The SPE Trinidad and Tobago Section recently hosted an Applied Technology Workshop (ATW) on oil and gas effluent discharge management in Port of Spain, Trinidad and Tobago.
The event brought together petroleum and petrochemical industry professionals involved in generating effluent discharges to the receiving environment, regulators, and those involved in the design, construction, operation, and maintenance of treatment systems for effluent discharge.
The goals of the workshop were to
- Explore regional and international legislation as applied to effluent discharge in the oil and gas industry and compare with the local regulatory framework in Trinidad and Tobago.
- Define the compliance issues of water pollution rules in Trinidad and Tobago specific to the oil and gas industry.
- Obtain the industry best practice for effluent treatment and disposal with emphasis on large oil and gas drilling and production operations both onshore and offshore.
- Explore the available technology and its applicability to achieve compliance.
There was a consensus that urgent collaborative action is needed among all stakeholders. The path forward received endorsement from the country’s regulators (the Ministry of Energy and Energy Affairs [MEEA] and the Environmental Management Authority [EMA]), operators, and service providers. The areas of focus in the workshop included legislative reform, use of applicable technology, and availability of resources.
Legislative Reform
Participants discussed the Trinidad and Tobago legislation pertaining to effluent discharges. There were also presentations on experiences setting effluent discharge standards in the North Sea using the Convention for the Protection of the Marine Environment of the Northeast Atlantic or OSPAR Convention, for possible use as a framework.
The topics of discussion about legislative reform centered on the following:
Are our current water pollution rules relevant and appropriately framed in the current environment?
The consensus was that there is an opportunity for the review of the current Water Pollution Rules created in 2001 and amended in 2006. For example, there is the need for ambient water-quality standards coupled with discharge standards. Current discharge standards were deemed to be stringent by some presenters compared with other jurisdictions such as OSPAR. OSPAR is using a holistic or risk-based approach in regulating effluent by the use of mixing zones and impact-based ambient water-quality standards vs. technology-based discharge parameters. To develop new ambient water-quality standards, a baseline study must be conducted on the receiving environment of Trinidad and Tobago.
Are our standards applicable to all sectors?
The discussions highlighted the need for industry-specific effluent discharge standards. There are different challenges and available technologies within the various industrial sectors that require specific regulations. The consensus was that one set of regulations is ineffective for all industrial sectors. The Trinidad and Tobago Bureau of Standards’ “Specification for the Effluent from Industrial Processes Discharged into the Environment” can be used in the development of oil industry-specific regulations.
Is compliance monitoring and reporting efficient and effective?
Participants suggested an opportunity for improvement with regard to compliance monitoring and reporting. Current environmental impact assessments focus on specific project sites (for example, a single well) rather than a cumulative assessment of an affected area. The use of strategic environmental assessments vs. specific environmental impact assessments under existing legislation should be considered.
How do we repair the disconnect between the certificate of environmental clearance (CEC) rules and water pollution rules?
Operators cited inconsistencies in recent CEC rules regarding which effluent discharge parameters are to be regulated. In the past, the CEC rules specified the effluent parameters to be regulated. In recent times, the rules require all parameters in Schedule II to be met, which may pose a challenge to attaining the goals with the existing technology by using the “end-of-pipe” discharge criteria.
Is there room for fiscal incentive for onshore and offshore operators?
Operators shared technical and financial issues associated with effluent treatment. With the retrofitting of offshore operations, for example, there are space restrictions, high cost of new technology, and logistical challenges. Bringing existing waste onshore for treatment also poses logistical and operational challenges. It was suggested that financial incentives be made available to operators for treating effluent closer to the source.
How can we speed the implementation of legislation?
Changing legislation can be a lengthy process in Trinidad and Tobago. However, representatives of the Bureau of Standards suggested that regulations may be used as a viable option instead of changing the legislation.
Should drill fluids and cuttings be regulated under the water pollution or waste management rules?
The discussions suggested that this is an area for further work because there were two aspects for consideration: offshore discharge and onshore treatment of drill cuttings.
Use of Available Technology
Participants gave presentations on existing and emerging technologies for effluent treatment by service providers. In summary, available technologies may be selected based on the quantification of toxic components in the effluent and treatment goals. There were presentations on the use of ceramic membrane technologies and macro porous polymer extraction (MPPE) technology as examples with international case studies in different regulatory regimes.
The MPPE case study was presented as an option for treating both dispersed and dissolved hydrocarbons in produced water streams with limited pre- and post-treatment requirements. A case study was also presented on the treatment and reuse of black and gray water for onshore drilling.
The following summarizes the discussions on technology:
- Best available technology should be used in the development of standards. Operators should indicate what technologies are currently in place and what can work through shared lessons learned.
- There is potential to reuse and recycle liquid effluent (produced water and onshore drilling waste water).
Availability of Resources
There were discussions about infrastructure challenges such as laboratory services and availability of human resources.
The following summarizes the discussions about resourcing:
- Laboratory accreditation. There is a requirement for the infrastructure to be available to support the legislation with regard to effluent sampling and testing. Attendees shared concerns with the repeatability of effluent test results provided by various laboratories in Trinidad and Tobago. There is an opportunity to improve laboratory testing and reliability of results through a coordinated quality assurance program by an appropriate body such as the Bureau of Standards.
- Human resources competency. There is a need for qualified and competent effluent treatment professionals at the operator and regulatory levels. Discussions revealed a gap in the competencies and skills of professionals. There is a need for specialists in industrial ecology and water treatment. Most of the local graduates are environmental management professionals. It was suggested that the local universities play a role by offering programs based on the needs of the industry.
- Staffing levels. A concern of regulatory bodies, the level of staffing needs attention to support legislation related to permitting and enforcement.
- Use of data resources. The EMA is the repository for all environmental data. It was suggested that these data be made available in a database to be more effectively used and incorporated into geographic information systems and mapping.
Recommendations
A committee and/or technical working group should be established to set the framework for managing future processes by incorporating the workshop’s recommendations. The group should be formally set up at a governmental level by a cabinet-appointed committee. Representatives of the committee and working group should comprise regulators, industry representatives, the Bureau of Standards, the Institute of Marine Affairs, environmental consultants, and service providers. A technical working group that was formed in 2013 should be expanded to include new focus areas explored in the workshop.
The terms of reference for the committee should be established to include targets and milestones. OSPAR, for example, has a template for which a covenant was signed by company leaders and regulators in environmental management.
The terms of reference should contain the following at a high level:
- Review of legislation and recommendations for changes and improvements
- Risk-based rather than end-of-pipe discharge standards
- Use of strategic impact assessments vs. environmental impact assessments
- Development of industry-specific water-quality standards (impact-based rather than parameter-based)
- Identification of best available technology and lessons learned for effluent management
- Laboratory accreditation standards
- Resourcing (increasing competency standards)
It is recommended that the MEEA be the lead facilitator of the working group because it regulates the country’s energy industry and is well poised to bring all stakeholders together.