Regulatory Citation(s):

 

78.83. Surface and coal protective casing and cementing procedures.

 

(c) The surface hole shall be drilled using air, freshwater, or freshwater-based drilling fluid.

 

 

Question:

 

Is injecting detergent into the air stream permissible when drilling the surface or coal protective hole?

 

 

Response:

 

Detergents are most commonly used to reduce surface tension and facilitate the removal of cuttings.  They also enable faster penetration rates and lower pressure while drilling.  These benefits contribute toward a cleaner hole, which is critical during cementing operations.  Since detergents are typically additives associated with tophole operations, using them is permissible when drilling the surface or coal protective hole as long as they are a standard formulation and used in a conventional manner.