Beruflich Dokumente
Kultur Dokumente
September 2015
Amec Foster Wheeler Environment
& Infrastructure UK Limited
Contents
1.
General information
1.1
Introduction
1.2
Project background
1.3
1.4
1.5
1.6
1.7
9
9
2.
2.1
Introduction
11
2.2
11
2.3
15
2.4
15
Hydrocarbons BREF
Supplementary materials
11
15
16
3.
18
3.1
Introduction
18
3.2
18
4.
4.1
21
4.2
21
21
Overview
Identification of BAT for routine operations
Identification of techniques for risk management (BARM)
21
21
22
4.3
23
5.
Data collection
5.1
5.2
29
29
Confidentiality
29
29
Table 1.1
Table 3.1
Table 3.2
9
18
19
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Appendix A: Details of key activities undertaken for upstream hydrocarbon production installations
Appendix B: Details of initial conclusion on risks for key activities (to prioritise key environmental issues)
Appendix C: Possible table for scoring risk assessment approaches against ISO 31000
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14
22
26
27
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1.
General information
1.1
Introduction
The European Union (EU) is currently facing challenges in domestic production of natural gas and
crude oil, resulting in an increase in import dependency for these fossil fuels. In order to improve the
security of energy supply, the EU is currently developing strategies for further diversification of its
energy supply including the development of renewable and other indigenous energy sources1.
Offshore operations are moving towards more technically challenging formations and environments
and Member States are currently assessing the potential for the development of unconventional
hydrocarbon sources using hydraulic fracturing, not only onshore but also offshore. There is also
increased use of stimulation and enhanced recovery techniques in conventional activities, to maximise
production.
On 28 May 2014 the Commission adopted a Communication on a European Energy Security Strategy2
that calls upon Member States to exploit, where this option is chosen, hydrocarbons () taking into
account the decarbonisation priorities. This Communication also recalls that conventional oil and gas
resources should be developed in Europe, both in traditional production areas and in newly discovered
areas, in full compliance with energy and environmental legislation, including the Offshore Safety
Directive 2013/30/EU3.
A number of pieces of both general legislation and environmental legislation apply to upstream
hydrocarbon exploration and production from both conventional and unconventional sources at the EU
level. As a complement to existing EU legislation, the Commission adopted a Recommendation4 on
minimum principles for the exploration and production of hydrocarbons (such as shale gas) using highvolume hydraulic fracturing (HVHF). The Recommendation called on Member States to, inter alia,
ensure that operators use best available techniques (BAT). Both the Communication on the
exploration and production of hydrocarbons using HVHF5 and the Communication on energy security
announced that the Commission would organise an exchange of information between Member States,
the relevant industries and non-governmental organisations promoting environmental protection in
order to identify the Best Available Techniques. The Energy Security Communication explicitly called
for the development of a BREF for hydrocarbon exploration and production covering hydrocarbon
development from both conventional and unconventional sources (the Hydrocarbons BREF). The
Hydrocarbons BREF is intended to be complementary to the BREF on management of waste from
extractive industries6 that is currently under review and will identify BAT for the management of waste
from onshore hydrocarbon exploration and production.
The technical working group (TWG) established to draw up the Hydrocarbons BREF will hold its kickoff meeting from 13 to 15 of October 2015. The purpose of this background paper is to provide
members of the TWG with an outline of the matters that are proposed for discussion at the kick-off
meeting.
http://www.consilium.europa.eu/uedocs/cms_Data/docs/pressdata/en/ec/141749.pdf
http://ec.europa.eu/energy/doc/20140528_energy_security_communication.pdf
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:178:0066:0106:EN:PDF
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014H0070
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52014DC0023R(01)
http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1404484842400&uri=CELEX:32006L0021
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1.2
Project background
Amec Foster Wheeler Environment & Infrastructure UK Ltd (hereinafter the contractor) has been
contracted by Directorate General Environment of the European Commission (hereinafter the
Commission) under Contract No. 070201/2015/706065/SER/ENV.F.1 to support the development of a
BREF on upstream hydrocarbon exploration and production.
The Hydrocarbons BREF will be able to be used as a reference by industry in the development of new
and novel techniques by providing a clear picture of what can be considered BAT and BARM for the
management of impacts and risks of hydrocarbons exploration and production.
The BREF will establish EU-wide BAT and BARM, based on an assessment of the most advanced
industry practices, taking into account that companies have developed their own techniques and some
of them have set themselves high safety and environmental management standards.
BREF is the abbreviation for Best Available Techniques (BAT) Reference document. BREFs
summarise BAT already applied in a given industrial sector under economically viable conditions. As
such, these reference documents reflect existing performance in the real world and so help to share a
common understanding of high-level performance across different types of industrial activities. The
overall objective of this contract is to support the Commission in the identification of the Best Available
Techniques (BAT) and Best Available Techniques for Risk Management (BARM) for the upstream
hydrocarbons exploration and production sector through the production of a Hydrocarbons BREF
(hereinafter the Hydrocarbons BREF). This should assist licensing and permitting by competent
authorities of Member States.
BAT in this context means:
the most effective and advanced stage in the development of activities and their methods of operation
which indicates the practical suitability of particular techniques for providing the basis for emission limit
values and other permit conditions designed to prevent and, where that is not practicable, to reduce
emissions and the impact on the environment as a whole:
techniques includes both the technology used and the way in which the installation is
designed, built, maintained, operated and decommissioned;
available techniques means those developed on a scale which allows implementation in the
relevant industrial sector, under economically and technically viable conditions, taking into
consideration the costs and advantages, whether or not the techniques are used or produced
inside the Member State in question, as long as they are reasonably accessible to the
operator; and
best means most effective in achieving a high general level of protection of the environment
as a whole.
BARM effectively sits within the definition of BAT above. The explicit reference to BARM, however,
reflects on the significant focus that exists within the upstream hydrocarbons exploration and
production sector in the implementation of measures to avoid and minimise effects on the environment
resulting from incidents and accidents. This makes the identification of BARM a specific task under
this project.
In undertaking this work, the purpose of the contract is to organise an exchange of information aimed
at elaborating the content of a Hydrocarbons BREF which:
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1.3
This background paper has been prepared by the contractor and lays down the issues proposed for
discussion at the TWG kick-off meeting. It outlines the Hydrocarbons BREF process and the
proposed detailed scope of the BREF and is supplemented by a strategy for data collection and a
proposal for priorities for the elaboration of the BREF.
Although it is recognised that many members of the TWG may already have views on what constitutes
BAT and BARM for upstream hydrocarbon exploration and production, at this first TWG meeting the
intention is to focus on agreeing the scope of the Hydrocarbons BREF and on the type of information
that the TWG members can provide to assist in the determination of BAT and BARM.
Section 2 of this paper contains a proposal for the scope of the Hydrocarbons BREF. In section 3, a
proposal for the scope of the processes and operations is presented and the key environmental issues
are identified; these will be the basis for the technical descriptions to be included in the Hydrocarbons
BREF. Section 4 presents the range and type of data needed in order to reach conclusions on BAT
and BARM.
Proposals which are to be discussed at the kick-off meeting are set out in a box within the document.
It is expected that the kick-off meeting will provide the basis for discussing and agreeing the scope of
the Hydrocarbons BREF, and the key environmental issues to be covered.
1.4
Please take note of the following advisory actions for you to complete before attending the kick-off
meeting:
1. If you believe that issues other than those included in this background paper need to
be discussed at the kick-off meeting please address your request for inclusion to
catherine.baker@amecfw.com by Friday 2 October 2015. Such a request must also
include a justification / rationale for each new item proposed. These suggestions will be
discussed at the kick-off meeting;
2. Essential background reading It is recommended that each TWG member read and
familiarise themselves with the contents of:
a. this background paper;
b. the strategy for data collection; and
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3. Consider the types of information you hold related to BAT and BARM that you could
bring to the information exchange process and prepare to indicate as such during the
meeting.
1.5
The kick-off meeting will initiate the information exchange process, by facilitating discussions of the
proposals raised in this background paper together with any further issues that are raised in the
meeting.
The success of the kick-off meeting and the decisions made will rely heavily upon input from
attendees, and it is therefore important that all attendees consider the matters raised in this paper
carefully, prior to coming to the meeting, so that they can raise questions and make suggestions
during the meeting.
The TWG is a technical group and the discussions to be held at its meetings will be technically related
to offshore and onshore exploration and production of hydrocarbons. It is not a forum for discussion of
political or procedural issues related to current or future EU policy. Consequently, attendees should
understand, in general, the technical matters related to this subject.
The aims of the kick-off meeting are included in the following list:
To get to know each other as members of the TWG and to share experiences and
information.
To discuss and agree upon the scope of the Hydrocarbons BREF.
To discuss and agree upon the structure of the Hydrocarbons BREF.
To determine the main environmental issues and risks that the Hydrocarbons BREF will
focus on.
To discuss and agree on the data collection process, types of data/information that are
needed, and to identify specific contributors for these data/information.
To present the tools that the TWG will use to collect, exchange and analyse information.
In particular, the internet based platform will be presented to the TWG.
To clarify issues concerning confidentiality of information submitted by TWG members.
To agree on a general timeframe for the work.
As a result of the kick-off meeting, the process for drawing up the Hydrocarbons BREF will be clarified
so that the TWG and Amec Foster Wheeler can be assigned clear tasks.
During the kick-off meeting, the discussions will be kept general, and will not include in-depth technical
debates. For example, deciding whether a particular technique is BAT or BARM will not be discussed
at this stage, as answers to questions of this nature need to be informed by the subsequent data
collection exercise.
1.6
The work flow includes two plenary TWG meetings. Between these meetings two formal drafts of the
Hydrocarbons BREF will be presented to the TWG for comments. The overall process is scheduled to
take 35 months. The milestones are as follows:
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January 2016
Information gathering
February 2017
TWG comments
April 2017
October 2017
TWG comments
December 2017
March 2018
April 2018
10
June 2018
1.7
This section aims to provide a general overview of the role of the TWG and the contractor (Amec
Foster Wheeler).
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2.
2.1
Introduction
The Hydrocarbons BREF, will be a non-binding BREF for the permitting of installations for the
exploration and production of hydrocarbons.
The overall scope of the Hydrocarbons BREF covers environmental impacts and risks of upstream
hydrocarbons exploration and production activities and should address the entire lifecycle of extraction
of natural gas and crude oil in all phases of a project. In particular, the Hydrocarbons BREF should
address activities with current or likely future relevance in the EU which may pose a potential
environmental or human health concern, including major accidents. The Hydrocarbons BREF will be
compatible with, and complementary to, the risk management framework of the Offshore Safety
Directive.
The Hydrocarbons BREF should identify:
BAT to manage the impacts (i.e. prevention or mitigation of releases of pollutants during
normal operations of an installation);
Best Available Risk Management (BARM) Practices (e.g. for releases of substances to
the environment as a result of unplanned incidents that are not part of normal operations
or for seismic events).
2.2
Geographical coverage
Depending on the geographical location of the facilities, the upstream exploration and production of
hydrocarbons can divided into onshore and offshore facilities. Some processes and technologies are
the same in onshore and offshore facilities but there are also differences which lead to different
potential risks and impacts.
Proposal 1
It is proposed that the scope of the Hydrocarbons BREF will cover:
Activities within the European Union;
Onshore facilities;
Onshore activities that are covered by the Management of waste from extractive
industries BREF will be excluded from the scope;
Offshore facilities.
It is proposed that the Hydrocarbons BREF does not duplicate activities covered by other BREFs
e.g. for Large Combustion Plants, Management of Waste in Extractive Industries, Waste Treatment.
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Proposal 2
It is proposed to include both conventional and unconventional hydrocarbons within the scope of the
Hydrocarbons BREF. More specifically it is proposed to cover the exploration and production of the
following products (the end products themselves are relatively similar (oil/gas), it is more the
geological formations / technique for extraction that differ):
Natural gas from:
Conventional sources;
Shale formations ("shale gas");
Low permeability reservoirs ("tight gas");
Coal-bed methane;
Oil from:
Conventional sources;
Tight oil.
Life-cycle stages
A number of studies have been undertaken on behalf of the Commission Services on the risks and
impacts of upstream hydrocarbon exploration and production (and on possible measures to address
these). These studies have characterised a number of stages across extraction which can be defined
across the well and field lifecycle. In particular the AEA (2012) study on hydraulic fracturing in shale
summarised six key stages as:
Stage 1: Site identification and preparation.
Stage 2: Well design; drilling; casing; cementing; perforation.
Stage 3: Technical hydraulic fracturing.
Stage 4: Well completion and management of wastewater.
Stage 5: Production.
Stage 6: Decommissioning.
Subsequent studies by Amec Foster Wheeler (with IPPE and Philippe and Partners) to look at all
unconventional (and subsequently conventional) fossil fuels recognised that hydraulic fracturing
acted as an additional life-cycle stage compared to the conventional upstream production of oil and
gas. On that basis for those operations that do not involve hydraulic fracturing five key life-cycle
stages exist.
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Proposal 3
It is proposed that the Hydrocarbons BREF will cover the following life-cycle stages:
Site identification and preparation (establish baseline environmental conditions,
exploration);
Well design, drilling, casing and cementing;
Well stimulation including technical hydraulic fracturing, enhanced recovery (where
relevant);
Well completion;
Production (oil and gas extraction);
Project cessation, well closure and decommissioning.
Boundaries of operations
Together with defining the lifecycle stages, the scope of operations that will be covered by the
Hydrocarbons BREF needs to be defined. For offshore upstream exploration and production,
operations may require the development of port facilities and oil and gas pipeline infrastructure. Such
operations are considered outside the scope of the Hydrocarbons BREF as such operations are
considered separately from the upstream oil and gas exploration and production process itself (e.g.
port facilities are required by other types of industry such as ship building and offshore renewables).
In a similar manner, the onshore upstream production methods might include only the development
and operation of the production site and any onsite storage prior to product distribution.
Proposal 4
It is proposed that the scope of the Hydrocarbons BREF to be limited to the environmental risks and
impacts associated with the upstream exploration and production of hydrocarbons from onshore
and offshore conventional and unconventional hydrocarbons only.
It is proposed that the Hydrocarbons BREF does not cover any downstream activities such as
processing of crude oil and gas.
It is proposed that the techniques to be included in the Hydrocarbons BREF should under no
circumstances lead to a reduction in safety of workers.
Figure 2.1 and Figure 2.2 illustrate at a high level those processes and technologies covered within
the scope of the Hydrocarbons BREF. All activities that occur outside of the red dotted lines are
proposed to be excluded from the scope of the Hydrocarbons BREF.
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Figure 2.2
Proposal 5
Regarding the scale of operations to be covered by the Hydrocarbons BREF it is proposed to cover
all operations irrespective of the scale (e.g. production levels, water use etc.). However, the work
will be focused on those operations with greatest potential for adverse environmental impacts and
risks.
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2.3
Issues that are covered by other BREFs are proposed to be excluded from the scope of the
Hydrocarbons BREF. Where European legislation or International treaties (e.g. MARPOL) apply to
the application of techniques related to BAT and BARM in the upstream exploration and production of
hydrocarbons, the content of the Hydrocarbons BREF will be drafted in a manner that is
complementary to such legal obligations. In this context the Hydrocarbons BREF may provide
conclusions on BAT and BARM that assist in the implementation of such legal obligations.
Proposal 6
The scope of the Hydrocarbons BREF is proposed not to cover the following activities:
Waste from upstream onshore exploration and production activities that are covered
by the MWEI BREF (management of waste from extractive industries);
Activities described in BREFs under Directive 2010/75/EU on industrial emissions
(integrated pollution prevention and control)
Transportation by vessels or air transfer (e.g. helicopters);
Pollution from ships;
Activities subsequent to loading/unloading into vessels, subsea transport pipelines,
etc.
Safety of work and workers health (save to the extent that worker safety should not
be compromised).
2.4
As previously mentioned, the intention is for the Hydrocarbons BREF to be relatively short and to be
supported by/refer to supplementary materials. The structure of the Hydrocarbons BREF and the type
of supplementary documents is provided in the following sections.
Hydrocarbons BREF
Collection of all types of emissions data from every oil and gas installation would be a time-consuming
exercise and, in the case of the hydrocarbons extraction sector, is unlikely to bring significant benefits
to the drafting of the BREF.
Therefore the Hydrocarbons BREF will not provide a baseline assessment of emissions from all
individual upstream hydrocarbon exploration and production facilities across the EU. Rather, the
focus will be on the identification of the key environmental issues that exist in relation to such activities
and to collect data on the types of BAT and BARM that are applied to address such issues, based on
data from installations in the EU, and potentially elsewhere. The aim will therefore be to focus data
collection at the level of installations to the most essential parameters needed to determine BAT and
BARM.
Overall, the intention should not be to write a manual for upstream oil and gas production, but rather to
identify the best available techniques for managing environmental impacts and risks, and to refer to
examples of good practice where these already exist.
As a result, it is proposed that the structure of the Hydrocarbons BREF be concise in content.
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Supplementary materials
General information about the sector concerned: numbers and production capacity of
installations, geographical distribution, economics, key environmental issues, overall
emission and consumption data.
Applied processes and techniques: description of processes and techniques currently
applied in the life cycle of hydrocarbons projects intended for the upstream exploration
and production of natural gas and crude oil.
Potential environmental risks: description of potential risks arising from upstream
exploration and production activities, including unplanned events/ accidents, and risks
arising from specific activities that vary amongst installations (e.g. chemicals used and
waste management practices); review of statistical data on accidents and environmental
damage.
Current emission and consumption levels: observed usage of energy, water and raw
materials, emissions of key pollutants to air and water, generation of residues/wastes
from the activities, emissions of noise and odour. (This and the preceding two chapters
could be merged into a single chapter.)
Techniques to consider in the determination of BARM and BAT: catalogue of
techniques for, and, if relevant, associated monitoring for:
Prevention and management of environmental risks from unplanned
events/ accidents.
Prevention and management of environmental risks from wastes.
Preventing emissions to air, groundwater and surface water, soil and underground or,
where this is not practicable, for reducing emissions (from normal operation).
Reducing the use of raw materials, water and energy.
Site remediation measures.
Measures taken to prevent or reduce pollution under other than normal operating
conditions.
Emerging techniques: Describes the novel techniques identified for the sector.
Recommendations for further work.
References.
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Proposal 7
To discuss and agree on the structure of the Hydrocarbons BREF based on the structure presented
above.
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3.
3.1
Introduction
This section of the background paper covers the key processes and related environmental issues/risk
that should be addressed by the Hydrocarbons BREF.
3.2
The contractor has reviewed the risks and risk mitigation measures relevant to conventional and
unconventional hydrocarbons including stimulation techniques other than hydraulic fracturing. This
review was based primarily on a number of studies undertaken for the European Commission, which
in turn draw upon a wide range of different literature sources and industry expertise. Appendix B
provides a summary of a (draft) categorisation and prioritisation of environmental issues relevant to
onshore and offshore hydrocarbon exploration and production activities.
Based on that review, the highest risk/impact activities from upstream exploration and production of
hydrocarbons are set out in the tables below. Many of these potential impacts are of course welladdressed by practices in existing and planned installations, and it is these practices that the BREF
will seek to capture. (Note that the wording of the activities/processes concerned has been modified
compared to that in Appendix B, to help with setting the scope of the Hydrocarbons BREF.
Proposal 8
It is proposed that the Hydrocarbons BREF should focus on identifying BAT and BARM for the key
environmental risks and impacts listed in Table 3.1 and Table 3.2. This should be subject to
discussion with the TWG at the kick-off meeting.
Table 3.1 Key environmental risks and impacts related to upstream onshore exploration and
production
Issue
Relevant activities/processes/techniques
Groundwater
contamination
Well integrity / well casing (leakage of chemicals and seepage of oil and gas)
Production (spillages)
Handling of fluids emerging at the surface following hydraulic fracturing (produced/flowback water)
Well stimulation including hydraulic fracturing and enhanced recovery (direct groundwater
contamination by chemicals and hydrocarbons)
Drilling wells - handling of drilling muds and fluids from drilling (surface run-off from surface spillage
and leakage of chemicals, oil, contaminated sediments, drill muds and fluids, drill cuttings)
Production (spillages)
Surface water
contamination
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Relevant activities/processes/techniques
Water resource
depletion
Well completion
Releases to air
Table 3.2 Key environmental risks and impacts related to upstream offshore exploration and
production
Issue
Relevant activities/processes/techniques
Seabed
disturbance
Sea-bed infrastructure impact, e.g. pipework, concrete mattresses, rock dumping, anchoring, piling,
jacket footings in-situ
Discharges to sea
Releases to air
Physical presence
Marine
biodiversity
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In-field riser/flowline rupture, topsides vessel / heat exchanger rupture, fuel tank loss of
containment, topsides drainage system failure (Tier 2)
Bunker hose failure, dropped tote tank, small-hole riser leak, helideck fuel spills (Tier 1)
(Note events listed here by Tier are for indicative purposes only, actual spills may vary)
Storage and handling of completion fluids (accidental loss of containment and discharge to sea of
e.g. corrosion inhibitor, biocide, oxygen scavenger)
Storage and loading of hydrocarbon cargo (accidental loss of containment and discharge to sea)
Drilling rig (air emissions from drilling rig and associated supply and transport vessels)
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4.
4.1
For each technique identified it is envisaged that the BREF will provide information on:
Technical description;
Environmental risks/impacts addressed;
For BAT for routine operations:
Achieved environmental benefits:
Environmental performance and operational data;
Cross-media effects;
For BAT for avoidance of environmental risks (BARM):
Quantitative risk management performance and operational data (estimate of typical
reduction in consequence/frequency of accidents);
Qualitative description of risk management performance where quantification is not
practicable (e.g. this could be the case for issues such as habitat damage which is
highly site-specific);
Other risk-related and environmental effects;
Technical considerations relevant to applicability [potentially also include worker safety
considerations here];
Economics;
Driving force for implementation;
Example installations;
Reference literature.
4.2
Overview
Identification of BAT and BARM will be the task of the TWG, based on information and/or proposals
provided by the contractor (which will in turn take into account data provided by the TWG and other
stakeholders). The following will be used to identify BAT and BARM:
(1) Expert judgement of the TWG.
(2) Multi-criteria analysis of techniques, taking into account e.g. Environmental performance;
Cross-media effects; Applicability to new and existing plants; Economics, including capital cost
and operating costs Current application of the technique in Europe or other countries.
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The expectation is that the Hydrocarbons BREF should cover both of these aspects i.e. strategic
approaches to risk assessment and management, and the specific measures identified as best for
managing specific identified environmental risks.
Based on experience to date, the risk assessment and management processes applied by companies
are largely similar in general terms, and all bear similarities to the process set out in ISO 31000:2009.
The hydrocarbons sector does not currently follow an industry-wide risk assessment approach. A
typical approach, however, would cover the following components:
Identification of potential environmental hazard scenarios.
Evaluation of the consequences and effects of these scenarios.
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4.3
In order that all TWG members have a common understanding of the types of conclusions on BAT
and BARM that should be reached as part of the Hydrocarbons BREF examples of such conclusions
are provided below. In this context it is important to
Note: For the sake of clarity, the activities covered by the Hydrocarbons BREF will be
unambiguously defined in the document. In addition, it will be mentioned that the list of
techniques described in the Hydrocarbons BREF is neither prescriptive, nor exhaustive
and that other techniques may exist that provide at least an equivalent level of
environmental protection to those identified as BAT or BARM within the BREF itself.
The Hydrocarbons BREF will consist of a number of individual conclusions for BAT and
BARM indicating the technique(s) or combination of techniques that are BAT or BARM
for achieving a particular environmental objective. The description of the techniques will
be short but informative enough to be useful to the competent authorities and operators.
Undefined acronyms and technical jargon will be avoided.
Each individual conclusion may be featured with or without an associated environmental
performance level with regard to the BAT / BARM identified.
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Risk assessment
Risk identification
Communication
and
consultation
Risk analysis
Monitoring
and
review
Risk evaluation
Risk treatment
Example 2 below provides an indication of the typical processes that could be applied to identify the
best available risk management practices in relation to accidental chemical spills, as well as the
general approach linked to the ISO 31000 process for risk management.
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Figure 4.3
In order to reduce hydrocarbon emissions in wastewater discharge from offshore oil and gas
operations, BAT is to use one or a combination of the techniques given below:
Technique
Description
Applicability
Oil separators
Generally applicable
Membrane
filtration
Flocculants
The emission level associated with the abovementioned techniques is for wastewater discharges to
contain less than 0.1% hydrocarbons by volume. [Note that this is illustrative only]
Risk identification
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Risk analysis
Risk evaluation
Risk treatment
The table below provides an example of the types of techniques that might typically be assessed as
BARM for an installation in terms of avoiding accidental chemical spills, based on the preceding steps.
Technique
Description
Spill prevention,
control and
mitigation
Housekeeping
Chemical
inventory
management
Equipment
performance
management
Leak detection
Training and
competency
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5.
Data collection
5.1
The method of data collection needs to be targeted so as to minimise efforts expended on data of little
concern and to derive that data of greatest relevance for identifying BAT and BARM.
Proposal 9
It is proposed to:
Produce tailored data collection tools for the identification of BAT and BARM. This
may take the form of separate (short) questionnaires for offshore and onshore
activities to be completed (by stakeholders/TWG members, potentially with initial part
completion based on data already available) for each technique with information that
could be directly incorporated into the Hydrocarbons BREF, along with a justification
for performance.
Not ask people for data on levels of emissions, etc. unless this is directly related to the
BAT/BARM in question. Be very clear that the Hydrocarbons BREF should be a
focused data collection and information exchange process, not one that should seek
to assess all releases of all pollutants from all installations.
Confidentiality
Confidential business information and sensitive information under competition law could potentially be
useful for the contractor in its assessment (e.g. cost, production volume) and in drafting the
Hydrocarbons BREF in general.
If any information submitted to the contractor is considered confidential business information or
sensitive information under competition law and should therefore not be reported in the Hydrocarbons
BREF this should be clearly stated when sending the information and the reason/justification for the
confidentiality/sensitivity should be given.
Confidential business information and sensitive information under competition law will not be reported
in the Hydrocarbons BREF, unless the information provides an important basis for the conclusions and
the provider of the information (having checked compliance with competition law) specifically
authorises the contractor to report the information in the Hydrocarbons BREF.
There are several ways to deal with confidential/sensitive data in the Hydrocarbons BREF such as the
aggregation or the anonymisation of information. This can be done by the contractor if necessary with
the help of those who supplied the information.
Confidential information will not be accessible to the rest of the TWG on the internet based platform for
exchange of information.
5.2
A SharePoint site will be used for the exchange of information. Further details on how this site will
operate will be presented at the kick-off meeting.
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A1
Sub-stages
Processes/technologies
Stage 1 - Site
identification &
preparation
2. Exploratory Surveys
Licensing
General investigation:
Gravity and magnetic surveys by boat to capture geological
information and identify leads for further exploration.
Geophysical testing/investigations:
Seismic surveys shock waves are sent into the subsea geological
formations and response times monitored for returned waves to
further identify and define reservoirs.
Stage 2 - Well
design &
construction
3. Well design
5. Well drilling
6. Stimulation
Hydraulic fracturing
Others
7. Well completion
Stage 3 Production
8. Platform installation
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Sub-stages
Processes/technologies
9. Platform operations
Stage 4 Project
cessation and well
closure
Stage 5 Post
closure and
abandonment
12. Topside
decommissioning
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Sub-stages
Processes/technologies
15. Shipping
Onshore installations
Stage of
hydrocarbon
production process
Sub-stages
Processes/technologies
Stage 1 - Site
identification &
preparation
1. Identification of resource
(desk study)
General investigation:
- Aerial survey of land features e.g. satellite imagery, aircrafts, etc.
Geophysical testing/investigations:
Land based seismic
Development of conceptual model
3. Exploratory drilling
Stage 2 - Well
design, construction
and completion
4. Exploration well
construction
Rig installation
Drilling of vertical or deviated wells
Casing installation
Well stabilisation
5. Appraisal
Well testing (some preliminary testing may be carried out before the
well is plugged temporarily)
Treatment of waste water from exploratory wells
Revised conceptual model and resource estimate
Assessment (evaluate technical and economic viability for the whole
project and develop plans for production)
6. Well stimulation
Hydraulic fracturing
7. Well completion
8. Field development
design (not all necessarily
required)
Other techniques
Stage 3
Development and
Production
Detailed design
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Sub-stages
Processes/technologies
9. Construction and
installation
Site clearing
Access infrastructure(i.e. roads, infrastructure)
Commissioning
11 Development drilling- if
required, once field
development in place
Stage 4 Project
cessation, well
closure and
decommissioning
14. Decommissioning of
equipment and reclamation
Plugging of wells
Removal of well pads
Waste management
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15. Rehabilitation
Site restoration
Monitoring
Relinquishing licences
B1
Issue
Description
Examples of relevant
activities/processes/techniques
Risk level
Groundwater
contamination
and other risks
(includes
induced
seismicity)
9 (high)
9 (high)
6 (moderate) from
exploratory wells,
Surface water
contamination
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9 (high) from
production
9 (high)
9 (high)
9 (high)
Moderate/high
6 (moderate)
6 (moderate)
9 (high)
6 (moderate)
6 (moderate)
B2
Water
resource
depletion
Description
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Examples of relevant
activities/processes/techniques
Risk level
6 (moderate)
6 (moderate)
6 (moderate)
6 (moderate)
Moderate/high
9 (high)
12 (high)
2 (low)
Moderate
6 (moderate)
5 (moderate)
8 (moderate)
5 (moderate)
12 (high)
4 (low)
10 (high)
3 (low)
B3
Zoning and
land take
Biodiversity
impacts
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Description
Examples of relevant
activities/processes/techniques
Risk level
4 (low)
8 (moderate)
3 (low)
4 (low)
4 (low)
6 (moderate)
5 (moderate)
5 (moderate)
8 (moderate)
Upstream hydrocarbon
exploration and production
facilities might have impacts in
biodiversity such as loss of
habitat and surface disturbances.
6 (moderate)
6 (moderate)
6 (moderate)
4 (low)
B4
Description
Examples of relevant
activities/processes/techniques
Risk level
Noise
Visual impact
Traffic
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6 (moderate)
4 (low)
4 (low)
5 (moderate)
Upstream hydrocarbon
exploration and production may
have a significant visual impact.
This somewhat depends on the
characteristics of the area (rural
vs. Industrial) and cumulative
impact of a large number of
wells. This has particularly
relevant with regard to
unconventional hydrocarbons, as
they may imply working in
natural or rural areas that have
not been previously developed.
4 (low)
15 (very high)
Geophysical testing/investigations:
Localised increase in traffic
5 (moderate)
4 (low)
4 (low)
4 (low)
5 (moderate)
4 (low)
4 (low)
4 (low)
4 (low)
B5
Seismicity
Accidental
events
Description
Upstream hydrocarbon
exploration and production
activities have the potential to
impact on strate below ground
leading to increased seimicity
with potential impacts on
pollution pathways underground
and activities aboveground both
on- and off-site. This may result
from matters such as
uncontrolled drilling, unexpected
seismic properties of the area,
errors in the calculations.
Examples of relevant
activities/processes/techniques
Risk level
4 (low)
4 (low)
Low
Issue
Description
Examples of relevant
activities/processes/techniques
Risk level
Seabed
disturbance
3 (low)
Rock dumping
9 (high)
12 (high)
12 (high)
12 (high)
3 (low)
Pipelines/bundles decommissioning:
Removal of mattresses, sand bags, grout
bags, and frond mats.
1 (low)
4 (low)
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B6
Description
Examples of relevant
activities/processes/techniques
Risk level
Discharges
to sea
6 (moderate) for
deterioration of
water quality,
Tier 1:
20 (very high) for
deterioration of
water quality,
12 (high) for
sediment fouling
9 (high) for
sediment fouling
Tier 2:
16 (very high) for
deterioration of
water quality,
9 (high) for
sediment fouling
Tier 3:
6 (moderate) for
deterioration of
water quality,
4 (low) for
sediment fouling
6 (moderate) for
deterioration of
water quality,
9 (high) for
sediment fouling
6 (moderate) for
deterioration of
water quality,
9 (high) for
sediment fouling
6 (moderate) for
deterioration of
water quality,
6 (moderate) for
deterioration of
water quality,
6 (moderate) for
deterioration of
water quality,
9 (high) for
sediment fouling
9 (high) for
sediment fouling
4 (low) for
sediment fouling
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6 (moderate) for
deterioration of
water quality,
B7
Description
Examples of relevant
activities/processes/techniques
Risk level
9 (high) for
sediment fouling
4 (low) to 20 (very
high), as
hydrocarbon spills
above
4 (low)
3 (low) for
deterioration of
water quality,
6 (moderate) for
sediment fouling
12 (high) for
deterioration of
water quality,
20 (very high) for
sediment fouling
Diesel/chemical deliveries/loading
9 (high)
4 (low)
12 (high) for
deterioration of
water quality,
6 (moderate) for
solid
12 (high) for
deterioration of
water quality,
20 (very high) for
sediment fouling
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B8
Description
Examples of relevant
activities/processes/techniques
Risk level
Releases to
air
5 (moderate) for
Contribution to
global emissions
5 (moderate) for
Contribution to
global emissions
8 (moderate) for
local air pollution,
10 (high) for
Contribution to
global emissions
10 (high)
Planned flaring:
8 (moderate) for
local air pollution,
16 (very high) for
Contribution to
global emissions
12 (high) for
Contribution to
global emissions
Unplanned flaring:
6 (moderate) for
local air pollution,
9 (high) for
Contribution to
global emissions
September 2015
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6 (moderate)
8 (moderate) for
Contribution to
global emissions
B9
Description
Examples of relevant
activities/processes/techniques
Risk level
HVAC systems
8 (moderate)
6 (moderate)
8 (moderate) for
Contribution to
global emissions
4 (low) for
Contribution to
global emissions
Physical
presence
Marine
biodiversity
impacts
9 (high)
10 (high)
3 (low)
10 (high)
10 (high)
12 (high)
1 (low)
12 (high)
6 (moderate)
Hydrocarbon spills,
Tier 3: 20 (very
high)
Tier 2: 16 (very
high)
Tier 1: 12 (high)
September 2015
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8 (moderate) for
accidental,
B10
Underwater
noise
Description
Examples of relevant
activities/processes/techniques
Risk level
10 (high) for
planned
5 (moderate) for
behavioural
responses,
6 (moderate) for
damages/injuries
5 (moderate)
Well drilling
3 (low)
Well cementing
3 (low)
5 (moderate) for
behavioural
responses,
6 (moderate) for
damages/injuries
5 (moderate)
3 (low)
8 (moderate)
6 (moderate)
8 (moderate)
Rock placement
when leaving
pipelines: 6
(moderate)
Removal of
matresses etc.: 8
(moderate)
Visual impact
(for near
shore
operations)
Accidental
events
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3 (low)
Platform
3 (low)
C1
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C2
Score
Weight
Yes (1)/
No(0)
1-5?
Understanding the external context is important in order to ensure that the objectives and concerns of
external stakeholders are considered when developing risk criteria. It is based on the organizationwide context, but with specific details of legal and regulatory requirements, stakeholder perceptions
and other aspects of risks specific to the scope of the risk management process. The external context
can include, but is not limited to:
the social and cultural, political, legal, regulatory, financial, technological, economic, natural and
competitive environment, whether international, national, regional or local;
key drivers and trends having impact on the objectives of the organization
The internal context is the internal environment in which the organization seeks to achieve its
objectives. The risk management process should be aligned with the organization's culture,
processes, structure and strategy. Internal context is anything within the organization that can
influence the way in which an organization will manage risk. It should be established because:
a) risk management takes place in the context of the objectives of the organization;
b) objectives and criteria of a particular project, process or activity should be considered in the light of
objectives of the organization as a whole; and
c) some organizations fail to recognize opportunities to achieve their strategic, project or business
objectives, and this affects ongoing organizational commitment, credibility, trust and value.
It is necessary to understand the internal context. This can include, but is not limited to:
policies, objectives, and the strategies that are in place to achieve them;
capabilities, understood in terms of resources and knowledge (e.g. capital, time, people,
processes, systems and technologies);
September 2015
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C3
information systems, information flows and decision making processes (both formal and
informal);
The objectives, strategies, scope and parameters of the activities of the organization, or those parts of
the organization where the risk management process is being applied, should be established. The
management of risk should be undertaken with full consideration of the need to justify the resources
used in carrying out risk management. The resources required, responsibilities and authorities, and
the records to be kept should also be specified. The context of the risk management process will vary
according to the needs of an organization. It can involve, but is not limited to:
defining the scope, as well as the depth and breadth of the risk management activities to be
carried out, including specific inclusions and exclusions;
defining the activity, process, function, project, product, service or asset in terms of time and
location;
defining the relationships between a particular project, process or activity and other projects,
processes or activities of the organization;
identifying, scoping or framing studies needed, their extent and objectives, and the resources
required for such studies.
Attention to these and other relevant factors should help ensure that the risk management approach
adopted is appropriate to the circumstances, to the organization and to the risks affecting the
achievement of its objectives.
The organization should define criteria to be used to evaluate the significance of risk. The criteria
should reflect the organization's values, objectives and resources. Some criteria can be imposed by,
or derived from, legal and regulatory requirements and other requirements to which the organization
subscribes. Risk criteria should be consistent with the organization's risk management policy (see
4.3.2), be defined at the beginning of any risk management process and be continually reviewed.
When defining risk criteria, factors to be considered should include the following:
the nature and types of causes and consequences that can occur and how they will be
measured;
September 2015
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Score
Weight
C4
September 2015
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Score
Weight
September 2015
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