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Topic 23: Implication of the offshore industry toward "zero harmful discharge"

Patricia Fleitas's picture

Current situation in the North Sea, impacts of dissolved subtances to the environment, new legislation and how the industry will be prepare to the new challenge. What is the current situation in your own country?

Comments

Maria Christou's picture

I come from Cyprus. Although Cyprus is an
island, the sea around us hadn’t  been
widely exploited. There weren’t  any oil
and gas rigs around, no offshore wind farms and no wave farms. That means that there
weren’t any harmful discharges from offshore industries, so there was no risk.

All these until recently. The government of
cyprus has recenty announced that drillings in the Mediterrenean sea, in a
field off the coast of Cyprus, have revealed natural gas which will create
great prospects for the island and the habitants, and will make Cyprus energy independent.
The gas is estimated to be exported by 2019.

Of course these is a great advantage for
our country, however  in the future we may face a lot of risks;
both environmental and health.

 

 

Reference

http://www.bbc.co.uk/news/business-16346507

http://in.reuters.com/article/2012/07/06/energy-cyprus-gas-idINL6E8I63R920120706

 

Abdulazeez Bello's picture

 Nigeria
is a country blessed with hydrocarbon reserves in the Niger-delta region. Exploration
activities started in the late fifties and have spanned more than five decades.
One of the biggest challenges befalling this profitable Industry is that of
Safety and Environmental pollution.  They
seem to be no proper legislation in place to reduce the menace of oil spillage
and gas flaring.  Industry best practices
are not followed when decommissioning platforms and working fluids are most times
channelled into the sea.  The Impact of these
poor safety practices has made areas in the Niger-delta region [1] unhabitable
for living, Agricultural farming and aquatic life.
The present administration in his effort to sanitize the environment as put
together a comprehensive document, PIB 2012, [2], to properly regulate the
activities of Oil exploration. This document if passed into law should address
the practices of gas flaring and discharges of non-biodegradable fluids into
the sea.

References

1.       http://www.youtube.com/watch?v=bq2TBOHWFRc

2.       http://www.nnpcgroup.com/PublicRelations/PetroleumIndustryBill.aspx

 

Igwe Veronica Ifenyinwa's picture

Bello I agree with you to a certain extent,
but the problem we have in Nigeria is not only the inadequacy of legislations but
our collective problem is the problem of implementation and observance of the
available legislation.

The presence of active
NGOs, coalition of pressure society groups and stakeholders are required in
Nigeria to pressurise the government to introduce more stringent measures and
influence the enactment of legislation for offshore oil and gas activities. All
political obstacles that may impede NGOs and the public from participating in
oil and gas environmental decision-making and implementation in Nigeria must be
removed.

Lastly, there is lack of data on the amount of wastes generated or the
number of offshore facilities in Nigeria. Hence there is need for better and
efficient data collection and analysis to facilitate record keeping and
information dissemination with a view to assisting the parliament in making
implementable laws that are people-driven and formulating a holistic plan for
the nearest future.

ikenna_ekekwe's picture

When it comes to environmental protection, there are a lot of already existing policies and decrees in Nigeria. In 1988, following the illegal dumping of toxic wastes in the former Bendel State, the Fedral Environmental Protection Agency (FEPA) was formed with a decree giving them the overal responsibility of protecting and developing the Nigerian envirinment. The EIA decree No. 86 of 1992 is also another document with the same aim of protecting the Nigerian environment. Bringing this point home to the Nigerian oil and gas industry, we have the Department of Petroleum Resources (DPR) which is an arm of the Ministry of Petroleum Resources has set out comprehensive standards and guidelines to direct the execution of projects with 100% consideration for the environment. DPR's Environmental Guidelines and Standards for the Petroleum Industry in Nigeria (EGASPIN) is one of many standards and guidelines which are now used. Also, all Oil companies have global corporate social and environmental policies which they implement in all their strategic business units worldwide, wtih Nigeria not an exception.

In light of the above, I dont think it would be right to say that a country like Nigeria with a hydrocarbon exploration history which spans over five decades has "no proper legislation in place to reduce the menace of oil and gas flaring".

 

Ikenna Ekekwe

Menelaos Michelakis's picture

(Topic : Current situation in uk waters : Aging of installations, hazards and challenges, situation in Greece)

There are too many posts about fossil fuel combustion and greenhouse gases, so i will make a contribution to this discussion that has to do mostly with a situation occuring in uk waters, the aging of installations, and how this could cause serious environmental problems.

United Kingdom has an advanced offshore industry installation system compared to other European countries. The main problem of united kingdom's offshore industry system, is that it has started getting old. Offshore installations, onshore installations, the pipes connecting installations with each other, as well as the fleet (semi-subs, barges etc.) used by the offshore industry, have started surpassing their average expected life limit. Most of the installations were constructed several decades ago, (1970's, 1980's), so some of them will need to ne paused, either because they do not fulfil the necessary requirements or because the reservoirs have been almost depleted. Of course, pollution, by dissolved substances to the environment, is an important matter, and if these old installations are not removed, the situation shall become worser, and pollution may appear due to leakages for instance.

Studies must be done for each installation about decomissioning/abandonment. I have not studied excessively the legislation regime about installation abandonment, but i am sure that the offshore industry won't let rotting debris in the position where old platforms stand today. This would create hazards for shipping and environment. It is a big challenge indeed for companies and engineers too, but i think caerful desigh and studies, will minimize risks and problems that will probably occur.

The discussion topic is very general, so i only mostly refer to the aging of installations, which is a much bigger problem for uk sector, than for Norwegian sector for example. I think that this information, describes the current situation in North sea, and if companies do not take measures, serious environmental impacts may occur.

The situation in my home country Greece, is far different. There are not such problems, because offshore industry is not as developed as here. No impacts of dissolved substances, no pollution, no problems with aging installations. Actually only this year serious geophysic research has started in the area south of Crete. Boreholes are expected soon, so there are not similar problems. There are other areas too, where geophysic research sould take place, like the aera between Greece and Italy (Ionian zone), Northeast Aegean sea, as well as the area between Greece and Cyprous, neat Megisti island, where there are proven natural gas reserves and hydrates. There are only 2 old installations at the area near the city of Kavala, that need to be paused mostly because of the reservoirs that are depleted. So, little Greece does not have such kind of problems (aging installations, pollution due to dissolved substances etc.)

Ref : Angus Mather, Offshore engineering - An introduction 

mohamed.elkiki's picture

I came from Egypt, where there are about 50 oil companies or more and potential of finding especially gas is very high. Most of discoveries till now are in the western desert and little in red sea and Mediterranean Sea. Therefore, I think there is very big chance to find still a lot of gas in offshore.About UK, I agree with you  Menelaos , they have very old installations but I look at it as very big experience and very high technology that attract many students and also engineers interested in oil industry to come to UK and learn from their experience to apply in their countries. Also, about pollution from leakage, I don’t think it can happen because if leakage happened it will cause blowout and companies are not to allow this happen because they will lose money and reputation so there is no worry from leakage and also there is specific tools to discover it and close it by dispatching for example or welding under the sea Another issue is about safety. in my country, safety is not actually important like I found in UK and companies in Egypt don’t even employ engineers for safety positions. Also, I did not take a safety course before however, I am petroleum engineer and I never heard that there is safety course in other universities in my country. I only knew that companies give special safety lessons for engineers before they got job or internship and I actually taken it.

Safety is very crucial issue in UK and this is one of the things that I think from my background made UK very successful and reach high technology and experience in the oil field.

SON CHANGHWAN's picture

I am coming from South Korea and we don’t have offshore field, so
try to write down another major oil producing country in North Sea, Norway,
instead of South Korea. Norway government endeavored to achieve decreasing harmful
discharge from 1996, environmental risk was reduced to 80 % of 2002 in 2006.   

Zero discharge is defined with; minimizing
discharges of harmful substances as contaminants in chemical/ products used and
discharged offshore.
Typical harmful substance during operations could be
gas emissions from process facilities, produced water from reservoir and
drilling cutting from drilling operations. By-product from drilling operation bring
back to the onshore and re-processed for disposal but gas emission and produced
water come out during production stage.

Gas emissions e.g. CO2, NOX are occurred from process facilities
like turbine, flare boom. Minimizing this, operators are developed that several
technical solutions are storing CO2 in depleted reservoir, combined cycle-power
and so on. Also, produced waters, majority (88 %) from whole discharges,
contain dispersed oil and organic compounds. It should not be discharged to sea
at all. For this, several technical solutions are suggested; re-injection well for pressure maintenance, disposal
well into water aquifers and water treatment.
Each technical solution is
viable but operator chooses optimized solution for individual filed considering
environmental impact assessment, feasibility.

 Norway started working on ‘zero
discharge’ earlier than other country and made a system for resolving this
issue by operators. Now statistics show the result, they did work right way. If
South Korea found any production field in our territory, we should follow their
system as a good model.   

 

Ref:

[1]http://www.npd.no/en/Publications/Facts/Facts-2011/Chapter-9/#Policy
instruments for reducing discharges of oil

[2] http://www.perf.org/pdf/Johnsen.pdf

[3] http://www.onepetro.org/mslib/app/Preview.do?paperNumber=00086801&societyCode=SPE

 

Regards,

 

SON, CHANG HWAN

Monday Michael's picture

The declaration of ‘zero harmful discharge’ in the offshore oil and gas is a welcome development especially for the oil-producing states of Nigeria. As pointed out by Abdulazeez, this declaration, if implemented diligently, should hopefully reduce the menace of oil spillages in the Niger-Delta area. Beyond oil spillages though, there is also the ever-present problem of produced water, which is water produced during the process of exploration for oil and gas and it is a complex mixture of organic and inorganic chemicals, oil, grease and sometimes naturally-occurring radioactive materials which could harm the environment [1] [2].
Produced water is inevitable in the exploration process, what is of concern is the type of treatment methods (and perhaps the depth of it), if any, that it undergoes before being discharged into the surrounding area: land or sea. For companies operating in developed countries such as Norway, the USA and the UK, there exist strict guidelines as to the concentration of dissolved metals in the produced water discharged into land or sea. Table 6 in the article [2] depicts this clearly.

Companies operating in these regions of the world invest time, money and other resources into technologies to reduce the concentrations of these lethal chemicals in produced water. The Norwegian oil giant, Statoil has pioneered this with its CTour technology [3]. The implication of this on the oil and gas sector is cleaner produced water to be discharged into the environment and a more sustainable environment for fish and human habitation but increased cost of oil and gas products.

REFERENCES 
[1] http://ijlct.oxfordjournals.org/content/early/2012/07/04/ijlct.cts049.fu... http://www.arpnjournals.com/jeas/research_papers/rp_2011/jeas_0811_540.p... http://www.offshore-mag.com/articles/print/volume-66/issue-4/norway/ctou...

Kyeyune Joseph's picture

Produced water is the main waste product on any oil and gas production platform. It contains various components that include hydrocarbon compounds from oil, organic compounds such as phenols, fatty acids, inorganic compounds from formation water, solid particles like sand, and products from corrosion, scaling, wax as well as traces of compounds used in oil processing and production. These various contaminants are deemed to be harmful when disposed directly into the sea. Disposal of produced water and solid discharge is regulated mainly through oil and grease concentration, toxicity levels and produced sand/solids. In the North Sea and GoM, effluents in produced water discharges are limited to monthly and daily averages. In US, monthly limits are 29mg/l and daily being 42mg/l while China permits 10mg/l and 100mg/l respectively [1]. At the moment, Norway has similar limits like US. However, Norway is one of the countries that are targeting zero harmful discharge. This means all contaminants in produced water must be removed before disposal into the sea or re-injection into wells.

Zero harmful discharge is targeted at reducing/eliminating toxicity of compounds in produced water that endangers marine life. This calls for improvement in current technology employed in water treatment systems offshore. Technologies like gas floatation, coalescence, gravity separation are being used to treat produced water. However,some of these cannot ensure total removal of all contaminants to achieve zero harmful discharge. This calls for adoption of technologies like such as Nano filtration, membrane separation and other advanced filtration systems. This will come at a cost to operators in form of acquisition of new technology, training, as well research and development.

Improvement in subsea separation is also another avenue towards achieving zero harmful discharge. At the moment, subsea separation mainly targets separation of oil, gas and water but not specifically concerned at the level of effluents in produced water before re-injection. Improvement in this system can ensure that all effluents are removed prior to reinjection of produced water.
In summary, given the fact that produced water treatment is one of the most expensive operations on offshore oil production systems, a move towards zero harmful discharge will call for more resources in research and development of effective systems, installation and their operation.

References
 
[1] Cardoso, C., Mahmoudkhani, A., Caprio, A., Costa, M. & Nair, M. 2012, "Facilitating Treatment of Produced Water from Offshore Platforms by an Oxidation/Coagulation/Flocculation Approach", SPE Latin America and Caribbean Petroleum Engineering Conference. Society of Petroleum Engineers, Mexico City, Mexico, 16-18 April 2012. SPE 153643, available at onepetro.

Daigle, T.P., Hantz, S.N., Phillips, B. & Janjua, R. 2012, "Treating and Releasing Produced Water at the Ultra Deep water Seabed", Offshore Technology Conference. Houston, Texas, USA, - 2012. OTC 23622, available at onepetro.

Tony Morgan's picture

Zero harmful Discharge[2] in the UK by 2020 –
The UK and NORWAY amongst other European neighbours is lucky to be far advance in it’s efforts to prevent and minimise the damaging effects of discharges.
From the 1967 grounding of vessel the Torrey Canyon spilling 117,000 tonnes of oil into the North atlantic the wheels have been turning, first with the Oslo convention followed by the Paris Convention with these great efforts being joined officially in 1998.

[1]''The OSPAR commission has various strategies based around its guiding principles of ;
1. protection and conservation of ecosystems and biological diversity;
2. hazardous substances;
3. radioactive substances;
4. eutrophication.
As agreed at OSPAR/MMC 1998, the OSPAR Commission meeting in 1999 adopted a further Strategy on Environmental Goals and Management Mechanisms for Offshore Activities. ''

This last strategy has a number of implications and is critical to the success of continued Oil and Gas operations along with containing many of the lessons for worldwide adoption in developing oila nd gas regions or in developing subsea technologies or energy industries such as wave and wind power developments.
The critical areas being addressed are ;
Produced water
Drill cuttings managment
Chemicals management

As my learned colleague has already noted some developments in Produced water technologies ( such as EPCON and CTOUR by STATOIL) which have helped to acheive a 15% reduction in oil in water levels meeting hte OSPAR targets til 2006 and there has been marked progress in the area of chemicals management as noted below i would like to question the current practices for drill cuttings management whilst introducing some of the critical success factors in the area of  chemicals management.
Introduction and adoption of technologies for cleaning drill cuttings at source as produced with contingency plans such as skip and ship being adopted/enforced instead of the old permissions for drill cuttings to be allowed to build up around the base of the host structure or well area.

Chemicals management has seen a continued and successful decline (around 90%) since 2003 when recording was officially introduced across the board.
This is mostly due to the mandatory adoption of fluids and usage being permit controlled to the point of 'posing little or no risk - PLONOR', the banning of hazardous substances such as oil based drilling muds since 1992 and the phased replacement of fluids or substances by substitution with improved environmental options by refernce to their PLONOR substance database. This should be a model which can be systematically adopted by other countries and industries in years to come.

In the area of drill cuttings it must be noted that skip and ship practices whilst being an easy option for companies to meet target levels or performance standards these practices can have at best a detrimental or even serious environmental impact or footprint due to the various energy used in the overall process eg excessive vessel movements, air emmissions, noise etc which leads us to the latest thinking on environmental performance.

There is specific gaps in the current legislation[4] however which does not address some key non oil substances which can be damaging therefore there is a clear danger that prescriptive legislation (as has been previously questioned as part of the macondo debate) is not ideal since the solutions developed in order to meet the requirement can result in unforeseen negative impacts which may even be worse but totally legal.

The latest ammendments in 2011 begin the process of moving to a balanced risk based approach [3],[4] ''Offshore Petroleum Activities (Oil Pollution Prevention and Control) (Amendment) Regulations 2011''

The concept of taking a fully holistic approach where the overall environment impact is assessed using risk analysis tools is one which Norway has led the world on and the UK appear to be embracing now.

It is this writers view that this type of goal and performance setting should result in the true balancing of all environmental strategies to get the right balanced decision for the future protection of the subject area of development.


[1]OSPAR -  http://www.ospar.org/content/content.asp?menu=00860305360000_000000_000000
[2]Zero Harmful Discharge  - http://www-static.shell.com/static/usa/downloads/alaska/discharge_myth_buster_final_0809.pdf
[3]Risk Based Approach - http://www.genesisoilandgas.com/Media%20Centre/Documents/Produced%20Water%20article%20for%20TCE%20August%202012.pdf
[4]Legislation - http://www.oilandgasukenvironmentallegislation.co.uk/Contents/topic_files/offshore/Produced_Water.htm

 

regards
tony morgan

Siwei Kang's picture

I have to say this topic is a good and interested one. Zero harmful discharge is attracting more attention by many countries and multinational corporations, especially after the oil spill happened in the Gulf of Mexico. I am from China and has been working in China National Offshore Oil Corporation (CNOOC) for more than 5 years. CNOOC is the largest offshore oil and gas company in China. It is engaged in exploration and production in Chinese offshore and has many overseas blocks in other countries, like Indonesia, Neigeria and Canada.

Based on my working experience, CNOOC always has strict standard in HSE, including offshore wast discharge. Take chinese offshore for example, CNOOC is the main operator. The discharge standard from Chinese government in Bohai Bay and South China Sea are 30 mg/L and 50 mg/L respectively.  For CNOOC, it has stricter standard in these seas, 17 mg/L in Bohai Bay and 25 mg/L in South China Sea seperatively. These standards are executed perfectly during the past 30 years.  

Different countries have different discharge standards, most of which are zero harmful. But how to execute them to ensure the oil and gas activities are environmental friendly, it depends on the effective HSE management of companies.

JIEFU's picture

Actually I am a little doubted about the perfect exacute you mentioned here according to my own experience, beacuse my university is right situated in the city next to Bohai Bay. I have heard lots of seniors words those years when I was there, they said they hardly touch seafood now as the so-called seafood taste more like 'petroluem'. I will not deny there is exaggerated part, but it does reflect a fact that the recent massive offshore practice has impact on our environment. I'm sure our government has taken some actions upon these issues, both regulation level and exacution level, but how many differences these actions made indeed, it's still a big question mark.

Siwei Kang's picture

I admit that there is some severe environmental issues in some cities along the Bohai Bay. But is it really caused by offshore oil and gas? I highly doubt it. In fact, many industries like steel manufacture and paper mill are the source of pollution. In all offshore area operated by CNOOC, there is no environmental accident happened or caused by discharge of oil. i appreciate it if you could provide some data reference or news reference to support your comment.

 

Keqin Chen's picture

Like Mr. Kang, I am also from CNOOC. And I
could not agree more on his comments and CNOOC are dedicating to prevent
environmental pollution.

Other than the Zero Discharge on Oily water,
I would like to add some information about the discharge control of oily drill
cuttings. In South China Sea, the standard discharge
criteria of drill cuttings are less than 1% of oil content. And each well will
bring over 100 m3 of
drill cuttings.

Generally two ways can be chose, one is re-injection
to the formation and the other way is to discharge based on the stringent criteria.

And CNOOC asks for more. Yacheng 13-1 PFA Project
has an innovative waste recycling system to process the produced drilling cutting.
These oily drill cuttings will be put into the funnel to be filtered, heated
and recycled. After the removal of the residual oil, the emissions standards can
be achieved and then shipped back to  terminal
to be processed further, after which can be used in paving.

Keqin Chen

Msc of Oil and Gas Engineering

ID:51126368

Henry Tan's picture

Can you provide any references for the data mentioned?

Siwei Kang's picture

Patricia Fleitas's picture

I am totally fascinated with the topic due to the HUGE CHALLENGE that it will represent in the short term to the European offshore operations and middle-long term for the rest of the world.

European oil and gas operations represent for the rest of the world the fundamentals to develop prescriptive legislations in other countries. As Nigeria, China, Venezuela among others; their own legislations has been adopted taking UK, Norway and US as references. And for us, as new engineers that may come back to our countries, we need to raise the voice for best practices in our energy industry.

Produced water is a by-product inevitably generated during the production of hydrocarbons and is considered the largest waste stream of oil and gas activities. Worldwide in 2007 one barrel of oil production was equivalent of three barrels of produced water discharged to the sea, representing a total of 250 million barrels of produced water per day. Currently, the maximum of total hydrocarbon content in produced water to be discharged to the sea is very similar worldwide; for example:

• UK, Australia, Malalysia, is 30mg/l,
• US is 42mg/l daily and 29mg/l average monthly
• Kuwait and Mediterranean sea is 40 mg/l
• Venezuela is 20mg/l

Environmental concerns in Netherland and extensive research in Europe have demonstrated that current technologies for water treatment helps to meet the maximum target explained above, however produced water contains dissolved substances such as BTEX, PAHs, NPDs and phenols that cannot be removed using current gravitational technologies, so these components can be found even 10 km away from the discharging point, with concentrations than may affect the marine and ecosystem life. As a result, Netherland government implemented the “zero harmful discharge” and due to the influence of Netherland for the rest of the world, it is likely that other countries implement this legislation.

Now, What is the implication of the offshore industry toward “zero harmful discharge” ?. Well, it represents a huge challenge for the current operators due to they need to install new equipments to remove the dissolved substances such as: MPPE, membrane, C-tour (this technology is not very efficient to remove BTEX), re-injection to wells, biological treatments, among others. Furthermore, lack of space on existing platform, modification of the operating philosophy, selection of commercial proven technologies, personal training requirement and continuous discharge water monitoring will raise the cost of offshore operations and time to implement them.

Countries as Cyprus, Venezuela, Nigeria, India which an emerging offshore operations needs to be aware of this information and be prepared to take our industry in an environmental friendly development.

Note: Venezuela legislation reported a maximum of 20mg/l, however monitoring of produced water discharged in Maracaibo offshore operations is not public. Further analysis about its implementation I can’t extend, but I would like someday have a transparent record of operations such as the one reported by OSPAR in the North Sea platforms. It may be the same case in Nigeria.

William J. Wilson's picture

Patricia Fleitas I can see how you can get excited about this subject, the complexities and multiple solutions are very broad.  The cost of implementing new equipment and the cost of monitoring them will be massive.  Statoil stated that in the short term it would cost in the region of 4.5Billion NOK (approximately £500million), so with the huge costs involved reaching near zero concentrations of synthetic substances are clearly an issue for strategic business operations, as Patricia mentioned. ALARP springs to mind here as businesses will see the overheads increase and targets like 30mg/L will only just be made.  Organisations will review the selection of proven commercial technologies aimed at getting the ratio of environmental concentration (PEC) and the tolerance level (NPEC) below 1. (PEC/NPEC >1 = environmental risk is unacceptable). How far are all the North Sea oil and gas companies going to go and what do they see as an acceptable cost to reduce the harmful discharge?

References: http://www.perf.org/pdf/Johnsen.pdf

William Wilson
MSc Subsea Engineering

Felipe.Santana.Lima's picture

I’d like to discuss the real viability of the “zero harmful discharge” concept, and I’m quite surprised that this hasn’t been challenged yet in this forum. Please don’t take me as pessimistic; my intention is just to introduce a different perspective.

I have been working in Norway for four years and this concept, as mentioned by many, is very much alive here. Although I appreciate all the efforts and think we are going on the right direction, personally I do not believe any country will ever achieve the “zero harmful discharge” objective.

On one extreme we see practices in some regions such as dumping produced water into the sea without proper treatment, flaring of all produced gas just because it is not economically attractive to export it, pre-commissioning of pipelines without proper care, etc. These are definitely practices to be prevented and condemned.

Least critical but also a serious problem are the aging facilities specially in the UK sector of the North Sea. Although built on the best available technologies at their time, today they do not comply with the best standards. Nevertheless implementing all necessary modifications to bring them to the current standards is not an easy task and probably not a viable one in many instances.

A third, even less critical but the hardest to solve is the discharges from the current best available technologies and probably the future ones as well. Even if we deploy water treatment systems that make the produced water cleaner than the seawater itself before disposal; utilise the produced gas on whatever option cleaner than flaring it, etc; we still need to build our systems out of thousands of tonnes of steel (which have discharges in the production stage), we still need vessels which emit gases to install the systems and do intervention whether they are topside of subsea, we still need to maintain these systems, we still need energy (whether generated offshore or supplied from shore) to operate them, etc. And these activities will always have harmful discharges, no matter how much we manage to reduce them by making the processes and systems cleaner and more efficient.

My point is not that we engineers should give up striving to make cleaner and cleaner technologies because the cause is lost. Instead, what I’m trying to argue is that as well as we are convinced that a 100% reliable system is just a theoretical proposition and not achievable, we might accept that ZERO harmful discharges is also impossible in practice. A more realistic approach, in my opinion, would be similar as the one we adopt with regard to safety, i.e. ALARP. We shall keep striving to develop systems that have the lowest practicable amount of discharges (and for this we need to consider the entire system lifecycle from ideation through to decommissioning and disposal), applying always the best available techniques (BAT) and keep this process in a continuous improvement. The European IPPC directive, for example, seems to take this approach.

In sum, my opinion is that whilst uncontrolled discharges are just unacceptable, absolute ZERO harmful discharges are in the real world impossible. In between, an “as little harmful discharge as reasonably practicable” alternative is a viable and rather motivating approach.

Ike Precious C.'s picture

Thank you Felipe; As a student with none of these offshore exerience(s), I was about to ask this question, Is "Zero Harmful Discharge" really achievable? To what level do we term a discharge are having zero harm? To what degree is a discharge termed harmful? Like Siwei mentioned, CNOOC has very strict standards in HSE, whose standards will be termed as loose? Is the term "Zero Harmful Discharge" going to differ with respect to Environments?
For example, since 2010, Nigeria has been on the Gas flaring issue. Penalties were introduced if gases  were flared and a deadline set as at 2010. This seemed not to work as these companies kept on flaring and paying the fines while the deadline has always been shifted to a future date. With respect to this example, there seems to be no end to such discharges because these companies prefer to keep paying these fines and keep up with production while the people within the environment suffer.
If the "Zero Harmful Discharge" will really make a global impact, I think there needs to be harmony between the Regulators and Operators, irrespective of location. For instance, there are recent developments so as to harmonize the all the Offshore regulations in Europe as one but I know the UK authorities have been cold towards the harmonization of some of their Regulations with EU regulations because other countries' considerations may lower their safety standard.

Thank you.

Thomas Ighodalo's picture

 

 In the early years of Crude oil recovery, Gas flaring was the easiest approach to deal with associated gas accompanying the oil, however with the increase in the price of Gas, a rethink to this approach has been one of the reasons for shift to zero harmful discharge by oil companies. The price of gas at well head rose from 0.54$/mscf in Jan 1976, to a record high of 10.79$/mscf in July 2008.[1]. thus flaring gas was seen as flaring cash, and thus means of recovering the the flared gas were put in place. Other factors/means that could lead achieve zero harmful discharge are-

1. Government fiscal incentives i.e the Associated Gas frame agreement of1992 (Nigeria), introduced a 3 yr tax holiday and All investments necessary to separate oil from gas from reserves into suitable production is considered as part of the oil field development.[2]. This lead to some major gas projects such as Oso condensate project, Escravos gas project, LNG project and West African gas pipeline project been initiated.

In 1998, the Nigerian Government provided additional incentives for investment in economic utilization of flared gas. These fiscal incentives included [2]
o Gas projects taxes at 30% vs. 85% for oil projects.
o Capital expenditures for gas projects chargeable under Petroleum Profits Tax.
o Tax holiday of 5 to 7 years.
o Exemption on custom duties and VAT on gas related development equipment.
o Investment capital allowance of 15%
o Interest deductibility on loans
o Dividends during tax holiday are tax free. 

2. strict sanctions

3. reduction in corruption: this can not be exempted because it is alot cheaper for the oil companies to pay off a government regulatory body rather than put in measures to achieve zero harmful discharge.

 

references

1.

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http://www.eia.gov/dnav/ng/hist/n9190us3m.htm 

2. http://cdm.unfccc.int/filestorage/I/J/V/IJVMCX2UTZ43S7916KDP0RN8OABHE5/Annex%203A.pdf?t=ZE98bWVubXZ0fDAvrR2wnyzZNc-FqYJ1ztt8

 

 

 

 

"Everything we hear is an opinion not a fact"

 

 

Ike Precious C.'s picture

Thank you Felipe; As a student with none of these offshore exerience(s), I was about to ask this question, Is "Zero Harmful Discharge" really achievable? To what level do we term a discharge are having zero harm? To what degree is a discharge termed harmful? Like Siwei mentioned, CNOOC has very strict standards in HSE, whose standards will be termed as loose? Is the term "Zero Harmful Discharge" going to differ with respect to Environments?
For example, since 2010, Nigeria has been on the Gas flaring issue. Penalties were introduced if gases  were flared and a deadline set as at 2010. This seemed not to work as these companies kept on flaring and paying the fines while the deadline has always been shifted to a future date. With respect to this example, there seems to be no end to such discharges because these companies prefer to keep paying these fines and keep up with production while the people within the environment suffer.
If the "Zero Harmful Discharge" will really make a global impact, I think there needs to be harmony between the Regulators and Operators, irrespective of location. For instance, there are recent developments so as to harmonize the all the Offshore regulations in Europe as one but I know the UK authorities have been cold towards the harmonization of some of their Regulations with EU regulations because other countries' considerations may lower their safety standard.

Thank you.

Patricia Fleitas's picture

Felipe, I quite agree with you. For sure the measurements on "Zero harmful discharge" is something that cannot be done in one day. It requires huge effort of the industry to manage the way to achieve it, taking into consideration the technologies available for it. Right now, there are not commercial scale technologies that can achieve the removal of dissolved substances (PAHs, NPD, BTEX, alkyl phenols). However, the is a technology called Macro Porus Polymer Extraction (MPPE) that can remove up to 95-99% of dissolved toxic hydrocarbons and It has been proved at pilot scale with very good results. In addition there are other technologies pointed out by OGP (Aromatics compounds).


Netherland government is taking it very seriously and it is likely that OSPAR could agree to follow the measurement, but both knows very well that it will implicate a significant investment to change current produced water treatment system into the installed off shore platforms. In all the cases the measurement will be develop "as reasonable as practicable", nobody make the standards without evaluate all the scenarios and implications for the industry and for the environment. 


On the other hand, I disagree when you pointed out that is impossible to avoid the contamination of the environment. In the past, we used to flare gas, discharge cutting drilling to sea and discharge produced water with 50ppm. Now days, the operators are very keen to develop their activities in an environmental friendly way, because the society is against of the underlying consequences to people and environment. I think that it is good, because engineers have the huge challenge to develop better technologies and standards.

Burning of flammable gas during oil and gas exploration is a
hazardous process called gas flaring. It occurs when the pressure relieve valve
releases gas from an auxiliary passage during over pressuring of the plant
equipment out of the system and burnt with a complete combustion system through
the pilot flame tip. The major effect of gas flaring is attributed to its
contribution to the emission of carbon dioxide into the atmosphere and the
emission of methane and sulphur gas that affects respiratory organs.

Developed countries tries to limit the effect of gas flaring
system into the atmosphere, although not to zero limit at present. Developing
countries struggles to achieve such high standard but with collaboration with
global gas flaring reduction team that helps to raise awareness and understanding
of gas flaring and venting issue as a key achievement, gas flaring has been  reduced in percentage, this also implies
working with oil companies.

Zero harmful discharge also relates to the use of chemicals
in the oil industry for cleaning process. The discharge oil industry also dump
into the sea is a large risk. In the UKCS, such recovery water from drilling is
well regulated by the HSE.

References:

http://www.touchoilandgas.com/zero-discharges-from-petroleum-a164-2.html

http://web.worldbank.org/WBSITE/EXTERNAL/NEWS/0,,contentMDK:21032487~menuPK:34480~pagePK:64257043~piPK:437376~theSitePK:4607,00.html

Ekaterina Pavlichenko's picture

Zero Harmful Discharge is a subject close my heart; ExxonMobil has been active for a while in developing and applying carbon capture and storage technology to safely capture, transport and store CO2 in stable underground geologic formations, with the main focus on Norway and it’s Zero Harmful Discharge Policy, in the Sleipner field where Exxon is active, around 5 million metric tons of CO2 where captured for underground injection in 2010. Also, in 2011 two Exxon platforms Jotun and Ringhorne where modified with technical solutions for substituting environmentally harmful chemicals with more environmentally friendly alternatives, which will help reduce environmental risks related to discharges into the sea.

Emissions into the air focus on CO2, NOx and volatile organic compounds (nmVOC) and the global focus is to reduce these steadily. Speaking for ExxonMobil, Exxon participates in the global CO2 quota trading and in Norway companies also have the opportunity to participate in the ‘Business Sector NOx Fund’ in which Exxon contributes as so do most energy companies in this sector. In this, companies pay an amount equal to their own NOx emissions. The fund is used to implement the most cost effective NOx reduction measures across all business sectors.

But these measures are a long way off from full Zero Harmful Discharge and until the world follows Norway’s lead in legislating and enforcing these policies, a few unscrupulous Production Companies and Operators will continue to apply the minimum standards of environmental safety.

Mohamed H. Metwally's picture

In my opinion, the extensive use of the word "Zero" within HSE concepts and regulations has stripped off the power of the word in a way that the alarming nature of it has no longer been there.

Just like "Zero tolerance policy"....dreadful, isn't it?! 

Now, I want to ask...how can we achieve "zero" discharge while companies are yet to be ready with the technology or capabilities to do so?. It is very easy to convene and come up with rosy recommendations without defined steps or time frame for our target. 

adavis's picture

At the moment, I live in Florida and I have to admit that the thought of having oil rigs off the coast isn't very appealing even with a "zero harmful discharge" policy.  There's a pessimistic side of me that realizes that even with all the sincere desire by the energy companies to protect the environment, there are always situations where individuals or small groups lose sight of that goal and create situations where accidents happen.  As with safety, I do believe that all accidents are avoidable.  However, I believe the weak link in most situations is the human element.  As human beings, we often focus too heavily on a finite set of input variables (such as meeting production or getting the job done) and lose track of the bigger picture (protecting ourselves and the environment).

However, having said that, the pragmatic side of me realizes that Florida's energy needs continue to increase.  Those needs will be met by either producing our own energy or importing energy from elsewhere.  I realize that regardless of where the energy comes from there will always be an environmental impact even if not a drop of oil or gas is spilled.  As we consume energy, we change the environment around us.  Though I’m still not thrilled with the thought of drilling of the coast of Florida, I am will to consider it.

Kwadwo Boateng Aniagyei's picture

Global discharges and emissions of energy products and by-products have sky-rocketed mainly due to industrial and economic growth. "Zero harmful discharge" will minimise unsafe disposals of toxic substances. It is very encouraging to find countries like Norway championing this course.  must admit that the intensity of the definition of "zero" cannot be achieved but at least this tells us that the industry players and governments have to some extent pledged their commitments to achieving and maintaining a clean and safe environment. Several operational goals have been set by several governments and agencies and strict adherence to these procedures will help lower toxic discharges into the environment. Technological developments like Carbon Capture and Storage have also been brought on stream to help control harmful discharges. Also other policies like emissions trading are also ripe for aiding zero harmful discharge. The philosophy of a zero harmful discharge can be achieved to some extent and this can happen in the  presence of strict and well monitored regulations.

Manuel Maldonado's picture

I tend to agree with Felipe on this subject, however not to the point that ‘it won't be achievable'. Discharge permissions are very regulated and companies are leading towards that objective Zero Harmful Discharges. This is a goal for the oil companies and services companies. The development of new technologies to improve water polishing such as gas flotation and induction units, hydrocyclones and filters are becoming more effective and water treatments are reaching better water quality.

New installations are designed for water separation and water polishing while the old installations were only designed for oil separation. This makes a big difference because new installations are achieving water quality close to zero mg/lt of oil in water while oil installations are reaching only levels below 20 mg/lt oil in water. Saying that, this is a good indication that all companies and regulatory entities are making their best efforts to reach those targets either by implementing new technologies or improving process performance.

Now zero discharges would also move to a different direction such as not discharges at all. It means reinjecting produced water or exporting or injecting produced gas. This subject has been discussed from the operations and subsurface management perspective. It will required drilling new wells or adapting existing ones. This has been an option which has been around the oil industry for years but has not be positively approached due to high capital and operating costs and poor equipment reliability.

Existing regulations are reinforcing this concept by imposing maximun discharges limits which oil companies must meet. However, it is very difficult for the regulators to perform an strict control on this and on the other hand some companies take advantage of this and deviate from that. But they are a very low population which at some point have to be within compliance otherwise they would incur in serios penalties. 

Currently the as low as reasonable practicable approach can be used but following the technology development and new research I think this will be achievable.

The obvious implication of zero
discharge policy is a cleaner environment where living organisms can strive.

But this also implies a higher CAPEX in
the form of technology and equipment and OPEX in the form of energy usage and
workers training to production companies

This could have an adverse effect on
exploration for oil and gas especially in an area like the North Sea where most
of the remaining fields are believed to be marginal. Other effects could be an
increase in hydrocarbon products.

Also, such directive could lead to more
focused research on other energy sources to meet energy needs.

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