascertain the current status of knowledge on
recolonisation.
To assess availability of appropriate historic benthic survey data to study
recolonisation of drill cuttings.
To review the available macrofaunal data and identify any trends and patterns.
The literature search showed limited data is available which documents the colonisation
or recolonisation of drill cuttings piles except for the Dutch and Norwegian sectors.
This information is not representative since the drill cuttings piles in the central and
northern North Sea are significantly thicker. The information does have some value in
determining recolonisation rates and identification of opportunistic species that can
tolerate and take advantage of contaminated substrates.
Data from Remotely Operated Vehicle (ROV) studies were also limited but they did
provide a snapshot in time of parts of some piles and their principal value was in
identifying the presence of indicator species.
Immediately after discharge, the benthic community is eliminated under the discharge
pile and is impoverished in the surrounding area with the impact decreasing with
distance. The accumulated evidence appears to demonstrate that recolonisation of piles
begins during the first 1 to 2 years after cessation of cuttings discharge. Recolonisation
is characterised by the appearance of opportunistic species such a Capitella capitata
(bristle worm) which dominates the communities during the first 5 years. In the
surrounding area recovery of the impoverished benthic community commences. This
recovery slowly increases as a more stable climax community develops. This climax

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Phase I Summary Report (Rev 2)

community may be close to the original situation or significantly different for a long
time depending on factors such as remaining contaminant level.
The exact mechanism of the long-term recolonisation process, rates and succession, is
poorly understood due partly to the lack of a standardised methodology and protocol for
biological sampling during benthic surveys across all North Sea sectors.

2.4

Research Area 2.2 In-Situ Environmental Impact


Aim
Achievements

Gaps

To determine type and magnitude of contaminant release from


piles and assess their fate in particular uptake into the food chain
1. Completed site investigation of reactants and products in
sample cuttings pile
2. Identified that the rate of organic matter decomposition is rapid
and of the order of 40 g carbon/m 2/y
3. Observed directly the precipitation of metal mono and
disulphides within the pile
4. Calculated flux changes, which suggest that there are low
exchange rates of metals with overlying seawater.
1. Not all potential contaminants are addressed
2. No further information on food chain uptake

Short Summary of the work


This research area included a review of existing data as well as carrying out new field
trials.
From the literature review it was found that generally the piles were found to contain
significant amounts of contaminants the levels of which decrease rapidly from source.
Higher concentrations of heavy metals such as chromium, copper, nickel, lead, zinc,
barium and hydrocarbons were observed in association with the cuttings than those seen
in natural North Sea sediments.
The fate of heavy metal contaminants within cuttings piles is influenced by:
particle size
organic matter content
the type of benthic fauna
the local sedimentation rate
Also important are the biogeochemical pathways such as adsorption and desorption
particularly from oxyhydroxides of iron and manganese and adsorption into organic
matter or the assimilation into the gut of benthic infauna.
Hydrocarbons within the piles remain relatively unchanged with time as a result of
depleted oxygen, low ambient temperature, type of drilling fluids used and the lack of
significant bioturbation. They do not leach out in any substantial quantities over time
but will stay bound to the sediment particles trapped within pore water and degrade
slowly.

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Drill Cuttings JIP
Phase I Summary Report (Rev 2)

The data set obtained from the field trials yields evidence for high rates of
biogeochemical diagenetic reaction close to the apex of the pile, decreasing rapidly with
radial distance. Gradients in oxidant and reactants within the pore water of the pile
have sharp interfaces through the pile thickness. The process of redox digenesis
produces dissolved sulphide, which may lead to a mechanism of heavy metal
stabilisation.
Three notable pointers to the fate of contaminants were identified:
1. The rapid rate of organic matter decomposition which is of the order of 40 g
carbon/m2/y (used up in degradation)
2. Precipitation of metal mono and disulphides were directly observed within the pile.
This means they become non-bioavailable.
3. Fluxes suggest low exchange rates of metals with overlying seawater.
The investigation into food chain uptake yielded no further information.

2.5

Research Area 2.3 In-Situ Environmental Impact


Aim
Achievements

Gaps

To review existing information on rates and processes of pile


material breakdown (physical, biological and chemical)
1. Provision of evidence that a wide and variable range of
contaminants has the potential to be naturally biodegraded.
2. Confirmed that degradation rates cannot reliably be estimated
but timescales are likely to be long.
3. Suggestion that seafloor transport and erosion are likely to be
of greater significance than natural sedimentation rates.
4. Suggestion that biodegredation rates vary between piles and
within piles.
It is hard to draw firm conclusions based on the evidence
available. For that, an improved understanding of the following
areas would be necessary: microbial processes, factors limiting
biodegredation, erosion, sedimentation, faunal colonisation and
identification of signal compounds.

Short Summary of the work


The size and hydrocarbon content of a pile may decrease through a process of bacterial
decomposition, erosion, dispersion and complexing. The conditions, however, within
the pile influence degradation and the physical characteristics affect erosion rates.
The parameters that can affect degradation rates are suggested and the speed at which
hydrocarbon contaminants break down into more benign compounds and hence
recovery times of a given pile are estimated.
The suggested parameters are:
The presence of microorganisms in the cuttings piles. Except in the surface zones
the piles are largely anaerobic and the microorganisms present degrade hydrocarbons
very slowly. The surface zone is generally changing through varying erosion/
bioturbation/ sedimentation/ recolonisation processes, all of which enhance

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Phase I Summary Report (Rev 2)

degradation by micro-organisms and are therefore important influences on the


recovery time of the benthic ecosystem.
The conditions for degradation. The complicated interplay of environmental
conditions within the piles makes prediction difficult. It is fairly well established
that lack of oxygen and other electron acceptors limit degradation in-situ.
Temperature will also be an important factor, although the indigenous microbial
population is likely to have adapted to ambient temperatures. On available evidence
it would appear that in some piles nutrient concentrations, water availability and
exchange and toxicity may be limiting to microbial degradation in-situ.
There appears to be relatively little evidence that piles form a hard surface but they do
appear to be relatively impermeable to seawater. The water content is 14-60% with
very low levels of seawater exchange.
Sedimentation and erosion are important environmental processes affecting cuttings
piles. Natural sedimentation rates are very variable within the North Sea, but a
maximum rate of 3.5mm/year is likely. Erosion is also variable with much higher rates
in the shallower areas of the North Sea than in the deeper regions. This is the reason
why there is an absence of piles in the southern North Sea and Dutch sectors. In theory
the influence of environmental conditions can be estimated (see also Report 3.2
mathematical modelling) but it is not possible at present to apply these reliably to actual
piles. Some piles, however, do appear to be eroding over a period of 5-50 years rather
than being buried by a slower sedimentation process.

2.6

Research Area 3.1 Environmental Effects from Disturbance


Aim
Achievements
Gaps

To determine potential causes of disturbance at existing cuttings


piles and identify the likely extent of the disturbance
Provided input to mathematical modelling based on non-validated
but pragmatic industry professional judgement
Results are not validated and apply only to existing displacement
operations.

Short Summary of the work


This scope was primarily to provide data for input into the mathematical model for
cuttings pile material dispersal in research area 3.2. Quantitative information on
dispersal was not available therefore a workshop was held on 1 st September 1999. The
purpose was to attempt to better quantify the types of disturbance mechanisms and the
magnitude, volume or volume rate, of the disturbance typical piles may be subjected to.
An estimate of the 3- dimensional water space a disturbance would occupy, excluding
any environmental dispersion effects was also made.
The workshop was attended by a number of industry experts to discuss:
the basis for estimates of potential causes of disturbance of piles
the likely extent of the disturbance
the uncertainty in pile composition
equipment in use for displacement operations.
methods employed during displacement operations
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Phase I Summary Report (Rev 2)

The report primarily focuses on disturbance mechanisms used for cuttings displacement
rather than the untested removal or containment techniques that have still to be trialed
as part of Phase II of the JIP.
While the numbers generated from this research area are not validated estimates they
nonetheless represent the best, pragmatic information available however considerable
care in their use is required. Phase II will provide an opportunity to calibrate these
estimates.

2.7

Research Area 3.2 Environmental Effects from Disturbance


Aim
Achievements

Gaps

To develop a mathematical model which will predict the likely


dispersal of pile material following disturbance
The existing model has been further developed to cover the
required aspects.
Contamination contours have been developed giving examples of
dispersion due to mechanisms identified in 3.1 and natural
events
A no effect concentration of 10mg/kg total hydrocarbons was
suggested.
The model and input data are not validated.

Short Summary of the work


An existing and established model, Proteus, (Reference 8) has been further developed to
include virtual cuttings piles and disturbance mechanisms identified in research area
3.1. The model is capable of simulating:

three-dimensional transport of particulate matter suspended in the water column


erosion from the pile
deposition on the seabed
geochemical processes
ecotoxicological risk

Research area 1.1 provided:


a realistic range of values to define the particle size and physical properties of the
cuttings pile material
the derivation of particle size distribution through the pile
total oil content data including mean and maximum concentrations in cuttings
(50mg/g and 110mg/g respectively).
Research area 1.2 provided:
A representative no-effect concentration value used for risk assessment
bioturbation depth, 5cm, for Corophium Volutator (mud shrimp)

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Environmental data on currents and waves have been derived from measurements made
in the North Sea and general references on North Sea wave data. From the assembled
data two virtual cuttings piles have been defined for different North Sea locations to
provide conditions of maximum and minimum dispersion.
A range of disturbance mechanisms was defined based on data generated from research
area 3.1. These modelling of these mechanisms gave results ranging from widespread
distribution to limited local impacts. Disturbances giving insignificant spread were
excluded from further modelling. Where there were a range of results for a specific
activity the worst case was used.
Trawling had a minor impact based on a single trawl pass but did not capture the effect
of redistribution by dragging material. For all mechanisms the oil content in the
cuttings often gave a higher seabed concentration of oil within an assumed bioturbation
depth (5cm). That resulted in elevated risk ratios of Predicted Environmental
Concentration to No Effect Concentration (PEC/ NEC) with potential biological impact.
A No Effect Concentration (NEC) value of 10mg/kg total hydrocarbons for the test
species Corophium volutator (mud shrimp) has been derived from the work in research
area 1.2. This value is very close to what is generally considered to be the upper limit of
background values and may be considered to be conservative.
Natural disturbance was modelled with and without storm wave influence. The model
showed little or no erosion of the pile under the action of current flows alone. Under
severe storm conditions the pile was found to erode at a rate of approximately
180m3/day (a 70,000m3 pile would take 390 days of such storm activity to remove
entirely) and may indicate that piles will erode gradually with time. This is susceptible
to the uncertainties in present knowledge on erosion thresholds.
Phase II will provide an opportunity to calibrate these results.

2.8

Research Area 4.1 Bioremediation Solutions


Aim

Achievements

Gaps

To evaluate the potential and practicality for enhancing natural


biodegradation of piles in situ and assess its likelihood to
significantly alter actual or potential environmental effects
Degradation is likely by both aerobic and anaerobic means but is
largely limited by availability of suitable electron acceptors.
Strategies developed for accelerating degradation
Limited data on in-situ degradation rates

Short Summary of the work


This report investigated the possibility that bioremediation techniques may be of use in
reducing the pollution risk associated with installation removal.
Degradation of pile material in-situ is possible by both aerobic and anaerobic means but
is largely limited by the availability of suitable electron acceptors.
Below the pile surface zone which is oxygenated, 1-2cm, anaerobic processes are
thought to dominate. These will probably be significantly slower than aerobic ones but
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could contribute significantly to contaminant degradation. However, the evidence


suggests that seawater diffuses slowly, if at all, through the bulk of the pile material
restricting the flow of electron acceptors such as O 2, SO42-, and NO3-, which are
required by bacteria to biodegrade the contaminants. This is a further indication of the
inert nature of an undisturbed pile.
The proposed strategies for accelerating degradation focus on raising the level of
electron acceptors within a pile and a number of methods have been proposed. These
range from increasing the porosity of the piles to seawater or implanting slow release
agents for oxygen and nutrients, through to a more intensive mixing ( bioreactor) of
material with electron acceptors.
Bioremediation techniques that increase levels of electron acceptors within pile material
are likely to be appropriate for larger piles with smaller surface area/volume ratio.
They are also appropriate in areas where erosion rates are low. In areas with high rates
of erosion pile material is likely to disperse and increased biodegradation is unlikely to
be of value.
None of the methods proposed have been tested in the laboratory or field and further
work would be required to prove the concepts and determine efficacy, cost, treatment
time (none are likely to be rapid), and effects on the environment before any technique
could be used.

2.9

Research Area 5.1 Covering Solutions


Aim

Achievements

Gaps

To assess the practicality of covering a pile to prevent or reduce


effects on the surrounding environment and withstand damage
from other sea activities.
Containment is reasonably practical
Contained aquatic disposal would cause significant environmental
impact during construction.
Natural degradation would be slowed by a cover
Identify cover design require to resist damage from trawling
Contaminant movement out of contained pile material

Short Summary of the work


This report investigated the practicalities of covering piles in-situ .
Aquatic disposal methods worldwide have been reviewed to identify approaches to the
containment of wastes in the marine environment. Two main methods have been
identified; in situ capping and confined aquatic disposal (CAD). There are international
precedents for the use of these marine containment techniques.
The design concepts were considered in detail. In engineering terms capping in situ
with an armour stone/gravel layer over an absorbent sand layer was considered to be the
most feasible option. Chemical isolation would be provided by the sand layer,
biological isolation by the gravel layer and physical isolation by the outer armour layer.

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It is considered that a mattress cap would be costly, time consuming, less safe to
construct, and more prone to damage by other sea activities than placement of armour
stone. CAD is significantly more expensive than in-situ capping. It is more likely to be
economic to install either armour stone or CAD for a large pile.
The use of CAD moves the cuttings material into a containment pit when significant
release of contaminants may occur. It therefore has a greater environmental impact
than capping the pile.
It is likely that the armour stone design would resist erosion by storm events, however
the stone would be hazardous to trawling so an additional covering layer may be
necessary.

2.10 Research Area 6.1/6.2 Removal Solutions


Aim

Achievements

Gaps

To investigate means, existing or in development or proposed, for


removal and lifting of cuttings from the seabed. To assess and
compare their efficacy and support/disposal requirements, and
prepare data for assessing their environmental effects)
1. Preliminary evaluation of recovery systems, all potentially
capable of accessing the majority of cuttings and achieve
>90% recovery
2. Substantial dilution with seawater likely in most techniques
1. Practical trials required to validate claimed performance and
sediment releases
2. Means of handling of entrained water

The research in this project comprised the following main tasks:


Identification of and information gathering on recovery system techniques, including
method and indicative cost and schedule for a specified pile recovery
Analysis of data
Questionnaires were sent to 35 companies and on the basis of responses to those,
twenty-two recovery techniques were reviewed and evaluated however it should be
noted that:
Many of the techniques are at an early stage of their development and have not yet
fully specified all components of their systems.
The details of some techniques or components are confidential
There is no previous experience of controlled cuttings recovery against which to
calibrate the assessment
Uncertainties concerning the geotechnical characteristics of pile material
The environmental performance standards within which the techniques are to work
have yet to be defined
Key findings are that all systems are potentially capable of accessing the majority of
cuttings. Some, however, are limited in the extent to which they can access the piles if
installation structures are in place, but may be applicable if the structure has been
removed beforehand.
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With the majority of techniques all the cuttings lying outside the footprint of the main
structure and most of those in an outer substructure area can be recovered at present.
Only one technique appears able to address those within a template.
All techniques are likely to be able to excavate the majority of cuttings. It is possible
that if cuttings with high shear strength (of the order of 100kPa) are encountered some
techniques based on simple suction methods will yield very low rates of recovery.
Techniques which incorporate jetting systems and mechanical devices to break up
strong materials are preferred to maximise recovery but will increase disturbance.
All techniques except grabs are expected to substantially dilute the cuttings with
seawater during recovery. Cuttings in-situ contain approximately 50% solids by
volume, it is estimated that average solid concentrations in the flow to the surface will
be in the order of 5-10% increasing the bulk to be handled by a factor of 5-10. Higher
solids concentrations may be possible with some techniques but would require high
levels of operational accuracy and control. The ability to closely control pumping rates
is fundamental to achieving low dilution. At present only one technique claims to
provide this facility. Maintaining close contact between the excavation tool and the
cuttings will also influence dilution. Some techniques have poor contact and this will
be an issue when considering debris and confined work areas.
With the possible exception of grabs all techniques are vulnerable to delays due to
damage and blockage but there is little basis for differentiating between them.
As these techniques have not yet been tried, quantitative estimates of material release
during recovery operations are based on an intuitive ranking assessment. The
conclusions of this assessment are:
The greatest release of material is likely with grab based techniques
Relatively high releases will result with reverse circulation drilling and trailing
hopper dredger techniques
All other techniques are likely to give rise to lower releases but there is little to
distinguish between them at this stage
The actual rate of release will be highly dependant on the degree of operational care
which can be taken and that may be more important than the design of the technique in
determining losses during recovery.
All techniques are considered capable of recovering the majority of cuttings (>90%)
where the installation structure is still in place, based on information presented.

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2.11 Research Area 6.3 Removal Solutions


Aim
Achievements

Gaps

To assess the effects on the local environment of removal of


cuttings through disturbance, spillage leakage and energy use.
1. Assessment of impacts from all generic techniques
2. Most techniques will use about the same amount of power.
3. Suggestion that environmental impacts are more dependent on
pile characteristics than removal techniques employed and are
within the area of impact of the original drilling and
deposition.
Assessment based on insufficient performance data on lifting
equipment and non-validated modelling techniques

This report identifies and assesses the environmental impact of systems that could be
used to recover and lift drill cuttings to the surface (Research Area 6.1/6.2).
The assessment has shown that cuttings disturbance and redistribution will be the most
likely cause of environmental impacts during the removal process. All techniques will,
by their action, result in varying degrees of pile material disturbance. Modelling results
suggest that the area of seabed affected by the re-deposited material will be dependent
more on the characteristics of the material (e.g. cohesivity) than on variations in the
methodology of excavation.
The extent of any impacts generated by pile disturbance during recovery operations will
probably be within the area of effect from the original drilling operations. Distances for
major, moderate and minor ecotoxicological impacts are suggested.
During operations, the majority of re-suspension will occur during the excavation and
debris removal process. The excavation equipment and the operating procedures
chosen will be a main factor in determining the amount of material release into the
water column these include:
Working from the side of the pile with crawler based equipment is likely to produce
a greater impact than operating suspended or ROV based equipment from the top of
the pile
Operating from vessels, particularly in rough weather, will potentially disturb more
material than installation based operations
Sediment losses arising from mechanical breakdown of pumped lifting systems is a
major contribution to the environmental impact.
The use of mechanical agitators and jetting techniques will re-suspend more material
than simple suction alone.
A proportion of the cuttings pile will be re-suspended in the water column during
recovery. The concentration of oil and the relatively short exposure time of plants and
animals to the plume suggest that toxic concentrations will only be reached
episodically. The impact on the water column is considered to be minor.
Energy use calculations indicate that most techniques will use approximately the same
amount of power except where they are vessel based.
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Due consideration to nearby spawning/nursery areas and seabed fishing activity should
be part of the decision taking process (see 9.1) when planning the timing of the
operation.

2.12 Research Area 7.1 Onshore Disposal Solutions


Aim

Achievements

Gaps

To determine the practicalities of dealing on shore with the


recovered cuttings using technologies ranging from landfill to
thermal recovery of oil, and explore the potential for re-use of the
raw materials.
1. Capacity of processing options is sufficient in UK and Norway
and typical energy consumption is 1-3 GJ/tonne
2. Landfill capacity is available except for untreated oily waste
but is limited in UK to England requiring long distant
transportation.
3. Treatment costs typically 100-200/tonne and 25-80/tonne
for disposal
4. Re-use opportunities limited and would require processing
1. Current treatment processes are specified for fresh cuttings
which may have different characteristics
2. Impact of entrained water not known both onshore and
offshore.
3. Transport to shore of recovered material.

This report examined the practicalities and impacts of dealing with recovered drill
cuttings onshore and the potential for re-using the raw materials.
The total capacity of the identified processing options in the UK is estimated at about
300,000 tonnes year and 120,000 tonnes in Norway. The present UK and Norwegian
treatment capacities are generally considered sufficient to handle all existing cuttings
piles if they were brought onshore under a planned timetable. However, if all cuttings
from one of the largest fields in the UK were taken onshore in one year, and processed,
the capacity is insufficient.
Average processing costs are estimated at 192 per tonne but are almost double this in
Norway.
Present processing technologies are susceptible to changes in input quality and none are
established for treatment of old cuttings. The heterogeneity, including water content,
of any cuttings returned to shore implies uncertainty in the functionality of these
technologies. In addition, the effect of any offshore pre-treatment could have a
significant impact on material handling and processing onshore. It is implicit that the
radioactivity level of the material is compliant for onshore handling.
In the UK a number of landfill sites licensed to accept oily waste were identified with a
total capacity estimated at 360,000 tonnes per year of sludge and 1.5 million tonnes per
year of solids. Untreated cuttings could be classified as sludge; thus capacity is limited
for direct disposal. Processing to lower water content would be preferable to enable the
waste to be classified as solid. Capacity for solids is considered sufficient however

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transport and logistics will be challenging. In Norway cuttings have to be processed


prior to disposal and landfill capacity is 360,000 tonnes processed cuttings per year.
Landfarming is technically an option for disposal of cuttings although high salt content
would preclude it in the UK and it is not permitted in Norway. Brine Cavity disposal
may also be an option in the UK.
In the UK the average cost for transport and landfill disposal of sludge is estimated at
50/tonne and for solids 26-37/tonne. The average cost in Norway is 79 per tonne.
In the UK distances between the most frequently used ports, processing sites, and
landfill sites are significant and would lead to long distance transportation requirements.
There is potential for reuse of processed waste streams but high salt content limits
opportunity and a salt washing process adds to costs and complexity. Cleaned solid
residue could be used in construction materials, as covering on landfills, and possibly in
road cover materials dependent on chemical content and particle size. No cost or
energy benefit analysis has yet been conducted.
Environmental impacts from the onshore options in this report assume strict regulation
and no acute spillage situations. Impacts associated with processing are emissions to
air, odour and the potential for dust and noise. The energy consumption per tonne
processed is in the order of 1-3 GJ, with values ten times higher for some technologies.
Impacts associated with disposal should normally be negligible. There is, however,
always a risk associated with loss of containment of leachate with possible
consequences of environmental contamination and on human health.

2.13 Research Area 7.2 Offshore Disposal Solutions


Aim

Achievements

Gaps

To determine the practicalities of dealing offshore with the


recovered cuttings and explore the potential for re-using the raw
materials.
1. Reinjection is currently the only established technique for
processing cuttings offshore.
2. Where no suitable formation is available for injection, onshore
processing is currently the only technique to satisfy existing
regulations.
3. Emerging technologies with offshore application could
become viable.
4. Technologies are limited by weight/space demands
Validation of performance of techniques including those of
emerging techniques

This project focused on the practicality of dealing with recovered cuttings offshore.
The only currently established technique for dealing with cuttings offshore is
reinjection into a suitable formation. There are, however, a number of emerging
technologies, in addition to established onshore techniques, for cleaning cuttings that
have potential for offshore application. Onshore techniques (for use offshore)
considered were; grinding; direct thermal desorption; and indirect thermal desorption.
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Emerging techniques considered were; microemulsion; supercritical extraction using


liquid natural gas; and supercritical extraction using liquid carbon dioxide.
The engineering feasibility, performance, cost and environmental issues of seven solids
treatment options were compared with the following results:
Cuttings reinjection rated reasonably against most criteria as an established
technique. Where there is no suitable formation for reinjection other options need to
be considered.
Transport of solids to shore for treatment compared favourably when looked at in
terms of solid and water treatment rates and potential for reuse of recovered oil and
cleaned cuttings. This aspect, however, was not explored thoroughly and the impact
of the raw material on handling limitations, together with transportation cost and
environmental impact, could affect the comparison.
Of the options for offshore treatment followed by discharge to sea, grinding and
indirect thermal desorption systems scored well. Both are able to clean cuttings to
less than 0.5% residual oil content and have potential for good energy efficiency,
especially when the energy value of recovered oil is taken into account. These
techniques, however, have high deckspace, deck loading, health and safety issues,
and low processing rate implications and are probably best suited to vessel based
operation rather than from an installation. In addition, the operating and capital costs
are currently high in comparison with the other options.
The most promising emerging techniques are microemulsion and supercritical
extraction using liquid carbon dioxide, followed by discharge to sea. Their current
stage of development is such, however, that they could only be considered as viable
alternatives over the medium and longer term and address only total hydrocarbons.
The magnitude and nature of the environmental impacts of discharging cleaned cuttings
will depend on the mode of discharge i.e. dispersive or accreting. The choice would
depend on local receptor sensitivities.

2.14 Research Area 9.1 Cuttings Pile Evaluation Framework


Aim

Achievements
Gaps

To determine technical criteria for leaving cuttings piles in place


accepted by regulators and stakeholders and determine the same
criteria applying to the remains of cuttings piles which have, in the
most part been removed.
Overall strategy suggested
More detail, in all tiers, will be required to allow consistent
comparisons

The conceptual approach proposed for the provision of a methodology for the
evaluation of handling options takes the form of a tiered risk-based assessment
framework. This type of risk-based assessment is already used for regulatory decision
making on contaminated land issues in the UK, Europe and North America. The
application of this type of tiered framework to cuttings pile assessment and
management is intended to focus on the appropriate level of assessment for each site on
a case by case basis. The framework is designed to focus resources on those sites
which present most environmental risk whilst allowing sites identified as presenting
little or no risk to exit the assessment process at each stage.
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The proposed framework consists of three tiers:


TIER 1 Preliminary Site Assessment development of a preliminary conceptual site
model by means of a qualitative, and where possible quantitative desk-based
assessment.
TIER 2 Generic Quantitative Assessment collection of site-specific chemical,
physical and if necessary, biological data and comparison with generic (numeric)
criteria. Tier 2 also encompasses environmental risk assessment which includes
modelling of potential cuttings dispersion scenarios and an assessment of the potential
that any disturbance and/or contamination may effect the receptors in the area.
TIER 3 Comparative Assessment assessment of the management options for cuttings
accumulations which would, with further regulator and stakeholder input, aid decision
making in the determination of BEP and BAT for the remediation of any specific pile.
Throughout the proposed framework, the precautionary principle is applied such that
where information required for the assessment is unavailable or inadequate at any stage,
a worst case is assumed until better information becomes available. Only when there is
sufficient data to demonstrate minimal environmental risk from the cuttings
accumulation can a site be deemed to require no further action and not proceed to Tier
3.

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3.0

OVERALL DISCUSSION AND CONCLUSIONS

3.1

Summary of Findings
The research areas in Phase I have all been completed successfully and useful
conclusions drawn, although in some cases against a background of data limitations,
with varying degrees of success which have qualified the results.
The research areas, as mentioned in the background section, fall into three categories:
Problem Definition
Potential Solutions
Evaluation Framework
These are discussed in turn.
Problem Definition
The problem has been better defined but results have been limited largely as a result of
inconsistent sampling techniques and lack of data. The following are the main findings.
The volume of cuttings is now estimated as almost double that previously, based on
information from twice the number of sites. The heterogeneous nature of the piles
mean that they differ significantly both from site to site and within an individual pile. It
will therefore be necessary to assess each pile individually in order to conduct a
sufficient assessment to allow for appropriate evaluation of management options.
The toxic effects of the piles are generally unknown but the effects of total
hydrocarbons show acute and chronic effects in the region of 100 mg/kg and 10 mg/kg
respectively.
There is confirmation of recolonisation beginning 1-2 years after cuttings discharge
cessation by opportunistic species that dominate for the first few years. Thereafter
recovery is dependent on remaining contaminant level.
Contaminant release is now better understood, particularly with respect to heavy metals
which have low exchange rates with the overlying seawater and hydrocarbons which
decompose rapidly except for those below the surface zone which remain unchanged.
No further information on contaminant uptake into the food chain has been determined.
The surface of the piles is continually changing as a result of erosion, bioturbation,
sedimentation, recolonisation and microbial activity but the main bulk remains
relatively inert unless physically disturbed. This is largely due to lack of oxygen. The
rate of the surface activities depends on location and time of the year but generally
activities which erode the pile are faster than sedimentation.
The modelling tool, with its present limitations, can demonstrate cuttings material
redistribution, resulting oil concentration and potential ecotoxicological (simplistic)
effect when disturbed either naturally or as a result of operations. Its main benefit is

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that it could become a useful tool in comparative evaluation techniques of possible


disturbance events.
Potential Solutions
Potential solutions have been further examined but none have yet been validated by
carrying out field trials.
It is theoretically possible to enhance natural degradation and a number of methods
have been proposed. These are likely to be more relevant where erosion rates are low.
Two main approaches for covering the piles have been identified. The use of a
combination of sand, gravel and armour stone layers is more likely to be
environmentally sound than moving the pile into a containment pit which is then
covered.
Techniques to lift the pile material to surface are claimed to achieve >90% recovery but
the material will be significantly diluted with seawater and therefore there will be an
increase in volume of material for treatment and disposal.
All the lifting techniques will result in release of material and contaminants although
the amount and significance cannot be confidently predicted without more validation.
There is insufficient landfill capacity for untreated cuttings in the UK. There is
sufficient processing capacity in UK and Norway for all the existing cuttings as long as
the largest sites are not treated in one year. There is also landfill capacity for the treated
cuttings. Alternative uses would require at least salt washing.
Re-injection of cuttings is currently the only established technique of offshore disposal.
Emerging technologies include micro-emulsion and supercritical extraction using liquid
carbon dioxide but they are at an early stage of development.

Method for Evaluating Options


The proposed method of evaluation is based on a tiered system such as is already used
for other environmental regulatory issues. The framework is designed to focus
resources on those sites which present most environmental risk whilst allowing sites
identified as presenting little or no risk to exit the assessment process at each stage. It
uses the precautionary principal to ensure that worst case assumptions are made where
data is insufficient.

3.2

Outstanding Issues
It is clear from these findings that there are still a number of gaps. Furthermore, there
are a number of additional questions arising from Phase I that should be addressed
during Phase II.

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Sampling Methods
A consistent method of taking samples of cuttings pile material and benthic surveys
would provide better data as the basis for future work. The protocol(s) being developed
by the Norwegian Offshore Association (OLF) are designed to address this issue. They
are expected to be issued in 2000.
Toxic Effects of Cuttings Material
There is a lack of information on the leaching of toxic contaminants and the toxic
effects of the cuttings material as a whole and its components other than total
hydrocarbons. This covers the immediate effects, accumulations and effects up the
food chain.
Ecotoxicological studies have been sponsored by Phase I of the JIP to gain some further
knowledge on these issues.
Natural Degradation
There is still a lack of understanding of natural degradation processes and rates.
Additionally the source of the organic matter giving the rapid rate of decomposition
suggested in research area 2.2 is unclear.
Dispersion Modelling Uncertainties
Phase II trials can be used to validate both model input data and the dispersion
modelling.
Potential Solutions
None of the potential solutions have yet been proven by field trials. This uncertainty
will have reduced the quality and reliability of the current environmental impact
assessments.
Disposal of Seawater
The techniques for lifting the piles all dilute the cuttings with seawater. The treatment
and disposal implications of handling this volume of water have not yet been
adequately addressed.
Evaluation Framework
There is a lack of detail in the proposed methodology with particular respect to Tier 3.

3.3

Further Comments
The results of the dispersion modelling are based on the output from research area 3.2,
which is based on the output from 1.1, 1.2 and 3.1. Even though there are significant
uncertainties in those areas the dispersion modelling tool which has been developed will
be useful in highlighting the likely differences in environmental impact between

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different dispersion mechanisms. As such it can provide a tool to assist with


comparative assessment which will form part of Tier 2 of the evaluation framework
being developed under research area 9.1.
It is envisaged that the information from several of the research areas of Phase I of the
JIP and future work in Phase II, in conjunction with the consultation process will allow
the methodology for evaluation of options to be fully developed.

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4.0

REFERENCES

1.

OSPAR Convention 1992 Appendix1

2.

Determination of the Physical Characteristics of Cuttings Piles, using Existing Survey


Data and Drilling Information, R & D Programme 1.1, A Report for the UKOOA Drill
Cuttings Joint Industry Project, Cordah Environmental Management Consultants, Final
19 Jan 00

3.

UKOOA Drill Cuttings Initiative Research and Development Programme Project 1.2:
Cuttings Pile Toxicity, Environment & Resource Technology Ltd and Rogaland
Research, Final, 15 Dec 99

4.

UKOOA Drill Cutting Initiative, Research and Development Programme, Activity 2.1,
Faunal Colonisation of Drill Cuttings Pile Based on Literature Review, Dames & Moore
and NIOZ, Final, 24 Dec 99

5.

Contaminant Leaching from Drill Cuttings Piles of the Northern and Central North Sea:
A Review and Field results from the Beryl A cuttings pile, Scottish Association for
Marine Science and Centre for Coastal & Marine Sciences, Final Jan 00

6.

UKOOA Drill Cuttings Initiative Research and Development Programme, Project 2.3:
Natural degradation and estimated recovery time-scales, Environment & Resource
Technology Ltd and Rogaland Research, Final, 16 Dec 99

7.

UKOOA Decommissioning Committee, Drill Cuttings Initiative R&D Programme,


Draft Report for Study Item 3.1, Identification & Quantification of Potential
Disturbance of In-Situ Piles, Ian Murray Engineering, Final Jan 00

8.

UKOOA Drill Cuttings Initiative Research and Development Programme Study 3.2:
Mathematical Model of Pile Dispersal Following Disturbance, BMT Marine Information
Systems, Final 18 Jan 00

9.

UKOOA Project 4.1 Acceleration of Natural Degradation, AEA Technology


Environment, Rogaland Research and SINTEF Applied Chemistry, Final Jan 00

10.

Practicality if Covering Drill Cuttings In Situ: task 5.1, Environment Resources


Management, Rev 2 (Final), Dec 99

11.

UKOOA Drill Cuttings Initiative, Research Areas 6.1 and 6.2, Removal Solutions
Identification and Effectiveness of Methods to Remove Drill Cuttings Piles from Seabed,
Dredging Research Ltd and CEFAS, Final Jan 00

12.

UKOOA Drill Cuttings Initiative, Research Area 6.3, Removal Solutions


Determination of Environmental Effects of Removal Solutions, HR Wallingford, Rudall
Blanchard Associates, and CEFAS, Final Jan 00

13.

UKOOA Drill Cuttings R&D Program, Impact from Onshore Disposal Study Item 7.1,
Det Norske Veritas, Rev 1(Final), 17 Jan 00

14.

Task 7.2: Techniques for Offshore Treatment and Disposal of Retrieved Drill Cuttings
Piles, Environmental Resources Management, Final 17 Jan 00

15.

UKOOA Drill Cutting Initiative, Research and Development Programme, Activity 9.1,
Determination of Acceptance Criteria for Cuttings Pile Management, Final 14 Jan 00

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