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Recycling of Drill Cuttings


Federico Hernandez, Daniel Sequeira, Derrick Dauson

Penn State University


Introduction to Engineering Design
November 14th, 2016

Abstract
A continuous problem that the American society faces every day lies on how to dispose
unwanted trash without harming the environment. This is a very hard task for local governments
and private companies because there are residues that can be hazardous for people and the
environment if they are not treated correctly. For Chevron, this problem goes one step further.
This company performs fracking across different states in the United States, which is a process
where a hole is dug in the ground to extract oil. This process creates drill cuttings since
perforating the ground in order to create a well produces them. These cuttings are very dangerous
for the environment because they have copious amounts of oil, hydrocarbons, heavy salts, among
other dangerous substances. About 10,000 cubic feet of these wastes are extracted from each
excavation site and subsequently disposed in a landfill. The environmental and moral problems
with this plan must be considered. Alternatives to sending the drill cuttings to landfills include
creating useful landfill from them and extracting the wastes from them to give them other uses.

Table of Contents
Abstract

1.0 Executive Summary

2.0 Introduction

3.0 Methods, Assumptions, and Procedures

11

4.0 Results and Discussion

21

5.0 Conclusion

25

6.0 References

28

List of Figures
Figure 1: Image of Typical Drill Cuttings

Figure 2: Existing Conditions System Diagram

Figure 3: Final System Diagram

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List of Tables
Table 1: Stakeholders and Their Needs and Requirements

Table 2: Stakeholder Requirements Related to Specifications

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Table 3: Comparison Between Concepts

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1.0 Executive Summary


The world is in desperate need to help its environment because soon the damage being caused
will be too much for it to be reversible. This problem extends further when fracking comes into
the picture. Fracking is a process in which people extract oil from the ground. They do this by
excavating a hole in the ground with high pressured water. The residue of the excavations is very
dangerous given the radioactivity they present and the oil that it comes out with. To solve this
problem and not lose the functionality of fracking to excavate oil there must be a solution that
impedes the drill cuttings reach the landfills.
In this aspect, two types of solutions were found. The first one is referred as cleaned
cuttings because after the cuttings are extracted from the earth, they are cleaned from residue oil
and from the radioactivity that they come with. Bunker sand, garbage dumps, and Plot
Stabilizing Landfill, are all included in the cleaned cuttings. On the other hand, the non-cleaned
cuttings are used for roads and eco-landfill pits.
Bunker sand refers to the use of the cleaned cuttings to be used for battlefields as shields
for troops. The garbage dumps consist of using the cuttings instead of incinerated trash to fill
dumps which is better for the environment. In some areas, there is a need to level land so it can
fulfill its useful purpose and that land could be filled with cleaned cuttings. The non-cleaned
cuttings can be used to create roads with a procedure that is not affected by the oil inside of it.
These solutions were taken into consideration to solve the problem of the fracking
cuttings but not all of them were viable for industrial use. The final solutions for the drill cuttings
were, even out lots, roads, and eco-landfill pits.

2.0 Introduction
2.1 Advance Organizer
In this section, we are going to explain the existing and preferred conditions that we are
dealing with, as well as the stakeholders involved in the project. The needs and requirements of
each stakeholder is also explained in this section.
2.2 Subject
The problem that our design team faced was creating a sustainable system that repurposes
and recycles the drill cuttings that result from fracking. A system is a series of connected
procedures that form the entire product. Sustainability is the endurance of a system or process
that is not harmful to the natural environment and does not deplete resources over time. The
current method of disposing of the drill cuttings that result from fracking is not the most
environmentally sustainable process. Our goal is to create a process to recycle the drill cuttings
in a way that is inexpensive and sustainable. This process must satisfy the needs of the
stakeholders involved, which include the landowners, environmentalists, our client Chevron, the
government, citizens of nearby areas, and future researchers.
2.3 Existing Conditions and Preferred Conditions
Fracking is the process of drilling down into the earth in order to release gas that is
trapped in the rock (BBC News, 2015). Fracking is a necessary way of obtaining natural gas that
is not going away anytime soon, so it is important to make as many aspect of the process
environmentally friendly (BBC News, 2015). During this process, drill cuttings are produced.
Drill cuttings are the broken bits of solid material that are a byproduct of fracking (EPA, 2000).
Drill cuttings typically look like the ones shown in Figure 1 below.

Figure 1: Image of Typical Drill Cuttings

When Chevron drills their wells, approximately 10,000 cubic feet of drill cuttings are
produced. According to the Greeley Tribune, it takes approximately seven to ten days to dig a
well, meaning that there are about 1,000 cubic feet of drill cuttings produced per day (Dunn).
Currently, these drill cuttings are transported off site and disposed of in landfills. This way of
disposal can be harmful to the environment due to the number of hydrocarbons present in the
drill cuttings when they are produced, and it is a waste of material that could be recycled and
repurposed into something beneficial. Our goal is to create a way to recycle the drill cuttings in a
way that will be economically and ecologically friendly. There are ways to reuse the drill
cuttings with and without cleaning them. The major difference between cleaning and not
cleaning the drill cuttings is that cleaning the drill cuttings lowers the number of hydrocarbons
present. Cleaning the drill cuttings is more expensive, but it makes them less harmful to the
environment. Below is the existing system that Chevron currently uses (Figure 2).

Figure 2: Existing Conditions System Diagram

2.4 Stakeholder Analysis


The stakeholders involved in this project are shown in Table 1. The stakeholders are
listed in order of importance.
STAKEHOLDER

NEEDS

REQUIREMENTS

Chevron

Cost, sustainability,

Low cost, environmentally

innovation, safety, time,

friendly, innovative, ease of

market.

use, viable market of


proposed solution, low manpower needed

Government

Follows rules and regulations

Does not violate the


guidelines set by local and
federal governments.

Environmentalists

Environmental impact

Low destruction of land, least


amount of pollution possible.

Landowners

Environmental impact

Preserve land value, low


destruction to land.

Citizens Nearby

Environmental impact

Low pollution to the


environment.

Table 1: Stakeholders and Their Needs and Requirements


Our system for weighing the stakeholders requirements is based on Table 1. Since
Chevron is the sponsor of our project and therefore the most important stakeholder, their major
requirements are the ones that received the highest weighting. The needs of the government are
weighted lower than Chevrons top specifications since each proposed solution meets the rules
and regulations set forth by the government. The requirements of the environmentalists,

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landowners, and citizens nearby are the same as Chevrons when it comes to environmentally
friendliness, so the weight of these requirements is not noted. The cost of the process was tied for
the highest weight because, after all, Chevron needs to make money in order to stay in business.
Cost will be the most important requirement taken into consideration when it comes to producing
the final system. Along with cost, an equally important requirement is environmental
friendliness. The whole purpose of this project is to create a process that is more environmentally
friendly than the process that is currently used, so environmental friendliness is important to the
stakeholders. The requirement of the government that the process follows the guidelines set in
place is next because the process will not be allowed to take place if it does not follow these
regulations. Although these requirements are not as highly weighted, viable market of proposed
solution, and low man-power still need to be taken into consideration in order for Chevron to
make a profit off of the system we are creating.
2.5 Summary
This section of the report covers the existing conditions that are present in the disposal of
the drill cuttings and a system diagram is provided illustrating the system that Chevron currently
uses to dispose of the cuttings. A table listing the stakeholders involved, their needs, and their
requirements along with the weight associated with each requirement is provided as well. It is
also explained as to why each of these requirements is weighted the way that it is.

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3.0 Methods, Assumptions, and Procedures


3.1 Advance organizer
In this section, we are going to cover what, and how did we develop our concepts. We
also are mentioning the facts that were not found in the research that proved essential to develop
the concepts.
3.2 Methods
The first thing we did was determine the stakeholders and their needs, and analyze the
existing conditions of the drill cuttings, from there, we established our goal to be met with our
designs. We determined the stakeholder requirements based on the stakeholder needs. We
defined specifications as the descriptions of the key factors in our concepts, and guidelines used
to create concepts. Afterwards, we sought to develop specifications that meet with the
stakeholder requirements in a sustainable manner and tabulated them.
After determining the specifications, we set out to develop concepts, and analyzed them
based on our specifications. It was crucial for our concepts to meet the requirement specs, and
we decided which were viable based on them. Afterwards we compared our concepts, in order to
see which were viable and where they could be improved. We did not decide on one specific
concept, instead we created a system diagram that includes the various concepts in order to
provide flexibility for the client, thus reaching our recommendation.
3.3 Assumptions
The assumptions basically consist of facts and anticipations of data that could not be
found during research that need to be addressed in order for the concepts to work properly.
Our concepts rely on the fact that the cleaning process implemented will leave a
minimum amount of residual hydrocarbon and heavy salts in the drill cuttings. Also, we assumed

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that the cleaning process implemented by the client emits greenhouse gases, but the extracted
material will be recycled.
The transportation cost will be paid by the client unless the drill cuttings are sold to a
third party. If this is the case, the buyer of the cuttings will pay for its transportation.
Due to the lack of data provided by the client regarding cost and existing conditions of
the fracking process, we rely on the fact that our recommendations will adapt to the system used
by chevron. If this is not the case, the client will edit the recommendations in order for them to
adapt to their needs. Also, we did not receive information about the current cost of disposing the
drill cuttings, but given the existing conditions, we assume that the cost is about 200$ per ton
given that the cost of building a pit 9.90$ per bank cubic yard, and the cost of cleaning the
cuttings is about 150$ per ton (the estimates are further explained in the procedures section).
The client will investigate the regulations for the concepts based on the region and will
follow them accordingly, we expect that no regulations are being broken for our concepts.
3.4 Procedures
First of all, we determined the stakeholder, their needs, and their requirements (Table 1),
by performing an analysis on the users and people of relevance in fracking. Then we researched
and viewed the existing conditions, and determined their flaws and how could they be fixed. The
main flaw we observed is that the current system is not sustainable and does not meet all of the
stakeholder requirements. Afterwards, we set our goal that needed to be met in our project,
which is creating a process to use drill cuttings in a sustainable manner that improves upon the
existing conditions and meets the stakeholder requirements. Based on the stakeholder
requirements we performed an analysis of what specifications could be developed in order to

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meet the requirements in a sustainable manner. We created a table that related the specifications
that we determined with the stakeholder requirements (Table 2).
REQUIREMENT

SPECIFICATION

Low-cost

Cost: Final monetary expense per ton of drill cuttings. Calculated


by consideration of the project manager according to the funds
assigned. Recommended maximum amount: 200$ per ton
(Determined by analyzing cost of cleaning the drill cuttings 75$150$ per ton and added a 50$ per ton of transportation.

Environmentally

Eco-Friendliness: Amount of greenhouse gases produced and

Friendly, Low pollution

pollution to the environment. Needs to be analyzed by an ecology

to the environment,

expert in order to determine if the process was ecological or not.

preserving land value

We considered if it was met by our own criteria on each individual


concept.

Does not violate the

Regulation Compliance: Regulations and Laws respected by

guidelines set by the local concept. Recommended amount of regulations broken: none.
government.
Low manpower

Manpower: Overall work hours per 50 tons it would take to


develop the concept. Needs to be analyzed by head of the project
in order to determine if it uses their resources efficiently.
Recommended maximum amount would: 1h per 50 tons (Includes
Transportation).

Market Viability

Market: Potential Viability in Market. Determined by interviewing


Mr. Alvaro Campins, President of Pentacle Energy, per concept.
Table 2: Stakeholder Requirements Related to Specifications

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With the specifications determined, we weighed each one concerning the importance of
each stakeholder requirement. We created a 10-point based weighing system, and assigned each
specification a value on that range. We discussed and analyzed which specifications needed to be
weighed more heavily in order to make sure that we developed a sustainable concept. Since
Chevron is our most important stakeholder, we determined that cost and Eco-friendliness would
receive the highest weighting, with 3 each. The specification of market viability would receive
the next highest weighting with a weight of 2. The manpower specification received a weighting
of 1. We determined that the least weighted specification would be the regulation compliance
because all of our proposed solutions follow the regulations. This specification received a weight
of 0.5.
We started creating our concepts by researching the possible solutions that currently exist
to get idea of what are the current existing concepts and their flaws. With this in mind, we
developed our own by brainstorming ideas with each other, developing our initial concepts. We
later analyzed the concepts with our specifications and determined which were viable or not.
Afterwards, we compared the concepts and weighed them with our specifications. Finally, we
concluded that several of our concepts met the requirement specifications, so we decided to
design a system diagram which involved them all (Chapter 3).
We determined that the cleaning process of the cuttings was essential for the effective
development of our concepts. We researched for methods of cleaning the drill cuttings and found
a method that properly addresses our concerns of properly removing hydrocarbons from the
cuttings in a cost-efficient manner. Thermal treatment for cleaning the drill cuttings can
effectively remove hydrocarbons from the drilling waste. According to

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the Drilling Waste Management Information System (2016) Fact Sheet, the cost for thermal
treatment of drilling waste ranges from 75$ to 150$ per ton, providing a cheap and efficient way
of cleaning the drill cuttings.
In order to provide an organized way of describing our concepts, we divided them on two
categories: cleaned and non-cleaned. Following is a description of each of the concepts, analyzed
with the specifications. Note: Each concept was reviewed with Mr. Alvaro Campins in order to
determine the market potential, and the miscellaneous details in them.
3.4.1 Cleaned Drillings
These designs were created based on the similarity that cleaned drill cuttings have with
gravel. There is an included cost of 150$ for every design in this area section since that is the
highest estimated price of cleaning the drill cuttings and a reduced eco-friendliness due to the
carbon emissions emitted during the cleaning process.
3.4.1.1 Sandbags/Bunker Sand
This design consisted on using the large volume of drill cuttings and using them as
sandbags or support for buildings with bunker-like construction. The drill cuttings could be sold
to the government or private security services. We consider it to be ecological since it does not
pollute the environment and the drill cuttings are being recycled. It is also innovative since the
concept exploits the uses of the drill cuttings in an unusual and effective manner. However, it
requires an unnecessary amount of man-power and high number of hours in order to transport
and plan the logistics of the process. It also has an undefined market and due to the cheap price
of sand, potential user might avoid it. As well, it has very high transportation costs, since it
would potentially require long distances of transportation.
3.4.1.2 Garbage Dumps

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Garbage is usually incinerated and afterwards used as landfill and mixed with other
components that serve as landfill. Our idea consisted on using the cleaned drill cuttings in order
to replace the landfill the incinerated garbage is mixed with. This design takes brings an effective
use of the drill cuttings as landfill, and is innovative since it gives them an unprecedented use. To
our consideration, this concept is ecological since it serves as a useful landfill that does not
pollute the environment. It also would not require a lot of the clients manpower besides
transporting them to an existing garbage dump. However, the main barriers we found while
preparing this concept was that it could potentially have a high cost since the transportation to an
existing garbage dump may be at an extended distance and the market for it might be nonexistent around the drilling site.
3.4.1.3 Plot Evening Landfill
This design attempts to take advantage of the uses gravel can have in evening out land
plots for construction and various uses, and replaces the gravel for drill cuttings. This design has
various advantages, it can provide profits for the company that sells the drill cuttings and it gives
them an innovative application. It does not require a significant amount of logistics and
manpower, since it will be mainly managed by the buyer of the drill cuttings. A market for the
drill cuttings can be created since they can be sold for a cheaper quantity per ton than gravel,
40$-45$ per ton according to HomeAdvisor Inc. (2016), which can be very attractive to potential
buyers. This design can potentially reduce the cost of cleaning and transporting the cuttings to a
minimum.

3.4.2. Non-Cleaned Drillings:

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These designs were created taking into consideration the residual of hydrocarbons and
heavy salts in the drill cuttings. All of these designs do not have the cost of cleaning the drill
cuttings included in the cost specification, reducing the cost greatly.
3.4.2.1 Roads
This design consists on using the drill cuttings in order to create pavement for roads. This
design does not require cleaning the drill cuttings since the contact that a human has with the
roads is minimal, the potential harm that a user can receive is negligible. The cost of the paving
of the road depend on the transportation of the drill cuttings and the manufacture of the road
itself. Drilling sites usually are in remote areas that do not have roads, so there are potential
market and benefit for the client in using this design. It recycles the drill cuttings, putting them to
good use in an innovative manner.
3.4.2.2 Eco-Pits
This idea consists on using the cuttings in pits built near the drilling area. These pits are
open to the atmosphere, which allows them to accumulate rainwater. According to the Drilling
Waste Management Information System (2016) Fact Sheet, after a determined amount of time
the pit would have accumulated water with oil residues from the cuttings; the oil and water is
later extracted, partially cleaning the cuttings. Afterwards native plant seeds are placed in the pit,
and allow vegetation to reproduce in them. Pits will need to be built around the drilling area in
order to minimize transportation cost. According to R.S. Means Heavy Construction Cost Data
(Hale, D., 2016, p. 220) the pits will have an approximate cost of 9.90$ per bank cubic yard.
Other than that, the cost would be low because the cuttings would only be to transported a short
distance, and the pits do not require much maintenance. We are providing an estimated 50$ per
ton buffer regarding the price since machinery will be needed in order to extract the excess oil

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and water. Additionally, it is eco-friendly since it uses the minerals of the cuttings to nurture
plants. The logistics are straightforward but maintenance is required. The only man-power
needed would be from transporting the cuttings from one location to the other.

In the following table, we compared each concept with each other according to the
specifications. Values were given in a 1-10 scale (1 being no contribution to requirement spec
and 10 being requirement specification met), and afterwards multiplied by the weight of the
specification.

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Specifications

Sandbags

Garbage

Plot Evening

Dumps

Landfill

Roads

Eco-Pits

Cost (3)

Eco-Friendliness

Market (2)

10

10

Manpower (1.5)

Regulation

10

10

10

10

10

38.5/100

49/100

78/100

80.5/100

86.5/100

(3)

Compliance (.5)
Total:

Table 3: Comparison Between Concepts

We considered that the sandbags and garbage dumps concepts were not viable, given the
results of the requirement specifications. Despite its unviability, these designs served as a basis
for the concepts that we develop which did qualify as exploit the use of drill cuttings as
potentially useful landfill.
Since the remaining concepts weighed quite similarly, we decided to use them all as
viable solutions to the issue at hand. Given the different conditions that these concepts can be
used, we want to provide the client with several options that can be applied in order to achieve a
sustainable manner of meeting the stakeholder requirements.

3.5 Summary
In synthesis, this section of the report covers the process done in order to create, evaluate
and analyze our concepts. We provided a general description of what were the steps we took and

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how did we develop them. It emphasizes on providing detailed explanations and relations
between the facts and methods we used to create our concepts, such as relating the stakeholder
requirements and the specifications. Detailed descriptions and comparisons of the concepts
created were provided, allowing the reader to receive information and background to the final
recommendation that we achieved.

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4.0 Results and Discussion


4.1 Advance Organizer
In this section, we are demonstrating the results of our project. We are going to show our
recommended systems diagram with explanations on the changes we did upon the existing one.
As, well we will be discussing whether we improved upon the existing conditions with our
recommended solutions.
4.2 Final Prototype
Our recommended system for exploiting the drill cuttings consists on editing the existing
systems diagram and adding the concepts we created to it. As we mentioned in the previous
section, we determined that three of our concepts were viable solutions. We labeled them in the
following manner:
Solution 1: Plot Evening Landfill (Description in section 3.4.1.3)
Solution 2: Roads (Description in section 3.4.2.1)
Solution 3: Eco-Pits (Description in section 3.4.2.2)
Our final system diagram illustrated the process that we have designed for our client,
Chevron. The initial drilling of the well and the extraction of the cuttings remain exactly as they
were in the existing system diagram. Our process comes into effect when it comes time for the
trucks to come to the site. If there not a road currently available for them to access to site, a road
will be constructed using the solution we proposed involving the drill cutting being used for road
construction. However, if a road already exists, the system diagram continues as it did in the
existing diagram, with the trucks being loaded. The next step in the system depends on whether
or not a buyer of the cuttings has been found. If a buyer has not been found, the cuttings are
disposed of in eco-pits, as described in the eco-pits section. If a buyer of the cuttings has been

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found, the cuttings are transported to a cleaning location. Upon delivery, the cuttings are
unloaded from the trucks and cleaned of any hydrocarbons that may be present. The clean
cuttings are then loaded into trucks and transported to the desired location of the buyers. The
buyers will be able to use the cuttings in the evening of land.

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Figure 3: Final System Diagram

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4.3 Discussion
The existing diagram does not harness the potential that the drill cuttings have. There are
several uses that can be applied to them that were simply not being used, evidenced by the
concepts we developed. Not only there is a significant waste of potential in disposing the drill
cuttings in a pit, but also it has negative consequences in the environment damaging the land
where they are disposed. Briefly explained, the process of disposing and using the cuttings
currently used by our client is not sustainable. In comparison, the system diagram we developed
offers more options that the existing system diagram. It does not damage the environment and
provides a cost-effective manner of using and recycling the drill cuttings. It also offers the client
with much more versatility of using the drill cuttings. The final prototype we developed can
adapt to the unique conditions of each site and provide with sustainable solutions. Even though
we did not create a much cheaper way of using the cuttings, we did provide solutions that ranged
around the existing cost and improved upon various other conditions, such as eco-friendliness.
However, the most important aspect of the system diagram we developed a sustainable system
that properly exploits the drill cuttings and meets the stakeholder requirements.
4.4 Summary
In this section, we illustrated our proposed final system diagram. The proposed solution
offers three different ways of repurposing the drill cuttings depending on the characteristics of
the site and the demand for drill cuttings. Regardless of which solution is used, the final outcome
will be more beneficial to the stakeholders than the process that currently exists.

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5.0 Conclusion
5.1 Advance Organizer
In this section the process leading to the proposed resolutions are discussed, the extent to
which the problem was solved, and possible routes future researchers could take to be more
successful.
5.2 Review of the Analysis
The process leading to the proposed resolutions was long but effective. It started with the
research of what the drill cuttings were made of and why they were damaging to the
environment. One of the main focuses was to make the process eco-friendlier through out and
make the result as less damaging as possible. After the research was done, the specifications
were created to give us a solid idea of how to evaluate each solution and how important and
viable each one would be. We came up with five initial solutions which were eco-land pits,
roads, bunker sand, garbage dumps, and evening out land plots. The five initial solutions were
carefully studied and analyzed using the specifications set earlier in the project. Only three of the
five initial solutions became final solutions. The two solutions left out were the garbage dumps
and the bunker sand. These were not considered for the final solutions for different reasons, such
as a high cost and low reward and a low eco-friendly rating. The final solutions ended up being
eco-land pits, roads, and evening out land plots.
5.3 Evaluation of the Prototype
The problem was solved to a very satisfying effect given the problems that were exposed
during the investigation and because of the versatility that the solutions provide. The main idea
of the project, which was to have an eco-friendly, cost-efficient way to solve the problem of the

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drill cuttings was achieved. With the three solutions, the main problems are solved. They are all
eco-friendly because they are either cleaned before usage, or they are used where there is no
need for them to be cleaned. The idea of using the cuttings for personal use is also a success. For
example, if there are no roads to get to the place where the drillings are being made, the cuttings
would be used to create a road. If the road is already built, the cutting would be used as an ecofill for parts of the land. If there is no need for land to be filled, the cuttings would be cleaned
and then sold to the private or the public sector.
5.4 Future Recommendations
In the future, researchers could focus on new and innovative things given the technology
and the knowledge at the time. With the current technology, future researchers would be
benefited in a great manner to have more contact with Chevron directly. This was a barrier for us
because all the information that could be used directly from the company was from the
frequently asked questions. This was useful at times, but it took time for them to answer certain
questions and most of them were not necessarily useful for our topic at hand. Additionally, it
would be better in the future to do a lot more market research for the proposed solutions. With a
more in depth study the prices and the demand of the products we could be more accurate with
our predictions of costs and revenues. Finally, adding more variables to this experiment would
make it more accurate. For example, knowing all the chemicals inside of the cuttings and the
proportion of chemicals to oil to actual rock/sand would help to analyze better the data. With
these suggestions combined, the project would be a lot more successful.
5.5 Summary
The process leading to the solutions started with research of fracking, then it moved to
specifications for the solutions, after the initial solutions were created, and finally two of the

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solutions were eliminated. The proposed results are all ideas that will help the company with
revenue and at the same time are eco-friendly enough that they will not affect the environment.
Finally, future researchers could be in direct contact with Chevron and have a better market
research for the solutions to be more successful.

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6.0 References
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Hale, D. (2016) Heavy Construction Cost Data. Constructions Publishers and Consultants
Holloway, M.D., & Rudd, Oliver (2013) Fracking: The Operations and Environmental
Consequences of Hydraulic Fracking. Scrivener Publishing.

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Home Advisor (2016) How Much Does Pea Gravel Cost to Install? Retrieved From:
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Kolaneri, K. (May 20, 2014) Drillers, Pa. DEP look at recycling drill cuttings. State Impact.
Retrieved From: https://stateimpact.npr.org/pennsylvania/2014/05/20/drillers-pa-depexamine-recycling-drill-cuttings/
Lewis Kosnik, R. (2007) The Oil and Gas Industrys Exclusions and Exemptions to Major
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