by Jonathan Wills, M.A., Ph.D., M.Inst.Pet.,
for Ekologicheskaya Vahkta Sakhalina
(Sakhalin Environment Watch); 25th May 2000
Summary of Conclusions
1. It is legal, in most jurisdictions, to dump water-based drilling muds (WBM) and WBM-contaminated drill cuttings into the sea, if the dumper has a licence and meets certain conditions, such as reducing the oil content to a stated minimum. In North America and offshore Europe almost all discharges of oil-based drilling muds (OBM) ceased some years ago. The USA still permits synthetic-based drilling mud (SBM) discharges but these are currently being phased out in European waters.
2. The discharge of any drilling wastes into shallow, inshore waters, similar to the Sakhalin Shelf, is discouraged by European and North American governments and, in most areas, effectively banned.
3. Quantities of WBMs used are likely to increase, following the failure of SBMs to deliver expected environmental benefits, although the US has not yet accepted European arguments against SBMs.
4. Despite being less noxious than OBMs and SBMs, WBMs have ecological effects that may be more serious, widespread and prolonged than some industry sources would suggest. In particular, the effects of underwater plumes of extremely fine particles are not properly understood and may damage larval stages of commercial fish and shellfish.
5. WBM-contaminated cuttings usually contain additive residues of greater or lesser toxicity, whose exact chemical composition is often secret. These residues are not removed by most existing equipment on offshore exploration and production installations. Their effects on sealife, singly or in combination, are not fully researched. The precautionary principle should therefore apply.
6. Proven technology exists to re-inject and contain contaminated drill cuttings in underground reservoirs, either by installing equipment on each rig, platform or drillship, or by shipping the wastes to a port for onshore re-injection. Alternative disposal methods are available, such as treatment, recycling, incineration and/or landfill onshore. Sea dumping is environmentally damaging, technically unnecessary and, because of unquantified, long-term liabilities, may even be more expensive than offshore re-injection or onshore disposal.
7. Produced water from oil and gas installations can be a significant source of chronic oil pollution and usually also contains heavy metals, low-level radioactivity, traces of drilling fluid additives and poly-aromatic hydrocarbons. Its toxicity to sealife is proven and should be of at least equal concern to WBM-contaminated drill cuttings.
8. Technology also exists (and is almost universally used onshore) to re-inject almost all produced water - and also to clean it to much higher standards than currently apply, in practice, on European and North American offshore oilfields.
9. In the West, oil and gas corporations have generally co-operated with the regulatory process and have to some extent co-opted the regulators. They have influenced governments to modify the rules so that they take into account corporate financial concerns as much as, or more than, what independent environmental scientists would recommend, if not constrained by financial considerations. The Western oil and gas corporations operating in the Russian Federation may be expected to attempt to do the same - and will also exert political influence at a very high level to subvert the efforts by honest public servants to protect the environment. Russian officials, non-governmental organisations and the general public should be aware of and resist this insidious process, which can delay and weaken environmental legislation and enforcement.
10. Russia has an opportunity, on the Sakhalin Shelf, to set new world standards for environmentally benign offshore petroleum production, minimising waste discharges and establishing a rigorous but fair inspection regime to ensure full compliance - something most Western governments have so far failed to do.
Zero-discharge regimes - a personal view
This paper demonstrates that reducing drilling waste and produced water discharges from offshore oil and gas installations is desirable, technically achievable and, in most cases, economically advantageous. There is no technical obstacle, either, to reducing discharges to zero, using modern re-injection, re-cycling and "closed-loop" drilling and waste treatment/disposal systems. Where geology presents insuperable problems for re-injecting wastes, there are other means of dealing with them, such as shipment ashore for processing and disposal. To a great extent, this already happens in countries such as Norway, Denmark and the Netherlands, where electors expect their politicians to deliver on environmental pledges - and punish them at the polls if they do not.
The author is not impressed by arguments about the supposed "non-water quality environmental impacts" of shipping wastes ashore, particularly the oil industry's vaunted concern about the air pollution from increased energy use by the vessels, road vehicles and industrial plant involved in the process. Unlike the widespread, chronic, subtle and poorly-understood effects of marine pollution, these atmospheric emissions can easily be compensated for by reduced flaring offshore and by other energy-saving and pollution-reduction measures that the oil industry and its client governments could implement if they were so minded. The case advanced by the industry, in its discussions with the US Environmental Protection Agency over SBM discharges, and with the OSPAR countries over the disposal of North Sea drill cuttings piles, appears specious and motivated more by economic self-interest rather than environmental concern. If the industry can reduce to zero its waste discharges to the sea, then that is exactly what it should be told to do.
The role of governments is to enforce reduced- or zero-discharge regulations firmly and fairly, so that there is a true "level playing field" where no corporation can gain financial advantage by dumping more or dirtier waste than its rivals. Too often, governments and international bodies such as OSPAR allow their officials to be enticed into interminable and ever more detailed technical discussions whose main purpose is to soften and dilute regulations, delay and obstruct compliance, and to confuse the public and their elected representatives. In this respect, the behaviour of the UK and US governments in particular is a cautionary tale rather than an example of how to be effective.
It is naïve to imagine, as both British and American politicians do, that a cosy relationship between industry and government can deliver effective regulation when, in fact, there are fundamental divergences of interest: the modern global corporation's financial structure is incapable of taking fully into account the long-term benefits of environmentally benign industrial activity, however "green-minded" individual executives may be; and the public, for whose environment elected governments act as trustees, cannot afford to allow short-term corporate financial objectives to obstruct desperately-need environmental improvements. Anyone who believes otherwise will suffer insuperable difficulties in understanding the relationship between industry, government and the environment. We do not necessarily need more conflict between regulators and the regulated but we do need a clearer definition of their respective roles. We also need more money and time spent on enforcement of the law. Private citizens are not allowed to negotiate with their rulers which laws they choose to observe and which they find it personally advantageous to break; nor should the oil and gas corporations be, even if they have become richer and more powerful than many of the governments they attempt to suborn and co-opt.
Russia's laudable efforts* to require minimal or zero discharges on the new Sakhalin Shelf oil and gas fields should be supported and extended, and may well turn out to be a model of fair, affordable, effective regulation, based on sound ecological science and the public interest.
That is, after all, what elected governments are supposed to do.
Jonathan Wills
Bressay, Shetland, Scotland ZE2 9ER.
25th May 2000
*Prior to the May 2000 presidential announcement of the proposed dismantling of the State Ecological Committee.
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