by Jonathan Wills, M.A., Ph.D., M.Inst.Pet.,
for Ekologicheskaya Vahkta Sakhalina
(Sakhalin Environment Watch); 25th May 2000
The Law on Offshore Wastes Discharges in Different Jurisdictions
The Norwegian State Pollution Control Authority (SFT) regulates the use of drilling fluids/muds through discharge permits. Water based muds are tested under OSPAR formats for bio-accumulation potential and bio-degradability and given a discharge permit if judged to be environmentally friendly. Synthetic muds are similarly evaluated and can be given a discharge permit according to their properties, but at present discharge of SBMs is not allowed north of the 62nd parallel. All oil-based muds are injected or taken to shore for treatment. The discharge of solids containing more than 1% oil, by weight, is forbidden - whether the drilling fluid is water-, oil- or synthetic-based.
There is a specific prohibition on the discharge of "pipe dope" - compounds used to join sections of drill pipe, which often contain high proportions of lead and other heavy metals. The regulations also deal explicitly with well testing, workover and cementing -notoriously polluting procedures:
Discharge of oil to water during well testing in addition to discharge via the process plant, is prohibited. Separation fluid contaminated with oil may not be discharged.
The operator must assess and where necessary choose disposal solutions other than burning of the fluid phase in the well stream during well operations (well cleaning, testing, workover, etc.).
The operator shall consider measures that can reduce the discharge of excess cementing chemicals during cementing work, e.g., by choosing methods of disposal other than discharge of the excess or adapt the equipment and routines with a view to minimising the excess volumes.
Norwegian regulations (See: 1. Norwegian State Pollution Control Authority [SFT]. 1998. Requirements for Ecotoxicological Testing and Environmental Assessment of Offshore Chemicals and Drilling Fluids. SFT, Oslo; 2. Norwegian State Pollution Control Authority [SFT]. 1999a. Environmental Monitoring of Petroleum Activities on the Norwegian Shelf; Guidelines 99:01. SFT, Oslo; 3. Norwegian State Pollution Control Authority [SFT]. 1999b. Pollution Control Act, 1981. SFT, Oslo) are just as detailed and specific as those in the UK, but requirements appear to be more stringent and enforcement more rigorous, although there is still considerable reliance on self-regulation and self-reporting by the industry. As of 1 Sept. 1998, Norway's general conditions for permits to discharge offshore (in addition to specific requirements for each installation and/or field) included the following:
- A 40mg/l limit for oil in discharged water, averaged over a month, with a specific prohibition on diluting produced water before a sample is taken for analysis. This appears to suggest that such pre-sampling dilution may have been a problem in the past.
- Water and mud purification plants to be operated to "optimum environmental effect" - in other words, if the equipment makes it possible to do better than the official standard, then that is what should be done.
- Detailed specifications for sampling and laboratory analysis of samples - including "parallel samples" sent to independent laboratories, as a check on the validity of the operator's own testing.
- Annual, independent assessment of each operator's sampling and analytical techniques.
- Detailed records of the quantities of produced water discharged.
- On-line analysers for oil in water are compulsory, with spot checks on parallel samples five times a month, to check that the on-line equipment is properly calibrated.
- Independent samples, once a week, of produced water re-injected.
- Separate sampling and analysis of aromatic hydrocarbon components in produced water, again with parallel samples for independent, monthly checks by infra-red equipment.
Norway uses the standard OSPAR "A" and "B" lists for offshore chemicals and requires that discharge of these "shall be reduced as much as possible, e.g., through recycling". Operators are required to ensure the purity of the substances they use, with minimum contamination by other chemicals. Discharge of unused chemicals into the sea is expressly forbidden, even if they are on list A or B and their toxicity is therefore well known. All discharges must have a permit and chemicals not on the lists must be separately tested and notified.
The following tables show the A & B lists of offshore chemicals currently permitted in Norway, which is generally considered to be the most stringent regulatory environment in the OSPAR countries:
Table 4: SFT List A chemicals
|Acetic acid||Aluminium silicate|
|Aluminium sulphate ||Ammonium acid phosphate|
|Ammonium bisulphate|| Ammonium chloride|
|Ammonium hydroxide ||Ammonium sulphite|
|Amylase (25%)/amlylopectin polymer (75%) (only as a preservative for pregelatinised starch with a maximum concentration of 5%)*)|| Ascorbic acid|
|Attapulgite clay|| Barite with lowest levels of trace metal impurities (weighting agent)||
|Barium sulphate ||Bentonite (weighting agent)|
|Butanol|| Calcium bromide||
|Calcium carbonate (weighting agent)|| Calcium chloride|
|Calcium hydroxide ||Calcium lignosulphonate|
|Calcium nitrate|| Calcium oxide|
|Calcium sulphate ||Calcium phosphate|
|Carboxymethyl cellulose ||Carboxymethyl hydroxyethyl cellulose|
|Causticized lignite ||Cellulase|
|Cellulose fibre ||Cement grade G|
|Citric acid ||Cornstarch|
|Cotton seed hulls ||Diatomaceous earth|
|Dicalcium silicate||Dolomite (weighting agent)|
|Ethanol (rendered undrinkable) ||Ethyl cellulose|
|Ferric sulphate ||Ferrous carbonate|
|Finely divided iron oxide|| Formic acid*)|
|Glass beads ||Glycerine|
|Graphite|| Guar gum|
|Gypsum|| 2-Hydroxyethyl ether cellulose|
|Hydroxyethyl cellulose ||Hydroxypropyl Guar gum|
|Ilmenite (weighting agent) ||Iron carbonate|
|Iron lignosulphonate|| Iron oxides (weighting agent)|
|Lightly calcined magnesium hydroxide|| Lightly carbonated magnesium hydroxide|
|Magnesium chloride|| Magnesium hydroxide|
|Magnesium oxide ||Manganese tetraoxide (weighting agent)|
|Olive pits ||Polysaccharide |
|Potash ||Potassium bicarbonate|
|Potassium carbonate ||Potassium chloride|
|Potassium nitrate ||Potassium phosphate|
|Pre-gelatinised potato starch|| Propanol|
|Pyrophosphate|| Silica gel|
|Silica sand|| Silicon dioxide|
|Soda ash|| Sodium acetate|
|Sodium benzoate|| Sodium bicarbonate|
|Sodium bisulphite|| Sodium borate|
|Sodium bromide|| Sodium carbonate|
|Sodium carboxymethyl cellulose (or CMC)|| Sodium chloride|
|Sodium lignosulphonate|| Sodium nitrate|
|Sodium nitrite*)|| Sodium phosphate|
|Sodium silicate|| Sodium sulphite|
|Sodium tetraphosphate ||Sodium thiosulphate pentahydrate|
|Sorbitol|| Starch (untreated)|
|Sugarcane molasses ||Tricalcium silicate|
|Vegetable fibre|| Vermiculite|
|Wood fibres|| Xanthan gum|
Table 5: SFT List B chemicals
|Acetone||Calcium Stearate |
|Diethyleneglycol|| Ferric chloride|
|Formaldehyde|| Glutaraldehyde |
|Hydrochloric acid|| Metasilicate |
|Potassium iodide||Potassium hydroxide |
|Phosphoric acid ||Sodium hydroxide |
|Sodium hypochlorite|| Triethyleneglycol|
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