Environmental Stds for Offshore Drilling

Alan Spackman is Director ofOffshore Technical and Regulatory

Affairs for the InternationalAssociation of Drilling Contractors

(IADC). His duties involve participationin industry standards organisations

and responding to numerousregulatory proposals at both theinternational and national level.

He is IADC’s principal representativeto the International Maritime

Organization, a specialised agencyof the United Nations dealing withmaritime safety and environmentalprotection. Mr Spackman joined the

association in 1991 after retiringfrom the US Coast Guard, where he held the rank of Commander.He received a Masters in Naval

Architecture and Marine Engineeringfrom the University of Michigan and

a Bachelor of Science from theUnited States Coast Guard Academy.

a report by

A l a n S p a c kman

Director, Offshore Technical and Regulatory Affairs, International Association of Drilling Contractors (IADC)

The need for measures to address pollution fromoffshore oil and gas activities has been considered bythe General Assembly of the United Nations and, forseveral years, has been discussed actively within boththe Commission on Sustainable Development (CSD)and the International Maritime Organization. TheUnited Nations Convention on the Law of the Sea(UNCLOS) creates both an obligation and providesa structure for such measures, which are beingpursued by several United Nations organisations.The United Nations CSD has considered the matterand has concluded that “there is no compelling needat this time to further develop globally applicableenvironmental regulations in respect of theexploitation and exploration aspects of offshore oiland gas activities.” Nonetheless, views are divided.Those in favour of international regulations orguidelines have argued that there are many oil-producing regions that do not have the capacity todevelop either national or regional standards and thatsome kind of international regulations or guidelineswould help them. Those who have argued againstglobal measures contend that offshore oil and gasactivities only pose a threat of local pollution, whichcan be dealt with through national regulations orregional agreements. The industry itself hasdeveloped only a modest number of high-levelstandards. The implementation of meaningfulenvironmental management systems by the oilcompanies, coupled with changes to well design andoverall operational procedures, may offer a means ofreducing adverse environmental impacts whilstavoiding prescriptive regulations.

T h e U n i t e d N a t i o n s a n d a S t r u c t u r ef o r E n v i r o nmen t a l R e g u l a t i o n o fO f f s h o r e A c t i v i t i e s

The United Nations Open-ended InformalConsultative Process was established by the GeneralAssembly1 to facilitate the annual review by the

assembly of developments in ocean affairs. It held itsthird meeting on 8–15 April 2002. The report of thismeeting2 makes the following recommendationswith respect to offshore oil and gas activities.

• The General Assembly should recommend thatregional seas conventions and action plans inregions where offshore oil and gas industries aredeveloping or are in prospect, and whereinstallations do not exist, should developprogrammes and/or measures to prevent, reduceand control pollution from offshore installations.

• The General Assembly should invite regional seasconventions and action plans that have developedsuch programmes and measures to make theirinformation and experience available for thisprocess.

• The General Assembly should invite InternationalMaritime Organization (IMO), United NationsEnvironmental Programme (UNEP) and WorldMeteorological Organization (WMO) toundertake an initiative, involving the relevantregional organisations as well as the oil and gasindustry, to develop guidance on the bestenvironmental practices to prevent and controlpollution from accidents on offshore installationsand to mitigate their effects.

The UNCLOS, which entered into force on 16November 1994, is a widely accepted treaty, havingbeen accepted by 138 nations (states party) as of 1October 2002. The convention provides an overallframework for environmental governance of offshoreand, to some extent, onshore oil and gas explorationand production operations. The implementation andenforcement principles of UNCLOS can besummarised as follows.

• States party must adopt laws and regulations on

Env i ronmenta l S tandards for Of f shore Dr i l l ing

B U S I N E S S B R I E F I N G : E X P L O R A T I O N & P R O D U C T I O N 2 0 0 3

Environment

1. Report of the Special Committee on the Charter of the United Nations and on the Strengthening of the Role of theOrganization, A/54/33 (1999).

2. Report on the work of the United Nations Open-ended Informal Consultative Process established by the General Assemblyin its resolution 54/33 in order to facilitate the annual review by the assembly of developments in ocean affairs at its thirdmeeting, A/57/80 (2 July 2002).32

spackman_pap.qxd 1/13/03 2:15 PM Page 32


pollution from land-based sources and throughthe atmosphere, taking into account internationalprovisions, and enforce these laws and regulations(Articles 207(1), 212(1), 213 and 222).

• With respect to seabed activities subject tonational jurisdiction, states party must adopt andenforce national laws and regulations to prevent,reduce and control pollution of the marineenvironment arising from, or in connection with,seabed activities subject to their jurisdiction andfrom artificial islands, installations and structures,which must be no less effective than internationalrules, standards and recommended practices andprocedures. States are also required to endeavourto harmonise their policies at the appropriateregional level (Articles 208 and 214).

• States shall adopt laws and regulations and takeother measures on pollution from seabed activitiesand from dumping, which shall be no lesseffective than international (in the case ofdumping, global) rules and standards (Articles 139,208, 209, 210 and 214).

• Coastal states are required to adopt and enforcenational laws and regulations to prevent, reduceand control pollution of the marine environmentfrom artificial islands, installations and structuresunder their jurisdiction. Furthermore, states mustadopt measures to minimise, to the fullest possibleextent, pollution from installations and devicesused in the exploration or exploitation of thenatural resources of the seabed and subsoil(Articles 194, 208 and 210).

• States should co-operate in establishingcontingency plans against pollution (Article 199).

• States shall enforce this legislation within theirjurisdiction (including vessels flying their flag andaircraft of their registry) and ensure that theirnationals, and bodies controlled by such nationals,comply with the requirements applicable in theareas of the seabed that are beyond nationaljurisdiction, known as ‘the area’ (Articles 139,208, 209, 210 and 214).

• States must adopt laws and regulations onpollution from vessels that are entitled to fly theirflag (flag states) that are at least as effective asgenerally accepted international rules andstandards (Articles 139, 208, 209, 210 and 214).

Industry trade organisations have also developed a

framework of standards, recommended practices andother guidelines for environmental protection. Theprincipal such organisations for the oil and gasindustries are the International Organization forStandardization (ISO), the International Associationof Oil and Gas Producers (OGP), the InternationalAssociation of Drilling Contractors (IADC) and theAmerican Petroleum Institute (API). Theseorganisations represent their membership beforegovernment and governmental organisations.3 TheSociety of Petroleum Engineers sponsors a semi-annual environmental conference and a number ofregional conferences with environmental ‘bestpractice’ as their focus.

It is noteworthy that Articles 208, 209 and 211 ofUNCLOS do not differentiate between internationalstandards, recommended practices and proceduresdeveloped by intergovernmental bodies such as theIMO and those developed by the industryorganisations producing internationally recognisedstandards such as the ISO, OGP, IADC and API.

L a n d - b a s e d S o u r c e s

A structure and action plan for addressing land-based sources of pollution was developed by the1995 Washington Global Program of Action for theProtection of the Marine Environment from Land-based Activities. This structure was reviewed at asubsequent meeting held in November 2001 inMontreal and is addressed in the Plan ofImplementation (Paragraph 32) developed at theWorld Summit on Sustainable Development inJohannesburg, South Africa, in September 2002.The structure is reinforced by a variety of regionalagreements. In the face of many otherenvironmental issues of greater priority, littleattention has been directed at the international leveltowards land-based oil and gas exploration andproduction operations. Industry-specific guidelineshave been published by API.4

O f f s h o r e A c t i v i t i e s i n A r e a s S u b j e c t t o

N a t i o n a l J u r i s d i c t i o n

Under UNCLOS, exploitation of seabed mineralresources is subject to the exclusive control of theadjacent coastal state out to the limit of its exclusiveeconomic zone or the limit of its continental shelf ifthe continental shelf extends beyond 200 miles. In1996, the United Nations CSD concluded that“there is no compelling need at this time to furtherdevelop globally applicable environmentalregulations in respect of the exploitation and


33

3. The International Maritime Organization recognises both OGP and IADC as non-governmental organisations withconsultative status. IADC is similarly recognised by the International Seabed Authority.

4. API RP 52, “Land Drilling Practices for Protection of the Environment”.


exploration aspects of offshore oil and gas activities.”5

Further, it was concluded that “the primary focus ofaction on the environmental aspects of offshore oiland gas operations continues to be at the national,sub-regional and regional levels,” and noted that, insupport of such action, there was a need to “shareinformation on the development and application ofsatisfactory environmental management systems.”6

Thirteen ‘regional seas’ programmes7 have beenestablished under the auspices of UNEP, involvingmore than 140 nations. Two other regionalprogrammes are based on free-standingconventions: The Convention for the Protection ofthe Marine Environment of the North-East Atlantic(OSPAR Convention) and the Convention for the Protection of the Marine Environment of theBaltic Sea (Helsinki Convention). In addition, ahigh-level intergovernmental forum, the ArcticCouncil, has been established to address the mutualconcerns faced by the Arctic governments andindigenous populations.

While no global measures have been adoptedregulating the discharges directly arising from theexploration, exploitation and associated offshoreprocessing of oil and gas, harmonised regulationswith respect to the exploration and exploitation ofoil and gas have been developed as part of theBaltic, Mediterranean, north-east Atlantic andKuwait regional programmes and under the ArcticCouncil. The matter has been considered by otherregional programmes; however, in general, theyhave decided that other issues should be givenhigher priority.

OGP has issued industry-specific guidelines foroperations in tropical rainforests, onshore areas inarctic and sub-arctic areas, arctic offshore regions,mangrove areas and ‘sensitive’ environments.8

The regional programmes also offer a means forintergovernmental exchanges on regulatory practiceand experiences, including exchange of informationon best environmental practice. The UNEPmaintains a website9 to facilitate the exchange of suchinformation as it relates to offshore oil and gasexploration and production.

A c t i v i t i e s i n t h e A r e a

Under Article 209 of UNCLOS, the development ofseabed mineral resources in areas beyond nationaljurisdiction (i.e. ‘the area’) is subject to control by theInternational Seabed Authority (ISBA). The ISBA hasdirected its efforts towards developing regulations forprospecting and exploration for polymetallic nodules,since this is the limit of current commercial interest.However, the ISBA has noted the potential forhydrocarbon and gas hydrates in areas where there is apotential claim for a continental shelf extendingbeyond 200 nautical miles, including the Atlanticseaboard of North and South America (including theLabrador Sea) and the Alaskan Arctic seaboard.10 Theauthority acknowledges that development potentialfor these resources is currently marginal, but notes thattechnological improvements in recovery efficiencyand greater access to deepwater areas are increasing therange of economically recoverable resources.

A t - s e a D i s p o s a l ( D u m p i n g )

The dumping of wastes at sea is governed by the 1972London Convention on the Prevention of MarinePollution by Dumping of Wastes and Other Matter.Seventy-eight nations have ratified or acceded to theLondon Convention. This agreement has been revisedand amended by its 1996 protocol (16 nations haveratified or acceded to the 1996 protocol). The protocolhas not yet entered into force; however, it has beenreported that it may enter into force as early as 2003.11

The protocol introduces a wider definition ofdumping than that contained in UNCLOS. Itincludes within the definition the expressions, “anystorage of wastes or other matter in the seabed andthe subsoil thereof from vessels, aircraft, platforms orother man-made structures at sea” and “anyabandonment or toppling at site of platforms or otherman-made structures at sea, for the sole purpose ofdeliberate disposal.”

The London Convention and protocol exempt thedisposal into the sea of “wastes or other matterincidental to, or derived from the normaloperations of vessels, aircraft, platforms or otherman-made structures at sea; the placement of matter


Environment

5. United Nations Commission on Sustainable Development, CSD Decision 4/15, paragraph 26.6. CSD Decision 7/1, paragraph 3(a).7. Black Sea, Caribbean, East Asian Seas, East African, Kuwait, Mediterranean, North-West Pacific, Red Sea and Gulf of

Aden, South Asian Seas, South-East Pacific, South Pacific, South-West Atlantic and West and Central Africa.8. See http://www.ogp.org/publications/index/html9. http://www.oilandgasforum.net10. Report of the Secretary-General of the International Seabed Authority under article 166, paragraph 4, of the United Nations

Convention on the Law of the Sea, ISBA/8/A/5, (7 June 2002).11. IMO, Report of the Twenty-Third Consultative Meeting of the Contracting Parties to the London Convention, LC 23/16

(10 December 2001).34


CETCO Offshore is the pioneer of technologically

advanced, cost-effective systems and products for

the treatment of offshore wastewater.

CETCO OFFSHORE

CETCO technology

is effectively used

worldwide for the

following applications:

Temporary and permanent produced water polishing.

Treatment of acid flowback and completion fluids.

Clean up of hydrotest and platform/pipelinedecommissioning fluids.

Waste minimisation of oil-based drilling mud and zincbromide recovery.

Bilge water polishing.

Deck drainage polishing.

for further information contact

CETCO Offshore

Maitland Quay Sinclair Road AB11 9PL

t: 01224 893850 f: 01224 894550

e: [email protected]

www.cetconorthsea.com

CETCO_ad.qxd 1/15/03 17:12 Page 35

36


Environment

for the purpose other than the mere disposalthereof, and the disposal or storage of wastes orother matter directly arising from, or related to theexploration, exploitation and associated offshoreprocessing of seabed mineral resources.” Thisexemption leaves considerable opportunity fordivergence of interpretation with regard to whatconstitutes ‘normal operations’ of offshore oil andgas drilling and production facilities, which somefind troublesome.

The Netherlands has recently proposed thatconsideration be given to expanding the LondonConvention to explicitly include a wide variety ofissues associated with offshore oil and gas activities,12

specifically:

• seabed activities;

• sub-seabed activities;

• offshore platforms (discharges, removal anddisposal); and

• matters related to past dumping activities (recoveryof wastes dumped in other marine engineeringactivities (e.g. OTEC, artificial islands).

A number of technical reports and guidancedocuments have been produced by OGP on the issue of decommissioning offshore oil and gasinstallations.13

P o l l u t i o n P r e v e n t i o n ( O i l , N o x i o u s

C h e m i c a l s , G a r b a g e a n d S e w a g e )

The IMO is the principal United Nationsorganisation for maritime safety and environmentalprotection. Developed under its auspices, theInternational Convention for the Prevention ofPollution from Ships 1973, as modified by the

Protocol of 1978 relating thereto (MARPOL73/78), covers accidental and operational oilpollution as well as pollution by chemicals, goods infive annexes that are currently in force or soon toenter into force: oil (Annex I), noxious liquidsubstances (chemicals) carried in bulk (Annex II),harmful substances carried by sea in packaged form(Annex III), sewage (Annex IV) and garbage(Annex V). Annexes I and II entered into force in1983 and currently have 121 contracting parties.Annex III entered into force in 1992 and currentlyhas 104 contracting parties. Annex V entered intoforce in 1988 and currently has 108 contractingparties. Annex IV has recently received its 88thcontracting party and will enter into force inSeptember 2003.

Obviously, a variety of ships is used to supportoffshore oil and gas exploration activities; however, asignificant number are also utilised directly in bothdrilling for (e.g. mobile offshore drilling units) andproducing (e.g. floating production units) offshoreoil and gas and these are subject to the provisions ofthe convention and its annexes through thelegislation and regulations imposed by the nationunder whose flag they are entitled to fly.

Fixed and floating platforms are also subject toMARPOL 73/78 because Article 2(4) of theconvention defines ‘ship’ as “a vessel of any typewhatsoever operating in the marine environment andincludes hydrofoil boats, air-cushion vehicles,submersibles, floating craft and fixed or floatingplatforms,” thus extending the convention tovirtually all offshore facilities. The coastal state underwhose jurisdiction such facilities operate is obliged toregulate such facilities. An agreement among theparties regarding the application of the provisions ofAnnex I effectively limits its applicability to thedischarge of machinery space drainage (which islimited in oil content to 15 parts per million or less,

Table 1: Average Annual Input (1990–1999) of Petroleum to Marine Waters by Source (Kilotonnes)

North America Worldwide

Best Estimate Min. Max. Best Estimate Min. Max.

Natural seeps 160 80 240 600 200 2,000

Extraction of petroleum 3.0 2.3 4.3 38 20 62

Platforms 0.16 0.15 0.18 0.86 0.29 1.4

Atmospheric deposition 0.12 0.07 0.45 1.3 0.38 2.6

Produced waters 2.7 2.1 3.7 36 19 58

Transportation of petroleum 9.1 7.4 11 150 120 260

Consumption of petroleum 84 16 2,000 480 130 6,000

Total 260 110 2,300 1,300 470 8,300

Source: “Oil in the Sea III: Inputs, Fates, and Effects”, Committee on Oil in the Sea: Inputs, Fates, and Effects, National Research Council, National Academies Press, 2002.

12. IMO, Future Work Program, “Future objectives for the London Convention 1972 and the 1996 Protocol thereto”,Submission by the Netherlands, LC 24/14 (9 August 2002).

13. See http://www.ogp.org/publications/index/html

Source




37

without dilution).14 Drilling and processingdischarges and production displacement waterdischarges are left to national (or regional) regulation.Industry guidelines have been developed by bothOGP15 and API.

There is an active effort underway, inspired byAustralia, to re-examine the applicability of theAnnex I requirements to floating production, storageand offloading units (FPSOs) and floating storageunits (FSUs), particularly with respect to thepossibility of oil outflow following accidental damageto the hull.16

There have been repeated, albeit unsuccessful,efforts to inspire the IMO to address offshore oil andgas activities more explicitly within the scope ofMARPOL 73/78. The most recent was led by theRussian Federation.17 One of the difficulties facedby the IMO in this regard is that the organisation’sfocus has traditionally been ships and shipping, sothe national delegations comprise shippingregulators. Only rarely have representatives ofnational oil and gas regulatory bodies been included.

Mobile offshore drilling units (MODUs), FPSOs andother vessels employed by the industry are confrontedwith a unique challenge in conforming to MARPOL73/78. While underway between operating locations,they are subject to their flag state’s interpretation ofMARPOL 73/78; however, when they activelyengage in oil and gas development activities, theybecome subject to the host coastal state’sinterpretation of MARPOL 73/78. Not only arethere wide variations in the interpretation andenforcement of the convention among coastal states,but there are also variations in interpretation as towhen the coastal state’s authority begins.

As loss of well control poses the most serious threatto the safety of a drilling unit, and of causing asignificant oil spill, the IADC has developed a seriesof minimum training standards in well control and aprogramme for accrediting training institutions withthose standards.18

O r g a n o t i n A n t i - f o u l i n g S y s t e m s

Concern over the adverse environmental impacts oforganotin paints used to protect against marine

growth on the hulls of ships and offshoreinstallations led the IMO to develop theInternational Convention on the Control ofHarmful Anti-fouling Systems on Ships in 2001.The convention will enter into force afterratification by 25 nations representing more than25% of the world’s merchant shipping tonnage.There is currently only one signatory.

A i r b o r n e P o l l u t i o n

There are a number of international agreements thatmay obligate nations to set standards for air emissionsfrom oil and gas activities.

• The United Nations Framework Convention onClimate Change (UNFCCC) attempts to stabilisegreenhouse gas concentrations in the atmosphere.The convention was adopted in 1992 and enteredinto force on 21 March 1994. The conventioncurrently has received 186 instruments ofratification.

• The protocol to the UNFCCC was adopted bythe parties to the UNFCCC in Kyoto, Japan, on11 December 1997. The protocol containsindividual emissions limitations and reductions forthe industrialised (Annex I) nations. It will enterinto force after not less than 55 parties to theconvention, incorporating Annex I parties, whichaccounted, in total, for at least 55% of the totalcarbon dioxide emissions for 1990 from thatgroup, have deposited their instruments ofratification, acceptance, approval or accession. Asat 25 September 2002, 95 parties (25 Annex Iparties, accounting for 37%) have ratified oracceded to the Kyoto protocol.

• The 2001 Stockholm Convention on PersistentOrganic Pollutants, which was developed, interalia, in response to concerns on long-rangeairborne pollution of the seas expressed in thenegotiations on the Global Program of Action toProtect the Marine Environment from Land-based Activities. The Stockholm Conventioncurrently has 22 of the 50 ratifications required forit to enter into force.

• Annex VI of MARPOL 73/78, which attempts tocontrol potentially harmful emissions (nitrogen

14. MARPOL 73/78, Consolidated Edition, Unified Interpretations of Annex I, “Requirements for drilling rigs and otherplatforms”.

15. OGP (formerly E&P Forum), “Exploration and Production Waste Management Guidelines, 1993”.16. IMO, Report to the Maritime Safety Committee and the Marine Environment Protection Committee on the 7th session of

the Sub-Committee on Bulk Liquids and Gases, BLG 7/15 (25 July 2002).17. IMO, Marine Environment Protection Committee, Follow Up Action to UNCED, “Development of the Environment best

practice guidelines in the offshore oil and gas activities”, Submission by the Russian Federation, MEPC 44/13/2.18. See http://iadc.org/wellcap.htm



Environment

and sulphur oxides) in the exhaust of ships’engines. Indications are that Annex VI will enterinto force in 2004. The IMO is also examiningstrategies to control greenhouse gas emissionsrelated to ship operations.

In addition, there are regional agreements such as theUN Economic Commission for Europe’s Conventionon Long-Range Transport of Air Pollution.

P o l l u t i o n I n t e r v e n t i o n a n d R e s p o n s e

The Oil Pollution Preparedness, Response andCooperation Convention (OPRC Convention) wasadopted in 1990 and entered into force in 1995. AnIMO convention, it was designed to helpgovernments combat major pollution incidents byfacilitating co-operation and mutual assistance inpreparing for and responding to major pollutionincidents. Requirements regarding oil pollutionemergency plans on installations are set out in theOPRC convention. Sixty-six nations are parties tothe OPRC Convention.

In 2000, the IMO adopted the Protocol onPreparedness, Response and Cooperation toPollution Incidents by Hazardous and NoxiousSubstances (2000) (HNS Protocol), which followsthe principles of the OPRC Convention forhazardous and noxious substances other than oil.With only one contracting party, the HNS Protocolhas not entered into force.

Regional centres have been established in Malta (inco-operation with UNEP) and in the Caribbean toassist in training and anti-pollution efforts.

The International Convention Relating toIntervention on the High Seas in Cases of OilPollution Casualties 1969 entered into force in1975. This convention affirms the right of a coastalstate to take measures to protect its territory fromoil pollution from casualties occurring on the highseas. The convention has 77 contracting parties. A1973 protocol to this convention extends itsprinciples to substances other than oil. The protocolentered into force in 1983 and currently has 44contracting parties.

Industry-specific guidance on emergency response isprovided by ISO 15544.19

B i o l o g i c a l D i v e r s i t y

At the 1992 Earth Summit in Rio de Janeiro,world leaders agreed on a comprehensive strategy

for ‘sustainable development’. One of the keyagreements adopted at Rio was the Convention onBiological Diversity. This convention sets outcommitments for maintaining the world’secological underpinnings whilst maintainingeconomic development. The conventionestablishes three main goals: the conservation ofbiological diversity, the sustainable use of itscomponents and the fair and equitable sharing ofthe benefits from the use of genetic resources. Thisfree-standing convention entered into force in1993 and has been ratified or otherwise acceptedby 186 nations.

E n f o r c e m e n t

While there is a commonly held view thatinternational agreements and their regulations directthe actions of industrial activities, they do not. Itmust be emphasised that it is only through theestablishment of implementation and enforcement oflegislation or regulations at a national level that theseagreements are given practical effect.

There are no established means for states party toUNCLOS to force non-parties, or even other statesparty to UNCLOS, to effectively implement theconvention; however, there is growing pressure forthe industrialised nations to take action against non-conforming nations through trade agreements andthrough restrictions or conditions placed on aid anddevelopment programmes.

M e a s u r i n g a n d R e p o r t i n g

E n v i r o n m e n t a l P e r f o r m a n c e

Most of the conventions described here have one ormore measures intended to foster compliancethrough requirements for monitoring or reporting ofconformance with provisions of the convention or itsregulations for compliance purposes. Some arestraightforward, for example requirements underAnnex I of MARPOL 73/78 for oil content metersand recording devices to ensure that the regulationsregarding percentage oil content of ships’ bilge waterdischarge are met. Others, such as those agreed underthe Framework Convention on Climate Change,require governments to collect and aggregate largevolumes of data.

In late 1997, a private-sector initiative was begunwith the mission of developing globally applicableguidelines for corporations to use for voluntarilyreporting on their economic, environmental andsocial performance. While targeted initially atcorporations, the goal was to develop guidelines that

19. ISO 15544, “Petroleum & natural gas industries – Offshore production installations – Requirements and guidelines foremergency response”.38



could be used by any business or governmental ornon-governmental organisation.

Convened by the Coalition for EnvironmentallyResponsible Economies, in partnership with UNEP,the Global Reporting Initiative (GRI) wasestablished as a permanent, independent globalinstitution in April 2002. The GRI released its‘Sustainability Reporting Guidelines’20 in June 2000.These guidelines encourage ‘triple bottom line’reporting of an organisation’s economic,environmental and social performance. They use 16high-level ‘core’ environmental performanceindicators and 19 additional indicators.

ISO 1400421 provides practical guidance aboutenvironmental systems, including general guidance about external reporting. ISO 1403122

provides guidance on the selection andimplementation of performance indicators that can be used by management of a company toevaluate and report (internally or externally) on the company’s environmental performance.

ISO is developing a further standard to provideguidance on communicating environmentalperformance.23

To date, there is no consensus on the appropriatemeasures of environmental performance for the exploration and production industries;however, the matter is under active considerationby the OGP.

While it is relatively simple to measure or at leastproduce reliable estimates of discharges and emissionsrelated to drilling activity, selection of measures bywhich performance is to be evaluated poses somedifficulty. For example, the volume of drill cuttingsproduced in drilling a well is generally considered amatter of environmental concern.

Sections of footage drilled as a normalisation factorwould provide for straightforward comparison on awell-to-well basis; however, it could result in a non-productive well being considered as superior to onethat is highly productive.

20. Available on the Global Reporting Initiative’s website at http://www.globalreporting.org21. ISO 14004:1996, “Environmental management systems – General guidelines on principles, systems and supporting techniques”.22. ISO 14031:1999, “Environmental management – Environmental performance evaluation – Guidelines”.23. ISO WD14063, “Environmental management – Environmental communications – Guidelines and examples”.



Environment

En v i r o nmen t a l M a n a g emen t S y s t em s

Environmental management systems are tools bywhich government and industry can strive toimprove environmental compliance and perform-ance. A number of management system guidelineshave been produced. Such systems generally requirethe establishment of:

• management commitment to managingenvironmental performance;

• a process for identification of applicableenvironmental legislation, regulations andstandards; and

• a process for attaining continuous improvementof environmental performance.

The ISO 14000 series of standards focuses oncorporate environmental management systems andoperating practices, products and services. Thestandards promote continual improvement withoutspecifying actual standards of performance. UnderISO 1400124, companies may register theirenvironmental management systems when it hasbeen demonstrated to conform to the specificationsprovided in the standard.

The European Union’s Eco-Management and AuditScheme (EMAS) was made available in 199525 as atool for companies and other organisations toevaluate, report and improve their environmentalperformance. The European Commission hasrecognised ISO 14001 and its European counterpart,EN ISO 14001, as establishing a specification forenvironmental management systems correspondingto its regulations.26

Both OGP and API have produced industry-specific guidance on the development of combinedsafety and environmental management systems.27,28

OGP has worked with UNEP to produce specificguidance on ‘Environmental Management in Oiland Gas Exploration and Production’.29 In addition,the IADC has developed guidance on thedevelopment of combined health, safety andenvironmental management systems for mobile

offshore drilling unit operations in the north-westEuropean region.30

Properly implemented corporate environmentalmanagement systems continuously challengemanagement to assess both current operations andnew endeavours to develop approaches that will helpthem achieve improved environmental performance,with or without the imposition of specific goals orstandards by regulatory bodies.

Compliance with regulatory standards can beimproved by a systemised process for identifying theapplicable standards, incorporating them intocompany policies and procedures, distributing themto operations personnel and providing appropriatetraining. For drilling contractors, this might bedifficult. Environmental permits or stipulations aregenerally issued to the operating company, can besite-specific and may be regarded as proprietary.Where such permits are in the public domain or aremade available to the contractor, an important issueis whether the contactor relies on the operatingcompany’s interpretation of the requirements or its own.

Adopting new or improved technology can be onemeans of improving environmental performance. Forexample, using slim-hole or expandable casingtechnology provides the potential for a well to bedrilled with the production of fewer cuttings andwith less total energy expended when compared witha traditional telescoping well design.

Unfortunately, these benefits can be offset by themore complex procedures required to drill such wells,the more complex well control situations that may beencountered and the potential for a longer period forreturn on investment because of lower productionrates in the smaller well bore. Similarly, diesel enginescan be fitted with selective catalytic reduction units toreduce emissions of certain pollutants. However, suchunits tend to reduce both fuel efficiency and theengine’s ability to respond rapidly to increased powerdemands. A drilling contractor may fit suchequipment to satisfy the demands of one client, onlyto find that subsequent clients do not wish to bear theincreased costs. For the contractor, this is difficult toreconcile with the goal of ‘continuous improvement’.

24. ISO 14001:1996, “Environmental management systems – Specification with guidance for use”. 25. Council Regulation (EEC) No. 1836/93 (29 June 1983).26. Decision 97/265/EC (16 April 1997).27. OGP (formerly E&P Forum), “Guidelines for the Development and Application of Health, Safety and Environmental

Management Systems”, 1994.28. API RP 75, “Development of a Safety and Environmental Management Program for Outer Continental Shelf Operations

and Facilities”, Second edition, July 1998.29. OGP (formerly E&P Forum), “Environmental Management in Oil and Gas Exploration and Production”, 1997.30. IADC North Sea Chapter, “North West European HSE Case Guidelines for MODUs”, August 2002.40


S tandards for Of f shore Dr i l l ing

Revising operational procedures to improveefficiency can also improve environmentalperformance, for example the use of sharingagreements to obtain greater efficiency in the use ofaircraft and supply vessels, or eliminating ‘standbyboats’. However, the cost, in terms of responsivenessor safety, may be unacceptable either in terms ofoperations or to the regulator.

Environmental management systems also challengemanagement in other ways. Prescriptive regulatorystandards may relieve management of difficultdecisions on comparative benefit. Regulatorystandards tend to be ‘stovepipe’ standards, i.e. theytarget environmental ‘benefits’ in one specific area,having already determined that potentially adverseimpacts in other areas need not be considered, orsimply ignoring such impacts. For example,prohibiting seabed disposal of drill cuttings solvesperceived location-specific water quality problems;however, it requires that another disposal site beidentified, that the cuttings be stored, handled and transported to that site (with the attendantsafety concerns, energy usage and potential forspillage) and, ultimately, the disposal at the chosensite be mitigated.

Operating under an environmental managementsystem, management is charged with deciding onthe comparative benefits of the possiblealternatives, with the potential of subsequentlybeing asked to justify its decisions to shareholdersor others with interest in the management system.Shareholders and others may also wish to evaluatethe environmental performance for specificoperations or activities or compare the company’senvironmental performance with that of its peers.Some of the multinational oil producers who havereported their environmental performancepublicly have already come under pressure todisaggregate their data so that their performancecould be examined in specific areas. While thedrilling contractor and its equipment andpersonnel clearly will impact the environmentalperformance of a particular operation, theoperating company’s commitment to improvingenvironmental performance will have a far greaterimpact. The operating company not only selectsthe contractor, but generally dictates the design ofthe well and the materials to be used in itsconstruction.

Only the operating company can effectively makecomparative assessments of the environmentalimpact of one development project against anotheron either a regional or global basis. Ultimately, it isthe environmental ethic of the operating companiesthat will drive environmental performance in thedrilling industry. ■

ENHANCED GRIPPING WITH LESS CASING CONTACT

Want to optimize

WIRELINE TRACTOR PERFORMANCE?

Now you can with a

bi-directional ‘smart’ crawler

tractor from SmarTract

REALTIME MONITORING & CONTROL

- optimization of speed & force

- cablehead tension

- uses standard wireline cables

- up to 1,000 lbs reverse force

REDUCED RISK

PROVEN EXPERIENCE

- 2 ” tubing to 9 ” casing & drillpipe

- a Gulf of Mexico tractor depth record holder

- an ERD probable world record holder

- helicopter portable

LIGHTWEIGHT & MODULAR

COST SAVING EXAMPLES USING SMARTRACT CRAWLER

- cement bond log: 5 hours vs. 25 hours on drillpipe

- sump packer: 12 hours vs 36 hours on drillpipe

- fishing: 5 minutes bi-directional force vs. 7-10

days rig mobilization and conventional fishing

- plug setting: entire job (dock to dock) of 30 hours

vs. 5-6 days with coiled tubing

To learn more about SmarTract technology and

how it can help you, visit our web site at

www.smartract.com or call our Houston or

Aberdeen offices.

www.smartract.com U.S. 713-952-3479

[email protected] U.K. (0)1224 343658

2904 Rodgerdale

Houston, TX 77042

Production

Logging

Perforating

Fishing

Seismic Data

Acquisition

Plug Setting

Cement Bond

Logging

Pipe

Recovery

7/8

5/8


Documents

Environmental Stds for Offshore Drilling