NEL Produced Water & Environmental Conference

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1 NEL Produced Water & Environmental Conference Safina Jivraj, Environmental Skills Group Manager (London) 20 th November 2013, Kuala Lumpur

2 Genesis In operation for 25 years, Genesis is an O&G consultancy, offering a full service engineering portfolio from early phase consultancy through to FEED & detailed design. With a workforce of over 1450 worldwide, a global lnetwork of 11 offices spanning six continents, t our team of multinational, multidiscipline engineers are strategically located, where our clients need us this includes Kuala Lumpur. Genesis is committed to providing excellence to our Clients by offering a complete range ofenvironmental consultancy including environmental engineering solutions in design. Supporting our clients from cradle to grave, Genesis is a One Stop Shop utilising the skills and expertise of trained personnel who participate in compliance management, engineering design support and environmental modelling in house (to support decision making & demonstrate regulatory compliance). 2 Genesis Environmental Capability

3 AGENDA Environmental Challenge Legislative Safeguards Risk Based Approach Implication on Industry Operator Obligation Service Provider Offering Examples Conclusions 3

4 ENVIRONMENTAL CHALLENGE Fate and Effect of produced water are of growing environmental concern Produced water is the largest effluent associated with offshore oil and gas production In 2010 global production rates of produced water exceeded 50% (OGP). In the UKCS this figure reached over 130% (between ) (UKO&G). Witha number ofworldwide fields coming to end offieldfield life and volumes released increasing, regulators are increasingly more vigilant over safeguards But what is produced water? 4

5 Produced water is made up of formation water and injection water used to enhance oil and gas recovery, which assists in driving oil and gas to the surface. 5

6 Produced Water is disposed of in several key ways Injection back to source reservoir Injection to other sub-surface formation Discharge overboard into the sea Due to cost and operational factors the most common route for disposal is to sea but why the concern? 6

7 Produced water contains a variety of components Dispersed HC Suspended oil Non polar (BTEX, PAH..) Cr, Hg, Cd.. Disolved HC Metals Particulates t Produced Water Suspended Solids Production Chemicals Radioactive Material Polar HC Radon, Radium.. Discharge to the environment has the potential to cause harm to marine organisms 7

8 PERCEPTION OF RISK Dissolved fractions are more bio available than dispersed Biota are able to uptake HC components (BTEX, Phenols, PAHs) which are toxic Production chemicals (polar) can persist and have long term impacts on marine organisms But to understand the process of harm, its important to know: A component must be bio-available and toxic at the discharge concentration to have a harmful effect 8

9 LEGISLATIVE SAFEGUARDS The OSPAR Convention for protection of Marine Environment is the instrument for regulating international cooperation It is signed by 15 nations (members of the EC and the UK) OSPAR has been pushing the agenda for protection of marine environment since its formation Over the past 5 years, OSPAR has been formulating recommendations for taking a Risk Based Approach, taking a more holistic view to produced water discharge. 9

10 Current Legislative Safeguards Current Performance Standards in the UKCS Dispersed oil: 30mg/l oil in water (which does not adequately address dissolved components) Harmonised Mandatory Control Scheme (HMCS) for use and discharge of Production Chemicals, requiring substance level toxic pre-screening. Guiding Principles UKCS Approach to achieve the Performance Standard involved application of : Best Available Techniques (BAT) Best Available Practices (BEP) So what is changing? g 10

11 OSPAR RECOMMENDATIONS In 2008, in support of the EC TGN on Risk Assessments for new substances, OSPAR looks at the opportunityto to implement RBA in produced water management A decision was made to meet its existing goals of 2001/01: Reducing oil and other substances into the sea Ensure an integrated approach was adopted Give priority to actions related to the most harmful components of produced water OSPAR Recommendations 2001/01 also has a zero harmful discharge target by Is RBA the ticket? ik 11

12 THE UK POSITION Current regulations already give DECC the power to request reasonable information under theeiaregs andoffshore Chemical and Oil Pollution Prevention and Control regs., however: The UK have submitted implementation plans to the OSPAR Offshore Industry Committee 2013 which have been accepted. RBA proposals to UK operators and UKO&G are yet to be agreed and finalised. So what is the Risk Based Approach? 12

vary amongst users, the basis is universal: To reach a

proposal combines: a Whole Effluent Assessment (WEA) a

Predicted No Effect Concentration (PEC/PNEC) approach on

13 Risk Based Approach Fig. 1 Risk Based Approach Although the definition for RBA may vary amongst users, the basis is universal: To reach a level of zero harmful discharge from produced water The proposal combines: a Whole Effluent Assessment (WEA) a complementary tool which looks at whole effluent testing a EIF (Env. Impact factor) = Predicted Environmental Concentration / Predicted No Effect Concentration (PEC/PNEC) approach on all and every substances identified in the produced water. As such it is a preservative measure, which has the advantage of being clear and consistent. 13

14 The development of EIF is guided by the principle, that areas of uncertainly should be resolved in favour of protecting the environment, therefore assumptions can sometimes be conservative. 14

15 The EIF method is not designed to serve as an estimator of impact, rather a measure of environmental risk that can be used to compare benefits of alternative management strategies. 15

16 ENVIRONMENTAL IMPACT FACTOR (EIF) EIF is expressed by comparing PEC/PNEC A ratio of PEC/PNEC = 1 presenting a 5% risk of harm is widely acceptedasa as a tolerable effect Therefore if PEC > PNEC, there may be a risk of ecological harm Similarly if PEC < PNEC, the risk of harm is acceptably near zero isk ronmental of Injury Injury (%) Probability Percentage of Envi ri Ratio PEC/PNEC of PEC/PNEC Ratio Fig. 2 PEC/PNEC Ratio verses Environmental Risk 16

17 PREDICTEDNO EFFECT CONCENTRATION (PNEC) PNEC is an estimated lower limit of effect on marine biota for a single component The values are derived from toxicity testing EC50, LC50 and NOEC for naturally occurring components HOCNF scheme for production chemicals An assessment factor is applied to Fig. 3 EU TGD requirements for PNEC derivation PNEC to counter uncertainty in the value. Expected PNEC = PNEC/Assessment factor 17

18 PREDICTEDENVIRONMENTAL ENVIRONMENTAL CONCENTRATION (PEC) PEC is obtained by dispersion modelling PEC should ldbe determined dt dwithin the water column, at a defined dfi d distance from the installation Concentration fields can be 1D, 2D, or 3D, but must demonstrate an over estimating and be validated using field trials 18

19 Implication of RBA on UK Industry DECC have been formulating a 4 tiered approach Stepwise process to screen installations by risk DECC is to provide Operators an overview of how the process will be applied with examples Operators to review and agree with proposals prior to fully implementation What has been the Norwegian experience? 19

20 NORWEGIAN APPROACH A pioneer in adopting the RBA for Produced Water Management Operators are obliged to report their annual EIF Norwegian Regulators use this information to assess where improvements can be made EIF G ullf aks C Gullf aks A Snorre A Statfj tfjord C Oseberg felt eltse nter He idrun No rne S tat atfjord A Statfjord B Visund Troll B Ve slef rikk Ose berg C Troll C Sleip eipner T Huldra Sleip eipner A Varg Gullfaks B Brage Åsgard B Åsgard A Yme Njord Tro ll A 20

21 OPERATOR OBLIGATION Adoption of RBA will become increasingly important within an Operators strategic planning. Potential for increased monitoring and reporting Project lenders may require ventures to demonstrate zero environmental harm as a measure of lending risk. Re negotiation of terms with leased FPSO s providers to accommodate change toward RBA. Deck space constraints to accommodate produced water abatement kit, adding topside weight and capex. Substituting production chemicals which may be more costly or which the operator has limited prior experience. Clear guidance is needed by Regulators to ensure successful alignment 21

22 SERVICE PROVIDEROFFERING OFFERING Much can be offered to support the introduction of RBA, from permit support, sampling, assessment andmonitoring monitoring, annual reporting. I will focus on RBA and how it can be used in early design consideration. Examples that follow, demonstrate some work that has been undertaken in this area. It s important to note that in certain scenarios no additional consideration is necessary beyond modelling. 22

23 This could be a result when produced water discharges are lowand the environmental risks rapidly disperse to <5% at the normal operating release which can be reflective of a highly dispersive environment 23

24 RBA EXAMPLES At other times, abatement technology may be necessary to remove undesirable water dissolved components such as aromatics, heavy metals and polar hydrocarbons which are bioavailable. RBA can allow Operators and Service providers to understand which primary components are contributing to a high EIF providing the opportunity to mitigate in design. PW EIF Mass Balance for Base Case 0% 0% 0% 0% 5% 10% 25% Dispersed oils (EIF heptan) BTEX PAH1 Phenol 1 7% Disolved HC 53% KI3821 Scaletreat 8063 Courtesy of D.T. Meijer and C. Madin [9] 24

25 EIF USED IN BAT ASSESSMENTS a b Fig. 7 a/b- EIF use in BAT Assessments 25

26 STEP WISE REDUCTION EIF Epcon installed, Discharge of biocides reduced, Application of H 2 S scavengers optimised New H2S scavengers New Epcon installed EIF of from components in Produced Water following Risk Management initiatives 2% 6% 7% BTEX 25% Naphthalene 8% 29% 14% 1% 8% 2 3mg PAH 4+mg PAH Pheols Aliphaphics H2S Scavenger Corroson Inhibitor Other chemicals Improved separation YEAR BTEX= benzene, toluene, ethyl benzene and xylene; PAH= Poly cyclic aromatic hd hydrocarbons Courtesy of Statoil [12] Fig. 8- Mass Balance of Components Contributing to the EIF 26

27 PEC CHEMICAL BASED ANALYSIS Chemical concentrations after 30 days continuous release (summer) BTEX MEG Corrosion inhibitor Scale Aliphatic inhibitor hydrocarbons Date: 19/03/13 27

28 EIF CHEMICAL BASED ANALYSIS Environmental risk Gyptron SA3220 (scale inhibitor) 0.00% Aliphatic hydrocarbons 0.06% BTEX 0.30% MEG 0.02% BTEX MEG Cortron RN 537 (corrosion inhibitor) Cortron RN 537 (corrosion inhibitor) 99.62% Gyptron SA3220 (scale inhibitor) Aliphatic hydrocarbons EIF Time (days) Date: 19/03/13 Fig. 10 Primary contributor to EIF 28

29 EIF COMPONENT ANALYSIS 29

30 EIF COMPONENT ANALYSIS 100ppm Corrosion Inhibitor (RN-537) Max EIF = 47 Minor contributions omitted for clarity 30

31 EIF COMPONENT ANALYSIS 10ppm Corrosion Inhibitor (RN-537) Disperse d oil 5.07% RN537_D 0.59% SA3220_C 0.05% BTEX 56.17% MEG 1.08% SA3220_A 0.04% SA3220_B 0.00% RN537_B 37.00% Max EIF = 8 RN537_B BTEX Dispersed oil MEG RN537_D SA3220_C SA3220 0_ A SA3220_B Minor contributions omitted for clarity 31

32 EIF COMPONENT ANALYSIS summary Using chemical component data rather than chemical summary data, risk is considerably reduced At 800ppm RN 537, maximum EIF =800 At 100 ppm RN 537, maximum EIF = 47 At 10 ppm RN 537, maximum EIF = 8 The above levels are consistent with reported values from existing assets in other parts of the world where improvements have already been made Main risk stems from N,N Didecyl N,N dimethylammonium Carbonate due to very low toxicity value Any further mitigation should still focus on concentration of RN 537 in discharge, or the behaviour of N,N Didecyl N,N dimethylammonium Carbonate to demonstrate Best Available Techniques have been used to minimise impact 32

33 CONCLUSIONS RBA offers a process of good operator stewardship and a mechanism to deliver consistent environmental performance DECC have yet to decide the final format for implementation of RBA It is important that this strategy provides clear guidance on how RBA is to be implemented to ensure its success Operators a strategy for RBA is crucial so that pre investment needs can be assessed A risk management tool such as DREAM with a proven track record will be useful to Operators in PW cost benefit analysis & risk reduction strategies Service providers can use RBA in project planning and therefore it is important to begin offering such support to Operators early in facility design to gain deeper understanding on abatement technologies (merits and demerits) or simply, used for better production chemicals selection. RBA are you ready! 33

34 Ms. Safina Jivraj Environmental Skills Group Manager - London safina.jivraj@genesisoilandgas.com Tel.: Fax:

The Environment Impact Factor (EIF) for produced water discharges a tool for reducing environmental impacts

The Environment Impact Factor (EIF) for produced water discharges a tool for reducing environmental impacts H. Rye 1, M. Reed 1, M. Kristin Ditlevsen 1, S. Berntsen 2 & E. Garpestad 2 1 SINTEF Applied