This paper addresses critical issues concerning the regulation of synthetic-based fluids in Outer Continental Shelf waters. Synthetic-based muds were not envisioned when discharge criteria were formulated a decade ago. It is critical that the U.S. Environmental Protection Agency investigate this new category, since the original permit language and discharge criteria may inhibit the utilization of this new technology and prevent the realization of volume reduction that can be achieved using synthetic-based muds.

To date, the EPA has not addressed the use of inhibitive mud systems as a control technology for reducing the quantity of pollutants. Drilling through shale formations is an integral part of drilling wells in the Gulf of Mexico. Solving problems associated with these formations can benefit the EPA, industry, and the environment.

The use of synthetic-based muds offers greater waste reducing capabilities than water-based muds. They also permit drilling in areas which now require oil-based mud to combat troublesome shales. Compared to hauling oil-based mud, synthetic-based muds offer significant non-water quality advantages in the areas of air pollution, worker safety, reduction of potential spills, and reduction in landfill usage.

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