Service contract to support the Development of a BAT ...ec.europa.eu/environment/integration/energy/pdf/Background paper.pdf · BAT and BARM for upstream hydrocarbon exploration and

Service contract to support the

Development of a BAT reference document on upstream hydrocarbon exploration and production (Hydrocarbons BREF) Technical Working Group kick-off meeting background paper

September 2015

Amec Foster Wheeler Environment & Infrastructure UK Limited

3 © Amec Foster Wheeler Environment & Infrastructure UK Limited

Draft - see disclaimer

September 2015 Doc Ref. 36406

Contents

1. General information 5

1.1 Introduction 5

1.2 Project background 6

1.3 Purpose and content of this background paper 7

1.4 Before coming to the meeting 7

1.5 Objectives of the kick-off meeting 8

1.6 Time schedule for drawing up the Hydrocarbons BREF 8

1.7 Role of the TWG and of the contractor 9 The role of the TWG members 9 The role of the contractor is to: 9

2. Scope of the Hydrocarbons BREF 11

2.1 Introduction 11

2.2 Proposal for the scope of the Hydrocarbons BREF 11

2.3 Limitation on the scope and exclusions to be discussed at the kick-off meeting 15

2.4 Structure of the Hydrocarbons BREF and types of supplementary documents 15 Hydrocarbons BREF 15 Supplementary materials 16

3. Key processes and environmental impacts 18

3.1 Introduction 18

3.2 Key environmental issues 18

4. Identification of BAT and BARM 21

4.1 Information required on BAT and BARM (elements needed) 21

4.2 Process for identification of BAT and BARM 21 Overview 21 Identification of BAT for routine operations 21 Identification of techniques for risk management (BARM) 22

4.3 Format of conclusions on BAT and BARM 23

5. Data collection 29

5.1 Data collection process 29 Confidentiality 29

5.2 Information exchange – IT platform 29

Table 1.1 Proposed milestones for Hydrocarbons BREF 9 Table 3.1 Key environmental risks and impacts related to upstream onshore exploration and production 18 Table 3.2 Key environmental risks and impacts related to upstream offshore exploration and production 19




Figure 2.1 Scope of Hydrocarbons BREF boundary – offshore upstream production 14 Figure 2.2 Scope of Hydrocarbons BREF boundary – onshore upstream production 14 Figure 4.1 Categories of environmental risk management (RM) 22 Figure 4.2 Risk management process according to ISO 31000:2009 26 Figure 4.3 Example 1: An individual BAT conclusion that contains an associated emission level 27 Figure 4.4 Example 2: An individual BARM conclusion with an associated environmental performance level 27

Appendix A: Details of key activities undertaken for upstream hydrocarbon production installations Appendix B: Details of initial conclusion on risks for key activities (to prioritise key environmental issues) Appendix C: Possible table for scoring risk assessment approaches against ISO 31000




1. General information

1.1 Introduction

The European Union (EU) is currently facing challenges in domestic production of natural gas and crude oil, resulting in an increase in import dependency for these fossil fuels. In order to improve the security of energy supply, the EU is currently developing strategies for further diversification of its energy supply including the development of renewable and other indigenous energy sources1. Offshore operations are moving towards more technically challenging formations and environments and Member States are currently assessing the potential for the development of unconventional hydrocarbon sources using hydraulic fracturing, not only onshore but also offshore. There is also increased use of stimulation and enhanced recovery techniques in conventional activities, to maximise production.

On 28 May 2014 the Commission adopted a Communication on a European Energy Security Strategy2

that calls upon Member States to exploit, where this option is chosen, hydrocarbons (…) taking into account the decarbonisation priorities. This Communication also recalls that conventional oil and gas resources should be developed in Europe, both in traditional production areas and in newly discovered areas, in full compliance with energy and environmental legislation, including the Offshore Safety Directive 2013/30/EU3.

A number of pieces of both general legislation and environmental legislation apply to upstream hydrocarbon exploration and production from both conventional and unconventional sources at the EU level. As a complement to existing EU legislation, the Commission adopted a Recommendation4 on minimum principles for the exploration and production of hydrocarbons (such as shale gas) using high-volume hydraulic fracturing (HVHF). The Recommendation called on Member States to, inter alia, ensure that operators use best available techniques (BAT). Both the Communication on the exploration and production of hydrocarbons using HVHF5 and the Communication on energy security announced that the Commission would organise an exchange of information between Member States, the relevant industries and non-governmental organisations promoting environmental protection in order to identify the Best Available Techniques. The Energy Security Communication explicitly called for the development of a BREF for hydrocarbon exploration and production covering hydrocarbon development from both conventional and unconventional sources (the Hydrocarbons BREF). The Hydrocarbons BREF is intended to be complementary to the BREF on management of waste from extractive industries6 that is currently under review and will identify BAT for the management of waste from onshore hydrocarbon exploration and production.

The technical working group (TWG) established to draw up the Hydrocarbons BREF will hold its kick-off meeting from 13 to 15 of October 2015. The purpose of this background paper is to provide members of the TWG with an outline of the matters that are proposed for discussion at the kick-off meeting.

1 http://www.consilium.europa.eu/uedocs/cms_Data/docs/pressdata/en/ec/141749.pdf

2 http://ec.europa.eu/energy/doc/20140528_energy_security_communication.pdf

3 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:178:0066:0106:EN:PDF

4 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014H0070

5 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52014DC0023R(01)

6 http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1404484842400&uri=CELEX:32006L0021




Participation in the TWG provides an opportunity to demonstrate and 'showcase' the best environmental management practices already being applied in Europe and beyond in the industry.

Addressing public concerns and environmental impacts are key to the development of the sector. The Hydrocarbons BREF will address such issues for hydrocarbons exploration and extraction activities.

1.2 Project background

Amec Foster Wheeler Environment & Infrastructure UK Ltd (hereinafter the contractor) has been contracted by Directorate General Environment of the European Commission (hereinafter the Commission) under Contract No. 070201/2015/706065/SER/ENV.F.1 to support the development of a BREF on upstream hydrocarbon exploration and production.

The Hydrocarbons BREF will be able to be used as a reference by industry in the development of new and novel techniques by providing a clear picture of what can be considered BAT and BARM for the management of impacts and risks of hydrocarbons exploration and production.

The BREF will establish EU-wide BAT and BARM, based on an assessment of the most advanced industry practices, taking into account that companies have developed their own techniques and some of them have set themselves high safety and environmental management standards.

BREF is the abbreviation for Best Available Techniques (BAT) Reference document. BREFs summarise BAT already applied in a given industrial sector under economically viable conditions. As such, these reference documents reflect existing performance in the real world and so help to share a common understanding of high-level performance across different types of industrial activities. The overall objective of this contract is to support the Commission in the identification of the Best Available Techniques (BAT) and Best Available Techniques for Risk Management (BARM) for the upstream hydrocarbons exploration and production sector through the production of a Hydrocarbons BREF (hereinafter the Hydrocarbons BREF). This should assist licensing and permitting by competent authorities of Member States.

BAT in this context means:

‘the most effective and advanced stage in the development of activities and their methods of operation which indicates the practical suitability of particular techniques for providing the basis for emission limit values and other permit conditions designed to prevent and, where that is not practicable, to reduce emissions and the impact on the environment as a whole:

‘techniques’ includes both the technology used and the way in which the installation is designed, built, maintained, operated and decommissioned;

‘available techniques’ means those developed on a scale which allows implementation in the relevant industrial sector, under economically and technically viable conditions, taking into consideration the costs and advantages, whether or not the techniques are used or produced inside the Member State in question, as long as they are reasonably accessible to the operator; and

‘best’ means most effective in achieving a high general level of protection of the environment as a whole”.

BARM effectively sits within the definition of BAT above. The explicit reference to BARM, however, reflects on the significant focus that exists within the upstream hydrocarbons exploration and production sector in the implementation of measures to avoid and minimise effects on the environment resulting from incidents and accidents. This makes the identification of BARM a specific task under this project.

In undertaking this work, the purpose of the contract is to organise an exchange of information aimed at elaborating the content of a Hydrocarbons BREF which:




a) collects information on technologies and practices applied in the EU (and where insufficient experience is available in the EU, worldwide) in the hydrocarbon upstream exploration and production sector for onshore and offshore activities;

b) determines, where relevant, associated environmental and operational performance indicators;

c) takes into account the entire life cycle of a well/pad/concession site from the planning phase to the post-closure phase;

d) specifies, where relevant, environmental and operational monitoring needs;

e) assesses economics of the application of BAT and BARM for the sector;

f) proposes BAT and BARM.

The Technical Working Group (TWG) will take the form of an informal expert group comprised of representatives of the Member States; industries concerned with hydrocarbons exploration and production, including equipment and material suppliers and service providers; and non-governmental organisations promoting environmental protection and safety of workers. The TWG will be involved in the exchange of information highlighted above and is the primary audience of this background paper.

1.3 Purpose and content of this background paper

This background paper has been prepared by the contractor and lays down the issues proposed for discussion at the TWG kick-off meeting. It outlines the Hydrocarbons BREF process and the proposed detailed scope of the BREF and is supplemented by a strategy for data collection and a proposal for priorities for the elaboration of the BREF.

Although it is recognised that many members of the TWG may already have views on what constitutes BAT and BARM for upstream hydrocarbon exploration and production, at this first TWG meeting the intention is to focus on agreeing the scope of the Hydrocarbons BREF and on the type of information that the TWG members can provide to assist in the determination of BAT and BARM.

Section 2 of this paper contains a proposal for the scope of the Hydrocarbons BREF. In section 3, a proposal for the scope of the processes and operations is presented and the key environmental issues are identified; these will be the basis for the technical descriptions to be included in the Hydrocarbons BREF. Section 4 presents the range and type of data needed in order to reach conclusions on BAT and BARM.

Proposals which are to be discussed at the kick-off meeting are set out in a box within the document. It is expected that the kick-off meeting will provide the basis for discussing and agreeing the scope of the Hydrocarbons BREF, and the key environmental issues to be covered.

1.4 Before coming to the meeting

Please take note of the following advisory actions for you to complete before attending the kick-off meeting:

1. If you believe that issues other than those included in this background paper need to be discussed at the kick-off meeting please address your request for inclusion to [email protected] by Friday 2 October 2015. Such a request must also include a justification / rationale for each new item proposed. These suggestions will be discussed at the kick-off meeting;

2. Essential background reading – It is recommended that each TWG member read and familiarise themselves with the contents of:

a. this background paper;

b. the strategy for data collection; and




c. the proposals for priorities for the Hydrocarbons BREF; and

3. Consider the types of information you hold related to BAT and BARM that you could bring to the information exchange process and prepare to indicate as such during the meeting.

1.5 Objectives of the kick-off meeting

The kick-off meeting will initiate the information exchange process, by facilitating discussions of the proposals raised in this background paper together with any further issues that are raised in the meeting.

The success of the kick-off meeting and the decisions made will rely heavily upon input from attendees, and it is therefore important that all attendees consider the matters raised in this paper carefully, prior to coming to the meeting, so that they can raise questions and make suggestions during the meeting.

The TWG is a technical group and the discussions to be held at its meetings will be technically related to offshore and onshore exploration and production of hydrocarbons. It is not a forum for discussion of political or procedural issues related to current or future EU policy. Consequently, attendees should understand, in general, the technical matters related to this subject.

The aims of the kick-off meeting are included in the following list:

To get to know each other as members of the TWG and to share experiences and information.

To discuss and agree upon the scope of the Hydrocarbons BREF.

To discuss and agree upon the structure of the Hydrocarbons BREF.

To determine the main environmental issues and risks that the Hydrocarbons BREF will focus on.

To discuss and agree on the data collection process, types of data/information that are needed, and to identify specific contributors for these data/information.

To present the tools that the TWG will use to collect, exchange and analyse information. In particular, the internet based platform will be presented to the TWG.

To clarify issues concerning confidentiality of information submitted by TWG members.

To agree on a general timeframe for the work.

As a result of the kick-off meeting, the process for drawing up the Hydrocarbons BREF will be clarified so that the TWG and Amec Foster Wheeler can be assigned clear tasks.

During the kick-off meeting, the discussions will be kept general, and will not include in-depth technical debates. For example, deciding whether a particular technique is BAT or BARM will not be discussed at this stage, as answers to questions of this nature need to be informed by the subsequent data collection exercise.

1.6 Time schedule for drawing up the Hydrocarbons BREF

The work flow includes two plenary TWG meetings. Between these meetings two formal drafts of the Hydrocarbons BREF will be presented to the TWG for comments. The overall process is scheduled to take 35 months. The milestones are as follows:




Table 1.1 Proposed milestones for Hydrocarbons BREF

BREF development step Specific milestones for Hydrocarbons BREF

1 Kick-off meeting of TWG 13-15 October 2015

2 Questionnaire for data collection (if required) January 2016

3 Information gathering A deadline for providing information will be set at the kick-off meeting. The beginning of September 2016 is suggested.

4 First draft of the Hydrocarbons BREF February 2017

5 TWG comments April 2017

6 Elaboration of 2nd Hydrocarbons BREF October 2017

7 TWG comments December 2017

8 Elaboration of final draft of the Hydrocarbons BREF for TWG meeting

March 2018

9 Final meeting of TWG April 2018

10 Elaboration of final version of the Hydrocarbons BREF

June 2018

1.7 Role of the TWG and of the contractor

This section aims to provide a general overview of the role of the TWG and the contractor (Amec Foster Wheeler).

The role of the TWG members

The TWG members should be prepared to

collect, verify and assess targeted technical and economic information on exploration and exploitation of hydrocarbons and to identify best practices in the EU (and where insufficient experience is available in the EU) worldwide;

Provide feedback on the draft Hydrocarbons BREF;

propose and verify the analysis of candidate techniques for BAT and Best Available Risk Management Practices.

TWG members should be prepared to actively participate in this exchange of information process that will be the core activity of the group.

Apart from the kick-off meeting, the group will have a Final meeting in May 2018 which will resolve outstanding issues of the exchange of information with a view to concluding the technical discussions within the group.

In addition to the meetings of the group, meetings of subgroups on the basis of a mandate issued by the Commission might be convened on an ad-hoc basis.

The role of the contractor is to:

Collect, verify and assess information on exploration and exploitation of hydrocarbons, identify best performing installations in the EU (and where insufficient experience is available in the EU, worldwide).




Interact with the TWG on information to be provided by the TWG. If TWG members provide incomplete or insufficient information, the contractor will ask the TWG for completion.

Visit installations to gather and validate information for drawing up the BREF, if and where necessary; this may involve visits by Amec Foster Wheeler to installations in different EU Member States and outside the EU.

Identify candidate techniques for BAT and BARM.

Treat information that is not available in the public domain as confidential if this is requested by the TWG. Information collected will only be used for the purpose of elaborating the Hydrocarbons BREF.

Prepare all drafts of the Hydrocarbons BREF as well as the final Hydrocarbons BREF.




2. Scope of the Hydrocarbons BREF

2.1 Introduction

The Hydrocarbons BREF, will be a non-binding BREF for the permitting of installations for the exploration and production of hydrocarbons.

The overall scope of the Hydrocarbons BREF covers environmental impacts and risks of upstream hydrocarbons exploration and production activities and should address the entire lifecycle of extraction of natural gas and crude oil in all phases of a project. In particular, the Hydrocarbons BREF should address activities with current or likely future relevance in the EU which may pose a potential environmental or human health concern, including major accidents. The Hydrocarbons BREF will be compatible with, and complementary to, the risk management framework of the Offshore Safety Directive.

The Hydrocarbons BREF should identify:

BAT to manage the impacts (i.e. prevention or mitigation of releases of pollutants during normal operations of an installation);

Best Available Risk Management (BARM) Practices (e.g. for releases of substances to the environment as a result of unplanned incidents that are not part of normal operations or for seismic events).

2.2 Proposal for the scope of the Hydrocarbons BREF

Geographical coverage

Depending on the geographical location of the facilities, the upstream exploration and production of hydrocarbons can divided into onshore and offshore facilities. Some processes and technologies are the same in onshore and offshore facilities but there are also differences which lead to different potential risks and impacts.

Proposal 1

It is proposed that the scope of the Hydrocarbons BREF will cover:

Activities within the European Union;

Onshore facilities;

Onshore activities that are covered by the ‘Management of waste from extractive industries’ BREF will be excluded from the scope;

Offshore facilities.

It is proposed that the Hydrocarbons BREF does not duplicate activities covered by other BREFs e.g. for Large Combustion Plants, Management of Waste in Extractive Industries, Waste Treatment.




Conventional and unconventional hydrocarbons

The oil and gas industry distinguishes between conventional fossil fuels (CFF) and unconventional fossil fuel (UFF). A universally recognised distinction between CFF and UFF is not available and the Hydrocarbons BREF will not seek to define these terms. Instead, it will focus on those activities, processes and environments with greatest potential for impacts and risks on the environment.

Whilst past EU exploration and production of hydrocarbons including natural gas have focused mainly on conventional resources, technological advances, in particular in the United States and, have opened up the possibility of extensive development of fossil fuels from unconventional reservoirs. While there is still considerable uncertainty as to their precise volume, reserves of unconventional fossil fuels in the EU are deemed significant.

Proposal 2

It is proposed to include both conventional and unconventional hydrocarbons within the scope of the Hydrocarbons BREF. More specifically it is proposed to cover the exploration and production of the following products (the end products themselves are relatively similar (oil/gas), it is more the geological formations / technique for extraction that differ):

Natural gas from:

Conventional sources;

Shale formations ("shale gas");

Low permeability reservoirs ("tight gas");

Coal-bed methane;

Oil from:

Conventional sources;

Tight oil.

Life-cycle stages

A number of studies have been undertaken on behalf of the Commission Services on the risks and impacts of upstream hydrocarbon exploration and production (and on possible measures to address these). These studies have characterised a number of stages across extraction which can be defined across the well and field lifecycle. In particular the AEA (2012) study on hydraulic fracturing in shale summarised six key stages as:

Stage 1: Site identification and preparation.

Stage 2: Well design; drilling; casing; cementing; perforation.

Stage 3: Technical hydraulic fracturing.

Stage 4: Well completion and management of wastewater.

Stage 5: Production.

Stage 6: Decommissioning.

Subsequent studies by Amec Foster Wheeler (with IPPE and Philippe and Partners) to look at all unconventional (and subsequently conventional) fossil fuels recognised that ‘hydraulic fracturing’ acted as an additional life-cycle stage compared to the conventional upstream production of oil and gas. On that basis for those operations that do not involve hydraulic fracturing five key life-cycle stages exist.




Proposal 3

It is proposed that the Hydrocarbons BREF will cover the following life-cycle stages:

Site identification and preparation (establish baseline environmental conditions, exploration);

Well design, drilling, casing and cementing;

Well stimulation including technical hydraulic fracturing, enhanced recovery (where relevant);

Well completion;

Production (oil and gas extraction);

Project cessation, well closure and decommissioning.

Boundaries of operations

Together with defining the lifecycle stages, the scope of operations that will be covered by the Hydrocarbons BREF needs to be defined. For offshore upstream exploration and production, operations may require the development of port facilities and oil and gas pipeline infrastructure. Such operations are considered outside the scope of the Hydrocarbons BREF as such operations are considered separately from the upstream oil and gas exploration and production process itself (e.g. port facilities are required by other types of industry such as ship building and offshore renewables). In a similar manner, the onshore upstream production methods might include only the development and operation of the production site and any onsite storage prior to product distribution.

Proposal 4

It is proposed that the scope of the Hydrocarbons BREF to be limited to the environmental risks and impacts associated with the upstream exploration and production of hydrocarbons from onshore and offshore conventional and unconventional hydrocarbons only.

It is proposed that the Hydrocarbons BREF does not cover any ‘downstream’ activities such as processing of crude oil and gas.

It is proposed that the techniques to be included in the Hydrocarbons BREF should under no circumstances lead to a reduction in safety of workers’.

Figure 2.1 and Figure 2.2 illustrate at a high level those processes and technologies covered within the scope of the Hydrocarbons BREF. All activities that occur outside of the red dotted lines are proposed to be excluded from the scope of the Hydrocarbons BREF.




Figure 2.1 Scope of Hydrocarbons BREF boundary – offshore upstream production

Figure 2.2 Scope of Hydrocarbons BREF boundary – onshore upstream production

Proposal 5

Regarding the scale of operations to be covered by the Hydrocarbons BREF it is proposed to cover all operations irrespective of the scale (e.g. production levels, water use etc.). However, the work will be focused on those operations with greatest potential for adverse environmental impacts and risks.




2.3 Limitation on the scope and exclusions to be discussed at the kick-off meeting

Issues that are covered by other BREFs are proposed to be excluded from the scope of the Hydrocarbons BREF. Where European legislation or International treaties (e.g. MARPOL) apply to the application of techniques related to BAT and BARM in the upstream exploration and production of hydrocarbons, the content of the Hydrocarbons BREF will be drafted in a manner that is complementary to such legal obligations. In this context the Hydrocarbons BREF may provide conclusions on BAT and BARM that assist in the implementation of such legal obligations.

Proposal 6

The scope of the Hydrocarbons BREF is proposed not to cover the following activities:

Waste from upstream onshore exploration and production activities that are covered by the MWEI BREF (management of waste from extractive industries);

Activities described in BREFs under Directive 2010/75/EU on industrial emissions (integrated pollution prevention and control)

Transportation by vessels or air transfer (e.g. helicopters);

Pollution from ships;

Activities subsequent to loading/unloading into vessels, subsea transport pipelines, etc.

Safety of work and workers’ health (save to the extent that worker safety should not be compromised).

2.4 Structure of the Hydrocarbons BREF and types of supplementary documents

As previously mentioned, the intention is for the Hydrocarbons BREF to be relatively short and to be supported by/refer to supplementary materials. The structure of the Hydrocarbons BREF and the type of supplementary documents is provided in the following sections.

Hydrocarbons BREF

Collection of all types of emissions data from every oil and gas installation would be a time-consuming exercise and, in the case of the hydrocarbons extraction sector, is unlikely to bring significant benefits to the drafting of the BREF.

Therefore the Hydrocarbons BREF will not provide a baseline assessment of emissions from all individual upstream hydrocarbon exploration and production facilities across the EU. Rather, the focus will be on the identification of the key environmental issues that exist in relation to such activities and to collect data on the types of BAT and BARM that are applied to address such issues, based on data from installations in the EU, and potentially elsewhere. The aim will therefore be to focus data collection at the level of installations to the most essential parameters needed to determine BAT and BARM.

Overall, the intention should not be to write a manual for upstream oil and gas production, but rather to identify the best available techniques for managing environmental impacts and risks, and to refer to examples of good practice where these already exist.

As a result, it is proposed that the structure of the Hydrocarbons BREF be concise in content.




The structure proposed for the Hydrocarbons BREF is:

Preface: legislative/ policy context and how information was collected and assessed.

Scope: description of activities covered by the document.

Conclusions: Sets out what are BAT and BARM for the sector based upon the information exchange. The chapter might also list techniques that are not considered BAT or BARM due to factors such as poor or non-credible environmental performance, lack of availability, affordability, technical and/or economic considerations for cross-media effects, or operational reliability.

Concluding remarks.

Glossary of terms and abbreviations.

Supplementary materials

General information about the sector concerned: numbers and production capacity of installations, geographical distribution, economics, key environmental issues, overall emission and consumption data.

Applied processes and techniques: description of processes and techniques currently applied in the life cycle of hydrocarbons projects intended for the upstream exploration and production of natural gas and crude oil.

Potential environmental risks: description of potential risks arising from upstream exploration and production activities, including unplanned events/ accidents, and risks arising from specific activities that vary amongst installations (e.g. chemicals used and waste management practices); review of statistical data on accidents and environmental damage.

Current emission and consumption levels: observed usage of energy, water and raw materials, emissions of key pollutants to air and water, generation of residues/wastes from the activities, emissions of noise and odour. (This and the preceding two chapters could be merged into a single chapter.)

Techniques to consider in the determination of BARM and BAT: catalogue of techniques for, and, if relevant, associated monitoring for:

Prevention and management of environmental risks from unplanned events/ accidents.

Prevention and management of environmental risks from wastes.

Preventing emissions to air, groundwater and surface water, soil and underground or, where this is not practicable, for reducing emissions (from normal operation).

Reducing the use of raw materials, water and energy.

Site remediation measures.

Measures taken to prevent or reduce pollution under other than normal operating conditions.

Emerging techniques: Describes the novel techniques identified for the sector.

Recommendations for further work.

References.




Proposal 7

To discuss and agree on the structure of the Hydrocarbons BREF based on the structure presented above.




3. Key processes and environmental impacts

3.1 Introduction

This section of the background paper covers the key processes and related environmental issues/risk that should be addressed by the Hydrocarbons BREF.

3.2 Key environmental issues

The contractor has reviewed the risks and risk mitigation measures relevant to conventional and unconventional hydrocarbons including stimulation techniques other than hydraulic fracturing. This review was based primarily on a number of studies undertaken for the European Commission, which in turn draw upon a wide range of different literature sources and industry expertise. Appendix B provides a summary of a (draft) categorisation and prioritisation of environmental issues relevant to onshore and offshore hydrocarbon exploration and production activities.

Based on that review, the highest risk/impact activities from upstream exploration and production of hydrocarbons are set out in the tables below. Many of these potential impacts are of course well-addressed by practices in existing and planned installations, and it is these practices that the BREF will seek to capture. (Note that the wording of the activities/processes concerned has been modified compared to that in Appendix B, to help with setting the scope of the Hydrocarbons BREF.

Proposal 8

It is proposed that the Hydrocarbons BREF should focus on identifying BAT and BARM for the key environmental risks and impacts listed in Table 3.1 and Table 3.2. This should be subject to discussion with the TWG at the kick-off meeting.

Table 3.1 Key environmental risks and impacts related to upstream onshore exploration and production

Issue Relevant activities/processes/techniques

Groundwater contamination

Site selection and underground characterisation

Well pad construction (spillages)

Well integrity / well casing (leakage of chemicals and seepage of oil and gas)

Drilling wells - handling of drilling muds and fluids from drilling

Well commissioning (hydrostatic testing water dosing and disposal)

Handling of fluids from well completion (spillages)

Production (spillages)

Handling of fluids emerging at the surface following hydraulic fracturing (produced/flowback water)

Well stimulation including hydraulic fracturing and enhanced recovery (direct groundwater contamination by chemicals and hydrocarbons)

Surface water contamination

Machinery (hydrocarbon spillage and seepage)

Drilling wells - handling of drilling muds and fluids from drilling (surface run-off from surface spillage and leakage of chemicals, oil, contaminated sediments, drill muds and fluids, drill cuttings)

Handling of fluids from well completion (spillage and seepage)

Production (spillages)





Water resource depletion

Water used for well drilling cementing

Water used for production (e.g. process plant)

Water used for hydraulic fracturing

Releases to air Power generation (air emissions)

Site equipment and vehicles (air emissions)

Flaring of gas (emissions of VOCs during drilling and production)

Well completion

Crude oil and gas processing

Table 3.2 Key environmental risks and impacts related to upstream offshore exploration and production


Seabed disturbance

Sea-bed infrastructure impact, e.g. pipework, concrete mattresses, rock dumping, anchoring, piling, jacket footings in-situ

Drill cuttings pile material and toxic contaminants on seabed

Discharges to sea Handling of residual chemical additives/hydrocarbons (planned/accidental releases to sea, e.g. mud additives in cuttings, drainage water containing hydrocarbons, cement, sewage water, ballast discharge)

Activities with potential for accidental hydrocarbon spills, e.g.:

o Well blowout (Tier 3)

o In-field riser/flowline rupture, topsides vessel / heat exchanger rupture, fuel tank loss of containment, topsides drainage system failure (Tier 2)

o Bunker hose failure, dropped tote tank, small-hole riser leak, helideck fuel spills (Tier 1)

o (Note events listed here by Tier are for indicative purposes only, actual spills may vary)

Handling of oil-based drilling mud cuttings (e.g. disposal to sea)

Planned liquid hydrocarbon discharge (drop-out) to sea surface

Handling/treatment of hydrocarbon-contaminated waste water (e.g. produced water) (discharge to sea, etc. during well completion and clean up, and during production).

Storage and handling of completion fluids (accidental loss of containment and discharge to sea of e.g. corrosion inhibitor, biocide, oxygen scavenger)

Storage and loading of hydrocarbon cargo (accidental loss of containment and discharge to sea)

Well closure / plugging

Releases to air Drilling rig (air emissions from drilling rig and associated supply and transport vessels)

Flaring (emissions from during blowdown, completion or unplanned event)

Production (accidental gas releases due to loss of containment)

Production (planned gas emissions from venting, fugitive emissions)

Physical presence Drilling/production facilities (impact on commercial vessel operations e.g. shipping/fishing)

Offshore facility lighting (impact on seabirds and migration)

Jacket decommissioning (physical presence of jacket footings left in situ)

Marine biodiversity

Seismic surveying (impact on marine species due to high impact noise)




The oil and gas industry has a large number of techniques at its disposal that continuously evolve. The intention is to classify processes only as far as is needed to explain their environmental impacts and risks. For instance, once a drilling operation is in process the likely environmental impacts remain the same, almost regardless of the exact drilling method used.

Appendix A includes details of some of the key activities undertaken on upstream onshore and offshore hydrocarbon production installations. These lists are intended to provide further context to the key environmental impacts and risks described above, and the processes and technologies mentioned there. As mentioned above, Appendix B contains draft conclusions on the (potential) risks associated with different processes/techniques, where BAT/BARM can be used to reduce risks.




4. Identification of BAT and BARM

4.1 Information required on BAT and BARM (elements needed)

For each technique identified it is envisaged that the BREF will provide information on:

Technical description;

Environmental risks/impacts addressed;

For BAT for routine operations:

Achieved environmental benefits:

Environmental performance and operational data;

Cross-media effects;

For BAT for avoidance of environmental risks (BARM):

Quantitative risk management performance and operational data (estimate of typical reduction in consequence/frequency of accidents);

Qualitative description of risk management performance where quantification is not practicable (e.g. this could be the case for issues such as habitat damage which is highly site-specific);

Other risk-related and environmental effects;

Technical considerations relevant to applicability [potentially also include worker safety considerations here];

Economics;

Driving force for implementation;

Example installations;

Reference literature.

4.2 Process for identification of BAT and BARM

Overview

Identification of BAT and BARM will be the task of the TWG, based on information and/or proposals provided by the contractor (which will in turn take into account data provided by the TWG and other stakeholders). The following will be used to identify BAT and BARM:

(1) Expert judgement of the TWG.

(2) Multi-criteria analysis of techniques, taking into account e.g. Environmental performance; Cross-media effects; Applicability to new and existing plants; Economics, including capital cost and operating costs Current application of the technique in Europe or other countries.

Identification of BAT for routine operations

For routine operations (and routine releases of pollutants, waste generation, etc.) it is proposed to cover key sources of releases, such as atmospheric emissions, discharge of chemicals, waste water releases, water usage, drill cuttings releases and waste generation.




Based on information collected from the literature and data provided by stakeholders/TWG members, a description of the performance achieved – in quantitative terms wherever possible – will be provided. This will describe emissions / performance before and after application of the technique in question.

The performance associated with BAT may be, for example, expressed as an emissions concentration (e.g. mg/m3 of an air pollutant emitted or % oil content in discharged waste water), or alternatively it may be expressed as a quantity per unit of production.

For BAT for routine operations, the Hydrocarbons BREF will focus on BAT that is precise and measurable effect, and where possible quantifiable.

Identification of techniques for risk management (BARM)

The focus on risk management for this Hydrocarbons BREF represents a key difference compared to other BREFs. A topic for discussion at the Technical Working Group (TWG) kick-off meeting will be how to compare, and potentially score, risk management approaches.

Risk management approaches within the industry can be considered at a number of different levels:

1) The overall strategic (e.g. company-wide) approach taken to risk assessment for hydrocarbon extraction projects.

2) The specific measures that are taken to manage environmental risks, which results from the above approach, incorporating the following two categories of measures:

a. Organisational practices

b. Technical measures

The first of these leads on to the second, but the effectiveness of the specific risk management measures identified in the risk assessment process is highly dependent on the rigour with which the assessment is applied and the expertise of those applying it.

Figure 4.1 Categories of environmental risk management (RM)

The expectation is that the Hydrocarbons BREF should cover both of these aspects i.e. strategic approaches to risk assessment and management, and the specific measures identified as best for managing specific identified environmental risks.

Based on experience to date, the risk assessment and management processes applied by companies are largely similar in general terms, and all bear similarities to the process set out in ISO 31000:2009.

The hydrocarbons sector does not currently follow an industry-wide risk assessment approach. A typical approach, however, would cover the following components:

Identification of potential environmental ‘hazard’ scenarios.

Evaluation of the consequences and effects of these scenarios.




Estimation of the likelihood of the scenarios occurring.

Determining the risks by combining the consequences and the likelihood (typically using a risk matrix).

Reviewing whether the risks are tolerable against accepted criteria, e.g. regulations/norms.

Identifying measures, including BAT/BARM, through which to manage the risks.

It would be challenging to robustly compare the relative merits of different risk assessment approaches, as they are generally organised and worded in different ways (for example they often use different terminology and values for scoring of consequence/severity and likelihood of environmental aspects). It is, therefore, proposed to use the ISO 31000:2009 risk management standard as a benchmark for comparison.

Possible scoring of risk assessment and management approaches

Subject to further discussion and review by the TWG, a scoring system that addresses each of the ISO standard elements could be applied to evaluate the risk assessment approaches used by individual organisations. The purpose of scoring would be largely to capture whether approaches match the intent of the ISO standard, rather than to address every aspect of it.

The table in Appendix C provides an overview of example criteria that may be used to score risk assessment approaches. These criteria have been derived directly from the ISO standard and framed in terms of a scoring that captures the extent to which an organisation has implemented particular aspects within their own processes. The example shown here is for the ‘Process (Establishing the Context)’ aspect (see Figure 4.2), as set out in Section 5.3 of ISO 31000:2009. Similar criteria would, if the general approach is agreed, be drawn up for Sections 5.4 (risk assessment) and 5.5 (risk treatment) of the standard.

It is envisaged that the scoring of approaches against criteria will require a combination of subjective judgement, comments/questionnaire responses from TWG members, and any documented information provided by organisations within the TWG that can offer insights into organisational risk assessment approaches.

A weighting system may be required in order to ascribe values to particular criteria which may be considered more or less important in terms of risk assessment. This has yet to be developed, but is nevertheless included for information in the table.

4.3 Format of conclusions on BAT and BARM

In order that all TWG members have a common understanding of the types of conclusions on BAT and BARM that should be reached as part of the Hydrocarbons BREF examples of such conclusions are provided below. In this context it is important to

Note: For the sake of clarity, the activities covered by the Hydrocarbons BREF will be unambiguously defined in the document. In addition, it will be mentioned that the list of techniques described in the Hydrocarbons BREF is neither prescriptive, nor exhaustive and that other techniques may exist that provide at least an equivalent level of environmental protection to those identified as BAT or BARM within the BREF itself.

The Hydrocarbons BREF will consist of a number of individual conclusions for BAT and BARM indicating the technique(s) or combination of techniques that are BAT or BARM for achieving a particular environmental objective. The description of the techniques will be short but informative enough to be useful to the competent authorities and operators. Undefined acronyms and technical jargon will be avoided.

Each individual conclusion may be featured with or without an associated environmental performance level with regard to the BAT / BARM identified.




Such levels may take the form of an emission level, a consumption level or another kind of performance level. For example, with regard to BARM a performance level may relate to a percentage reduction in the likelihood of an accidental release taking place as a result of applying a particular technique or techniques.

Such levels will only be included where there is a sound basis for doing so and will be based on the information exchanged during this project. Levels will generally take the form of ranges rather than being one fixed value.

For defining the lower end of the range, it is necessary to take the performance of installation achieved by the BAT obtaining the best environmental performance as provided in the information exchange unless this performance is excluded from the range by the TWG. In that case, there will be an explanation in the supplementary information supporting the Hydrocarbons BREF of why it has been excluded, considering that the installation achieving the best performance for a given environmental indicator may not be able to be the best performer for other indicators.

The upper end of the performance level range will normally be derived by considering the range of performance associated with the application of the BAT / BARM concerned on the basis of the data collected through the exchange of information.

When defining the performance levels associated with BAT and BARM, rounded values may be used to take into account limitations of the data collection or technical issues (e.g. use of different monitoring methods, uncertainty of measurements).

Conclusions on BAT and BARM should address “other than normal” operating conditions (such as start-up and shutdown operations, momentary stoppages and the definitive cessation of operations) when these are considered of important with respect to environmental protection.

The Hydrocarbons BREF will look to ensure that individual conclusions are grouped together according to common features such as environmental issues or production process steps;

The BAT or BARM conclusions can also contain statements which indicate when certain techniques are not BAT or BARM and thus have been deliberately excluded from the conclusions due to factors such as poor or non-credible environmental performance, lack of availability, economics, technical and/or economic considerations for cross-media effects, or operational reliability.

Individual BAT and BARM conclusions with associated emission levels

Individual BAT and BARM conclusions with associated emission levels will contain a numerical range of emission levels. The units, the reference conditions (e.g. flue-gas oxygen level, temperature, pressure) — if applicable — and the averaging period (e.g. hourly/daily/weekly/monthly/yearly average) will be included in the Hydrocarbons BREF. The averaging period will generally relate to the averaging periods of the data submitted.

Information can be added to explain under what conditions the lower end of the emission levels can be achieved or to reflect different performances of different techniques.

An example of an individual BAT conclusion which includes emission levels associated with BAT is provided in Example 1 below.

Performance levels can be expressed in one or more ways depending on the information that is available, including the ways given below.

As concentrations (mass of pollutant released per volume). This is generally the most common way of expressing emission levels, but reference conditions and averaging periods are crucial for their comparability.




As specific loads (mass of pollutant released per mass of product manufactured or mass of raw material used). In certain cases, specific loads are a better indicator of performance than concentrations, for example where pollutant concentrations are increased as a result of measures to reduce effluent volumes and to conserve energy, e.g. closing water circuits. Also in this case, averaging periods are crucial for comparability.

Individual BAT and BARM conclusions with associated environmental performance levels other than emission levels

Environmental performance levels other than emission levels can be associated with certain BAT and BARM. Examples include consumption of material, water or energy, the generation of waste and reductions in risk. Such conclusions will be similar in design to Example 1 below.

Individual BAT and BARM conclusions without associated environmental performance levels

Individual BAT and BARM conclusions without performance levels, e.g. concerning site remediation, will be structured similarly as shown in the examples below, with the exception of the information related to the performance levels. It is recognised that there may be some important examples of BARM in particular where there is no readily quantifiable performance indicator. Key performance indicators used by companies may be a useful source of information in identifying quantifiable performance indicators.

Proposed general approach to identification of BARM

It is recognised that techniques to address accidental events with an impact on the environment will sometimes not have a quantitative performance-level associated with them. It is therefore proposed that (where no quantitative performance level exists), BARM to manage a particular (key environmental) issue could be presented as a number of available risk management techniques and these should be concluded to be BARM, unless it can be shown that other measures are able to achieve a comparable level of performance.

However, ideally there will be at least some examples of BARM where it is possible to assign a quantified performance level.

The general approach proposed for identification of BARM is different to that for BAT. It is expected that the best-performing companies will undertake a process of risk assessment and management to identify, at an installation level, the best risk management practices for each key environmental issue. Many companies’ processes for risk management follow an approach similar to that set out in ISO 31000, illustrated in the figure below.




Figure 4.2 Risk management process according to ISO 31000:2009

Example 2 below provides an indication of the typical processes that could be applied to identify the best available risk management practices in relation to accidental chemical spills, as well as the general approach linked to the ISO 31000 process for risk management.

Risk treatment

Monitoringand

review

Risk evaluation

Risk analysis

Risk identification

Establishing the context

Communicationand

consultation

Risk assessment




Figure 4.3 Example 1: An individual BAT conclusion that contains an associated emission level

In order to reduce hydrocarbon emissions in wastewater discharge from offshore oil and gas operations, BAT is to use one or a combination of the techniques given below:

Technique Description Applicability

a Oil separators Oil separators are used to separate hydrocarbons from wastewater prior to their discharge to the environment. Such separators should be capable of handling the maximum flow of possible discharges.

Generally applicable

b Membrane filtration

Membrane filtration effectively draws water through a membrane leaving pollutants on the surface of the membrane and clean water ready to be discharged.

Requires approximately 1m2 of space for every 100l of water to be treated per hour.

c Flocculants Flocculants can be used to bind hydrocarbons prior to clean water being drawn off from settlement ponds and discharged.

Requires the ability to locate settlement ponds prior discharge

The emission level associated with the abovementioned techniques is for wastewater discharges to contain less than 0.1% hydrocarbons by volume. [Note that this is illustrative only]

Figure 4.4 Example 2: An individual BARM conclusion with an associated environmental performance level

Accidental chemical spills to the marine environment in UK waters amount to around 0.03 percent of the total chemicals used offshore [ref OGUK 2014]. In order to reduce accidental chemical releases to the marine environment to below this level, BARM is to use a combination of the techniques given below:

Establishing the context

Establishing the context in relation to accidental chemical spills for an offshore installation would typically involve:

Establishing the baseline of the marine environment and identification of receptors potentially affected by chemical spills.

Establishing the baseline of the operations of the installation, including details of chemicals (expected to be) used, stored, and processes involved.

These would typically be done as part of an environmental impact assessment.

Risk assessment

The processes of risk assessment in relation to accidental spills of chemicals should involve the following (or equivalent) process.

Phase Key steps (examples only)

Risk identification Environmental Impact Identification (ENVID) to identify potential loss of containment events.




Phase Key steps (examples only)

Identification of Environmental Critical Systems and Elements (ECE). Based on installation design review:

o Chemicals stored at installation o Process design (review of process flow diagrams, P&ID)

For example: loss of containment of chemical storage

Risk analysis Identify potential causes of loss of containment events, covering: o Potential equipment failure o Human error

For example, assessment of: o Consequences for the environment of different loss of containment events involving

chemicals stored o Likelihood of loss of containment events of different sizes

Risk evaluation Comparison of level of risk from loss of containment events with relevant performance standards.

For example, this could involve modelling / quantitative analysis of chemical spills of different sizes.

Provides a basis for identification of appropriate risk treatment.

Risk treatment

The table below provides an example of the types of techniques that might typically be assessed as BARM for an installation in terms of avoiding accidental chemical spills, based on the preceding steps.

Technique Description Potential for performance assessment

a Spill prevention, control and mitigation

Ensure spill prevention, control and mitigation measures are in place to effectively manage with chemicals offshore

Qualitative only based on policies and procedures in place

b Housekeeping Ensure continual good housekeeping measures are practiced offshore

Qualitative only based on policies and procedures in place

c Chemical inventory management

Optimise the chemical inventory stored on a facility at any given time to levels consistent with requirements

Quantify by tracking chemical inventory data against work requirements

d Equipment performance management

Ensure equipment related to chemical storage, injection and management meets Performance Standards in terms of integrity, and via ongoing maintenance and repair

Quantify by tracking data on equipment performance and maintenance regimes

e Leak detection Provide means of detection for chemical releases Quantify by logging number of actual releases and near misses over time

f Training and competency

Ensure competency of personnel and provide training in chemical management, handling, storage and cleanup.

Quantify by recording level of competency and logging hours of personnel training

Monitoring and review

Keep assessment of risks under review and aim for continuous improvement.




5. Data collection

5.1 Data collection process

The method of data collection needs to be targeted so as to minimise efforts expended on data of little concern and to derive that data of greatest relevance for identifying BAT and BARM.

Proposal 9

It is proposed to:

Produce tailored data collection tools for the identification of BAT and BARM. This may take the form of separate (short) questionnaires for offshore and onshore activities to be completed (by stakeholders/TWG members, potentially with initial part completion based on data already available) for each technique with information that could be directly incorporated into the Hydrocarbons BREF, along with a justification for performance.

Not ask people for data on levels of emissions, etc. unless this is directly related to the BAT/BARM in question. Be very clear that the Hydrocarbons BREF should be a focused data collection and information exchange process, not one that should seek to assess all releases of all pollutants from all installations.

Confidentiality

Confidential business information and sensitive information under competition law could potentially be useful for the contractor in its assessment (e.g. cost, production volume) and in drafting the Hydrocarbons BREF in general.

If any information submitted to the contractor is considered confidential business information or sensitive information under competition law and should therefore not be reported in the Hydrocarbons BREF this should be clearly stated when sending the information and the reason/justification for the confidentiality/sensitivity should be given.

Confidential business information and sensitive information under competition law will not be reported in the Hydrocarbons BREF, unless the information provides an important basis for the conclusions and the provider of the information (having checked compliance with competition law) specifically authorises the contractor to report the information in the Hydrocarbons BREF.

There are several ways to deal with confidential/sensitive data in the Hydrocarbons BREF such as the aggregation or the anonymisation of information. This can be done by the contractor if necessary with the help of those who supplied the information.

Confidential information will not be accessible to the rest of the TWG on the internet based platform for exchange of information.

5.2 Information exchange – IT platform

A ‘SharePoint’ site will be used for the exchange of information. Further details on how this site will operate will be presented at the kick-off meeting.

A1 © Amec Foster Wheeler Environment & Infrastructure UK Limited



Appendix A: Details of key activities undertaken for upstream hydrocarbon production installations

Offshore installations

Stage of hydrocarbon production process

Sub-stages Processes/technologies

Stage 1 - Site identification & preparation

1. Desk studies and licensing

Desk studies of target area for favourable geological conditions

Licensing

2. Exploratory Surveys General investigation:

Gravity and magnetic surveys by boat to capture geological information and identify ‘leads’ for further exploration.

Geophysical testing/investigations:

Seismic surveys – shock waves are sent into the subsea geological formations and response times monitored for returned waves to further identify and define reservoirs.

Stage 2 - Well design & construction

3. Well design Desk studies for well design, planning and logistics

4. Transport of drilling rig Transport of drilling rig – vessels,

5. Well drilling Positioning of drilling apparatus – Seabed activities

Drilling – Drilling with water based mud (WBM)/ Oil Based Mud (OBM)/Synthetic Based Mud (SBM)

Drill Cuttings Management – Management of cuttings generated

Cementing and Casing– Cementing of well casings

6. Stimulation Hydraulic fracturing

Others

7. Well completion Well bore clean-up - handling potentially contaminated wastewater and solids/cuttings

Introduction of completion fluids – Introduction of chemicals to protect the well including corrosion inhibitors and biocides

Stage 3 - Production

8. Platform installation Engineering, Procurement and Construction (EPC) – facility design and construction – Onshore/nearshore activities to prepare platform for particular drilling site.

Transport of platform – shipping vessels

Piling for jacket foundations/anchor points- seabed activities to permanently install fixed platforms and/or floating production facilities

Rock dumping - depending on rig type may be necessary to use rock dumping as part of foundation design.

Hydrostatic testing – leak and pressure testing of production and utility systems

Subsea infrastructure – installation of subsea equipment as necessary including Includes ESPs, hydraulically-powered pumps, FLETS, PLETS, ESDVs, pigging equipment, manifolds, and X-trees. Also includes in-field flow lines, injection lines and umbilicals, but excludes piling

Pre-commissioning – Pressure testing, hydro-static leak testing






9. Platform operations Platform operations are divided into three categories: i) Production, ii) Topside utility systems and iii) Export systems

I Production:

Chemical injection – Use of production chemicals.

Subsea production systems – For larger networks tie-backs and sub-sea equipment has to be installed and maintained.

Oil/gas processing and handling – processing of extracted material to separate oil, water and gas

Waste water management – Treatment and processing of the water generated from reservoir fluid separation processes.

Off-gas management – flaring – management of gas generated from separation processes

Waste sand management – Washing and cleaning of contaminated sand before return to sea or return to shore

II Topside utility systems:

Power generation and combustion equipment - Main energy generation units for power on the platform, auxiliary power generation for process equipment

Hydrocarbon and chemical Storage – Includes both bunkered fuel for power generation and processed oil

Diesel/chemical deliveries/loading – Includes all receiving shipments of goods to the installation

Open loop sea water cooling – Seawater cooling systems for all thermal processes carried out on the platform

HVAC systems – air conditioning systems for accommodation block and equipment

Topside drainage systems – Covers sewers fir grey and black water, closed systems for process equipment and open systems for drainage on deck

Waste management – Covers all waste aspects not detailed already, principally drainage, solid waste management and return of material to shore

III Export systems:

Off-take – vessels – Off-take of oil to shuttle tankers

Gas/oil export pipelines – off-take of gas/oil via pipeline

Stage 4 Project cessation and well closure

10. Well closure Well Plugging – Closure of the well bore at multiple points using cement plugs

Conductor recovery – Recovery of the conductor from the well and return to the surface, may require cutting operations as necessary.

11. Management of cuttings piles

Leave in place – Management options for leaving cuttings in place.

Excavate to surface – Remove of cuttings piles to surface for return to shore

Excavate and redistribute on seabed – Options for redistribution of cuttings across the seabed

Stage 5 Post closure and abandonment

12. Topside decommissioning

Preparation of topside for removal – All clean down and removal processes to prepare topside for decommissioning and removal.

13. Jacket decommissioning Dismantling of structures – Dismantling of structures in preparation for removal of topside structures

Offshore marine growth removal – clean down to removal marine growth to prevent translocation of foreign species

Cutting of leg structures – Cutting of platform legs to remove the topside structure.

Leave in-situ components – Footings and base structures to be left in place






14. Pipeline and bundle decommissioning

Leave in place – Option to leave pipelines in place, may require further rock dumping.

Partial removal – Removal of concrete mattresses and non-vital support structures

Full removal – full removal of pipelines using jet washers to entrench pipelines where necessary.

15. Shipping All decommissioning activities – Multiple shipping activities as required for decommissioning processes

Onshore installations



Stage 1 - Site identification & preparation

1. Identification of resource (desk study)

Desk studies of target area to establish geological conditions and hydrocarbon potential

Licensing

2. Surveys and conceptual model

General investigation: - Aerial survey of land features e.g. satellite imagery, aircrafts, etc.

Geophysical testing/investigations:

Land based seismic

Development of conceptual model

3. Exploratory drilling Baseline surveys (ecology, hydrology, groundwater, community impact, etc.)

Mobilisation of drilling rig and equipment and people to the drill location

Site preparation (e.g. site clearing, accessibility, infrastructure)

Support camp (outside boundary)

Stage 2 - Well design, construction and completion

4. Exploration well construction

Well pad construction

Rig installation

Drilling of vertical or deviated wells

Casing installation

Well stabilisation

5. Appraisal Well testing (some preliminary testing may be carried out before the well is plugged temporarily)

Treatment of waste water from exploratory wells

Revised conceptual model and resource estimate

Assessment (evaluate technical and economic viability for the whole project and develop plans for production)

6. Well stimulation Hydraulic fracturing

Other techniques

7. Well completion Well completion (screens, valves, etc.)

Stage 3 – Development and Production

8. Field development design (not all necessarily required)

Field development (planning and design): ‐ Field development concept ‐ Front-end engineering design

Detailed design






9. Construction and installation

Implementation of development plan ‐ Site clearing

Access infrastructure(i.e. roads, infrastructure)

10. Hook-up and commissioning

‐ Well hook-up to production system ‐ Pre-commissioning

Commissioning

11 Development drilling- if required, once field development in place

Development drilling (if required) - Small drilling field - Large drilling field

12. Hydrocarbon production - hydrocarbon extraction and processing

Crude oil & gas processing - operation of plant and process equipment and maintenance activities

Well workover – well maintenance, etc.

Process treatment systems - waste water collection and management

Utility systems - wastewater and sewage collection and treatment

Waste handling - waste handling, storage, collection and transport

Hydrocarbon offtakes - product export, onshore pipelines/road tankers

Stage 4 Project cessation, well closure and decommissioning

13. Decommissioning and rehabilitation planning

Project cessation, well closure and decommissioning

14. Decommissioning of equipment and reclamation

Plugging of wells

Removal of well pads

Waste management

15. Rehabilitation Site restoration

Stage 5 Project post closure and abandonment

16. Project closure and abandonment

Monitoring

Relinquishing licences

B1 © Amec Foster Wheeler Environment & Infrastructure UK Limited



Appendix B: Details of initial conclusion on risks for key activities (to prioritise key environmental issues)

Environmental issues related to upstream onshore exploration and production

Issue Description Examples of relevant activities/processes/techniques

Risk level

Groundwater contamination and other risks (includes induced seismicity)

The potential for groundwater contamination exists as a result of both the materials being used as part of the exploration and production processes as well as the materials being extraced. Such substances may be toxic to human health / the wider environment, may remain trapped in groundwater for significant periods of time and, as a result of the interactions between groundwater, soil, surface water and marine waters, may leak into other environments with consequences beyond the site of the exploration / production activity.

Contamination may result from the poor storage of materials, accidents and incidents, over-use and infrastructure failure.

Well pad construction: spillages from machinery

9 (high)

Well casing: leakage of chemicals and seepage of oil and gas during drilling of wells

9 (high)

Produced water management: Spills / releases of produced water

6 (moderate) from exploratory wells,

9 (high) from production

Well completion: Leakage of chemicals / hydrocarbons

9 (high)

Well commissioning: contamination from hydrostatic testing water availability, chemical dosing, water disposal

9 (high)

Wastewater and sewage collection and treatment; waste handling; plugging : Long term contamination of due to surface spills and leakages during

9 (high)

Hydraulic fracturing: Contamination by chemicals and hydrocarbons

Moderate/high

Surface water contamination

Surface water contamination can carry significant consequences for both flora and fauna within that surface water, the potential contamination of water sources used for human consumption as well as potential downstream consequences of surface water contamination being transport elsewhere. Contamination may result from poor design of surface water storage or spillage of such water as a result of incident or accident.

Mobilisation of drilling rig and equipment: spillages and leakage from machines and vehicles

6 (moderate)

Site preparation: exposed land leading to pollution risk to surface runoff and erosion.

6 (moderate)

Drilling of wells: surface run off from surface spillage and leakage of chemicals, oil, contaminated sediments, drill muds and fluids, drill cuttings.

9 (high)

Management of produced water: Leakage and spills onto surface and subsequent surface runoff to water bodies.

6 (moderate)

Well workover: discharge of chemicals used

6 (moderate)





Risk level

Wastewater and sewage collection and treatment: surface runoff contamination

6 (moderate)

Waste treatment: accidental release to surface water

6 (moderate)

Hydrocarbon offtake: leakage from pipeline within the site

6 (moderate)

Plugging of wells and removal of pads 6 (moderate)

Hydraulic fracturing: contamination by chemicals and hydrocarbons

Moderate/high

Water resource depletion

Onshore exploration and production may require the use of large quantitiies of water. This is particularly lined to unconventional hydrocarbon production, especially hydraulic fracturing, which implies the use of a large quantity of water. This has further ecological and water availability impacts.

Depletion may result from unsustainable and continuous extraction of water for fracturing purposes

Drilling of wells: water used for drilling and workers

9 (high)

Casing installation: quantities of water for cementing

12 (high)

Well commissioning: water used to conduct various testing such as hydrostatic testing

2 (low)

Hydraulic fracturing: water used for HF Moderate

Releases to air The operation of diesel engines, drilling rigs and other ground level powered machines poses the potential to result in increased air pollution and local air quality issues. This issue is magnified in upstream unconventional hydrocarbon production, due to the significant scale of required mobile power generation at each site is especially related to unconventional gas stemming from drilling and fracturing operations.

Futhermore, methane and hydrogen sulphide are likely to be released to air from wells both in point source and diffuse form with both local air quality and climate change consequences if not fully controlled.

Geophysical testing/investigations: Dust and exhaust emissions from survey equipment, exposed land and vehicles.

6 (moderate)

Site preparation: Dust from exposed land. Exhaust emissions from vehicles and generators.

5 (moderate)

Well pad construction: GHG from exhaust, machinery, generator and dust from construction material, exposed land

8 (moderate)

Rig installation: Dust and GHG emissions from vehicles and machinery

5 (moderate)

Drilling of wells: Release of trapped gas, VOCs, emissions from flaring, CO2 emissions from generators and emissions from construction equipment and vehicles.

12 (high)

Casing installation: Dust emissions from cementing, machinery and generators

4 (low)

Exploratory wells: Flaring of trapped gas and emissions of VOCs

10 (high)

Produced water management: hydrocarbon release to air from produced water treatment

3 (low)





Risk level

Well completion: Flaring and venting of gas and VOCs.

4 (low)

Production: Flaring of produced gas, emissions from machinery, equipment and generators.

8 (moderate)

Wastewater and sewage collection and treatment: emissions from treatment plant and generator

3 (low)

Waste handling: emissions from waste treatment e.g. incineration, TDUs, treatment plant, vehicle exhaust and generators.

4 (low)

Hydrocarbon offtakes: vehicle emissions and pipe leaks

4 (low)

Plugging of wells: odour and fugitive emissions from chemical leaks and insufficient plugging.

6 (moderate)

Zoning and land take

Hydrocarbon operations may require substantial tracts of land to be fenced off for exploration and production purposes, placing pressure on both land availability, as well as potential environmental pressures on surrounding land used. This issue is common of all oil and gas operations, but it has been increasingly related to unconventional hydrocarbons (especially shale gas) because some of the most extensively used technologies (such as horizontal drilling) usually need a much larger portion of land than conventional hydrocarbon extraction. The risks related to this are pollution to drinking water sources, removal of land for alternative uses and ecological/environmental impacts. Cumulative impacts may be significant.

Geophysical testing/investigations (land based seismic): loss of land and vegetation. Damage to local infrastructure

5 (moderate)

Site preparation: Land and vegetation clearing, excavation

5 (moderate)

Well pad construction: Removal of vegetation and loss of land to access road, construction area, storage area. Industrialised area.

Hydrocarbon production - Hydrocarbon extraction and processing: Area required to install treatment facility

Decommissioning / plugging of wells: Revegetation of land, etc. and reversion to prior/alternative use

8 (moderate)

Biodiversity impacts

Upstream hydrocarbon exploration and production facilities might have impacts in biodiversity such as loss of habitat and surface disturbances.

Site preparation: Loss of habitat and surface disturbances

6 (moderate)

Well pad construction: Removal of vegetation and loss of land to access road, construction area, storage area. Industrialised area.

6 (moderate)

Produced water management: Spills to surface may change sediment characteristic. Produced water high in salt, oil/grease, chemicals and maybe NORM.

6 (moderate)

Well drilling: Risk to habitat and species due to disturbances to the environment,

4 (low)





Risk level

spillages, air emissions, miss-use of chemicals, constant loud noise.

Plugging of wells: Impact to soil from accidental spillages, vehicles, etc.

6 (moderate)

Noise Noise is common to all hydrocarbon exploration and production activities. It is recognised that this can be especially relevant where technologies such as horizontal drilling are used, especially because these new technologies imply a significant increase in the use of vehicles as well.

Site preparation: Vehicle, machinery, generators intermittent or constant noise

4 (low)

Well pad construction and rig installation: Construction noise.

4 (low)

Drilling of wells: High noise level occurring continuously for a period of time. Impact very significant

5 (moderate)

Visual impact Upstream hydrocarbon exploration and production may have a significant visual impact. This somewhat depends on the characteristics of the area (rural vs. Industrial) and cumulative impact of a large number of wells. This has particularly relevant with regard to unconventional hydrocarbons, as they may imply working in natural or rural areas that have not been previously developed.

Site preparation: Industrialisation of area – altered landscape

4 (low)

Well drilling: Impact of drilling rigs 15 (very high)

Traffic The movement of materials, products and staff both to and from hydrocarbon exploration and production sites can have consequences not only in terms of congestion, but also in terms of noise, pollution from vehilces (including material falling from vehicles themselves) and light.

Geophysical testing/investigations: Localised increase in traffic

5 (moderate)

Mobilisation of drilling rig and equipment 4 (low)

Site preparation: Increase in number of vehicles – burden on local access road capacity

4 (low)

Well pad construction and rig installation: Increase traffic during construction period (short-term)

4 (low)

Drilling of wells: Large number of vehicles potentially loading large burden on local road infrastructure

5 (moderate)

Produced water management: Produced water transportation

4 (low)

Hydrocarbon production: Increase traffic from vehicles collecting “offtakes” on site

4 (low)

Wastewater and sewage collection and treatment: Movement of vehicles for disposal

4 (low)

Waste handling: Movement of vehicles for disposal

4 (low)





Risk level

Plugging of wells, removal of well pads: Increased construction noise and traffic from vehicles and workers to dismantle

4 (low)

Seismicity Upstream hydrocarbon exploration and production activities have the potential to impact on strate below ground leading to increased seimicity with potential impacts on pollution pathways underground and activities aboveground both on- and off-site. This may result from matters such as uncontrolled drilling, unexpected seismic properties of the area, errors in the calculations.

Geophysical testing/investigations (land based seismic): Disturbance to wildlife and humans from vibrations or explosions.

4 (low)

Hydraulic fracturing: Potential for induced seismicity

Low

Accidental events

Many of the above environmental issues may be affected through accidental events (spills, releases, fire/exposion). The BREF should consider these accidental events, as well as routine operations

Environmental issues related to upstream offshore exploration and production


Risk level

Seabed disturbance

Seabed disturbance from placing of equipment on the seabed, rock dumping, cuttings pile.

Piling for jacket foundations and/or mooring line anchors

3 (low)

Rock dumping 9 (high)

Installation of sea-bed production infrastructure: laying pipes, concrete mattresses, etc.

12 (high)

Drill cuttings pile, if present 12 (high)

Well closure: Excavation of the pile and recovery to surface (potentially releasing toxic contaminants to the water column and seabed)

12 (high)

Topside / jacket decommissioning: Dropped objects e.g. module loss during lifting/transportation (accidental events).

3 (low)

Pipelines/bundles decommissioning: Removal of mattresses, sand bags, grout bags, and frond mats.

1 (low)

Shipping activities: Anchoring 4 (low)





Risk level

Discharges to sea

Planned and unplanned releases of hydrocarbons, chemicals used in production, or wastes have the potential to cause contamination of sea water and the seabed.

Well drilling: Residual chemical additives/hydrocarbons to sea (planned release). Potential causes include mud additives in cuttings; drainage water containing quantities of hydrocarbons; sewage water released; ballast discharge released containing contaminants

6 (moderate) for deterioration of water quality,

9 (high) for sediment fouling

Well drilling: Accidental hydrocarbon spills e.g. well blowout, FPSO hull tank failure, offtake vessel hull tank failure, eExport pipeline rupture (Tier 3); in-field riser/flowline rupture, topsides vessel / heat exchanger rupture, fuel tank loss of containment, topsides drainage system failure (Tier 2); bunker hose failure, dropped tote tank, small-hole riser leak, helideck fuel spills (Tier 1)

Tier 1: 20 (very high) for deterioration of water quality, 12 (high) for sediment fouling

Tier 2: 16 (very high) for deterioration of water quality, 9 (high) for sediment fouling

Tier 3: 6 (moderate) for deterioration of water quality, 4 (low) for sediment fouling

Handling of oil-based mud cuttings: drilling cuttings potentially contaminated with residual OBM



Cementing and casing: Accidental release to sea of cement and associated chemical additives.



Well completion: Liquid hydrocarbon drop-out to ocean surface, discharge of hydrocarbon-contaminated waste water to sea, etc. during well bore clean up.



Introduction of completion fluids: Accidental discharge to sea of completion fluids (e.g. corrosion inhibitor, biocide, oxygen scavenger) resulting from loss of containment



Chemical injection: Accidental release to sea of production chemicals


4 (low) for sediment fouling

Subsea production system: Discharge of hydraulic fluids (containing MEG and other chemicals)






Risk level


Oil production, processing and handling: Hydrocarbon spills as above

4 (low) to 20 (very high), as hydrocarbon spills above

Produced water management: Discharge of PW to sea: Planned or accidental release (containing residual hydrocarbons, production chemicals and reservoir contaminants)

4 (low)

Produced sand management: Planned or unplanned discharge to sea

3 (low) for deterioration of water quality,

6 (moderate) for sediment fouling

Hydrocarbon and chemical storage: Accidental loss of containment of hydrocarbon cargo to sea

12 (high) for deterioration of water quality,

20 (very high) for sediment fouling

Diesel/chemical deliveries/loading 9 (high)

Open loop seawater cooling of process and utility systems: Discharge of cooling water to sea: thermal pollution from planned releases, residual antifoulant from unplanned releases

4 (low)

Waste management: Accidental loss of liquid or solids wastes to sea during transfer to support vessel for onshore disposal

4 (low) for liquid,

6 (moderate) for solid

Oil offtake: Accidental loss of containment during hydrocarbon offtake by offtake tanker



Oil export pipeline/tie in equipment: Loss of containment of crude from export pipeline



Shipping activities: Containment failure on rig or shipping

4 (low) for rig,

9 (high) for shipping





Risk level

Releases to air

Air pollution can result from surveying, installation and supply vessels but also from platform transportation.

Gravimetric surveys, seismic surveys: CO, CO2, NOx and SOx, etc. (local air quality and global climate change impact).

3 (low) for local air pollution,

5 (moderate) for Contribution to global emissions

Transport of drilling rigs, including supply vessels



Drilling: Emissions from drilling rig 8 (moderate) for local air pollution,

10 (high) for Contribution to global emissions

Well completion: Flaring emissions 10 (high)

Platform installation: Emissions from platform transportation



Piling for jacket foundations: Emissions from installation vessels



Gas production, processing and handling: Accidental gas emissions during production and Planned gas emissions, e.g. venting, during production


12 (high) for Contribution to global emissions

Off-gas management: Flaring – planned flaring and unplanned flaring of gas for safety purposes (process blowdown)

Planned flaring: 8 (moderate) for local air pollution, 16 (very high) for Contribution to global emissions

Unplanned flaring:6 (moderate) for local air pollution, 9 (high) for Contribution to global emissions

Power generation and combustion equipment: Emissions from power generation/turbines/process systems



Emissions from combustion equipment other than GTGs (e.g. turbine compressor drivers, fired heaters, EDGs, diesel firewater pumps)

6 (moderate)





Risk level

HVAC systems 8 (moderate)

Gas export pipeline/tie in equipment: Failure of gas export pipeline leading to atmospheric emissions

6 (moderate)

Topside/jacket decommissioning: Power generation for manufacture of temporary steelwork, dismantling structures inshore, module separation and cutting, onshore transportation of recovered material to recycling site or landfill facility



Decommissioning: Emissions from shipping activities


4 (low) for Contribution to global emissions

Physical presence

Physical presence of the upstream exploration and production facilities can lead to impacts to commercial vessel operations (shipping/fishing), long term habitat loss from presence on seabed and seabed distrurbance.

Impact on commercial vessel operations (shipping/fishing)

9 (high)

Drilling: Drilling vessel lighting (impact on sea birds)

10 (high)

Drilling: Vessel visual impact (for near-shore operations)

3 (low)

Subsea production system: Long term habitat loss from presence on Seabed

10 (high)

Cuttings pile: Long-term pile presence and contaminant persistence

10 (high)

Jacket decommissioning: Physical presence of jacket footings left in situ.

12 (high)

Pipeline/bundles decommissioning: Rock placement when leaving pipeline/sections in place

1 (low)

Marine biodiversity impacts

Loss in marine biodiversity/ habitat and release of organic matter due to the oil and gas operations.

Transport and placement of drilling rig: drilling vessel introduces Invasive/ foreign species to area

12 (high)

Also impacts from:

Releases of chemicals to water, 6 (moderate)

Hydrocarbon spills, Tier 3: 20 (very high)

Tier 2: 16 (very high)

Tier 1: 12 (high)

Discharge of PW to sea: Planned or accidental release (containing residual

8 (moderate) for accidental,





Risk level

hydrocarbons, production chemicals and reservoir contaminants)

10 (high) for planned

Underwater noise

Generation of underwater noise causing potential disturbance to marine life (i.e. marine mammals and fish).

Surveying: Seismic surveys 5 (moderate) for behavioural responses,

6 (moderate) for damages/injuries

Positioning of apparatus on seabed: piling for exploratory drilling

5 (moderate)

Well drilling 3 (low)

Well cementing 3 (low)

Piling for jacket foundations 5 (moderate) for behavioural responses,

6 (moderate) for damages/injuries

Installation of sea-bed production infrastructure

5 (moderate)

Operation of subsea infrastructure 3 (low)

Topsides noise and vibration from production and utility equipment

8 (moderate)

Well plug and abandonment (P&A) recovery: Cutting

6 (moderate)

Jacket decommissioning: Dismantiling structures, abrasive cutting of jacket legs and members.

8 (moderate)

Pipeline and bundles decommissioning: Rock placement when leaving pipelines, etc. in place; removal of mattresses, etc.

Rock placement when leaving pipelines: 6 (moderate)

Removal of matresses etc.: 8 (moderate)

Visual impact (for near shore operations)

Near shore operations might have visual impacts on livelihoods dependent on natural/wilderness appeal for tourism.

Drilling rig and support vessels 3 (low)

Platform 3 (low)

Accidental events

Many of the above environmental issues may be affected through accidental events (spills, releases, fire/exposion). The BREF should consider these accidental events, as well as routine operations

C1 © Amec Foster Wheeler Environment & Infrastructure UK Limited



Appendix C: Possible table for scoring risk assessment approaches against ISO 31000

The table below outlines a possible approach for comparing companies’ risk assessment approaches against ISO 31000:2009. It is intended to outline the general concept, and it is recognised that the ‘example wording’ for example would need further elaboration were this approach to be taken forward.

The ‘weight’ component is included to reflect the fact that some aspects may be considered more important than others. A larger score (e.g. 5) would be assigned to elements with a greater importance.




Text as derived from ISO 31000:2009 Example wording for scoring system Score Weight

Establishing the Context – External Context Does the organisation consider the objectives and concerns of external stakeholders when developing risk criteria?

Yes (1)/ No(0)

1-5?

Understanding the external context is important in order to ensure that the objectives and concerns of external stakeholders are considered when developing risk criteria. It is based on the organization-wide context, but with specific details of legal and regulatory requirements, stakeholder perceptions and other aspects of risks specific to the scope of the risk management process. The external context can include, but is not limited to:

the social and cultural, political, legal, regulatory, financial, technological, economic, natural and competitive environment, whether international, national, regional or local;

key drivers and trends having impact on the objectives of the organization

relationships with, perceptions and values of external stakeholders.

Organisation has policies, procedures and practices in place for engagement with external context and stakeholders as part of decision making.

Organisation has policies, procedures and practices in place to ensure compliance with all legal and regulatory requirements, and international codes and standards.

Organisation has policies, procedures and practices in place that ensure it can consider informal pressure from external stakeholders as part of decision making.

Organisation has policies, procedures and practices in place that ensure it can apply societal norms and standards not necessarily enshrined in law.

Organisation has policies, procedures and practices in place that enable it to anticipate social responsibility and proactively engage with interest groups, stakeholders, etc.

Establishing the Context - Internal Context To what extent is the risk management process aligned with the organization's culture, processes, structure and strategy?

The internal context is the internal environment in which the organization seeks to achieve its objectives. The risk management process should be aligned with the organization's culture, processes, structure and strategy. Internal context is anything within the organization that can influence the way in which an organization will manage risk. It should be established because:

a) risk management takes place in the context of the objectives of the organization;

b) objectives and criteria of a particular project, process or activity should be considered in the light of objectives of the organization as a whole; and

c) some organizations fail to recognize opportunities to achieve their strategic, project or business objectives, and this affects ongoing organizational commitment, credibility, trust and value.

It is necessary to understand the internal context. This can include, but is not limited to:

governance, organizational structure, roles and accountabilities;

policies, objectives, and the strategies that are in place to achieve them;

capabilities, understood in terms of resources and knowledge (e.g. capital, time, people, processes, systems and technologies);

the relationships with and perceptions and values of internal stakeholders;

the organization's culture;

Organisation has policies, procedures and practices in place for risk management that are followed rigorously for all projects and activities.

Organisation has policies, procedures and practices in place for risk management that are consistent across all activities.

Organisation has an established commitment to risk management at all levels including leadership positions.





information systems, information flows and decision making processes (both formal and informal);

standards, guidelines and models adopted by the organization; and

form and extent of contractual relationships.

Establishing the Context - Context of Risk Management Process Does the organisation have in place an established and dedicated process for risk management?

The objectives, strategies, scope and parameters of the activities of the organization, or those parts of the organization where the risk management process is being applied, should be established. The management of risk should be undertaken with full consideration of the need to justify the resources used in carrying out risk management. The resources required, responsibilities and authorities, and the records to be kept should also be specified. The context of the risk management process will vary according to the needs of an organization. It can involve, but is not limited to:

defining the goals and objectives of the risk management activities;

defining responsibilities for and within the risk management process;

defining the scope, as well as the depth and breadth of the risk management activities to be carried out, including specific inclusions and exclusions;

defining the activity, process, function, project, product, service or asset in terms of time and location;

defining the relationships between a particular project, process or activity and other projects, processes or activities of the organization;

defining the risk assessment methodologies;

defining the way performance and effectiveness is evaluated in management of risk;

identifying and specifying the decisions that have to be made; and

identifying, scoping or framing studies needed, their extent and objectives, and the resources required for such studies.

Attention to these and other relevant factors should help ensure that the risk management approach adopted is appropriate to the circumstances, to the organization and to the risks affecting the achievement of its objectives.

Organisation has in place an established risk management process, for which goals, objectives, strategies, scope and parameters of the activities of the organization are defined and documented.

Organisation has dedicated resources within the organisation to the process of risk management and for carrying out the specific activities required as part of this process.

Establishing the Context - Defining risk criteria Does the organisation have in place defined risk criteria?

The organization should define criteria to be used to evaluate the significance of risk. The criteria should reflect the organization's values, objectives and resources. Some criteria can be imposed by, or derived from, legal and regulatory requirements and other requirements to which the organization subscribes. Risk criteria should be consistent with the organization's risk management policy (see 4.3.2), be defined at the beginning of any risk management process and be continually reviewed. When defining risk criteria, factors to be considered should include the following:

the nature and types of causes and consequences that can occur and how they will be measured;

Organisation has policies, procedures and practices for defining risk criteria, and defined criteria are applicable across projects and activities.

Risk criteria incorporate nature and types of causes and consequences that can occur and how they will be measured.

Risk criteria incorporate likelihood and consequence criteria.

Risk criteria incorporate parameters for the determination of risk levels.





how likelihood will be defined;

the timeframe(s) of the likelihood and/or consequence(s);

how the level of risk is to be determined;

the views of stakeholders;

the level at which risk becomes acceptable or tolerable; and

whether combinations of multiple risks

Risk criteria take into account views of stakeholders.

Risk criteria definitions account for level at which risk becomes acceptable or tolerable.

Risk criteria take into account combinations of multiple risks.

5 © AMEC Environment & Infrastructure UK Limited


Documents

Service contract to support the Development of a BAT ...ec.europa.eu/environment/integration/energy/pdf/Background paper.pdf · BAT and BARM for upstream hydrocarbon exploration and