Environmental Aspects, Impact and Effects

What is an Environmental Aspect?

It is any activity, product or service of an organization that has the potential to interact with the
environment thus causing a noticeable or measurable change to it.

Types of Environmental Aspects.

Environmental Aspects are Direct or Indirect

Direct Environmental Aspects: These are activities, products or services resulting from facilities
under direct control of an organization.

Indirect Environmental Aspects: Activities, products or services resulting from facilities under the
influence, but not direct control, of an organization.

ENVIRONMENTAL ASPECTS E & P ORGANIZATIONS

Oil Exploration and Production activities life cycle includes:
 Geophysical
 Seismic
 Exploration
 Development
 Production
 Decommissioning

Aspects can be considered as a consequence of:

 Normal operating conditions
 Abnormal operating conditions
 Incidents, accidents and potential emergencies
 Past, current and planned activities

For oil and gas operations they include the following:

 Air emissions- Flaring. Venting and Hydrocarbon Gas leakage
 Discharges to water-Aqueous Effluent/Oily Water Discharge
 Solid and other wastes-Drilling mud and Chemicals/Hazardous Wastes
 Land and groundwater contamination – Oil Spillage
 Use of natural resources-Land Use and Degradation
 Water management
 Noise and vibration
 Effects on ecosystems
 Social impacts

Evaluation of Environmental Aspects

The determination of significant environmental aspects is a three step process whereby we;
1. Identify the aspect.
2. Assess the data available on the environmental impact of the aspect.
3. Evaluate the significance of the impact from the aspect.
Identification of Environmental Aspects

We can identify an aspect through many sources of documentation including:

 Environmental Impact Assessment;
 Internal and external audit reports;
 External communications, such as complaints or inquiries;
 Internal incident reports and corrective action reports;
 Environmental baseline reports;
 Environmental Evaluation Report;
 Environmental studies associated with Field Development Plans;

Environmental Impacts
Everything we do impact on the environment. From the highly energy intensive industrial activities
like dredging and drilling to the individual and natural impact. The extent of impact or prolong
impact that leads to effect is dependent on the level of energy exerted.

The impact of E & P activities on the environment can be:

 Temporary or permanent
 Acute or Chronic
 Short term or Long term
 Positive or Negative
 Beneficial or Adverse

Significant Aspects
A significant Environmental Aspect is an environmental aspect that has or can have a significant
environmental impact.
When does it become significant?
 When it poses a risk to the environment
 There is a law concerning it
 Communities are worried about it
 Affects reputation
 There’s a better technology to do it
 There is insufficient information on it

Aspects vs. Impacts for E & P organizations

Aspects Impacts

Geological survey
Seismic - loss of biodiversity
Exploration
Well drilling - air pollution
Chemicals - water/ groundwater pollution
Production
Pipe laying - land pollution
Flaring - thermal pollution
Transportation
Refining - socio-economic/health
Decommissioning
ENVIRONMENTAL REGULATIONS AND LEGISLATIONS

In a bid to curb environmental damage, responsible governments around the globe have enacted
laws to restrict or restrain, as applicable, industrial activities from impacting negatively on the
environment.

In Nigeria, there have been various attempts by the federal government to enact legislations for
the protection of the environment. There have been increasing regulations and legislation on the
environment. This upsurge was accentuated by the worsening of the environment brought about
by the oil boom of the 70s and rapid industrial development which accompanied it.

List of Environmental Regulatory Agencies

1. Federal Ministry of Environment
2. The Department of Petroleum Resources
3. State Environmental Protection Agencies
4. Local Government Environmental Protection Agencies
5. International Conventions

ROLES AND RESPONSIBILITIES OF REGULATORY AGENCIES

Federal Ministry of Environment

 Specification and enforcement of environmental standards
 Regulation of industrial effluent discharges
 Review and approval of EIAs submitted

Department of Petroleum Resources

 Licensing authority with regards to E & P operations
 Responsible for the enforcement of environmental legislation for E & P operations

In pursuance of success in executing their roles and responsibilities, DPR has enacted specific
standards and guidelines for the petroleum industry. These requirements are documented in DPRs
Environmental Guidelines and Standards for the Petroleum Industry (EGASPIN)

DPRs Specific Standards

Production
-No discharge to Environment without permission
-Set Limits for all Effluent Discharges
-Set Limit for Noise, Heat, Radiation and Smoke for Flare gas.
-Noise- 80Db
-Heat-6.31kw/m2
- Smoke- 60% light transmission
- Monitoring Oily waste
- Gaseous emissions
- Monitoring of PH, THC & Metal concentration
-Monitoring of all recipient environment when waste is discharged.
Considerations for Regulatory Compliance
The benefits from complying are the driving force for regulatory compliance. They include:
- Assets integrity
- Risk and liabilities reduction
- Cost reduction
- Improved environmental condition
Other regulatory compliance drivers, mainly internal are:
- Company Policy
- Company Reputation
- Good Performance
- Industry Benchmark

International Policies and Practices

The international community has many Non-Government Organizations (NGOs) that work with
national governments and industry to help establish policies, standards, and practices that help
protect people and the environment. The World Bank (WB) and its related International Finance
Corporation (IFC) are important NGOs that play a major role in many large industrial projects
around the world. The WB and IFC have established environmental guidelines and standards for
projects that they participate in. The WB Pollution Prevention and Abatement Handbook includes
elements for General Environmental Guidelines as well as onshore Oil and Gas Development

The World Bank guidelines cover the following environmentally related issues for the petroleum
industry:
• Air Emissions
• Liquid Effluents
• Hazardous Materials and Wastes
• Solid Wastes
• Ambient Noise
• Monitoring
• Recordkeeping and Reporting
• Environmental Control - energy efficiency, environmentally sound processes, proper
maintenance and operation of facilities
Air Emissions
The WB has specific recommendations for onshore oil and gas VOCs, including benzene 20 mg/m3 max.
development project. For drilling, the WB recommends that Hydrogen sulfide 30 mg/m3 max.
Sulfur oxides 1000 mg/m3 max.
gel-based based muds be used and that diesel based muds be Gas fired nitrogen oxides 320 mg/m3 max.
eliminated. If chemicals are to be used in drilling and other Oil fired nitrogen oxides 460 mg/m3 max.
operations, then the less toxic chemical should be selected. Odor Not offensive
Flaring should be minimized and low NOx burners should be
Liquid Effluents
used. Sulfur should be removed from gas before burning and Odor Not offensive
knockout drums should be used to capture condensates. Spill pH 6-9
prevention should be in place and control measures taken, Biochemical Oxygen Demand 50 ppm, max.
Total Suspended Solids 50 ppm, max.
including leak detection and prevention, repair programs, and
Oil and Grease 20 ppm, max.
tank and vessel monitoring and corrosion prevention Phenol 1 ppm, max.
programs. Oil should be recovered from wastewaters. Finally, Sulfide 1 ppm, max.
good housekeeping should be practiced and appropriate Total Toxic Metals 5 ppm, max.
Temperature Increase <3 C
operating and maintenance programs should be in place.
 Oil and Grease 42 ppm daily avg., 29 ppm mo. avg.
The IFC offshore guideline addresses the EHS Deck Drainage No sheen
management system, environmental guidelines Non WB mud/cutting No discharge w/o LC50 compliance
for air, water, wastes, and NORM, environmental WB mud/cutting No discharge w/o LC50 compliance
Diesel mud/cutting No discharge
best practices, emergency response, health, Chemicals Toxicity testing for hazard/impact
safety, monitoring, reporting, and supervision. Produced Sand Re-inject or dispose onshore
The recommended IFC standards for offshore Produced Water Meet guidelines if disposed offsite
discharges are listed in the adjacent figure. Sanitary 1 ppm Chlorine
Cooling Water < 3 C increase

Other policies and practices have been proposed by other NGOs. In 2001, the Government of
Norway and the World Bank Group proposed the Global Initiative on Natural Gas Flaring Reduction.
The initiative’s goal is to support national governments and the petroleum industry to reduce
flaring and venting of gas associated with the extraction of crude oil by:
 Commercialization of associated gas
 Development of regulations for associated gas
 Establishing a voluntary flaring and venting reduction standard
 Capacity building related to carbon credits for flaring and venting reduction projects

Guidance to achieve the voluntary standard includes recommendations to eliminate routine

sources of venting gas that could be captured, conserved, or routed to a flare. An additional
recommendation is to reduce large sources of associated gas flaring, primarily those sources
associated with production, except for those related to emergencies, safety, and operational
upsets.

Other international organizations also have programs and guidance related to environmental
protection. The International Union for the Conservation of Nature and Natural Resources has
issued guidelines for environmental protection during oil and gas exploration in the tropics,
mangrove areas, and artic offshore regions (www.iucn.org). Conservation International has
published a policy paper on oil development in the tropics called “Reinventing the Well:
Approaches to Minimizing the Environmental and Social Impact of Oil Development in the Tropics”

The Equator Principles are followed by more than two dozen financial institutions in 14 countries
that have pledged not to provide loans for projects unless certain environmental conditions are
met as listed below (www.equator-principles.com):
 Risk categorized according to environmental/social screening
 Environmental assessment completed
 Environmental and social conditions addressed
 Environmental management plan prepared
 Consulted with stakeholders and NGOs
 Environmental expert to monitor and report
 In compliance with environmental and social covenants

The International Association of Oil and Gas Producers (OGP) is a key industry group that provides
standards, practices, and guidance in the environmental aspects of O&G operations. Among the
documents and guidance from the OGP are the following:
 Environmental management in oil & gas exploration and production;
 Guidelines for produced water injection;
  Flaring and venting in the oil and gas
exploration and production industry;
 Petroleum industry guidelines for reporting
greenhouse gas emissions;
 Exploration and production waste
management guidelines;
 Oil Industry operating guideline for tropical
rainforest;
 The oil and gas industry - from Rio to
Johannesburg and beyond: Contributing to
sustainable development.
There are also national O&G organizations that
provide environmental guidance and
recommended principles and practices. The
American Petroleum Institute (API) (http://api-
ep.api.org) has produced the Environmental
Stewardship Program, the Environmental and
Safety Mission and Guiding Principles, the
Environmental Stewardship Program Pledge for
CAREFUL Operations, and the Onshore Oil & Gas
Production Practices for Protection of the
Environment. The Australian Petroleum
Production and Exploration Association (APPEA)
(www.appea.com.au) has established an
Environmental Policy, Code of Environmental
Practice, and Code of Environmental Conduct. The
United Kingdom Offshore Operators’ Association
(UKOOA) (http://www.ukooa.co.uk) has developed
a set of Environmental Principles.
ExxonMobil Environmental Performance
 Maintain strong emergency response preparedness
 Seek opportunities to conserve industrial water use
 Protecting biodiversity fundamental part of EMS
 Understand and respond to climate change
 Improve energy efficiency
 Reduce flaring
 Global Climate Energy Project
 Performance Reporting
 Spills
 Expenditures
 Air emissions
BP Environment and Society
 GHG – no net increase from 2001 levels (10% reduction from 1990
 Biodiversity and Conservation – localized approach
 Sensitive Areas – only if in compliance with standards and
regulations, publish risk assessments
 Performance Reporting
 Air emissions
 Spills number and volume
 Discharges to water
 Hazardous waste
Shell Policies and Standards
 HSE Policy – systematic approach, targets, appraisals
 Biodiversity Standard – maintain ecosystems, conservationism
 Environmental Minimum Standards
 No continuous flaring/venting for new facilities
 SOx and NOx within range for OECD
 Produced water discharge only if compatible
 No discharge of oil-based mud
 ESIA for all new projects, major facility developments, significant
modifications, or abandonment
 Performance Reporting – emissions, energy efficiency, fines,
flaring, spills, waste, water use, public perception Oil and Gas
Development (Offshore)

The International Organization for Standardization has developed a a well know environmental
management standard, ISO 14000. This is a set of voluntary standards, consisting of ISO 14001 and
14004, that provide specific requirements and principles for environmental management. OGP’s,
API’s, and APPEA’s industry principles and practices are consistent with this standard.

Oil and gas companies also develop their own policies, practices and standards. Some of these are
shown on the adjacent figures. Petroleum companies need to be aware of the international and
national policies, standards, and practices that are being used, and evaluate as to how their own
environmental policies, standards, and practices should conform to or be influenced by them. In
order to attract partners, petroleum companies must be able to show that they comply with a
consensus on what is appropriate for environmental protection. This will also provide for the
public’s confidence that companies can operate safely and in concert with the environment and
with the people in the areas in which they operate. This helps assure access to resources and
promotes a cooperative relationship. In addition, new ideas for policies, standards and practices
will need to be evaluated for benefits and improvements that they may provide for operational and
environmental performance. This can help assure that people and environment are protected, and
can be used to work with regulators improve and establish the regulations under which the
industry operates.

Environmental Management System

An Environmental Management System is define as an organization’s structure of responsibilities

and policies, Practices, procedures, processes and resources for the protection of environmental
management issues.

An EMS is a way of working which enables the organisation to control the environmental effects of
operations and improve its environmental performance

The EMS is structured around the “continual improvement” cycle of Plan, Do, Check and Review.
PLAN - Decide what needs to be done
DO - Put in place an action program for achieving it
CHECK - Confirm that implementation is achieving the plan
IMPROVE- Re-examine progress and change the plan if needed

Essential Elements of an EMS

1. Demonstrable Management Leadership
2. Policy and Strategic Objectives
3. Organisation and Responsibilities
4. Hazards and Effects Management Process
5. Standards, Procedures and Document Control
6. Implementation, Monitoring and Corrective Action.
7. Training
8. Audit

EMS and ISO 14000

ISO stands for Internationale Standard de Organisation

The ISO sets standard for management system in various business disciplines such as quality and
environment. ISO 14001 establishes the required standard of a management system to ensure
continuous improvement in environmental performance

ISO 14001 is a system to control and reduce environmental impacts. Organizations with an existing
EMS may seek ISO certification from any of these accredited external agencies
 KPMG
 Lloyd

The certification process itself entails the following

- Initial assessment
- Final assessment
- Issue of certificate
- Surveillance contract

It is important to note that ISO certification is not a regulatory requirement, at least not at the
moment. So why bother about ISO, why external certification?
 1. It serves as a reassurance to stakeholders that you are dedicated to upholding your
environmental policy
2. It helps in risk reduction

Other benefits include

1. Improvement in environmental performance
2. There is enhanced competence development
3. Excellence in operations
4. Energy consumption reduction
5. Stakeholders relationship improvement
6. Cost savings

Summarily, ISO means------

- Be aware of environmental aspects of your work
- Be in control of your environmental aspects
- Be responsible and act wisely
- Manage your work to reduce impacts
- Improve your performance

Remember, ISO is a means to an end not an end in itself. Organizations must be seen to produce
real performance improvements in aspects that their stakeholders regard as important

Environmental Impacts of Petroleum Operations

There are many sensitive environments in the Niger Delta and most petroleum operations will have
the potential to produce environmental impacts if not properly managed. Mangroves and salt and
freshwater habitats have particular environmental importance in areas such as the Niger delta.

Impacts of petroleum operations vary depending on the location, type of operation, and other
factors. On a gross scale, offshore facilities create different impacts than those on land. Those in
pristine habitats are likely to generate greater environmental concerns than operations planned in
areas already modified by human activity. Tropical forests are more diverse and generally less
disturbed by Man than are biological communities in Nigeria’s savanna grasslands.

Evaluation of and sensitivity to the facility location during the planning process can help to
minimize adverse impacts even when the operation is located in an area rich in biodiversity.
Whether facilities are concentrated or spread out affects dispersal patterns for migratory animals
like caribou. The need for roads, pipelines, electrical power generated offsite, etc. can affect the
habitat disturbance pattern. If new facilities are remote from human settlement and activity, they
can allow for influx of development that isn’t necessarily related to the operation (secondary
impacts). For example, new communities are settling on dredge spoils deposited on river banks in
swamp operational area.

Petroleum operations can have both primary impacts, those closely tied to the operation in time
and space, and secondary impacts, those occurring later as a consequence. Vegetation removal
and grading for roads and drill pads, gravel mining, and dredge/fill activities lead to primary
impacts such as direct habitat loss or excess erosion or interference with natural drainage. When
land is left bare, fast colonizing, weedy species usually have the advantage, resulting in secondary
impacts of changes to community composition.

Harm to individual organisms may occur through impaired behavior or mortality from noise,
vehicles, and accidents such as fires. Animals can become trapped in well cellars, open pipeline
trenches or open sections of pipeline in staging areas. Harm can also result from exposure to toxic
substances or creation of attractive nuisances such as wetlands overlying contaminated areas or
reserve pits.

Harmful exposures may also be posed by waste discharges such as flares, produced water, drill
cuttings discharge, and oil spills. Biologically available materials and nutrients from such discharges
into water bodies can change their character from clear, nutrient poor waters to those clogged
with algae and starved for oxygen as algae and vegetation grows, accumulates, and decomposes.

Impacts such as those above can be avoided or minimized by proper evaluation and planning.
Understanding how to mesh petroleum extraction with biodiversity conservation starts with
effective planning on a regional scale. Individual companies are usually only able to influence
practices carried out in the concession areas they are responsible for. But understanding how to
promote resource development so it minimizes conflicts with biodiversity values starts at an early
stage and should involve the appropriate government ministries.

The location of facilities should take into account the local distribution of sensitive plants and
animals. These can be evaluated through appropriate surveys and by accessing existing
information. Mapping efforts utilizing GIS can be very helpful tool.

A source of information and guidance on preventing impacts is the Energy and Biodiversity
Initiative (EBI), convened by CELB (www.celb.org/xp/CELB/programs/energy-mining/ebi.xml). The
EBI brings together energy companies and conservation organizations to develop and promote a
framework of best practices for integrating biodiversity conservation into upstream oil and gas
development. EBI has created a set of practical guidelines and tools to minimize impacts to
biodiversity and maximize contributions to conservation wherever oil and gas resources are
developed. The guidelines address all stages of the project lifecycle—from pre-bid to
decommissioning—and are designed to be integrated into existing company management systems.

It is also important to understand the relationships and needs for biodiversity conservation and
integrate this with community development activities. Oil companies may have greater resources
than local governments to devote to conservation that can be brought to bear on mitigation and
extend efforts to promote biodiversity through education, land set asides, acquisitions, training,
and management of conservation areas.

Oil and gas operations occur in several ecosystems in Nigeria. Onshore acreage and operations are
located predominantly in the wetland forest, marshes and shorelines, except for some blocks
located in the Derived Savanna vegetation zone. The wetland ecosystem of Nigeria has some very
distinctive characteristics that make it very sensitive to construction activities. The rest of the
blocks are located in the Atlantic Ocean
Petroleum operations can impact the environment through three main processes. The first of
these is habitat loss which is one of the major impacts of human activities on ecosystems. Oil and
gas development contribute to the overall cumulative impacts of habitat loss, but other activities
like logging, tourism and urban development exert far greater pressure. In Nigeria, the major
pressures on mangrove resources are clearing for timber and charcoal production, shrimp farming
and tourism development. In Nigeria, it is estimated that mangrove forests are lost at a rate of 500
Ha/year to these pressures (out of an estimated 10,000 Km2). Rapid population growth in the last
50 years has exacerbated this problem.

The second major process impacting environments is habitat fragmentation, the breaking up of
large pieces of habitat into smaller, less functional pieces. Fragmentation can lead to reduction in
plant and animal species numbers and diversity and to population losses of common species.
Plants and animals need continuous space to feed and reproduce. When space is broken into
pieces this can impact the area available for shelter, food, and behavioral activity which can
adversely affect plants and animals.

The third major process that impacts environments is habitat degradation. Human presence or
disturbance can lead to subtle changes in the physical, chemical, and biological characteristics of
habitats. Disturbance can lead to edge effects that erode habitat quality of adjacent ecosystems.
Small alterations in elevation in wetland systems can introduce saltwater into freshwater habitats
and destroy or degrade the freshwater systems. Excessive nutrients or toxic materials can have
biological impacts.

The following are likely impacts that may occur due to petroleum operation activities:
• Loss of Species and Habitat Loss and Fragmentation -The breaking up of large pieces of
habitats into smaller less functional pieces can lead to loss of habitat and a reduction in
plant and animal species numbers and diversity.
• Wetland Loss Leading to Increased Erosion and Siltation: Vegetation provides protection
against erosion of coastlines, rivers, streams and creeks. Mangroves act as filters in the
swamp, trapping sediment and stabilizing banks preventing erosion. If mangroves and
other vegetation are removed this can result in increased sediments washed into the river.
This may result in numerous impacts such as degradation of water quality, a need to
increase dredging of channel, and additional loss of land. The removal of mangroves and
other vegetation must be carefully considered and, when necessary, re-establishment of
the vegetation and/or erosion controls should be carefully considered to reduce impacts.
The natural control of coastal erosion is often not appreciated until an engineering solution
is sought to combat erosion following the clearing of coastal vegetation.
• Hydrology Changes: Intrusion of saltwater into freshwater systems can adversely affect
them. Hypersalinity (e.g., saltwater from the ocean or from produced water) will affect
even brackish systems. So too small alterations in elevation can influence hydrology and
mangrove wet and dry fluctuations. Changes in the flows and salinities of water will cause
changes in the aquatic community and vegetation. This may cause adverse impacts to
fisheries and cause vegetation to die.
• Oil Spills: Wetland and terrestrial vegetation can be affected by oil in different ways.
Mangroves rely on their pneumatophores (prop root systems) for respiration. If coated
with oil, pneumatophores become sealed and the mangroves may suffocate. Furthermore,
 oil can cause damage to root membranes, leading to the failure of salt control in saltwater
systems leading to death by loss of water through a process called osmosis.
• Spoil Areas and Drained Wetlands: Many marine, coastal, and wetland sediments have the
potential to generate acid runoff when they are dried and exposed to oxygen. These
sediments contain sulfides that react with oxygen to form sulphuric acid when exposed to
air when the wetland is drained or when spoils are deposited on dry land. Runoff from such
areas may be acidic and can have detrimental impacts in rivers and canals, and may also be
corrosive to pipelines and other equipment.
• Secondary Impacts: Opening new areas with roads and canals invites people to relocate
and settle in the new areas. This will lead to secondary impacts from the communities that
arise, even though they are not directly related to petroleum operations.

Experience has shown that it is both easier and cheaper to avoid environmental impacts than to try
to reverse them. Later chapters will cover some ways to minimize and avoid impacts. As a best
practice, the following are Prevention and Avoidance Principles that work well under most
circumstances
1. Upfront planning
2. Limit access to undisturbed or highly sensitive areas
3. Minimize footprint
4. Maintain natural conditions
5. Manage construction wastes

Air Emissions
Air Pollutants are gaseous emissions that can cause undesirable modification of atmospheric
constituent, which may have harmful effects on Flora, Fauna or Materials.

Pollutants from E & P Activities

 Hydrocarbons
 Methane
 Non-methane hydrocarbons
 Volatile Organic Compounds (VOC)
 Nitrogen Oxides
 Carbon Oxides (Carbon dioxide and Carbon monoxide)
 Particulate

Impacts of Air Pollutants

 Carbon dioxide traps radiation rays in the atmosphere, this heat up the Environment resulting
into Global warming. Other gases like Sulphur dioxide which also have this effect are termed
Green house gases.
 Air pollutants can cause negative impacts on Human health. Carbon monoxide reduces the
oxygen carrying capacity of blood, impairs mental function and aggravates cardiovascular
disease. A large number of Volatile Organic Carbon compunds are carcinogenic.
 Sulphur oxides and Nitrogen oxides when oxidized and hydrolyzed results into acid rain.
 Sulphur dioxide is known to reduce atmospheric visibility and damages plants.
Climate Change and Global Warming
 Greenhouse gases trap heat from the sun that is normally reflected back into space from the
Earth's surface, thus acting like glass panels, which let light in and keep heat inside.
 Without greenhouse gases the World would be a lot colder, but recently levels of some
greenhouse gases have begun to increase. The increase of greenhouse gases and global climate
change are partly associated with each other, which could have detrimental effects such as
rising sea levels and extinction of species that cannot cope with the change.

Sources of Air Pollution

 Drilling Emission Sources
 Flaring, well tests, flowbacks
 Pits
 Controlled Combustion Sources
 Pits and Ditches
 Equipment Leaks
 Floating Roof Tanks (Rim seals and other Fittings)
 Fugitive Emissions
 Tank cleaning
 Vapor displaced from Oil tanker vessels

Regulatory Requirements on Air Emissions

Department of Petroleum Resources (DPR)
 Prescribe Emission Limits that represents the maximum allowable levels of pollutants from
gaseous emission sources.
 Part 3, section 3.8.8.1 of the DPR Guidelines and Standards stipulates that Waiver and permit
be obtained for gas flaring and also the payment of fine for flaring Gas. The section further
mandates that only pretreated and clean gas can be flared.
 Part3, section 4.4.2, stipulates the development of emission inventory, sampling and laboratory
analysis of ambient air around Flare sites and Production facilities for the following- Particulate,
Hydrogen Sulphide, Ozone and Volatile Organic Compounds

Best Practices to Manage Air Pollution

Gas Flaring/Venting Emission
 Gas Recovery Preferable if high value products are obtainable
 Liquefied Petroleum Gas obtained by refrigeration is the most common Gas Recovery Product.

Emissions from Pits and Ditches

 Eliminate pits and ditches and replace with tanks and pipes.
 Cover pits and ditches.

Combustion Sources
 Optimize Equipment Performance
 Reduce excess oxygen
 Install Retrofit Controls
 Particulate collection from flue gas using:
 Electrostatic Precipitator
Environmental Impacts of Air Emissions

E&P facilities produce various types of air emissions. An evaluation of the potential environmental
impacts from air emissions requires an identification of the equipment and facilities that emit air
emissions and an understanding of type and quantity of air pollutants emitted by the operations.

Flares act as control devices burning waste. Flares also convert greenhouse gases (GHGs) like
methane to CO2, which on a volume basis have much lower global warming factor. However,
burning gas produces excessive amounts of CO2, which is usually the largest greenhouse gas
contributor from petroleum operations.

Offshore platforms tend to contain both oil processing equipment and gas processing equipment
such as dehydrators and compressors. Due to limited space and the need to carefully manage
weight, gas turbines may replace engines as compressor and generator drivers. Depending on the
quality of the gas being burned, gas turbines will emit air pollutants such as oxides of sulfur (SOx),
oxides of nitrogen (NOx), carbon monoxide (CO) and particulates.

Gas plants are typically much larger facilities than compressor stations or tank batteries. In these
facilities, most emission point sources like vents are hard piped to a flare. This means that most
emissions are burned in the flare and reduced approximately 98%. The flare does produce CO2 and
SO2 (if H2S is present in the gas sent to the flare). CO2 is a greenhouse gas and SO2 can contribute
to acid rain. The other large source of emissions at gas plants can be fugitive emissions.

Tank batteries may have flash gas, the gas that comes out of the production stream when pressure
is reduced in equipment or tanks *like CO2 coming out of a Coke can when it’s opened+. Emissions
can be controlled by capturing the vapors in a small compressor called a “vapor recovery unit” or
by routing them to a flare. Flaring of this gas can reduces hydrocarbon emissions by 98% but
produces CO2.

Compressor station engines are the typical large source at compressor stations. Engines emit
mostly NOx, CO, and CO2 as combustion products or byproducts.

Glycol dehydrators remove moisture (water) from natural gas using a glycol compound and these
can emit BTEX (benzene, toluene, ethyl benzene, and xylenes). Benzene is a toxic air pollutant that
can cause cancer and other health effects. Properly installed and operating controls can reduce
BTEX and most other emissions from these units by 90-98%.
Hydrocarbons Methane (CH4) (a greenhouse gas)
As noted above, most oil and gas
Non-methane hydrocarbons (NMHC)
operations emit pollutants, which Volatile organic compounds (VOC)
can enter the environmental and
may have negative impacts
depending on concentration, Combustion Byproducts SOx, NOx, CO, Particulates
toxicity and volumes over time. Products of incomplete
Pollutants can be grouped combustion (PIC)
according to their type and source.
The adjacent figure lists some of the Hydrogen Sulfide H2S
important pollutants for the
Carbon Dioxide CO2 (a greenhouse gas)
petroleum industry. Oil and gas are made of hydrocarbons and some of these are important
pollutants. Pollutants called combustion byproducts form when fuel is burned and are a natural
byproduct of combustion. Hydrogen sulfide is one such byproduct and can be fatal at certain
concentrations. Carbon dioxide is another and it is the major greenhouse gas. It sometimes occurs
naturally in our produced gas and is one of the principal products of combusting fuels containing
carbon (e.g. wood, coal, oil, natural gas).

Combustion byproducts include products of incomplete combustion (partially oxygenated),

hydrocarbons, particulates, and large, complex aromatic hydrocarbons. NOx means molecules with
one nitrogen atom and any number of oxygen atoms (e.g., NO and NO2 and N2O). SOx means
molecules with one sulfur atom and any number of oxygen atoms (e.g., SO2 and SO3).

CO2 is the primary emission of ALL hydrocarbon combustion processes. The amount of CO2
emitted depends only on the amount of carbon burned. The main “negative impact” of CO2 is that
it is the major man-made contributor to global warming. Control of CO2 is very difficult and
expensive. The best control is not to make it in the first place (e.g., to conserve energy).

Air pollutants don’t stay in the atmosphere forever. Volatile organic compounds (VOCs), such as
BTEX, are usually oxidized to form CO2 and water. SOx, NOx, and particulates wash out in the rain,
or deposit onto the ground or water bodies. Acid rain from SO2 dissolved in rainwater to form
sulfuric acid is an example of this. CO2 is taken up by plants and dissolves in the oceans. The
problem is that, before they can be removed, pollutants have time to interact with and affect
people and the environment.

Air emissions can produce health effects that range from immediate effects associated with
exposure to high levels of H2S to chronic or long term effects such as cancer from long term
exposure to pollutants like benzene. For example:
• 500 ppm of hydrogen sulfide (H2S) can kill in a few minutes. H2S can be emitted from gas
and oil production. Flaring gas and fugitive emissions from oil and gas operations convert
H2S to SOx, a significantly less toxic form.
• SOx forms sulfuric acid when in contact with water and moisture, and can irritate lungs and
eyes.
• High ozone levels cause eye and lung irritation. Ozone if formed from an atmospheric
reaction from NOx emissions.
• Exposure to particulates can cause irritation to the lungs and over time can cause lung
damage.
• For both acute and chronic effects, there are pollutant concentration levels below which
there are no adverse health effects.
• Carcinogenic pollutants promote cancer. This could be considered a chronic effect, but it is
usually shown as a separate category. A major difference is that for carcinogenic pollutants
there may be no safe level - ANY exposure increases the chance of developing cancer, at
least slightly. Medical experts are not in complete agreement about this.
• Pollutants can fall into one, two, or all three of these categories. (Or none, if they don’t
directly impact human health. CO2 is an example.)
.
Beyond health effects, there are also issues related to destruction of the ozone layer in the
atmosphere, acid rain, and odors. The ozone layer acts to shield UV and cancer causing rays.
Emission of halons from fire fighting equipment, Freon from refrigerators and air conditioners, and
Arklone solvent used in oil in water testing react with ozone and can contribute to loss of the ozone
layer. Acid rain pollutants, like SOx and NOx, form acids in the atmosphere that are deposited in
rain. This can cause changes in acidity of soil and natural waters that may lead to loss of forest and
aquatic animals. Many pollutants, such as CO2, CO, and NOx, will not produce any odors, but VOCs
and substances such as H2S can produce objectionable odors even at small concentrations in air.
The World Health Organization (WHO) has set an objectionable odor threshold for H2S at 5 ppb.

The impacts of pollutants are not only a function of their

concentration but also their lifetime in the atmosphere. How Long Do Pollutants Stay In the Atmosphere?
As you can see from the adjacent figure, the lifetimes of
CO2 120 years
different pollutants vary considerably. The shorter-lived
Methane 12 years
pollutants can be local or regional problems. Since CO2 CO 2 months
and methane are relatively inert, they have time to spread Benzene 2 weeks
across the globe and, as GHGs, they will have an effect on H2S 1 week
the temperature of the whole earth. This is an example of Formaldehyde 1 day or less
“Starting Local Looking Global”. Emissions of CO2 and
methane occur locally but have global impact.

As previously noted, some air emissions such as CO2, NOx and methane are greenhouse gases, so
named because they act much the same was as glass panes do on a greenhouse to trap the heat
from solar radiation and thereby warm the interior of the greenhouse. Without these gases, heat
would escape back into space and Earth’s average temperature would be about 60ºF colder.
Greenhouse gases help regulate the temperature of the earth and their effect can be greater as
their atmospheric concentrations increase.

To illustrate this, the adjacent figure is a graphical

look at the greenhouse effect. Energy comes from
the Sun in the form of incoming solar radiation.
Some of the radiation is absorbed by water vapor
and gases in the atmosphere, some by the earth,
and some is reflected back into space. The
radiation absorbed by the earth is radiated back as
longwave radiation. Some of this energy is
absorbed by GHG molecules in the atmosphere.
This causes the atmosphere to heat up.

The greenhouse effect is not bad. Without it, we

could not live on earth. However, there is Man-made gases that trap radiation from the earth’s surface:
concern about the “enhanced” greenhouse
effect that is caused by increased concentrations Relative importance*
Carbon Dioxide 60%
of GHGs, particularly CO2, that cause the
Methane 20%
atmosphere to be warmer than it would be CFCs 10%
without the addition of extra CO2 from burning Nitrous Oxide (N2O) 6%
fossil fuels like coal, oil, and gas. Other 4%

*Relative importance to the enhanced greenhouse effect

The major GHG gases and their relative importance to the enhanced greenhouse gas effect are
shown in the adjacent figure. Carbon dioxide is the major source of the enhanced GHG effect.
Almost all of this carbon dioxide is created by burning fuels that contain carbon. In the combustion
process, the carbon in the fuel is converted to CO2.

Methane is the next largest contributor to the enhanced GHG effect. Methane comes from natural
sources such as organic decomposition in swamps and from some human activities. Oil and gas
exploration and production activities contribute about 10% of the methane that is in the
atmosphere.

Nitrous oxide is the only other GHG gas that is routinely produced in oil and gas operations. NOx is
a combustion byproduct produced in small amounts from flaring and fuel fired compressors,
turbines, and engines. However, it is relatively small compared to CO2. CFCs are chlorinated
fluorocarbons released from fire fighting and refrigeration equipment.

An enhanced greenhouse effect can effect changes in global temperatures, rain fall rates, and sea
levels. Changes in climate may have the following impacts:
 Health impacts – More rain may create a wetter climate that results in more mosquitoes and
more cases of malaria.
 Vegetation and species impacts – Nigeria could develop a drier climate which could convert the
Niger River Delta to a vast grassland or even a forest over a century or so. Animal species that
inhabit grasslands could move into the area. Valuable fish species could be lost if spawning and
nursery grounds are lost in the Niger Delta. Local crops could be impacted or even fail due to
changes in temperature and rainfall.
 Coastal impacts – Rising sea levels from melting ice caps could flood large areas of the coast
making these inhabitable and changing the marine and terrestrial habitats along the shore.

In summary, air emissions from oil and gas operations not only represent a loss of potentially
valuable product, but they can also have environmental and health impacts.

Produced Water
For as long as oil is produced, water must be produced along with it. The associated water that
comes with produced crude is referred to as “produced water”.

Oil and gas reservoirs may contain significant quantities of water, which is separated from the well
stream fluids following extraction – volumes tend to increase with reservoir life

The separated produced water is typically discharged overboard following treatment or it is re-
injected into the reservoir. Re-injection may reduce environmental impact (depending on where
the water is re-injected.

Since oil production is a daily event, discharged of produced water into natural water bodies must
also be a daily occurrence thus making ‘produced water’ the main source of oily water.

Regulatory Standards for discharge

In a bid to eliminate the negative impact produced water poses to the marine/aquatic ecosystem,
DPR requires that produced water must be treated before disposal
The DPR standards
In the past
 Oil in water< 10ppm for inland disposal
 Oil in water< 0ppm for offshore disposal

Current
 Oil in water- zero discharge inland
 Oil in water- 10ppm to zero

Potential Effects of Produced water

The effects from produced water are usually localized ( within 200m of discharge ) but can include:
- Bioaccumulation and ‘tainting’ of fish due to BTEX and PAH compounds
- Persistence and accumulation in sediments and seabed communities
Treatment Techniques
The techniques employed in the treatment of produced water before discharge overboard includes
but not limited to
 Gravity separation
 Gas separation
 Gas flotation
 Hydocyclones
 Advanced treatment technologies

Environmental Impacts of Produced Water

The oil and gas industry not only produces oil and gas, but also significant quantities of water. In
many cases, the amount of water produced can equal or exceed the amount of oil that is produced.
When the water is in contact with oil, chemicals will be transferred from oil into the water. Even if
the solubility is greater in the oil, the chemicals will still partition into the water. For many organic
chemicals we can expect that about 1 % of their weight will enter the water.

In addition the mixing of the oil and water causes minute droplets of oil to be suspended in the
water. Other chemicals in the water include salts and metals. The dissolved and dispersed oil and
chemicals can have an impact on the receiving water and habitats in contact with the water. This
includes people who live and work nearby and who may use the water. To prevent and reduce
impacts from produced water, it is critical to have an understanding of the chemicals in the water
and how they can have impacts.

Produced water presents a biological risk. In order for biological risk to be a factor we have to have
a chemical of concern present at a concentration that will cause an impact and we also need
exposure, that is, a way that the chemical will reach either aquatic or human life. Chemicals of
concern include those that occur naturally in oil such as BTEX (benzene, toluene, ethyl benzene,
xylene), PAHs (polyaromatic hydrocarbons such as naphthalene) and H2S (hydrogen sulfide).
Treatment chemicals are also potentially toxic. When mixed in the water, people can be exposed
to these chemicals through eating contaminated fish, by drinking or cooking with contaminated
water and by bathing or swimming in contaminated water.
Even though a chemical of concern may be present in water, its toxicity will depend on its
concentration, or dose. Generally, the higher the dose, the more toxic the chemical will be.
Produced water toxicity is important because it is usually the largest production waste stream and
the quantity tends to increase with time as a field matures. Hence the dose may also increase as
the field matures.

The chemical composition of the produced water will vary by field and it will contain various
amounts of chemicals that are potentially toxic. In Nigeria, produced water typically contains 75 to
100 ppm O&G and <10 ppm hydrogen sulfide at a pH 7.3 to 8.0. Other properties of produce water
are:
• Salinity varies from almost fresh to almost 10 times more salty than seawater
• Benzene and other hydrocarbons often present
• Treatment chemicals may be present in trace concentrations
• Low oxygen concentration
• Wide variation in toxicity
• Some constituents of produced water may be toxic to fish at 0.1 to 1 mg/l
• Temperature, pH, salinity, etc. will affect toxicity

A key concept that can be used to reduce the concentration of these contaminants, and thereby
reduce any effect they have on acute or chronic toxicity is dilution of the produced water through
dispersion. Some factors that affect dispersion are
• Energy of the receiving water body: stagnant, or currents/tides
• Discharge flow rate: volume discharged, turbulence
• Discharge depth: room to float or sink before hitting top/bottom
• Relative salinity and temperature compared to water body

Some discharge conditions will result in high concentrations of produced water. Others will result
in quick mixing and low concentrations. Quick mixing results in lower doses. Laboratory studies
have shown that dilution can reduce or eliminate impacts to fish.

It is important to remember that the effects of dispersion are on impacts within the receiving water
body. Dispersion does not apply to total hydrocarbon or oil and grease limits, as these are
regulatory limits set at the discharge point and not what will be achieved in the receiving water.
Discharge limits are based on the levels that technology can achieve and not necessarily on
potential risk of impact in the receiving water. However, regulatory limits may be expected to
achieve acceptable risk after nominal dispersion.

When considering toxicity, we look at both short term (acute) effects and long term (chronic)
effects. Acute effects result from short-term exposure, with effects seen in seconds to days. Death
could occur as a result of a short term exposure. Other acute symptoms might include behavioral
changes (poor swimming ability in fish, dizziness in people), human skin or eye irritation (redness,
itching). Chronic effects are delayed and may take weeks, months, or years to be seen. Chronic
effects include death, reduced fish reproduction, stunted growth, deformities, behavioral changes
and cancer. Generally chronic toxicity occurs at concentrations 10 time lower than acute toxicity
concentrations.
Ecological impacts from toxicity of produced water can include elimination of a key food source or
death of mangroves and freshwater species due to higher salinities. Fish tainting can occur when
fish can take up chemicals into their bodies from water, sediment, or food. This causes the fish to
taste oddly when eaten. Many hydrocarbons in produced water can cause tainting.

Although produced water may have very low

concentrations of chemicals when discharged and
dispersed, these chemicals may bioaccumulate within
plants and animals that are exposed to them. The
adjacent figure illustrates bioaccumulation, whereby
small animals and plants take up chemicals by ingesting
contaminated particles or adsorption through physical
contact, and are then eaten by larger animals that
accumulate the chemicals. Bioaccumulation is a
concern that chemicals will accumulate in fish resulting
in exposure to consumers of fish, which might be people, birds and other aquatic life.
Bioaccumulation increases the dose component of biological risk because the amount of the
chemical becomes higher at each food level. A chemical that bioaccumulates reaches higher
concentrations in animal tissues as it moves up the food chain. Good examples are DDT and PCB,
which are highly stable, fat soluble chemicals. Produced water constituents rarely bioaccumulate,
but PAHs, mercury, and biocides containing tin are constituents of concern.

In summary, it is important to remember that produced water can be a major emission from
production that tends to increase as the field grows older. Produced water contains constituents
from oil and production treatment chemicals that can have environmental and health impacts, and
impacts on mangroves and fish have been noted for some production fields due to the discharge of
produced water. Whether or not produced water will have an impact depends on the type and
amount of constituents in the produced water, the amount of water discharged, and how well it is
dispersed in the receiving water body.

Environmental Impacts of Drilling

In order to understand environmental
impacts, we must understand the Understanding the Drilling Process
drilling process. The adjacent diagram
illustrates the drilling process and the •Riser used for later sections of
generation of the main waste stream hole drilled to return drilling Cuttings
mud and cuttings to rig discharge
from drilling, the drill cuttings. The drill
•Drill string is inside riser
string, which connects to the drill bit, is
•Drill cuttings must be disposed
in the riser. Drilling muds or fluids are of after they are separated from
drilling fluid
pumped down through the riser to Riser
improve drilling lubrication, maintain
pressure on the well to prevent Blowout
Preventer
blowouts and to return drill cuttings
back to the rig.
2

On the offshore rig, the drilling mud is separated from the drill cuttings and the drill cuttings are
then discharged overboard or taken onshore for disposal. For onshore drilling operations, if water
based drilling muds were used, muds are often disposed in a landfill. If oil based muds are used,
cuttings are either landfilled, landfarmed or, more recently, are being injected back into a
subsurface formation. If land filled, cuttings may also go through a thermal desorption unit to
remove oil prior to final disposal.

While regulations often drive the decisions on

environmental technologies to be employed
for drilling wastes, the potential
environmental impacts must also be
considered. The adjacent figure illustrates the
fate of drill cuttings in the ocean environment.
Perhaps the most important point is that
environmental impacts from drill cuttings
generally occur in only a small area around the
well head. This is where a small pile of drill
cuttings will occur, particularly in shallow
waters.

Drill cuttings disperse as they descend through the water column. Once reaching the sea floor, they
biodegrade, disperse due to seafloor currents and mix with clean sediment by means of
bioturbation, the movement of sediment by sediment-dwelling animals. The ester based drilling
fluid used offshore in Nigeria is the most biodegradable and least toxic non-water based drilling
fluid on the market. These features ensure environmental impacts will be minimal and short in
duration.

Benthos refers to living grasses and organisms on the floor of the water body, whether it be canal,
near-shore or offshore. The presence of flora or grasses in this area creates a habitat and breeding
ground for small organisms up to larger fish. Not only are they a vital part of aquatic ecosystem,
they also act to stabilize the seabed floor and prevent turbidity which can in turn affect aquatic life,
such as clogging of fish gills or covering of benthos communities.

Drilling rig movements and operations can affect these seabed communities. First, rig movement
can clear flora, however in most instances this is reversible and it will re-grow and marine life will
re-establish. Then, discharge of cuttings leads to a build up of piles around the rig and smothering
of the sea grasses and marine life. It depends on the distribution and toxicity of the cuttings
whether the marine life will reestablish.

The adjacent figure of a “bulls-eye” Environmental Impact of Drill Cuttings

w/ Non-Water Based Fluids
diagram further illustrates the potential
impacts of drill cuttings containing non- Benthic Impacts
Sediment Toxicity
water based drilling fluids on the sea floor. High TPH
6 Mo.-3 Yr Recovery
However, note that beyond 200m of the
discharge there is little or no
environmental effects are observed. TPH is 2,000 500 200 50 50 200 500 2,000 Meters

total petroleum hydrocarbon. It is a means

Spotty Benthic Impacts
of analyzing for non-aqueous drilling fluids. Little or No Toxicity
Low TPH
Sediment toxicity is evaluated by exposing No Benthic Impacts 3 Mo.-2 Yr Recovery
No Toxicity
Spotty TPH
5
sediment dwelling organisms to sea floor sediments. The number of organisms that die during the
test indicates the level of toxicity, in that higher toxicity results in more dead organisms. Benthic
impacts are evaluated by measuring the number and diversity of benthic (seafloor) organisms on
the seafloor. Reduced populations of organisms indicate significant ecological impact.

While drill cuttings can cause significant impacts under some conditions, using drilling fluids with
low toxicity and high biodegradability and applying state of the art treatment technologies to the
drilling wastes can certainly reduce environmental impacts.

Drilling in onshore and coastal areas presents different problems than offshore and requires
considerations for minimizing footprint and managing wastes. Roadways, canals, pits, and disposal
areas can increase the area directly affected by the drilling operation and leave a lasting impact.
Chemicals, materials, and wastes need to be carefully transported to and from the site to avoid
contamination of offsite areas. On site, these need to be securely stored and safely handled.
Waste disposal needs to be carefully managed to prevent environmental impacts.

In addition, there will be local requirements and regulations regarding the environmental aspects
of drilling that must be met. In Nigeria for example, drill cuttings are not allowed to be discharged
to swamps and the near shore environment. This means that drill cuttings must either be re-
injected into the subsurface or treated and disposed onshore. Discharge is allowed in areas greater
than 3 km offshore. In these offshore areas, water based drilling fluids and synthetic ester-based
drilling fluids are allowed, and drill cuttings discharged containing ester based fluids must contain
no more than 5% drilling fluid.

While drilling performance traditionally focuses on improving drilling efficiency and reducing
drilling time, the environmental impacts of drilling must also be considered. The environmental
goal should be that once drilling is complete, what is left is smallest “environmental footprint”
possible and little or no environmental impact.

Oil Spill
An oil spill is simply the loss of oil from its primary containment and the subsequent polluting of the
environment by the escaped oil. The primary containment for oil includes pipelines, flowlines,
tanks and separators while the secondary containment include saverpits and bundwall.

Contaminated environment
The release of oil from its containment leads to environmental pollution. The contaminated
environmental media include air, surface water, groundwater and land. The contaminated
resources as a result of the spill will include soil, inland water, farmlands, swamps, mangroves,
fishing grounds, tourist sites, archeological sites and the open seas.

REGULATORY REQUIREMENTS
The release of oil into the environment is regulated by governmental agencies. These governmental
agencies include the Directorate of Petroleum Resources (DPR) and the FME.

The regulatory requirements by the agencies include the followings:

1. Prevention of oil spill through pipeline corrosion prevention and intelligent pigging.
2. Development and documentation of an oil spill response plan and procedures.
 3. Statutory reporting of oil spill to the DPR and the Federal Ministry of Environment
within 48 hours of incidents.
4. Activation of oil spill response planning through trainings and drills.
5. Stockpiling of a minimum quantity of oil spill response equipment and materials.
6. Restoration of polluted sites, clean-up and remediation.

The Tiered Spill Response and the National Oil Spill Response Plan
The oil industry in Nigeria has developed an industry wide oil spill response plan depending on the
size of the spill and the proximity (location).

Tier 1: Referred to as a minor spill, this is a spill that is less than 100bbls and occurring within
the operator’s premises. The operator using in-house spill responders and resources
contains this spill
Tier 2: Referred to as a medium spill, this is a spill that is greater than 100bbls but less than
500bbls and occurring within the operator’s premises but flowing beyond the operator’s
field. This spill is contained by using industry-wide spill response initiative. The other
operator’s pool resources, human and material to contain the spill.
Tier 3: This is a major spill with the releases of more than 1,000bbls of oil into the environment.
The spill response requires the activation of the National Oil Spill Contingency Plan. The
operator alerts the relevant regulatory agency and the National Commander of the
NOSDRA invite international companies like Oil Spill Responders Limited UK who
mobilizes for response immediately.

SOURCES AND CAUSES OF OIL SPILL

Sources of Oil Spill

There are several sources of oil spill pollution. Oil can be spilled during exploration and production
activities. The sources of oil spill are namely:

 Equipment failure
– Pipeline rupture,
– Damage to hull,
– Tank failure,
– Blow out
– Tanker accident
– Fire
– Leakages…
 Human errors
– Failure of operators to follow standard operating procedures (SOP) and
violation,
– Wrong attitude
– Carelessness
– Ignorance
 Intentional discharges- This is often carried out for the purpose of
– Pressure relief
– Safety of equipment
– Safety of people
 Operational upset - Start up and shut down procedures
  Sabotage- This is a deliberate action that is human induced with the intention of
– Theft of equipment
– Theft of product
– Compensation claim

Cost of Oil Spill

The cost of an oil spill can be divided into two main headings: Financial cost to the company and
economic loss to the environment
 Financial Cost
- Cost of oil lost
- Cost of equipment loss or damaged
- Cost of oil deferred
- Cost of clean-up
- Cost of compensation
- Legal cost
- Medical cost
- Cost of remediation and replacement of damaged resources
Economic cost
- Loss of Revenue to Government
- Loss of income - fishermen, farmer, tourism
- Loss of sensitive biodiversity ecosystem
- Loss of life and productivity
- Impact on socio-economics
- Loss of aesthetic and impact on resource value

FATE AND EFFECT OF OIL SPILL

Key Considerations
The considerations for oil spill are based on the properties of oil as a chemical which includes:
a. Toxicity
b. Biodegrabilility/Persistence
c. Bioaccumulation and tainting

Fate of Oil
The fate of oil in the environment is the pathway of pollution. It is a factor of both pollutants, the
environment and other physical factors such as climate and hydrology. When oil is released into
the environment the following process occur
1. Evaporation of light fractions
2. Dissolution
3. Dispersion on seas
4. Spreading on land
5. Emulsification of oil
6. Sedimentation
7. Absorption and adsorption
8. Bio-uptake, biodegradation and bioaccumulation
Environmental Impact
The environmental impact of oil includes:
1. Introduces toxic substance into soil and water environment
2. Smothering of bird and mammals.
3. Long term effect such as bio-accumulation in the food chain may result
4. Water/Groundwater Contamination.
5. Contaminates the plumage of bird.
Socio-economic Impact
1. Loss of revenue/income for fishermen, tourism worker e.t.c.
2. Loss of value due to poor aesthetic community.
3. Contamination of water bodies renders water non-usable to meet needs.

OIL SPILL PREVENTION

The management of oil spill can be categorized into four main headings:
Elimination of contamination
 Use of tight shut off valves
 Where practical weld rather than use flanges connections
Prevention of contamination
o Install ESDV
o Install Leak detection system
o Carry out surveillance exercises
Minimisation of contamination
 Use liquid seals
 Minimise number of pipework connections
 Contain at source
 Carry out regular drill and trainings
Minimization of impact
 Clean Up spill
 Provide surrogate materials for affected community

Environmental Impacts of Spills

Oil spills can occur during many industry activities for many reasons, including equipment failure,
human error, emergencies, or sabotage. Action should always be taken to prevent spills and be
prepared to respond to spills if they occur.

Oil spills can have many serious impacts depending on the amount and type of oil spilled and
actions affecting it in the environment. There are many different types of actions that affect oil
spills which can make it more complicated to respond to them and/or act to dilute the oil and help
reduce toxicity within the environment. Some actions that can with oil spills are:
• Spreading - gravity driven
• Advection - movement from wind & currents
• Evaporation - determined by composition
• Emulsification – droplet phase is water
• Dispersion - wave and wind energy break into small droplets
• Dissolution – some oil components dissolve in water
• Biodegradation (long-term)
• Photo-oxidation
The impacts of oil spills are not just confined to surface waters. They can impact the air through
evaporation and fires, the land by contact and oil-soaked soils, and even groundwater as oil moves
through the soil. This could produce impacts to wildlife and vegetation, even people, far removed
from the spill site. Key considerations for environmental impacts of oil spills include:
• Toxicity – Determined by characteristics of the material as well as the eventual
concentration and means of exposure in the environment.
• Biodegradability/persistence – Materials which do not degrade quickly will tend to be
persistent in the environment.
• Bioaccumulation - Concentrations of contaminants increase up the food chain, for example
starting with microorganisms and phytoplankton, and moving up to crabs and fish, then to
humans
• Smothering - Smothering of bird and mammals impairs their mobility, is an irritant to their
skin and eyes, and exposes them to a higher toxic dose. Oil coatings on vegetation and the
roots of mangroves will impede the flow of oxygen and water and can lead to death.
• Scale of the effect - The volume of the spill is a large determinant of the aerial extent to
which it will spread and significance of the impact.
• Duration - Is the spill leaking small amounts over a long period of time, or massive amount
in one release?

The toxicity, biodegradability, and persistence are determined by the properties of the oil and the
nature of the environment where it impacts. Some oil properties that determine toxicity or degree
of impact include density, viscosity, interfacial tensions, and the type of components in the oil, such
as BTEX or sulfur. Ambient conditions may also affect the eventual impact of a spill on the
environmental such as proximity to shoreline and sensitive habitats, the prevailing wind and
current conditions, and water and ambient air temperatures.

As example, in March 1989 the tanker Exxon Valdez ran aground on Blight Reef in Prince William
Sound, Alaska, spilling approximately 11 million gallons of North Slope crude oil. This was a very
cold, frigid environment. The forces of nature (waves, currents that break up the oil, evaporation)
were at work but very slow. The conditions meant that breakdown of the oil by naturally occurring
bacteria was slow. Oil can still be found in areas today and may be impacting the environment.

This adjacent slide illustrates the relative toxicity of Crude Oil

crude by volume compared with the components of Gasoline/Kerosene

gasoline, BTEX and other components. For example BTEX

crude is a million times less toxic than DDT, or a Low MW PAHs

g/L
thousand times less toxic than ammonia or BTEX ug/L
ppb
mg/L
ppm
Pp
thous

(benzene, toluene, ethyl benzene or xylene). NaCl

Ammonia

The primary defense any facility has against spills is Copper

the action taken by the operator before a spill occurs. DDT

Spill prevention should be a priority. By making it a

part of the everyday job routine, the behavior becomes integrated in to the job. New facilities
should have equipment tested before being placed into operation and prior to commissioning spill
prevention equipment should be in place and process monitoring and testing implemented. Check
valves, piping and tanks for drips or seeps. Notice whether the rainwater drains on the
containment areas are closed, and if necessary, locked. When equipment is taken out of service,
check it for both corrosion (pitting, etc) and for accumulation of corrosion by-products from other
areas. And, finally, make sure that a plan is in place should a spill occur so that response is rapid
and effective.

Tools for Environmental Protection and Impact Mitigation

Oil and gas companies have many sources that provide guidance and information for
environmental protection and mitigation of impacts.

An important tool for assessing and mitigating environmental impacts is the Environmental Impact
Assessment (EIA). The EIA is the key environmental document that the project team will produce
and its submission and approval is usually a regulatory requirement. It is also serves as the baseline
for developing the environmental management plan and frequently contains an evaluation and
assessment of socio-economic issues.

The EIA determines how environmental and socio-economic considerations are managed in capital
projects. The EIA will is more fully discussed in a later section.

Environmental Impact Assessment Process

An Environmental Impact Assessment (EIA) is a process of identifying, predicting, evaluating, and
mitigating the biophysical, social, and other relevant effects of proposed projects and physical
activities prior to major decisions and commitments being made. EIAs should be completed on all
projects and can be conducted on various levels ranging from a desk top study to a detailed field
study. EIAs should be considered a process that begins early in the life of a project and continues
through the life of the project. It’s a “living” document.

The purpose of an EIA is primarily as a planning and management tool that supports strategic
business objectives. Its aim is to identify positive and adverse environmental impacts of the project
and to determine how environmental standards can be met and adverse impacts minimized. The
EIA will help determine what levels of environmental change will be acceptable and will define
what the environmental management objectives will be for the project. Because of this, the EIA is
part of:
• Industry Standards of Performance
• Ethical Obligations
• Regulatory Requirements The EIA Process
An EIA should be used as a policy and Screening Monitoring & managing
• What types of projects
management tool to mitigate environmental and require an EIA?
• Proponent develops plan for
monitoring impacts
Scoping
other impacts and improve performance. To be Reporting
• What must be considered? • Summarize findings and
an effective as a planning and management tool, Determining Baseline
conclusions

EIAs are recommended from beginning to end of • Establish current conditions

a project. Exploration projects often provide the Assessing
• Determine the significance of
first opportunity to understand the risks, any project impacts, including
socio-economic impacts
liabilities and benefits of a project and to Mitigating
Decision-making
• Management and regulators
evaluate the project
Public involvement
• Public stakeholders may
participate in the process

establish relationships with governments, • Plan for mitigating

unavoidable impacts

communities and other stakeholders. 5

The EIA also provides the first understanding of

what the decommissioning plan will be and what monitoring and mitigation will be required during
operations. The adjacent figure shows the major steps in the EIA process.

The EIA is a policy and management tool for both planning & decision-making. It assists to identify,
predict & evaluate the foreseeable environmental consequences of proposed development
projects, plans, and policies. It also specifies the necessary environmental protection measures that
include mitigation measures and monitoring programs. The outcome of an EIA study assists
decision makers and the general public in determining whether a project should be implemented
and in what manner.

As previously stated, the EIA is a living

document, a process that grows with the
project. As such, environmental assessments
will be conducted at several stages during the
life of a project, each building upon the
previous, as shown on the adjacent figure.
The EIA can begin as a desktop study, and
then become a full EIA followed by field
monitoring for a period of time after the
environmental license is issued for the work
being done. The EIA is used to develop the
environmental management plan.

One of the studies usually required in an EIA is an Oil Spill Trajectory Model to assist with the
planning process to avoid or reduce environmental impacts. By doing an oil spill trajectory model,
the project representative can understand what the probability of impacting the coastline and if it
does what type of environment is likely to be impacted, such as a resort or sensitive environmental
area. This helps in deciding on redundancy systems such as double hull tanks for floating and
onshore facilities or other preventative measures that need to be decided early in the project.

Another study usually required is a trajectory model for the dispersion of drill cuttings in the
offshore and coastal environments. This helps determine the impact of the type of drilling fluid
being planned for use and whether there is a sensitive environment in the area that will be
impacted by the cuttings. Another critical consideration is whether there be accumulation of the
cuttings since cuttings mounds can have adverse impacts from physical smothering and from
toxicity of the oil and fluids on the cuttings. In some areas, a project may need to change the type
of drilling fluid planned for use to avoid accumulation or other adverse environmental conditions,
or the project may even be prohibited from discharging any cuttings. In these cases it may be
necessary to bring the cuttings to shore for appropriate treatment and disposal or to re-inject the
cuttings offshore.

Another discharge that should be considered by the EIA is produced water. The quantity and
quality of the produced water must be determined and a decision made on the type of treatment
and whether the produced water can be directly discharged or used for a beneficial purpose
onshore. If the desirable quality can not be achieved for discharge or beneficial use, then the
produced water will need to be re-injected into the producing formation or another non-potable
water formation, or handled by some other means to avoid adverse impact.
The EIA will also evaluate air emissions and air quality issues. For greenhouse gas emissions there
is a growing interest and real possibility of savings from GHG credits or at a minimum reducing the
impact on the environment by understanding the emissions associated with a project and utilizing
energy efficient and low emission emitting equipment such as low NOx burners or highly efficient
flares. As a result of completing a greenhouse emission inventory for a project the decision may be
made to avoid flaring and instead capturing gas to be used elsewhere or sold. In addition, worker
health issues are addressed through modeling by understanding what concentrations of various
pollutants are emitted, where the primary dispersion will occur, and whether it is near a populated
or sensitive area. The information from the assessment will be used to determine equipment
specifications to control NOX, SOX, H2S, and other emissions.

Major projects represent 20-30 year investments that may impact not only the environment but
also the social and economic aspects of the region. Undertaking a development is also a
commitment to evaluate and take into consideration socioeconomic needs of the people and
communities living near project facilities and the potential impacts that may be posed by the
project. To address the socioeconomic aspects of that commitment, the EIA should include a socio
economic baseline setting of any villages and community activities within or near project facilities
and operations. This study will consider the impacts of the projects on the potentially affected
communities as a whole and:
• Describe the “initial state” of the communities near the proposed support facilities that
might be affected by the construction or operations of these facilities (data acquired here
can be used in follow-up monitoring studies);
• Identify key stakeholders with interest in the project’s activities;
• Identify the presence of “indigenous peoples” or other groups that might warrant additional
consideration;
• Perform an impact assessment and develop recommendations for the project (and the EIA)
relating to project development and operations so that the project can minimize or
eliminate adverse impacts (and/or enhance benefits on local populations; and
• Provide data that will aid in designing public consultation programs.

A project with many different phases may have more than one EIA completed prior to each phase,
such as for seismic exploration, exploratory drilling, field development and project
decommissioning activities. Whenever possible each phase should build on previous work.
Whether the project is basic or detailed will depend upon the sensitivity of the area and the
expected significance of project impacts, so the project may start with an initial assessment of
potential environmental issues or identification of environmental liabilities.

Environmental Baseline Studies are completed to help assess the current status of the property and
document it for future comparisons. This provides the state of the environment before the project
begins. As the project progresses a measurement can be made and compared to the baseline to
determine any impact the operation may be having on the specific environment and how well
these are being mitigated. The same approach is applied for Sea Bed Surveys which are conducted
to understand potential risks and how to mitigate them for sea bed structures such as pipelines and
other. These will identify and categorize the status of marine life on the sea bed to determine
upfront potential impact and how it can be mitigated.
Environmental Evaluation Studies and Environmental Audits will take place through the life of the
project to monitor the environment and as a check to ensure findings and mitigation measures
from the earlier EIAs. Monitoring is frequently required by regulations, but the EIA will also
determine the appropriate monitoring that must be conducted under the environmental
management plan to assure that environmental controls are working and that no impacts are
occurring. This is important because the environmental licenses are issued based on commitments
made in the EIA to mitigate various impacts.

The EIA Process can run anywhere from 6 months to 2 years for a major project, so a strong
planning process is needed. It requires identifying a contractor, going out to bid, and awarding a
contract. Additional items include understanding the regulations and what is required for the
specific project such as discharge modeling, oil spill response modeling, or other studies that need
to be included in the EIA. There are various approval stages that may include public participation in
the form of a hearing.

In Nigeria, EIAs are regulated by two government bodies, the Federal Ministry of Environment
(FMEnv) and the Department of Petroleum Resources (DPR). The DPR requires that a preliminary
assessment of impacts (PAIR) be completed prior to submittal of the actual EIA for project
approval. This has the benefit of identifying any impacts to the environment that will require
mitigation if not already planned by the project. This is a good planning tool that is done up front
instead of having an EIA submitted later in the project with a major issue showing up that needs to
be addressed. However, the requirements for the two bodies can sometimes be in conflict of each
other so it requires a thorough understanding, planning and working closely with both groups. The
major steps in the process are:
1. Project Proposal/Initiation -This is the first step in the EIA Process. The FMEnv will be
notified in writing by the submission of a project proposal and a dully completed EIA
Registration/Notification Form, which is made available upon payment of N10, 000.
2. Screening - On receipt of the project proposal, the FMEnv will carry out Initial
Environmental Examination (IEE) and assign the project to Category I, II or III. Criteria for
categorization include magnitude, extent or scope, duration and frequency, risks,
significance, and mitigation measures available for associated/potential environmental
impacts. Various categories require different levels of effort and content in the report.
3. Scoping - On receipt of the screening report from FMEnv, the company/responsible party
will carry out a scoping exercise to ensure that all significant impacts and reasonable
alternatives are addressed in the intended EIA.
4. Draft EIA Report - Project proponent will submit at least 20 copies of a Draft EIA Report to
FMEnv for review. Evidence of public participation (proceedings of communication with
adjoining communities and stakeholders) are to be included.
5. Review Process: The Draft EIA Report will be reviewed by FMEnv. The form of review can
be either of the following:
• In-house (i.e. FMEnv only)
• Panel Review (sitting may be public)
• Public Review, which involves public, displays and reviews of the document for a
period of 21 working days
6. Final EIA Report: A final EIA Report will be submitted to the FMEnv within 6 months of
receipt of the Technical comments from the review process
 7. Technical Committee/Decision Making and Issuance of EIS: The Technical Committee
considers and approves the issuance of an Environmental Impact Statement (EIS) if the
comments from the review process are satisfactory and the Final EIA Report submitted
acceptable.
8. Certification: The Minister of Environment will issue a Certificate upon receipt of an EIS.
9. Project Implementation: Implementation of the project will commence after Certification,
in accordance within the stipulated mitigation measures and specification presented in the
Final EIA Report.

The specific steps for DPR Process include the following:

1. An operator or licensee initiates the project
2. An initial assessment/environmental screening and scoping of significant issues are carried
out by the initiator and the DPR.
3. A preliminary assessment of impacts (PAIR), focused on the selected project option is
carried out.
4. The Department of Petroleum Resources and the project initiator, screen the project for
potential significant and adverse environmental effects. The screening and the decision on
significant impact of the project shall commence and be made within thirty (30) days of
receipt of project preliminary assessment. If no significant impacts, the project may proceed
with appropriate mitigating measures and monitoring programme. If the PAIR identifies
potentially significant impacts then other requirements are triggered.

Mitigation and Management of Construction Impacts

Experience has shown that it is both easier and cheaper to avoid environmental impacts than to try
to reverse them. Basic prevention and avoidance principles work well for the construction phase of
projects and include:
• Upfront planning
• Limiting access to undisturbed or highly sensitive areas
• Minimizing physical and environmental footprint
• Maintaining natural conditions
• Managing construction wastes

The first principle, upfront planning, involves incorporating long-term environmental protection,
remediation and restoration plans during the front end load (FEL). This should include a structured
process and cross functional team with appropriate experts in the environmental issues of concern.
In many cases it may be appropriate to include creative solutions such the temporary road through
the jungle made from interlocking mats instead of a permanent asphalt road. All issues should be
screened issues upfront with a plan for resolution.

An inventory of habitat resources and an initial site assessment are likely upfront actions that will
provide a good baseline for project analyses and decisions on operations and mitigation. For this
purpose, remote sensing technologies can be very valuable for providing regional views and can
reveal spatial patterns and relationships not visible otherwise.

The second prevention principle is to limit access to undisturbed areas. Access is required in order
to move either oil exploration or oil and gas production equipment into an undeveloped site, and
to provide operational access. Such access should be located to minimize potential damage to
sensitive areas, and limited in size to minimize the footprint of the operations. The baseline and
remote sensing results will be valuable in making a determination of where these should be located
to minimize impacts.

In addition, local communities may take advantage of the new access to increase harvests of local
plants and animals. Such issues should be considered prior to access construction. Consider the
network of roads that can fragment a tropical rainforest and canals that can do the same thing in a
wetland environment and discuss. In these cases, there may be secondary impacts that will need to
be taken into consideration.

When possible, it is preferable to use existing roads than to build new ones. If new roads are likely
to contribute to poaching or encroachment, then physical roadblocks or removal of bridges should
be considered if feasible. New tracks may be stopped short of junctions with existing roads in
order to camouflage their presence. In wildlife or forest conservation areas, further support to
staff may be necessary, such as the establishment of new ranger posts on new access points into
conservation areas.

Other types of activities can also open up remote areas. For example, seismic survey lines create
access routes that may be exploited by others to harvest local forest resources. Access routes
should be as narrow as is practical, and should be disguised after use.

Helicopters can be used to transport equipment, material and people into remote areas and so
avoid the creation of permanent accesses like roads or canals. It also avoids altering existing
watershed drainage patterns when canals are dredged. In some situations, heli-rigs can be
transported by helicopters and assembled on site.

Aerial roadways or roads on piles can also be used in some circumstances to avoid cutting through
vegetation and reduce other impacts. Dredged spoils, placed by the banks of the dredged
channels, create high solid grounds that are attractive to local settlers and encourage settlements.
These new settlements exert pressures on the local forests resources, and can very quickly degrade
a large area of previously undisturbed forests. Consideration should be given to alternate disposal
of dredge spoils, for example, at a centralized low habitat value or previously degraded land area.
Placing dredge spoils far away from drill sites and facilities also keeps settlements far away, thereby
not exposing them to hazards from the operations.

To prevent potential impacts, new access areas should be considered for removal if they are no
longer needed for oil and gas operations. Encroachment is an insidious process, which will occur
unless actively designed against and controlled. It is also important that the location and
construction of any new roads is integrated with any future development plans.

The third prevention principle is to minimize the footprint. A final site should be selected with
careful consideration of existing and adjacent land use, drainage and subsequent restoration in
mind. Whether a terrestrial, wetland or aquatic site, there may be some flexibility in location
choice to allow the selection of a sensible site that maximizes the ultimate restoration of the site
and minimizes both the final footprint and the ultimate costs. The site should be located to
minimize impact to landscape, conservation areas, important fish and wildlife habitats, human
settlements, cultivated areas and tourist destinations.
For any site, use only the minimum amount of land necessary. This usually calls for some creativity.
Where feasible, multiple wells drilled from one site by directional drilling can reduce the amount of
land and reduce clearance and dredging or road access. The use of satellite production facilities
such as remote manifold platforms (RMP) to minimize the number of individual flow lines also
reduces the amount of land required. Clustered well sites simplify the use of this technique.
Pipelines should be laid along existing pipeline routes, and not necessarily take the shortest route,
and clearance for corridors and right-of-ways should be minimal. If excessive clearance happens
during construction, consider re-vegetating excess land to prevent erosion and impacts to water
quality.

Dredged spoils should be placed within diked disposal areas instead of side casting or pumping into
wetlands otherwise the spoils can erode back into the canals and silt them up, or leach acidic
runoff into the aquatic habitat. Topsoil should be salvage and store for reuse as backfill materials
as it contains seeds and nutrients that can maintain soil structure. Use low ground pressure
equipment to avoid compacting soil which can destroy the soil and thus lead to erosion and
flooding. Always strive to return leave or return the site to original topography as much as
possible. To do so, establish a baseline of the topography before construction work and follow this
for decommissioning.

The fourth prevention principle is maintaining natural conditions. This is particularly important
with regard to hydrology, especially in wetlands and aquatic habitats. Modifying hydrological
systems can disrupt drainage systems in highly dynamic environments and may yield surprising and
often painful results. All designs should be focused on aligning with the natural drainage systems.

To maintain natural conditions, a key activity to plan carefully is dredging. Avoid dredging from
saltwater systems into freshwater systems so as not to impact the salinity regimes. Follow existing
water courses instead. Changes in salinity and water flows from dredging can cause:
• Loss of vegetation by changes in salinity, either fresher or saltier.
• Increased erosion or scouring of the land surface where vegetation once stood, leading to
subsiding land and flooding. Channels may get sited up or washed away.
• Changes in long term ecosystem equilibriums whereby different aquatic environment and
habitats may result. In a coastal area, the shoreline may become established further inland
(land turns into sea) and vegetation and wildlife in an area may be replaced by other species
that may not be useful or as valuable as the previous inhabitants.

Pipelines can create the same problems as dredging so avoid creating pipeline routes from
saltwater systems into freshwater systems. Follow existing water courses instead or identify
transition points and block water exchange. In addition, plan placement of pipeline spoils carefully
to avoid cutting off surface water flow patterns. Cut channel breaks to help preserve natural
drainage the flow of water.

A serious potential consequence of altering natural conditions is acid sulfate soils. Many mangrove
forests occur on marine clay soils containing sulfides. If these soils are exposed to the air as a result
of dredging channels, digging holes or removal of surface layers while installing surface facilities,
sulfuric acid is released and the pH of the surrounding waters and soils can fall to acidic conditions
very rapidly. This can cause very severe impacts to freshwater and marine plants and animals and
can also cause severe damage to oil facilities increasing maintenance costs. In extreme cases, this
has led to abandonment of lands. The soil chemistry should be checked before dredging or other
similar activities, and if the soil types can generate acid sulfates, then construction activities should
be avoided or the soil handled with special confinements.

Vegetation is another key consideration for maintaining natural conditions. Vegetation provides
protection against erosion of coastlines, rivers, streams and creeks. Facilities should be sited some
distance away from coastlines and riverbanks and buffer strips of native vegetation should be
maintained between the facilities site and coastlines or riverbanks. The vegetation strip serves as
excellent alternative for engineered erosion control systems like sand bags and can save money
both during construction and later during operations. Clearing only what is necessary can result in
reduced construction costs and minimize environmental impacts.

The fifth prevention principle is managing wastes properly. Waste management is discussed in
detail in a later section, but here are some main practices to consider:
• A goal should be to minimize waste generation.
• Use a central facility to handle wastes if feasible.
• Avoid discharging raw sewage into inland or creeks as this maybe harmful to freshwater and
marine plants and animals.
• Construction debris should be planned for reuse as much as possible.
• Manage spills and drips of oil and chemicals by providing containment and leak collection
systems.

Mitigation and Management of Drilling Impacts

To reduce environmental impacts from drilling discharges, all projects should consider ways to
reduce or even eliminate drilling discharges. The EIA will be important in understanding the
potential impacts and what mitigation will be required. In many cases, zero discharge or additional
treatment will need to be considered. For some circumstances, less toxic and more biodegradable
drilling fluids will be appropriate.

The feasibility of re-injecting drill cuttings is frequently a consideration, particularly for swamp and
near shore drilling. Unlike cuttings dryers and centrifuges, this is truly a zero discharge technology.
It can only be technically feasible and cost effective when a suitable reservoir exists. To obtain this,
cuttings may need to be transported to a central reinjection facility if they can not be injected at
the drilling site. However, there are significant technical concerns with injection. Wells can clog up
and there is a risk of cuttings broaching the surface. Also, if the re-injection well is onshore,
particular care must be taken not to contaminate aquifers used for drinking water. The following
are the key technical issues regarding reinjection:
• Subsurface Geology Must Be Suitable For Injection
• Fracture Containment Is Critical
• Multiple Sealing Barriers Up To Groundwater
• Well Costs, Injection Horsepower Increase With Depth
• Fracture Geometry: Where Does The Waste Go?
Waste Management Conceptual Site Model:
Waste Release Site
The potential for environmental damage does not
necessarily make a material a waste, since many useful
products have the potential to cause environmental
damage. Rather a waste is something that we have no Drinking
further use for. However, many wastes are dangerous to Impacted
water
well
soil Leaching Volatilization
human health and the environment, and just because
there is no further use for them does not remove the Dissolution
Dissolved Phase
Migration
responsibility for appropriate management.
Groundwater

Management of wastes is very important for the following

reasons:
• Wastes can be harmful to the environment and human health
 Pollution of rivers, ocean and wetlands (rainfall and runoff)
 Harm to plants and wildlife
 Contamination of soil
 Contamination of ground water supplies
 Public nuisance and public health
• Wastes you don’t create you don’t have to manage
• Improper management (handling, containment, treatment and disposal) increases long
term liability and is more costly to manage than proper immediate management
• Managing waste costs money
• Wastes do NOT just “GO AWAY”

It is important to note that wastes should be managed as they are generated. Deferred
management increases liability and increases the logistical effort in cleaning up. Once control of the
site is lost, it is much more difficult to obtain access and remediate.

Look at your system comprehensively and determine where wastes are generated and discharged,
including air, soil, water, groundwater, and the interactions between these sources. The adjacent
figure lists various sources of wastes from oil and gas operations.

The next figure shows how wastes can impact people and the environmental even when it appears
remote. Waste can leach into the ground and down to the groundwater, where it may migrate.
Exposure to humans can occur through direct contact with soil and impacted groundwater (via a
well), discharge into surface water, and volatilization through the soil profile.

Waste disposal sites should not be considered “safe” waste disposal routes. Such sites must be
constructed and managed properly to avoid potential impacts from the following:
 Human and wildlife contact
 Air and particulate emissions
 Water and groundwater contamination
 Food chain interactions
 Loss of habitats and erosion
 Loss of land use
 Long term maintenance and costs
Hazardous wastes are materials that have a high potential for environmental damage, so special
management throughout their entire lifecycle is required. Many wastes have more than one
hazardous property. For example, oily wastes may be flammable and toxic, and batteries may be
corrosive and toxic, etc. Such properties are basically “risk” characteristics and are important as
they determine how and when a waste should be managed.

Minimizing wastes is important to reduce costs and the

potential for environmental and health impacts. Other
Sources of Waste
ways to reduce wastes are as follows:
 Don’t create waste in the first place Exploration
• drilling fluids
Community
• garbage
 Source Reduction- Focus on front end loading and • misc-metal, drill
bits.. • medical
Production • sanitary
early incorporation off environmental considerations • produced water • offices-paper,
• tank pit sludges computers
and environmental expertise into your projects • laboratory-oils, Others
 Treat, re-use, or re-cycle for another use solvents
Maintenance
• spills
• equipment-
 Manage handling and storage appropriately • lubricants
• cleaners
vehicles,
transformers

 Segregate and package appropriately for shipping and

disposal
 Manifest accurately
 Use secure and environmentally sound storage sites

There are 6 phases in the lifecycle of waste

WASTE GENERATION
management. The first phase is “generation”. It is at Source Reduction FINISH
this stage we have the greatest influence on waste
volume, characteristics and hazardous properties and, Complex Recycling
Major Process Change
Raw Material Change

consequently, the greatest influence on environmental Source Treatment

Product Redesign

impact and costs. Like project management principles, Housekeeping

Process Control
Equipt Maintenance
PROCESS
PROCESS
FOCUS
FOCUS
Auditing
it is important we front end load this process and Training
Simple Recycling ea
se
s
cr
thoroughly assess the project scope, plan well, and START
EQUIPMENT
EQUIPMENT
FOCUS
FOCUS icu
lt yI
n

iff
engage the right people early. Waste management eo
f D
OPERATION g re
OPERATION
decisions and consideration of waste impacts should FOCUS
FOCUS
De

be made early into projects to ensure the most Focus on:

Beginning-of-pipe: prevent the problem occurring in the first place.
appropriate environmental decisions. Source Systems approach: use a range of different methods.

reduction can occur within the operations, equipment, 9

and processes that are selected, as shown on the

adjacent figure.

The two next steps on the waste lifecycle are handling and storage. Just because storage may be
temporary, there is still potential for environmental and human harm. Additionally, wastes may
have to be segregated according to the risks they pose, the treatment and handling that they
require, and to prevent adverse interactions. Segregation is also important because it improves the
chances of recycling. Key points to consider are as follows:
 Know what you are dealing with and its properties; refer to MSDS
 Use correct PPE
 Refer to waste management plan or coordinator if unsure
 Use appropriate containers with sufficient volume, integrity and of suitable material
 Keep wastes (especially liquid wastes) on impervious surfaces
  Store liquid wastes in tight/ leak proof containers or tanks
 Segregate different types of wastes (e.g. Keep waste oil separate from solvents, detergents,
petrol/kerosene, radiator coolant water)
 Ensure waste is secure
• Protect it from blowing away
• Prevent scavengers from being impacted by it; fence it in
• Cover it if rainfall will lead to soil and groundwater contamination

The third phase of the waste lifecycle is transport. Failure to properly manage transport may result
in environmental impacts and higher costs. Here are some important points to consider for waste
transport:
 Complete manifests
 Keep wastes segregated during transport
 Know where the waste is going
 Ensure the waste handler and receiver is licensed and approved
 Use vehicles suitable for the wastes and that ensure waste is secure during transit
• Protect it from blowing away or falling off
• Keep it from leaking or splashing out

The fourth phase on the lifecycle is Recycling & Reuse. Reusing is the simplest kind of recycling.
We may often "already" be doing or using recycling techniques. For community relations and
regulatory reporting, it may be useful to "take credit" for the efforts already in place, such as
returning empty drums or used materials such as drilling fluids to the supplier. Examples of reuse
are separating vehicle batteries into acid and lead, using scrap metal, re-distilling solvents, and
using lightly contaminated soil for road construction. Questions to ask before reusing materials
are:
 What is it contaminated with?
 Is the material so contaminated that it can't be reused?
 Will re-use result in HS&E incidents?

The fifth phase of the waste lifecycle is treatment. Treatment acts to decrease waste and reduce
its impacts by decreasing its volume, toxicity, or mobility. Typical treatments for oil field wastes are
physical separation, biological, fixation, or thermal. Physical separations use gravity, centrifuges,
and filter presses to reduce volume and segregate particles from liquids. Biological treatments are
used to reduce and convert wastes in sanitary treatment systems and landfarms. Fixation uses
adsorption, absorption, and chemical interactions to solidify or capture wastes. Thermal
treatments are incinerators that burn wastes or heaters that dry wastes or remove and capture
liquid components such as solvents.

The last phase of the waste lifecycle is disposal. Disposal means providing a secure destination for
waste or residues to prevent environmental impacts. It is also important that the means of
disposal ensures that groundwater and surface water will not be contaminated. Disposal should
also ensure that the waste remain isolated from humans or other contact with wildlife. The
following are examples of disposal for oil and gas operations:
 Injection wells - Used for NORM, contaminated sludges, waste water, tank bottoms, and
drilling muds. Disposal wells for waste injection should be geologically and mechanically
isolated from usable sources of water.
  Storage - May be considered a form of temporary disposal.
 Landfills - These are the primary waste disposal method.
 In-place treatment methods - These are often used for surface impoundments and include
land spreading, landfarming, slurry reactors, and pit and pond closures.

In summary, it is important that waste be managed throughout its lifecycle. Waste management is
not just finding a place to dispose of waste when it has been created. Remember the waste
lifecycle and the order of priority for management:
 The first point is to minimize generation - Reduce.
 The 2nd is to Reuse and Recycle.
 Treat to reduce volume, toxicity, and other undesirable characteristics.
 Disposals is the last alternative, but only after the previous alternatives have been
considered.

Oil Spill Prevention and Response

The best way to protect our environment from oil spills is to prevent them from occurring. Our
most important prevention system is people - people who know how to handle an oil spill
emergency.

Typical Oil release sources

• Exploration-Drilling mud and cuttings discharge & Refueling

• Production-Produced water & Effluent discharge
•
Common reasons for oil spills

• Equipment failure-pipeline rupture, corrosion etc

• Process upset or flare carry over
• Human errors-risks are high in shutdowns, commissioning
• Intentional discharge-like produced water, effluent
• Sabotage

Crude oil is made up of complex hydrocarbon compounds that range from light gasses to heavier
tars and waxes. Oil is composed of thousands of compounds in varying quantities. No two crude
oils are exactly alike because of the many different compositions.

The different physical and chemical properties of crude and refined oils are very important - they
influence the physical and biological effects of an oil spill, the behaviour of a slick and the
effectiveness of clean-up operations. Some oils are far more harmful to the environment and more
toxic than others.

Oil floats on salt water (the ocean) and usually floats on fresh water (rivers and lakes). Very heavy
oil can sometimes sink in fresh water, but this happens very rarely. Oil usually spreads out rapidly
across the water surface to form a thin layer that we call an oil slick. As the spreading process
continues, the layer becomes thinner and thinner, finally becoming a very thin layer called a sheen,
which often looks like a rainbow. (You may have seen sheens on roads or parking lots after a rain.)
The behaviour of oil spilled into the environment depends of the type of the crude oil, as well as
the environment which it is spilled into, e.i. water- and air temperature, wind and wave conditions.
But in very general terms, the following will happen within hours:

Spreading: The oil spreads rapidly over a large area and breaks up in windrows, which are long and
narrow slicks with the same orientation as the wind.

Evaporation: The spreading causes the lighter fractions of the oil to disappear rapidly, leaving back
in the water only the heavier parts.

Emulsification: Wave action mixes water into the oil, forming a heavy and sticky
water-in-oil emulsion, sometimes called chocolate mousse.

During an oil spill, the demand for prompt answers to questions by response agencies, the Incident
Command, and the public is critical to the success of the response.
Information about the oil spilled is something that response agencies and the public want
immediately. For example, people want information about the chemical and physical
characteristics of the spilled oil, and its fate and effect in the environment.

What happens to spilled oil?

• Spreading
• Advection
Evaporation • Evaporation
• Emulsification
• Dispersion
• Dissolution
Spreading
• Other contributions:
Dispersion
Advection • biodegradation
(long-term)
Dissolved
• photo-oxidation

Depending on the circumstances, oil spills can be very harmful to marine birds and mammals, and
also can harm fish and shellfish. You may have seen dramatic pictures of oiled birds and sea otters
that have been affected by oil spills. Oil destroys the insulating ability of fur-bearing mammals, such
as sea otters, and the water-repelling abilities of a bird's feathers, thus exposing these creatures to
the harsh elements. Many birds and animals also ingest (swallow) oil when they try to clean
themselves, which can poison them. Depending on just where and when a spill happens, from just
a few up to hundreds or thousands of birds and mammals can be killed or injured.

A contingency plan is a plan for action prepared in anticipation of an oil spill. Contingency plans are
essential because they establish practical plans of action for all types of oil spills so that, when spills
do occur, a quick response can minimize the damage. The first step in developing a plan is to learn
as much about the area as possible. Regardless of the geography or the size of an area, contingency
plans normally include:

 identification of authority and a chain of command;

  a list of persons and organizations that must be immediately informed of a spill;
 an inventory of available trained spill personnel and spill response equipment;
 a list of jobs that must be done (in order of priority);
 a communication network to coordinate response;
 probable oil movement patterns under different weather conditions; and
 sensitivity maps and other technical data.

Planners need to know about:

 important or sensitive physical and biological resources within or near the area, such as
marshes, unusual flora (plant life) and wildlife resources such as fish, shellfish, marine
mammals and birds;
 important habitat areas required by particular species for spawning, feeding or migration;
 tides, currents and local climatic conditions, such as wind and severe weather patterns;
 shoreline characteristics; and
 proximity to roads, airports, trained response personnel, oil spill clean-up equipment, etc

Once a spill is discovered, the senior employee at the site is informed, and he or she reports the
spill to the government authority (or authorities) named in the contingency plan. Then the
government authority sends a representative to monitor the clean-up and ensures it is done
adequately.

The potential impacts of the spill are evaluated and workers begin trying to control it as quickly as
possible. Once the leakage has been stopped, the team concentrates on containing the oil. If
necessary, the team leader will set priorities for "booming". As much of the oil is recovered as
possible. The next step is to clean up the affected area and dispose of oil and debris.

How Do We Control The Oil's Movement?

By containing or diverting it. This prevents spreading, so that a smaller area is affected and clean-
up is easier. It also keeps oil from highly sensitive areas that are quickly damaged.

Floating Booms Floating booms are mechanical barriers that extend above and below the surface
of the water to stop or divert the flow of oil. They are used in three ways: to surround oil slicks to
reduce spreading and concentrate the oil for clean-up; to protect areas like harbour entrances or
biologically sensitive sites; and to divert oil to an area where it can be recovered.

The effectiveness of a boom depends on wave size, currents and wind conditions.

Sorbent Booms and Barriers Sorbent booms and barriers absorb a moving oil slick using a porous
material. They are used only when an oil slick is thin, because once their surface is saturated with
oil they don't work well. They must be removed carefully so that oil is not squeezed back into the
water.

How Do We Recover Oil From Water?

Once the oil is contained, it must be recovered from the water's surface. Equipment and people are
quickly put to work. Here's how.

Skimmers Skimmers mechanically remove oil from the water surface without causing major
changes in its physical or chemical properties. The effectiveness of any skimmer depends on the
type of oil spilled, the thickness of the slick, the presence of debris, the location of the spill,
ambient weather conditions and calmness of the water.

Sweep System A sweep system is a combination skimmer and boom that is attached to a ship or
small boat. As the vessel moves forward, the system contains and collects the spilled oil. It is then
pumped into storage tanks.

Sorbents Sorbents are materials that recover oil either through absorption or adsorption. They are
used for final clean-up of trace amounts of oil or to remove oil from areas that skimmers can't get
at. There are two basic types: natural organic materials like peat moss and sawdust; and synthetic
organic sorbents like polypropylene, polyester foam, polystyrene and polyurethane. Sorbents are
normally applied by hand, and recovered with nets, rakes, forks and pike poles.

Manual Recovery Manual recovery of oil with buckets and shovels is common, especially in areas
of high oil concentration near shore. Viscous oils are more easily removed by manual methods than
more fluid oils.

Shoreline Clean-up and Restoration

When oil is spilled on water, some of it often reaches the shoreline. Shoreline clean-up can be very
difficult and time-consuming. It is often impossible to protect all shoreline areas from oil
contamination so priority is assigned to the most sensitive areas.

Large waves crashing onto rocks and cliffs can remove and disperse oil naturally. These areas are
generally left alone. Also, particularly sensitive areas like marshes are often better left alone once
contaminated, since clean-up operations can cause more damage than if the oil were left to
degrade naturally. Walking on marshes drives the oil deeper; when they have to enter a marsh,
clean-up crews often put boards down to spread their weight, or use flat-bottom boats.
Shoreline clean-up often involves many people using simple hand tools such as rakes, shovels,
wheelbarrows and garbage bags, high- and low-pressure hoses and sorbent materials to soak up
the oil. Although these methods are very simple, they are often the most effective. Clean-up must
be done carefully. Some experts believe that much of the biological damage observed on Alaskan
beaches after the Exxon Valdez spill was caused by clean-up activities.

The method of clean-up that is most appropriate will depend on the type of shoreline and its
biological resources.

Chemical and Hydraulic Dispersion Chemical clean-up agents may be used if permission is granted
by the appropriate authority. Such agents are not permitted in fresh water or near biologically
sensitive areas.

High-pressure water hoses are used to wash oil from coarse sediments, rock surfaces and artificial
structures. Low-pressure water flushing has been used to remove oil from fine sediments, shores
with vegetation and marshes without causing excessive damage to plants and animals.

Steam Cleaning Steam can be used to clean artificial structures or rock faces.

Removal On sand beaches, graders and scrapers may be used to remove large amounts of oil.
Mechanical removal from pebble or cobble beaches is more difficult. On most types of beach, some
material is removed manually. Care must be taken to ensure that beach erosion does not take
place where sediment has been removed.

What Happens Once The Oil Has Been Recovered?

Two things - the water is separated from the oil, and the oil is disposed of along with any remaining
sorbent materials and other debris.

Separation All oil recovery methods produce some mixture of oil and water. Separation devices like
settling tanks are often attached to skimmers. Many synthetic sorbents can be pressed or squeezed
to remove the absorbed oil. Sometimes the oil and water are collected in recovery vessels that
have taps at the bottom; once the water has settled, it is removed from the bottom.

Disposal Regulations respecting the disposal of oil and debris are established by local, provincial
and federal governments. Disposal is one of the most difficult problems associated with clean-ups.
Relatively fresh oil may be re-refined. Sometimes recovered oil is burned.

What Happens if the Oil Can't be Recovered?

Sometimes, particularly in stormy weather, oil cannot be recovered. This can be a problem, but
under some circumstances it is actually a solution. High waves, as in the 1993 Braer spill, can break
up the oil, mixing it into the water and dispersing it into the water column. Natural processes such
as oxidation and bio-degradation eventually reduce the oil to its basic components.

Chemical Dispersants Chemical dispersants are detergent-like materials that are sprayed onto the
spilled oil. In the United States, their use is strictly regulated by the federal and State government.
They must pass toxicity and effectiveness tests before they can be used. Their use is approved on a
case-by-case basis. However, dispersion of oil into the water column can pose significant risks for
other marine life.

In-situ Burning In-situ burning can be used to burn the oil while it is on the water's surface, but the
oil must first be contained to make it thick enough. Studies have shown that the smoke plume
produced is an acceptable trade-off under some circumstances.

When Is It Best Not To Respond?

In three situations:
 When oil is spilled in a sensitive environment, it is sometimes best to leave the clean-up to
nature, as the activity itself may cause more damage.
 Sometimes natural removal processes are faster or more effective than human efforts. For
example, some storms can make shoreline conditions unsafe, but may also remove the oil
quite effectively.
 Areas such as the Shetland Islands where the Braer spill occurred are also best left, because
the action of high-energy waves will break up the oil.

Chemicals and Hazardous Materials

Chemical hazards are characterized by the nature of the causative chemicals, and they can be
grouped as shown below:

1. Toxic Chemicals
These are poisonous or toxin producing substances. They are capable of causing
physiological disorders in humans when taken in low does and sometimes lead to
death when the maximum permissible body dosage is reached or exceed.

2. Flammable chemicals
These are chemical substances that easily catch fire in the presence of naked light or
when their ignition temperature are reached. Some chemicals (e.g ether) are more
flammable than others (e.g benzene) as this depends on the temperature at which
they give rise to ignitable vapour, (flash point).

3. Corrosive Chemicals
A corrosive chemical is a highly reactive substance. It destroys the skin when in
contact with it, causing severe burns. It destroys clothing and other materials it
comes in contact with. It enhances the process of corrosion of metals.
Examples of dangerous chemicals, which should never be mouth pipetted, are
(i) All organic solutions and suspect ions of micro organism
(ii) Conc. acids, strong bases and corrosive chemicals
(iii) Solutions of radio active substances
(iv) All volatile liquids including petroleum products, pyridine Toulene, Benzene
etc.
4. Oxidizing substances
When these substances come in contact with other substances, they give rise to a
highly exothermic reaction, which may be violent.

Examples are: - Fuming acid, potassium chlorate, liquid oxygen etc.

5. Explosive/unstable substances
These are substances that are dangerously unstable. They react easily and
explosively with other substances e.g. air or water under unfavorably conditions.
They should be used in small qualities, and handled with utmost care. Examples are
acetylene, acetyl ides, chlorides of aluminum; silicon and titanium, Nitrogen halide,
nitro-compounds, picric acid and pirates, dinitrobenzene and azides esp. silver aside;
hydrogen peroxide and benzoyl peroxide.

6. Irritant substances
These are substances that cause an inflammation of the skin or the lung or the
alimentary canal. Examples include phenols and potassium dichromate, phosphorus
and arsenic compounds, and some fumes.

7. Radioactive substances
Radioactive substances are materials, which emit dangerous particles from their
unstable nuclei. A body that is hit by these particles is said to be irradiated.
Radioactive emissions are responsible for a lot of damage to human tissues such as
the blood cells and reproductive organs; and are capable of causing blood and other
tissue cancer.

8. Carcinogenic Chemicals
These are dangerous substances capable of causing somatic cancer in animal tissues
Examples are aflatoxin, nitrosamine aromatic amines etc

ENVIRONMENTAL HAZARD OF CHEMICALS

The environmental hazards indicate the degree of potential hazard due to

1. Toxicity,
2. Biodegradability or
3. Bioaccumulation/tainting.

(a) Toxicity
Toxicity is expressed using standard phrases;
i. Extremely toxic.
ii. Highly toxic
iii. Moderately toxic
iv. Slighty toxic
v. Practically non-toxic
vi. Insignificantly toxic

(b) Biodegradability:
The biodegradability rating reflects the results of standardised tests in which the
degradation of the compound is measured over a period of 28 days and can be
classified into 2 categories;
(i) Not readily biodegradable
(ii) Readily biodegradable
For readily biodegradable compounds, which biodegrade aerobically within a few
days, an additional warning ‘May cause oxygen depletion’ is added.
(c) Bioaccumulation/tainting:
Bioaccumulation of chemicals involves the uptake by organism at a rate exceeding
metabolic breakdown or excretion. It results in concentrations in the organism
exceeding those in the environment and possibly toxic to the organism or its
predators.

Bioaccumulation of chemicals which have an unpleasant flavour, even if only at low

concentrations, may lead to tainting and spoiling of the taste of organism consumed
by humans.

The standard phrases used for rating are;

i. High bioaccumulation potential
ii. Moderate bioaccumulation potential.
iii. May cause tainting.

ENVIRONMENTAL PRECAUTIONS.
These are measures taken to protect the environmental and are classed as follows:
 Prevent and minimise contamination of soil and ground water.
 Avoid gross contamination of soil and ground water.
 Minimise contamination of surface water.

DISPOSAL OPTIONS
Disposal options should take into consideration, the following factors;
 Physical and chemical properties of the chemical.
 Environmental precautions.
 Normal practices
 Suppliers disposal advice when available
 Regulatory requirement

Disposal options are

i. Encapsulation with solidifiers
ii. Dispose of at sea
iii. Flush into drain with excess water
iv. Incinerate
v. Transfer to safe, open, place, burn/evaporate
vi. Down hole injection
vii. Dispose of at (controlled) landfill site
viii. Land treatment
ix. Recycle or reuse prior to disposal, neutralisation may be necessary

DISSEMINATION
MSDS data are to be made available in two ways:

i. A set of hard copy laminated information sheets that cover all those chemicals that
are being used at a given location. Maintenance/update of the hard copy manual is
available from the Site Environmental Officer.
ii. Density: Concentration of matter, measured by the mass per unit volume.
Decommissioning, Corrective Action, and Monitoring

Managing Environmental Liabilities relating to Decommissioning & Abandonment

Environmentaly responsible operations and the proper decommissioning and abandonment of
facilities is important because of the potential for future liabilities. Currently, oil and gas
companies are spending billions of dollars each year on compliance issues and remediation of sites
before abandoning.

It can be very costly if environmental problems are found after decommissioning. For example,
ExxonMobil was recently found liable for $1B in damages at an old NORM disposal site in Louisiana.
Shell has also been found liable for $63 million at one of its sites.

Proper environmental compliance and abandonment is also necessary to preserve the corporate
reputation and to assure that the company continues to have access to resources around the
world. Saudi Arabia Texaco will spend about $20 million in the next 3 years in an effort to obtain
the concession renewal for the Wafra field in Kuwait. Saudi Arabia, like other countries around the
world, may link environmental stewardship to concession renewals and the right to operate.

The importance of decommissioning and abandonment is to protect people and the environment
by reducing risk to ecological receptors of concern, and to restore the environment. It is also
important to minimize future liabilities. The following issues should be addressed for
decommissioning and abandonment:

• Regulatory requirements/expectations - Most countries have regulations that must be

met, and in many cases international and company standards may apply. In addition, there
will likely be a stakeholder expectation that the land be left in a natural state or one usable
by the local community. Not meeting regulations can resulted in large fines. Not meeting
expectations can affect a company’s reputation and future business.
• Eliminate safety hazards to community – Many features of oil and gas fields can pose
safety hazards if not properly handled prior to abandonment. For example, water filled
borrow pits can be a drowning hazard or pose a health risk from insect borne diseases or
when used as a dumping pit by the community. Non-plugged wells can present a particular
danger to children who may fall into them, or represent a source for explosive gases. In
California, houses built over old wells that were improperly abandoned have had to be
vacated because of the gas infiltration.
• Reduce risk of adverse human health effects – Contamination that is left in place may
present an unacceptable health risk. Some notable examples have been homes built on
top of improperly closed NORM sites and improperly closed pits that were turned into fish
ponds.

The long term environmental impacts of the project should be considered early in the project with
regard to the decommissioning and abandonment plan (D&A) that will be likely. Costs for D&A are
increasing, and this must be evaluated as to the costs allow the project to be viable. If the project
goes forward, the issues that will be addressed during D&A should be considered in the design,
construction, and operation of the project. To do this, HSE experts and project team members will
need to be involved right from the project inception. D&A should always be carried out in such a
way as to cause no additional environmental impacts.
Although a D&A concept will be selected at the start of the project, the final D&A plan will be
evaluated and developed prior to terminating the project. It will usually be cheaper and easier to
manage if D&A is initiated just before or as the site ceases operating and the company continues to
control the site and the activities on it. Below are some of the major activities that will be
addressed in a D&A plan:
 Plug and abandon wells.
 Determine the proper closure for all pits and complete the closures.
 Clear the site and remove surface structures, including in some cases buildings, levees,
ditches, and roads.
 Remove, remediate, contain, or control contamination and sources of pollution.
 Restore the site, which may include re-grading slopes, placing topsoil, and replanting with
vegetation.
 Restore damage done by roads, canals, and dredging.
 Document the location of plug wells, restoration of the site, samples collected and analyzed
to show baseline and restoration levels.
 Put in place follow-up monitoring as necessary.
 Complete compliance records and actions.

From the above, it can be seen that it is important to restore both the visual footprint as well as to
remove or contain pollution. Visual issues that can be of particular concern are wells, mud pits, old
spills. Pollution left in place, even if it can not be seen or smelled, can still pose a significant risk to
people’s health, such as benzene in groundwater used for drinking. Also, physical disturbance (loss
of topsoil, dredging, etc.) can cause environmental damage that may need to be addressed. This
may also be a factor when cleaning up pollution, such as spills, when the cleaning process damages
plants or increase erosion. Many times cleanup may lead to mangroves to being cut down or
vegetation being trampled and this will have environmental impacts.

Decommissioning and abandonment involves a lot of activities. As previously noted, it most cost
effectively and efficiently performed immediately after operations are complete, when proper and
thorough planning has been conducted, and while the company still controls the land or facility.

The first opportunity is to plan for D&A during design, operation and the entire asset lifecycle. This
is consistent with the theme “to begin with the end in mind”. When we look at the activities in
D&A we are planning remediation and restoration at the very first of the project. However, like all
environmental issues it is more cost effective to prevent them occurring in the first place. Below
are some examples of the costs involved when the potential end impacts are not considered in
design and construction:
 Building near streams and creek beds increased the environmental risks and cleanup
requirements.
 Substantial unnecessary clearing of vegetation for locations requires future restoration.
 Removal of pad-eyes and lifting aids required re-engineering and costly re-installation.

A primary consideration to minimize long term D&A liabilities is to make sure that time is taken to
have it well planned. Prioritization should be given to those facilities areas that pose a hazard to
people through unsafe structure, to the environment through contamination and releases, and to
navigation and transportation by the presence of platforms and other structures. Characterization
should include the presence of hazardous wastes such as NORM and asbestos, and the dangers
posed by the physical presence of structures such as bore holes and pits. Once these are identified,
remember that the priority to address these may also be determined by regulatory requirements.

The adjacent figure illustrates how risk-based decision Risk-Based Decision Making
should be used for setting D&A priorities, cleanup targets,
& restoration needs. The left hand circle depicts the Statutory & Legal
Toxicity
Considerations
considerations involved to determine human health or Assessment
Community Bad
Publicity
Considerations
ecological risks-which include hazard, toxicity and exposure Hazard Risk Management
Assessment Risk
assessments. The right hand circle shows some of the Characterization
Decision

socioeconomic and other decisions which will also have to Human health or
ecological risk
Risk
Economic
Factors
Exposure
be managed such as statutory and legal considerations, the Assessment
Political
Considerations
Management
Options
RISK RISK
community, potential negative publicity, economic and ASSESSOR ROLE MANAGER ROLE

cost considerations, and political issues.

12

An example of a risk-based clean-up level for a site is 4% Total Petroleum Hydrocarbon (TPH). This
means that 4% of a soil mixture is oil. In many countries throughout the world, risk based levels
such as 4% TPH are being accepted by regulators for many sites, depending on the circumstances.
A risk based approach takes into account the site sensitivity and its future use (potential for human
exposure and ecological risk) in developing clean up goals.

The major points to remember in decommissioning and abandonment is that the outcome is
important for reducing potential HES impact and liabilities and for assuring the company’s
reputation and right to operate. Also, it has been shown that D&A will be easier to manage and
most cost-effective when it is planned and conducted while the site is still under operational
control. And finally, a risk-based approach can be very useful in prioritizing issues, supporting
appropriate decisions, and aligning with the expectations and needs of the community and
regulators.

Corrective Action - Protecting Human Health and the Environment

Site cleanup or other corrective action should only be undertaken if it will provide environmental
benefit. An evaluation can be conducted to determine the ecological risks being posed and what
will be needed to reduce the risk to acceptable levels. This will assure that current or potential
environmental impacts are identified and that any action taken addresses these in the most
effective manner.

Risk-based corrective action (RBCA) is an approach that is being used in many countries to evaluate
contaminated sites and develop the most effective remedial actions. Risk-based corrective action
is a streamlined approach to corrective action of contaminated sites based on risk-assessment
practices.

The overall expectation for the application of RBCA is that remediation will be practical and cost-
effective. To be practical, the remediation must work and result in meaningful results. Many
times remediation may be conducted that does not really produce any benefit to the environment.
In such cases, the treatment may not work or, if it does work, it does not address aspects that are
truly beneficial to the environment. A risk-based assessment can determine what needs to be
addressed to protect the environment and health. This also in part determines the cost-
effectiveness of the remediation. A risk-based assessment can help select the most appropriate
remedial action. Approaches can be compared as to how quickly they can be completed and what
will be the cost.

RBCA should be developed with input from stakeholders so that consensus is reached. Likely
stakeholders for a RBCA can be regulatory managers,.

ASTM’s Guide to Risk-Based Corrective Action at Petroleum Sites provides a standard approach to
risk-based evaluation and corrective action. The guide elements include:
 A framework for integrating traditional clean-up methods with risk-based decision-making.
 Describes steps and philosophy to build the framework.
 Provides opportunities for approaching regulators with a technically defensible risk-based
program. Other stakeholders can include hydrogeologists, toxicologists, environmental
engineers, environmental scientists, and modelers for developing the framework and
consensus.
 Provides default toxicity, fate, transport and biodegradation equations, linked in
commercial software.

When evaluating contamination and risk

Property
to environment and health, consideration Line
will be given to the source of Point of
Exposure
contamination, its fate and transport,
what will be the exposure, and at what
Point of Compliance
point will it be regulated. These ?? Will range from onsite to some distance ??
relationships are illustrated in the from point of exposure

adjacent figure. The source is where the Groundwater

Fate and Transport Along
contamination is, what it is, and what its Exposure Pathway
Source Term
properties are. Fate and transport means Drinking Water Well
how it travels, where, and how quickly.
Also of consideration is whether it will biodegrade as it moves, or adsorb to or react with soil,
water, or air as it moves. Exposure is how the contaminant will impact health and the environment
through the air, drinking water, skin exposure, or ingestion of food. Regulation can be applied at
the source, at the point of exposure some distance from the source, or at a point along the
transport route.

In many cases, if exposure is distant from the source, then biodegradation and dilution will reduce
the impact at that point. In such a case, control and remedial action may be different than what
would be applied at the source. In some cases, “natural attenuation” will be acceptable and can be
monitored to make sure that this is occurring and that exposure continues to decrease.

Risk of impact is a combination of the toxicity of the contamination and the level of exposure.
Most compounds and chemicals are toxic or can have a toxic effect but this is determined by how
concentrated it is during exposure. For example, a single aspirin will not produce a toxic effect
when eaten and can improve the health of a person, but many aspirins taken at the same time will
have a detrimental effect that can threaten health.