SECURITE ENVIRONNEMENT ET REHABILITATION

DES SITE

Niveau 3 (licence)
Semestre 5

Prof ETAME: CM , TD , TP
Dr AKUMBOM: CM , TD , TP
 UE: IUT PGE 54: HYDOCABURES ET ENVIRONEMENT

EC : PEG 524- SECURITE ENVIRONNEMENT ET REHABILITATION DES SITE

DUREE : 30 HEURES

General objectives

At the end of this course the students are expected to:

 Understand the security problems associated with the oil and gas industry
 Evaluate the environments impacts linked to the production of oil and gas
 Evaluate the decomissioning and site rehabilitation procedue
TEACHING PROGRESS
I- COURSE EVOLUTION

1- Presentation of course objective

2- Reminder on the previous course :
3- General questions on the course :
4- Lecture for the day
5- Home work :
a. Excercises to be done at home ;
b. Class exercises so that the students can better understand the course
SEQUENCES THEMES DURATION
1- Security of oil and gas assets
SEQUENCE 1 : L : 2h
2- Threats and statistics
SECURITY ASPECTS T : 2h
3- Current status
1- Security assessment approaches
SéQUENCE 2 : CM : 3h
2- Security assessment and process safety
SECURITY ASPECTS TD : 1h
management
Effects of oil and gas exploration and
SéQUENCE 3 : eploitation on the environment
CM : 3h
ENVIRONMENTAL 1. Gas flaring
TD : 1h
CONSTRAINS 2. Petroleum hydrocarbon spills

3. Drilling discharge and petroleum

derived chemical waste
SéQUENCE 4 :
4. Petroleum contamination of soil CM : 3h
ENVIRONMENTAL
sediment and water
CONSTRAINS
5. Human health risk
6. Socio- economic cost
SéQUENCE 5 : 1. Guidlines on sutanable decomissing
CM : 3h
DECOMISSIONING AND 2. Site rehabilitation
SITE REHABILITATION
SéQUENCE 6 : Tutorails
TD:6
TUTORIAL
TABLE OF CONTENTS
TEACHING PROGRESS................................................................................................................3
TABLE OF CONTENTS.................................................................................................................4
GENERAL INTRODUCTION........................................................................................................5
CHAPTER ONE.............................................................................................................................. 6
SECURITY OF OIL AND GAS ASSESTS....................................................................................6
1. Introduction.............................................................................................................................. 6
1.1 Threats and statistics.............................................................................................................. 7

2. Current status........................................................................................................................... 9
2.1 Industry (e.g. industry associations, standardization organizations)............................................ 9

2.2 Governmental (e.g. government organizations and the military)...............................................10

3. Security assessment approaches.............................................................................................12

3.1 Maritime security................................................................................................................. 12

3.2 Industrial security................................................................................................................. 14

4. Security assessment and process safety management (PSM)................................................ 17

5. Conclusion..............................................................................................................................17
CHAPTER TWO........................................................................................................................... 19
2.0THE EFFECTS OF OIL AND GAS EXPLORATION AND PRODUCTION ON THE
ENVIRONNMENT........................................................................................................................19
2.1. Introduction......................................................................................................................... 19
2.2. Environmental Issues, Human Health Risks and Socio–economic problems associated
with petroleum exploration and production............................................................................... 21
2.2.1. Gas Flaring and Venting ................................................................................................... 21

2.2.2. Petroleum hydrocarbon spills and accidental discharges................................................. 23

2. 2.2.1 Causes of oil spill........................................................................................................... 24

2. 2.2.2 Effects of oil spills..........................................................................................................24

2.2.3. Drilling Discharges and Petroleum–derived Chemical Wastes........................................25

2.2.4. Petroleum contamination of soil, sediment and groundwater................................................ 26

2.2.5. Human health risks associated with petroleum contamination and environmental degradation 26
 2. 2.6. Socio–economic costs associated with petroleum contamination and environmental
degradation............................................................................................................................... 27

CHAPTER THREE........................................................................................................................29
3.0 DECOMISSIONING AND SITE REHABILITATION...................................................... 29
3.1 Introduction......................................................................................................................... 29

3.2. Guidance on sustainable decommissioning of onshore assets.................................................. 35

3.3 Site rehabilitation................................................................................................................. 44

 CHAPTER ONE
SECURITY OF OIL AND GAS ASSESTS

1. Introduction
Security of oil and gas assets is defined as the process in which the operational (exploration and
production) and engineering assets are actively and passively protected by stringent physical and
operational measures to ensure resiliency and reduced degradation associated with security
breaches. The major forces driving this need for the implementation of security measures for the
protection of oil and gas assets are the international legislative framework and national
regulations concerning security compliance as well as the current and emerging threats to include
terrorism, piracy, inter-territorial crime, etc Security will be considered along the physical, the
engineering and operational aspects for these assets.

For the further analysis of the concept of Security Assessment, it is important for the key terms
to be understood. According to the American Petroleum Institute (API) Recommended Practice
(RP) 70 an offshore oil and gas installation can be defined as: “Any artificial island, facility or
other device permanently or temporarily attached to the subsoil or seabed of offshore locations,
erected for the purpose of exploring for, developing or producing oil, natural gas or mineral
resources.” Offshore oil and gas installations vary in shape, size and type depending on the type
of work they are designed to undertake. Offshore installations can broadly be categorized in
fixed structures that extend to the seabed and structures that float near the water surface. It
should be noted that all offshore oil and gas installations are deployed in the maritime domain
and thus suffer from being subjected to the main operational parameters and threats existing in
the shipping industry. Despite their common domain of deployment though, the application of
security protection measures for each of these installations can vary because they are industrial
facilities with complex and hazardous engineering processes.
 Johan Sverdrup offshore installation
The application and assessment of security for these installations require a different approach to
include risk and vulnerability analysis.

1.1 Threats and statistics

The exploration of security incidents data indicates a concentration of incidents in specific
regions of the world and the frequency of the type of attacks. The information has derived from
the public domain, academic sources as well as the press Figure 2. The first ever recorded such
incident was in 1899 off the shores of Montecito in California, USA (Kashubsky, 2011). There a
recently constructed oil derrick was attacked and demolished by a group of local residents who
opposed the existence of such activities in the area. The latest recorded incident was in 2019
(Mexico News Daily, 2019) in the Gulf of Mexico where an offshore rig was attacked by pirates
for the purpose of theft and looting of equipment, materials and money.
Figure 2 - Types and number of documented security incidents per country involving offshore oil
and gas installations from 1899 to 2018. (Source: M. Kashubsky (2011, 2012, 2013, 2016), M.
Kashubsky and A. Morrison (2013), www.start.umd.edu.
Threats can be categorized as:
International or domestic terrorists,
Activists,
Disgruntled employees or contractors,
Criminals (cybercriminals, pirates),
Inter-state adversaries.
The effects of a security incident to offshore installations can be the following:
Injury or death of personnel,
Damage or loss of assets,
Pollution to the environment,
Disruption of oil and gas production operations,
Disruption of oil and gas supply to the market,
Loss of income for companies,
The increase of oil prices,
Effect on global economies and stock exchange.
2. Current status
A preliminary literature review in the subject of security for offshore oil and gas installations has
brought results in the fields of industry, government and academia. These are described below:

2.1 Industry (e.g. industry associations, standardization organizations)

1. The American Petroleum Institute (API) has created two major Recommended Practices (RP),
API RP 70 (2003) and API RP 70I (2003). API RP 70 (2003) titled “Security for Offshore Oil and
Natural Gas Operations” is related to the assessment of security needs for oil and gas companies
in preparing procedures and operations for their offshore oil and gas assets. API RP 70I (2003)
titled “Security for Worldwide Offshore Oil and Natural Gas Operations” applies to worldwide
locations of offshore assets and is similar to API RP 70 (2003) in context. In addition to the two
above mentioned Recommended Practices, API also published the following documents
1.“Security Vulnerability Assessment (SVA) Methodology for the Petroleum and Petrochemical
Industries”in 2004 which applies to oil and gas companies and relates to the methodology and
process for the security and vulnerability assessment of assets without any focus in the offshore
environment.
2.“Security Guidelines for the Petroleum Industry” 2005. This document offers a generic
assessment, methodology, and lay-out of procedures for the security of oil and gas assets without
specifying offshore assets.
3. API Recommended Practice (RP) 780 was published 2013 as an update of the API 2003 SVA
methodology. API RP 780 (2013) outlines an SRA Methodology for the petroleum and
petrochemical industry. The focus of this publication was to expand the successful previous
editions without changing the basic methodology renaming the methodology from Security
Vulnerability Assessment (SVA) to Security Risk Assessment (SRA), in order to reflect the full
scope of the analysis; accounting for developments and experiences derived from the practical
use since the first version of 2003.

2. The International Association of Oil & Gas Producers (IOGP) has issued a number of reports
in the subject of security, acting as an advisory and recommendation body for IOGP members
companies.
1. IOGP Report 555 (2016) titled: “Conducting security risk assessment (SRA) in dynamic threat
environments” outlines an security risk assessment formwork as well as various assessment
techniques that can be used in the dynamic offshore field for oil and gas assets.
2. IOGP Report 537 (2015) titled: “Effective guard force management – Principles and
guidelines”, provides guidance for the setup and development of a guard force for an oil and gas
asset as well as advice on the administrative, organizational and contractual implications from
the engagement of a guarding force.
3. OGP Report 512 (2014) titled: “Security Management System – Processes and concepts in
security management”, provides a description of the organizational and process components for
the establishment of a Security Management System (SMS) in a company’s structure.
4. OGP Report 494 (2014) titled: “Integrating security in major projects - principles & guidelines”,
provides an insight into best practices for the integration of security planning and execution into
an oil and gas project lifecycle.
3. The International Maritime Organisation (IMO) issued the International Ship and Port Facility
Security (ISPS) Code in 2002 in response to the terrorist attacks of September 11, 2001. Along
with the issue of the ISPS Code, the International Convention for the Safety of Life at Sea, 1974
(SOLAS 74) amendments to chapter XI-1 and a new chapter XI-2 were also implemented.

2.2 Governmental (e.g. government organizations and the military)

1. In the United States of America (USA) the initiative for the security of offshore oil and gas
assets is lead primarily by the Department of Homeland Security (DHS) along with the U.S.
Coast Guard (USCG) and Department of Energy (DOE).

2. In Canada, the security of offshore installations (including oil and gas assets) is administered
by the Marine Transportation Security Act (MTSA) (1994) and its Marine Transportation
Security Regulations (2004). The main government body responsible for the enforcement of the
Marine Transportation Security Act (MTSA) and the Marine Transportation Security
Regulations is Transport Canada (TC) which is authorized to regulate security at offshore
facilities such as oil and gas drilling platforms.
3. The European Union (EU) covers the subject of security of oil and gas assets through the
concept of Critical Infrastructure Protection (CIP). EU Directive 2008/114/EC requires the
identification and designation of European critical infrastructures and the assessment of the need
to improve their protection. EU Directive 2008/114/EC classifies oil and gas production facilities
as critical infrastructure assets and European Critical Infrastructure (ECI) but it does not cover
oil and gas exploration facilities.
4. In Norway, the Norwegian Oil and Gas Security network, the HSE (Health, Safety,
Environment) Managers Forum, and the Norwegian Oil and Gas Operations Committee, with the
approval of the Director General of the Norwegian Oil and Gas Association, have issued
Recommended Guideline 091 (2015) for securing supplies and materials in the oil and gas
industry.
5. In Australia, preventive security arrangements for offshore facilities are regulated under the
Maritime Transport and Offshore Facilities Security Act 2003 and the Maritime Transport and
Offshore Facilities Security Regulations 2003. This legislation provides a framework for
operators of certain offshore facilities, ports, and ships, and a range of associated service
providers, to undertake security risk assessments and implement preventive security plans.
What about Africa

2.3 Academic research

In general a preliminary review of research publications indicates that the issue of security for
offshore oil and gas is addressed in the Academia through two main categories of scope: Policies
and Technical/Engineering aspects.
1. The Policies scope includes legislation, industry standards and governmental strategies and
initiatives. Notably Denton R.W. (1976) appears to have predicted the development of national
capability, industry standards and policies aiming to protect offshore oil and gas assets. His
recommendation for the centralized management of security aspects by a single governmental
entity and the integrated mitigation of security threats by both the oil and gas companies as well
as the government is something that took place after the terrorist acts of September 11, 2001.
2. The engineering and technical scope involves the risk analysis, vulnerability assessment and
engineering aspects of security mitigation.
3. Security assessment approaches
In general, the security for offshore oil and gas assets can be assessed using three (3) approaches:
a) Maritime Security
b) Industrial Security
c) CIP (Critical Infrastructure Protection)
Each approach uses a number of security assessment methodologies from which some are more
applicable to maritime and offshore oil and gas assets than others. Each approach investigates
specific features of the asset. Below some of these methods will be presented.

3.1 Maritime security

Methodologies for the security assessment of offshore oil and gas assets perceived as maritime
assets are the following:
a) Ship Security Assessment (SSA)/ Port Facility Security Assessment (PFSA) as described by
the International Ship and Port Facility Security (ISPS) Code (2002).
b) MSRAM (Maritime Security Risk Analysis Model) used by the United States Coast Guard
(USCG).

3.1.1 International Ship & Port Facility Security (ISPS) Code

The ISPS Code (2002) and the SOLAS 74 amendments can be applied to cargo ships, offshore
support vessels (OSVs) and mobile offshore drilling units (MODU), excluding fixed oil and gas
platforms and other offshore assets. The ISPS Code (2002) does require that vessel operators
designate a Company Security Officer (CSO) and a Ship Security Officer (SSO). Also, the ISPS
Code (2002) asks for the issuance of a vessel International Ship Security Certificate (ISSC), the
implementation of Ship Security Assessments (SSAs) (and Port Facility Security Assessments
(PFSA)) and the creation of Ship Security Plans (SSPs) (and Port Facility Security Plans (PFSP)).
The ISPS Code (2002) relies on the national legislative and security enforcement framework
allowing for the safe and secure interaction of maritime and oil and gas assets. The application
of the ISPS Code (2002) involves three (3) major phases as described in Figure 3
 Figure 3-ISPS code 2002 proces phases

3.1.2 MSRAM (Maritime Security Risk Analysis Model)

According to the USCG, MSRAM was developed shortly after the September 11, 2001, terrorist
attacks to act as a “Captain of the Port-level” risk analysis tool. MSRAM is used by USCG as a
terrorism risk analysis tool to understand and mitigate the risk of terrorist attacks on targets in
U.S. ports and waterways. Through the use of MSRAM Federal Maritime Security Coordinators
(FMSC) and area maritime security committees are enabled to perform detailed scenario risk
assessments on all of their Critical Infrastructure and Key Resources (CI/KR). MSRAM
combines these assessments and provides analysis to support risk management decisions. The
tool’s underlying methodology is designed to capture the security risk facing different types of
targets spanning every Department of Homeland Security (DHS) CI/KR industry sector,
allowing comparison between different targets and geographic areas at the local, regional, and
national levels. In MSRAM security risk is assessed based on scenarios involving a combination
of target and attack mode in terms of threat, vulnerability, and consequence.
3.2 Industrial security
The Industrial Security approach investigates the asset through its industrial operations and
systems and includes methods such as the following:
1) Security Risk Assessment (SRA)/ Security Vulnerability Assessment (SVA)
2) VAM-CF (Vulnerability Assessment Methodology for Chemical Facilities)
3) PRAF (Process Resiliency Analysis Framework)
From the above, the Security Risk Assessment (SRA) and Security Vulnerability Assessment
(SVA) from the American Petroleum Institute (API) will be described.
3.2.1. API Security Risk Assessment (SRA) The Security Risk Assessment (SRA) methodology
is incorporated in API (American Petroleum Institute) standard (STD) 780 (2013) and was
developed by the API as an industry-wide approach for assessing security risk at petroleum and
petrochemical facilities. It applies to a wide spectrum of security issues from theft to insider
sabotage to terrorism and for a broad variety of both fixed and mobile applications. The API
SRA is applicable to a broad range of industrial assets and operations. This includes
1. assets containing or processing hazardous materials such as chemical, refining, and
petrochemical manufacturing operations,
2. pipelines, and transportation operations including truck, marine, and rail.
3.2.2 Security Vulnerability Assessment (SVA)
Security Vulnerability Assessment (SVA) serves as a secondary evaluation that examines a
facility’s characteristics and operations to identify potential threats or vulnerabilities and existing
and prospective security and protection measures and procedures. SVA is aiming to assist the
offshore oil and gas operators and contractors in assessing security needs during the performance
of oil and natural gas operations. The SVA is applicable for national (RP 70) and worldwide (RP
70I) assets and operations. The SVA methodology has 5 steps as shown below:
Step 1: Potential Threat: Establish scenarios of potential threats. Worse case and most probable
scenarios should be considered.
Step 2: Consequence Assessment: Evaluate consequences for threat scenarios.
Step 3: Vulnerability Assessment: Assess the vulnerability of asset(s) considering threat
scenarios and existing versus future/potential/proposed/considered security measures in place.
Step 4: Mitigation: Determine scenarios with mitigation strategies (protective measures).
Step 5: Implementation: Develop and implement mitigation strategies for vulnerabilities,
consequences and threat scenarios identified and assessed. The SVA:
 Establishes the need for a company policy that clearly defines its security goals and
commitments including the protection of personnel, facilities and the environment as well as the
control of Security Sensitive Information (SSI).
 Establishes a communication protocol with authorities for emergency preparedness,
surveillance and reporting of security issues, assessing preparing for and responding to security
threats.
 Establishes a company-wide (owner/operator-wide) and (single or multiple) facilities specific
Security Plan which includes a Company Security Officer (CSO) and a Facility Security Officer
(FSO).

3.3 Critical Infrastructure Protection (CIP)

As per G. Giannopoulos et al (2012), the Critical Infrastructure Protection (CIP) approach
includes a number of analysis methods to include the following: 1) RAMCAP (Risk Analysis
and Management for Critical Asset Protection), 2) MBVA /MBRA (Model-Based
Vulnerability/Risk Assessment), 3) CIMS (Critical Infrastructure Modeling Simulation), 4)
CIPDSS (Critical Infrastructure Protection Decision Support System), 5) CIPMA (Critical
Infrastructure Protection Modeling and Analysis, 6) BIRR (Better Infrastructure Risk and
Resilience), 7) RVA (Risk and Vulnerability Analysis), 8) NSRAM (Network Security Risk
Assessment Modeling), 9) NEMO (Net-Centric Effects-based operations Model), 10) N-ABLE
(Agent-Based Laboratory for Economics), 11)MDM (Modular Dynamic Model), 12) MIN
(Multilayer Infrastructure Network), 13) FAIT (Fast Analysis Infrastructure Tool), 14)
EURACOM (European Risk Assessment and Contingency Planning Methodologies for
Interconnected Energy Networks), 15) COUNTERACT, 16) CARVER (Criticality Accessibility
Recoverability Vulnerability Espyability Redundancy), From the above methods, the most
applicable to offshore oil and gas assets have been selected to be described briefly.
4. Security assessment and Process Safety Management (PSM)
Process Safety Management (PSM) involves the review of safety utilizing Quantitative and
Qualitative methods to define risks, hazards and consequences of security incidents in offshore
oil and gas systems, equipment, processes, and operations. As per Nolan D.P. (2012), the
Qualitative process review methods include: • Checks lists • PHA (Process Hazard Analysis) •
What-If reviews • HAZOP (Hazard and Operability) review • Bow-Tie Analysis (barrier analysis)
The Quantitative process review methods include: ETA (Event Tree Analysis) • FTA (Fault Tree
Analysis) • FMEA (Failure Modes and Effects Analysis) It needs to be highlighted that Safety
hazards such as system failure, poor reliability and Security threats such as sabotage, physical
attack and subsequent damage of systems/equipment, cyber attacks, have the same preventive
barriers (such as procedures, processes, systems, etc) and consequences (such as system failure,
fire, explosion, loss of containment, environmental spill, loss of life, etc). So Process Safety
Management (PSM) and Security Assessment and Management for oil and gas assets have the
same objectives of protecting the asset, the operations, the personnel, and the environment.

5. Conclusion
It is important to understand that Safety and Security are terms with common disciplines,
deficiencies, and corrective measures. The efficient and successful assessment and management
of security risk for offshore oil disciplinary approach where safety, maritime and engineering
operations are analyzed and protected accordingly. Any use of security assessment methods shall
consider the industrial complexity and the subsequent interrelation of systems, equipment, and
operations. The use of Bow Tie Analysis has been illustrated to provide analytic assessment of
the barriers required for the mitigation of security threats and consequences considering the
industrial infrastructure layout and maritime operations of an offshore oil and gas asset. Using
Bow Tie Analysis the capability of advanced security planning can be achieved. Threat and
consequences mitigation measures can be selected and applied based on the different security
breach scenarios considered. Failing to assess security risk and select proper corrective or
preventive measures can lead to operational oversight and a series of domino effects which can
lead to catastrophic failure, the loss of lives and harm to the environment.and gas assets have to
consider a multidisciplinary approach where safety, maritime and engineering operations are
analyzed and protected accordingly. Any use of security assessment methods shall consider the
industrial complexity and the subsequent interrelation of systems, equipment, and operations.
The use of Bow Tie Analysis has been illustrated to provide analytic assessment of the barriers
required for the mitigation of security threats and consequences considering the industrial
infrastructure layout and maritime operations of an offshore oil and gas asset. Using Bow Tie
Analysis the capability of advanced security planning can be achieved. Threat and consequences
mitigation measures can be selected and applied based on the different security breach scenarios
considered. Failing to assess security risk and select proper corrective or preventive measures
can lead to operational oversight and a series of domino effects which can lead to catastrophic
failure, the loss of lives and harm to the environment.
 CHAPTER TWO

2.0THE EFFECTS OF OIL AND GAS EXPLORATION AND PRODUCTION ON THE

ENVIRONNMENT

2.1. Introduction
Petroleum exploration and production and export of oil and gas resources by the petroleum
sector has substantially improved the world’s economy over the past five decades. However,
activities associated with petroleum exploration, development and production operations have
local detrimental and significant impacts on the atmosphere, soils and sediments, surface and
groundwater, marine environment, biologically diversity and sustainability of terrestrial
ecosystems. Discharges of petroleum hydrocarbon and petroleum–derived waste streams have
caused environmental pollution, adverse human health effects, detrimental impact on regional
economy, socio–economic problems and degradation of host communities. Although there are
other potential anthropogenic sources of pollution, some of the major environmental
consequences such as air pollution, global climate change and oil spills may be regional or global
in scale.
Apart from other anthropogenic emission sources, atmospheric pollution in the production areas
is associated with emissions from flaring and venting of petroleum associated natural gas by
petroleum industries. Atmospheric contaminants from anthropogenic activities can be
categorized into
(i) gaseous pollutants,
(ii) persistent organic pollutants,
(iii)particulate matter and
(iv) trace element and/or heavy metals.
Release of petroleum hydrocarbons into the environment, whether accidentally or due to
anthropogenic activities, is a major cause of controlled water and soil pollution and may also
contribute to regional atmospheric pollution.

Petroleum is a naturally occurring complex mixture made up predominantly of hydrocarbon

compounds and frequently contains significant amounts of nitrogen, sulphur, and oxygen
together with smaller amounts of nickel, vanadium, and various elements. Petroleum compounds
can occur in solid form as asphalt, liquid form as crude oil and/or gaseous form as natural gas.
Petroleum hydrocarbons could be divided into four classes: saturates (pentane, hexadecane,
octacosane, cyclohexane), aromatics (naphthalene, phenanthrene, benzene, pyrene), asphaltenes
(phenols, fatty acids, ketones, esters, and porphyrins), and resins (pyridines, quinolines,
carbazoles, sulfoxides and amides).

Soils and sediments are the ultimate sink for most petroleum contaminants, such as benzene,
toluene, ethyl benzene, and xylenes(BTEX), aliphatic and polycyclic aromatic hydrocarbons
(PAHs). Petroleum hydrocarbon contamination of soils and sediment is a global concern because
of the toxicity and refractory character of the aromatic components in the absence of oxygen .
PAHs, which make up about 5% by volume, are a widespread class of environmental chemical
contaminants of anthropogenic or natural origin. Predominant oil pollution in the United
Kingdom contains high volumes of aliphatic hydrocarbons. It may also contain complex
mixtures of both the aliphatic and aromatic hydrocarbons in the tropical region. The inadvertent
discharges of petroleum hydrocarbons into the environment often pose threats to human health,
safety and the environment, and have significant socio– economic consequences. Evidence of
acute and chronic toxicity demonstrates the potential toxic and negative impacts of petroleum–
derived wastes on the tropicalenvironment. However, some of the multinational oil companies
have failed to adopt best practice strategies for risks mitigation and comply with environmental
regulations. The poor environmental management practices by the petroleum industries and the
failure worlds environmental regulations contribute towards environmental contamination with
direct consequences on the surrounding populations’ socio–economic wellbeing, human health
and the environment.

Environmental contamination, human health risks, safety and the environment, and negative
socio–economic consequences of most petroleum pollution in the world depend on the
intersection of the event, the geographic setting, the characteristics of the regional population,
corporate governance systems and political economy.
Environmental contamination and degradation associated with both onshore and offshore
petroleum exploration and production operations has not yet been properly addressed for the past
five decades.
2.2. Environmental Issues, Human Health Risks and Socio–economic problems associated
with petroleum exploration and production

There are several environmental impacts associated with the disturbance of forest and ground
surface from related activities such as site clearance, construction of roads, tank farms, brine pits
and pipelines, and other land modifications necessary for the drilling of exploration and
production wells and construction of production facilities. For example, some of the
environmental problems associated with oil exploration and production include oil spills, gas
flaring and venting, discharges of petroleum– derived chemical wastes, contamination of
controlled water sources, contamination of soil and sediments, the destruction of the farmland
and the marine environment. The major environmental issues arose primarily from the improper
disposal of large volumes of petroleum–derived hazardous waste streams, such as oily and toxic
sludge , equipment failure, oil spills/ operational discharges and sabotage of petroleum facilities.

In addition, accidental discharges from abandoned oil wells that were orphaned or not correctly
plugged and spills from oil bunkering (hacking into the pipeline to steal crude oil for illegal trade
or ‘artisanal refining’) pose serious environmental threats. Although there are several impacts
from other petrochemical industries, the adverse environmental condition in many parts of the
oil– producing host communities has affected human right to a healthy environment and makes
the people vulnerable to environmental and health hazards. Therefore, this section will discuss
some of the environmental issues, human health risks and socio–economic problemsassociated
with oil and gas exploration for and production.

2.2.1. Gas Flaring and Venting in the Niger Delta

Gas flaring and venting are widely used in the oil and natural gas industry to dispose of
associated natural gases for safety reasons during petroleum development operations and/or
where no infrastructure exists to bring it to market. The process of flaring (burning) and venting
(releasing into the atmosphere without burning) of petroleum associated gas has been
dramatically curbed in developed countries. Although Norway has adopted flaring reduction
measures and introduced a carbon tax, gas flaring and venting reduction strategies in Nigeria
seems ineffective over the past years.

Gas flaring and venting

The extent of economic loss due to gas flaring and venting is estimated at $2.5 billion annually in
a country like Nigerial and enormous economic benefits would have accrued to the Nigerian
government from harnessing this energy resource. Gas flaring and venting associated with
petroleum exploration and production generate complex consequences in terms of energy, human
health, natural environment, socio–economic environment and sustainable development.

Flaring of associated gas mainly emits carbon dioxide (CO2), carbon monoxide (CO) and a
variety of air pollutants, such as VOCs (which include carcinogens and air toxics), nitrogen
oxides (NOx), sulphur dioxide (SO2), toxic heavy metals, and black carbon soot. Gas flaring and
venting in the oil–producing areas and vehicular traffic emissions (COx, HC, NOx, SO2 and
particulate matters) contribute to atmospheric pollution. In spite of decree 99, which bans
unauthorized flaring,

Gas flaring in Nigeria

Nigeria flares over 75 % of the associated gas it produces and this represents a pollution
equivalent to 45 million tons of CO2 per day. Currently, Nigeria has over 123 flaring sites in the
Niger Delta region and has been regarded as one of the highest emitter of greenhouse gases in
Africa. Some 45.8 billion kilowatts of heat are discharged into the atmosphere of the Niger Delta
from combustion of 1.8 billion cubic feet of gas everyday and this is a major contributing factor
to the global warming crises. Further, it is known that incomplete combustion of petroleum
associated gases produces a variety of volatile organic compounds (VOCs) and polycyclic
aromatic hydrocarbons (PAHs).

Flaring of associated gas from oil and gas exploration and production operations has several
consequences on the environment.

1. Health problems in the communities

2. Poor agricultural yields

3. corrosion of zinc roofs

Further, assessment of the PAH compound ratios, phenanthrene/ anthracene and fluoranthene/
pyrene, suggested that predominant present of PAHs of pyrogenic sources in surface soils is an
indication that oil leakage and/or gas flaring contributes to soil contamination .

2.2.2. Petroleum hydrocarbon spills and accidental discharges

Oil spillage, which often results from accidental or operational discharges of petroleum
hydrocarbon into the environment, is a global issue that has been occurring since the discovery
of crude oil. Oil spill incidents associated with petroleum exploration and production operations
are common and have plagued various oil–producing host communities since 1956.

The Niger Delta has experienced a number of disasters from oil blowouts and examples of oil
pollution include blowouts and pipeline leakages. According to estimates, over 2,567,966 barrels
of crude oil has been spilled in 5733 incidents in the Niger Delta from 1976-2000 and about
549,060 barrels were recovered while 1,820,411 barrels were lost to the environment. The
cumulative spilt volume within the period is nearly 10 times more than the total quantity that was
spilled in the Exxon Valdez disaster. The cases of unreported spills by some oil exploration and
production companies could be related to the Nigerian National Petroleum Corporation (NNPC)
inspectorate classification guidelines whereby spillage are classify into minor, medium, major
and disaster. In past years, major oil spills has attracted a global attention and created awareness
due to the associated ecological, human health and environmental risks and/or damages that
result from such spillages.
 Oil spills

2. 2.2.1 Causes of oil spill

The main sources of oil spill and pollution are equipment failure, oil blowouts from the flow
stations, leakages from aged and corroded network of the pipelines,operational mishap,sabotage
and vandalization of the oil pipelines by the local militant groups. However, oil spill resulting
from the vandalization of pipelines either as a result of civil disaffection with the political
process or as a criminal activity causes a serious contamination of the environment.

2. 2.2.2 Effects of oil spills

Oil spills and production discharges resultes in disastrous effects on land, freshwater swamps and
the marine environment as well as potential threats to human health in the affected host
communities. The immediate effects of large scale spills and oil pollution in the coastal areas
(terrestrial ecosystems and shorelines) in the oil producing communities are often impacted.
Defoliation and mortality of the mangroves have been observed in swamps affected by oil spills.
The effects of oil pollution on the diversity and functioning of fish and turtle communities. In the
aquatic environment, the oil slick sometimes floats on the water surface where it is dispersed to
shorelines by wind and wave actions and invariably affecting the soil. When oil spillage occurs
onshore or near shore, the soil and other components of the terrestrial ecosystem are inevitably
affected.
2.2.3. Drilling Discharges and Petroleum–derived Chemical Wastes
Prior to the institution of statutory laws and regulations in the 1970s, the major petroleum–
derived wastes such as produced water, spent drilling muds, drilling cuttings and wastes that
require handling during site abandonment were commonly discharged into coastal waters,
swamps, and unlined evaporation ponds. In particular, produced water is the largest volume
waste stream associated with oil and gas exploration and production processes. The chemical
composition of the oil field produced water is complex, including large amounts of dissolved
salts, hydrocarbons, heavy metals, organic and inorganic components, naturally occurring
radioactive materials (NORMs) and chemicals added in the oil extraction and separation steps.
Produced water is either discharged into above ground storage facilities or reinjected into a
subsurface formation as a permanent disposal/secondary recovery process during onshore
operations, whilst it is either discharged through shore side outfalls or coastal rim releases
(within 4 miles from shore)during offshore or coastal operations.

Drill Mud

In many cases, the past and current disposal practices such as these have caused severe
environmental contamination of coastal waters, groundwater water, soils and sediments, and
marine ecosystems. The improper disposal of produced water on the ground is associated with
salt scars and potentially contaminated land that is difficult to remediate. The discharges of
petroleum–derived waste streams from oil and gas exploration and productions are toxic to the
coastal waters, soils and sediments near the discharge points. For example, disposal of produced
water poses several threats to marine ecosystems and local effects have been observed in shallow
estuarine or coastal waters. Adverse impacts to mangrove vegetation are the most obvious signs
of environmental effects resulting from produced water spills or discharges. The toxicity of
produced water is directly related to high salinity (3000 to > 350,000 mg/L total dissolved solids
[TDS]) and other parameters such as toxic metals, soluble organics and radionuclides contents.
In the marine environment, contaminants with petroleum–contaminated produced water are toxic
to a wide variety of aquatic organisms or estuarine organisms , therefore, there is no justification
for the continuous disposal of produced water into ecologically sensitive. Although oil spills and
discharges of petroleum–derived waste have plagued the natural environment for the past five
decades, there is an urgent environmental concerns for effective disposal and/or remedial
strategies for this highly saline water. Therefore, there is a need to develop sustainable strategies
to mitigate the effects of past and present petroleum– derived wastes disposal practices

2.2.4. Petroleum contamination of soil, sediment and groundwater

Petroleum hydrocarbon contamination of soil can occur in several ways, from natural seepage of
hydrocarbons in areas where petroleum is found in shallow reservoirs, to accidental spillage of
crude oil on the ground. Activities associated with petroleum exploration and production and
subsequent discharges of hydrocarbon–derived chemical wastes have caused contamination of
soils, groundwater pollution and ecosystem degradation. Ageing oil and gas production facilities
often discharge significant volumes of petroleum hydrocarbon into the agricultural land. The
total petroleum hydrocarbon concentrations levels in soils sampled from petroleum–
contaminated farmland varied from 9-289 mg kg–1 topsoil (0-15cm), 11-413 mg kg–1 subsoil (15-
30cm) and 13-178 mg kg–1 at the greatest depth measured (30- 60cm). Petroleum hydrocarbon
contamination of soil is a widespread and well recognized environmental problem associated
with oil and gas industries.

2.2.5. Human health risks associated with petroleum contamination and environmental
degradation
Discharges of petroleum hydrocarbon into the environment often expose human population
around the contaminated area to potentially dangerous toxic substances. There have been
reported cases of acute health problems among workers involved in the clean–up operation
following the Prestige oil spill in Asturias and Cantabria, Spain. Health effects of exposure to oil
spills in the aftermath of other accidents involving oil tankers and available data on the Prestige
oil spill. Acute exposures to aromatic hydrocarbons, which are common constituents of oil, are
known to cause respiratory symptoms and high molecular weight PAHs are of significant
concern because of the mutagenicity, carcinogenicity and bioaccumulation in organic tissues due
to their lipophilic character. Increasing evidence, mainly from the Prestige oil spill, suggests that
human population exposed to risks may experience long term respiratory effects and
chromosomal damage. It is widely known that exposure to PAHs can cause skin damage,
bronchial symptoms in children and has been implicated in the pathogenesis of skin tumours as
well as chromosomal disorders. The human health effects for the affected population during the
Prestige oil spill may have direct relevance for development of strategies for risks mitigation and
lessons learnt may further provide information for environmental management

2. 2.6. Socio–economic Costs Associated with Petroleum Contamination and Environmental

Degradation
The Niger Delta has suffered all forms of pollution and degradation arising from petroleum
exploration and production, and there are currently over 2,000 oil–polluted sites that need to be
remediated in this region. From the findings of independent experts, an estimated 9-13 million
barrels of oil have been spilled in the Niger Delta since drilling began in 1958 and about 7,000
spills have occurred between 1970 and 2000 . Due to the cumulative impacts of past and present
petroleum exploration and production operations, the Niger Delta has been seen as one of the
most polluted places in the world due to severe contamination associated with the operations of
petroleum industries. The activities of the oil multinationals have adversely degraded the
ecosystem and reduced the biodiversity of the Niger Delta area for several decades, thereby
affecting the general ecology of the area. Although the ecological effects associated with
petroleum contamination have only been spot-wise investigated, it is obvious that petroleum
exploration and production operations have impacted on agricultural soils, terrestrial ecosystem
and pose potential human health risks in the oil–producing host communities in the Niger Delta.
The environmental issues and human health risks associated with petroleum resources
exploration and production has seriously influenced the interaction of the people of the Niger
Delta with their natural environment. According to Aaron, the ecological devastation associated
with the activities of multinational oil companies have adversely impacted upon the original
occupations of the inhabitants of Niger Delta. For example, petroleum contamination has
negatively impacts on agricultural productivity and some people, who originally engaged in
farming and fishing, are facing loss of livelihoods through contaminated land and marine
environment. Over the past 50 years, the multinational oil companies have failed to swiftly deal
with environmental contamination resulting from oil spills, bunkering and discharges of
petroleum–contaminated wastes in the Niger Delta. The failure of existing government statutory
rules and regulations for environmental protection applicable to the Nigerian oil industry have
led to troubling environmental outcomes, failure to implement proper control and effect
preventative measures. However, the petroleum industry has influenced important political
decisions by the government and most of the environmental issues in the Niger Delta are linked
to poor governance (political and corporate) in all its dimension . Therefore, the fundamental
sources of environmental degradation are social problems that occur through the failure of
societies’ institution to deal adequately with a broad range of socio–economic and environmental
problems. As a direct consequence, the oil induced environmental issues and socio–economic
problems could be attributed to the unsustainable exploitation of petroleum resources, poor
governance and ineffective environmental regulations in Nigeria.
 CHAPTER THREE

3.0 DECOMISSIONING AND SITE REHABILITATION

3.1 Introduction
Decomissiong is the process whereby abandonned oil and gas fields are made safe and the land
or sea are reclaimed as much as possible to their original situation, so that they can be used for
other purposes. Agreement that former oil and gas producing sites should be decommissioned is
virtually universal in all oil producing states. There are several reasons for this:

a) Abandoned oil and gas fields are unsafe no mater how depleted an oil and gas field may be
there will always be residual hydrocarbons left below the surface. Unless secured underground
such products may leach out of the ground, polluting the surrounding environment and water
sources. Such pollutants may not just be oil and methane, but include a variety of other materials
notably toxic gases such as hydrogen sulphide, which are dangerous to human health.

b) Drilling for oil and gas invariably produces considerable quantities of industrial waste, notably
drilling fluids cuttings and other solid waste that may remain onsite. Some of this waste may be
polluting and should be removed and disposed of in an approved manner.

c) Abandoned oil and gas infrastructure may get in the way of any alternative use for the land.
Storage tanks, pipelines, buildings and roads may take up considerable space for no good reason
and should be removed. Tanks, if left to themselves, may rust down leaving many potential
safety concerns. Pipelines may present a hazard to future developments, particularly if their
existence is forgotten and they are not completely cleaned or vented. Such infrastructure may
take up a lot of space, which could be returned to local communities.

d) The potentail harzards of abandoned offshore platforms are obvious in terms of both shipping
and fishing. After abandonment and going dark such structures present obvious navigational
harzards. Undersea pipelines present a significant harzard to fishing nets and anchors. In addition
oil platforms contain a wide variety of serious potential pollutants that, if left to rot down will
leach into the sea causing serious pollution.
e) Both onshore and offshore oil and gas installations contain large quantities of recycable
material, from high grade steel and other metals to pumps and other machinery. This may not
just used on other facilities. Much of this material will need to be cleaned and decontaminated,
but it is likely to be highly valuable if well maintained. Unless this process is done in an orderly
manner with expertise, it may be removed, piece by piece, by host communities that may not be
aware of its hazardous nature.

3.1.1 Regulations
Case of Nigeria

Some of the laws that partain to decomissioning after production include

1.This was the Petroleum (Drilling and Production) Regulations (L.N.69 OF 1969), which refers
to the removal of oil equipment and the plugging of oil wells. However, as it was written right at
the beginning of the development of the oil industry it was not specific regarding rules of
procedure or liability. It did not demand any specific decommissioning plan, or detail
requirements for the condition of land, as the priority concern at the time was the prevention of
premature abandonment of wells.

2. Environmental Guidelines and Standards for the Petroleum Industry in Nigeria (EGASPIN) in
1991, and its 2002 revision. This clearly defined the requirement for decommissioning for the first
time. In relation to offshore structures, EGASPIN demands that all abandoned installations
standing in less than 100 metres of water and weighing less than 400 tonnes (without
superstructure) be removed entirely. The process of removal shall avoid any significant adverse
effects on navigation or the environment. Furthermore, after January 2003 no installation can be
placed on the Nigerian seabed unless it is designed so that total removal is possible. In terms of
onshore and near-shore decommissioning, EGASPIN outlines a variety of specific activities that
must take place to gain the required approvals from the Department of Petroleum Resources
(DPR): Isolation of wells from the surface, plugging with surface cement plugs and various other
matters relating the wells themselves. Processing equipment and facilities require appropriate
decontamination, demolition and removal, and the avoidance of conflict with existing land use is
clearly specified. Pipelines have to be decontaminated, excavated or plugged if left on site, while
surface facilities should be removed. EGASPIN demands that this should all be done within a
year of the facilities being abandoned. While EGASPIN is a considerable improvement on
previous regulation, it is still a vague guide with outstanding issues around enforcement and
liability.

3.The Environmental Impact Assessment (EIA) Act of 1992 stipulates that projects over a certain
magnitude in Nigeria require an EIA, which will be reviewed by the EIA Department of the
Federal Ministry of Environment prior to approval.

3.1.2 Problems associted with decommissioning

Many countries are experiencing a developing problem with decommissioning of oil and gas
assets. Major offshore facilities in the North Sea and elsewhere are nearing the end of their life
and the lack of planning and capacity for implementing decommissioning programmes have
highlighted the issue.

Case of Nigeria

(A) Many facilities have no decommissioning plan Many smaller facilities were built prior to the
EGASPIN and EIA rules and thus have no inbuilt plan for decommissioning. In Alberta, Canada,
and the United States of America (USA), where the number of non-producing wells that have
been abandoned but not decommissioned is very large, at least the relevant authorities have a
clear idea of their number and location. Moreover, the EIA act of 1992 makes no reference to
decommissioning of oil and gas assets. All mention to facilities for the petroleum industry relates
to ‘construction’, this is also the case for general infrastructure and waste treatment projects. In
practice, the EIA department will consider whether the ‘decommissioning-phase activities [are]
described, quantified and located on an appropriately-scaled map’ (NACGOND, 2014), yet there
are no set standards or categories. Therefore the very legislation and government department
responsible for overseeing the process does not have the legal backing to require operators to
consider environmental and social impacts of their projects during operation, decommissioning
or post-closure.

(B) The timing of decommissioning is left to the companies. Secondly, the timing of the start of
the decommissioning process has to be more explicitly defined. A significant part of the problem
with facilities left without decommissioning is that companies are effectively allowed to leave
such facilities until the end of the lease, regardless of whether they are producing. The decision
on the timing of decommissioning thus seems to be left to the company’s discretion, usually until
the end of the lease. Ideally companies should be required to report idle installations to the
regulator. The EGASPIN demands that decommissioning should be done within a year of
abandonment, but there is no apparent requirement for the companies to report when a field has
been abandoned or ceased production.

(C) Financial liability for decommissioning is unclear The EGASPIN does not seem to require
any estimate of the potential cost of decommissioning, within the plan, or require
concessionaires to provide proof that they can provide it. Moreover, there is no system to
accumulate such costs while the facility is producing oil or gas. Nor, if the facility is sold to
another operator does there seem to be a mechanism for the first operator to take its share of the
decommissioning liabilities. The danger here, as in other jurisdictions, is that if the facility is left
for long periods after it has ceased production then there will be no money available for
decommissioning.

(D) The system currently lacks a specific decommissioning process Other jurisdictions, notably
Thailand and Mozambique, set out a series of stages that define the obligatory process of
decommissioning. EGASPIN by comparison is not prescriptive. Licensees are “requested to
provide” environment evaluation or a plan if they have not included one in the original project.
In effect companies can produce whatever they originally put in the construction plans, which
will have been already approved. This makes no allowance for any changed circumstances
during the life of the facility. Elsewhere decommissioning is a process that includes consultation
with interested parties in stages, and plans are modified as a result. The decommissioning plan
requirements are frequently defined as “at minimum”. Much of the technical requirements are
outlined by EGASPIN, but not the process whereby the regulator checks that these have been
followed. The EIA Act is not specific enough about the review process of EIAs submitted by
prospective operators, nor does it cover postclosure assessments which are a vital part of
sustainable decommissioning.

(E) Recycling, disposal and remediation are omitted The law specifies a general remediation of
the land in vague terms. This uses the phrase “as far as possible to the original condition”, which
needs much greater definition. Disposal and decontamination – where safety is a major issue –
seems largely left to the company’s discretion.
(F) Unclear provisions for consultation with interested parties EGASPIN does suggest
consultations with host communities, but it is not clear who should do this or how. This is a
major problem because such consultations could be instrumental in improving the current bad
relationship between host communities and the oil producers. Certainly, the host communities
should have some say in how far facilities like roads and buildings should be demolished and
removed. Meanwhile, the scrap value of some redundant materials, or the materials themselves,
could be dispersed locally, not least because it might prevent amateur “decommissioning” by the
community.

(G) No post-decommissioning monitoring or evaluation As things stand, there is little provision

for monitoring the well sites for escaped gas or other pollution after the decommissioning
process. There is also no defined process which an operator must satisfy in order to relinquish
liability for the field.

3.1.3 International expirence in decomissioning

International best practice on oil field decommissioning is fairly straight forward with regard to
offshore fields, and is required by the UN Convention on the Law of the Sea, to which Nigeria is
a signatory. The United Kingdom, Norway and the USA all have well established domestic
regulations governed under their respective Federal or national regulatory agencies (see
bibliography). The process generally has several stages requiring a detailed plan, widespread
consultations with stakeholders and a formal approval process. In contrast to offshore
decommissioning, there are no major international treaties distinctly outlining the requirements
for onshore decommissioning. It is largely controlled within oil production licensing agreements
and host country environmental or planning law. This does not mean that rules relating to
onshore are less important than those for offshore. Onshore decommissioning is poorly regulated
worldwide, partly because it has largely been left to local government authorities, with much less
defined regulation. This has led to significant problems in both Canada and the USA. Currently
Alberta has some 83,000 inactive wells, many not officially abandoned, and none yet
decommissioned. Known as orphan wells, in many cases the original owners have disappeared
and liability for clearing the land is unclear. To counteract this problem, the industry has set up a
not-for-profit organization – the Orphan
Well Association – to decommission these wells with money given by the industry. Meanwhile,
the Alberta Energy Regulator has introduced a levy on existing producers – the Licensee
Liability Rating (LLR) – to help fund existing companies with their decommissioning costs. A
similar situation exists in many states in the USA, with thousands of wells left without
decommissioning or removal. In some states, the state agencies responsible have set up state
funds to fund the removal of these wells sites. Some have a levy on the industry to do so, while
others demand insurance from the companies concerned. This external experience illustrates that
unless detailed regulation and planning is in place, the problem will accelerate and leave the
State with a significant financial and social cost, and many areas blighted with abandoned
industrial waste unsuitable for future use.

3.1.4 Key principles in sustainable decomissioning

A number of key points have been raised that should guide the process of closure and
decommissioning. The following principles should be articulated as minimum standards by the
EIA department and the regulator of decommissioning. Prospective operators should be able to
illustrate that their decommissioning will satisfy the principles in the submission of an initial
decommissioning plan prior to receiving an operator licence. Increasing operator self-regulation
of operations throughout project life-cycles is a vital step towards improving industry procedures,
while making sure that the process of regulation, or the impacts of closure and post-closure are
not borne solely by the Government.

Improving corporate social responsibility and social license to operate of oil and gas companies
will require better closure and decommissioning procedures that have a broader focus than profit,
and demand a better relationship with the communities which they operate within.

Reducing the environmental and social impact of closure and decommissioning will require
thorough planning over many years, verified by experts and the regulator, consultation with
communities and stakeholders. Reclamation and recycling of materials can be maximised with
forward planning, which in turn will reduce the cost of decommissioning and closure. Removal
of hazardous waste and materials that have accumulated in the region through years of
operational negligence can reduce exposure to harmful substances. Rehabilitation of areas
affected during operation can be carried out during decommissioning to start the process of
returning the environment to its natural state and remove the barriers to thriving biodiversity and
local livelihoods.

Financial assurance for decommissioning is an area that needs immediate clarification to ensure
that the cost of implementing activities are known in advance and that funds are available to
execute. Iterative process of learning and development for both operators, regulators, civil
society and government through the establishment and review of a national decommissioning
framework and regulatory regime will strengthen institutional capacity. Monitoring and
enforcement of legislation to protect the social, economic and environmental wellbeing of the
Federation in a uniform way across the oil and gas sector can only be done when supported by a
fair and uniform process, defined by the Federal Government.

3.2. Guidance on sustainable decommissioning of onshore assets

3.2.1 Intergrated Decommissioning into project life cycle

1.1Decommissioning plans should beintergrated into project cycles before operations, prepared
for from projet feasibility stage, nd be intelinked with the remaining life of field or asset so that
suitable preparations can be made

1.2 Design for new production facilities should include features and characteristics to support and
simplify decommissioning and closure to significantly reduce financial, environmrntal, social,
health and safety impacts. Favourable tax benefits would incentivise development and adoption
of beetter technologies

1.3 No operation should start without the development of a conceptual decommissioning and
Rehabilitaion plan drafted at the deign, pre-feasibility and construction phases.

1.4 The conceptual DRP should become more detailed as the project moves into operation, and
as there is a greater understanding of logistical and contextual issues. There should therefore be a
pre-set timetable for periodic review and updating of the DRP, typically every three years. This
should be resubmitted to the regulator for review and approval. The regulator would retain the
right to delay operations if the DRP update is not submitted or not adequate.

1.5 the requirement for an updated and detailed final DRP is deffered until at the earliest five
years and at the latest two years before expected termination of the facility (or expiration of the
license, whichever comes earliest). It is therefore important that the plan is well articulated, prior
to closure date or LoF becoming apparent

1.6 The development of a final DRP takes severl years and must prepare for different scenarious
depending on the factors partiular to the specific field. These scenarios should take into account
the dynamics outline in Environmental Impact Assessment and risk assessments prepared for the
field, and the expectations of stakeholders. As operations enter the final stages, the operator most
give prior notice to the regulatory body who will arrange for DRP review to be put on an annual
or biannual schedule, depending on the complexity of the project.

3.2.2 Removal of Infrastructure

2.1 The DRP should outline a schedule for activities to remove equipment, plans for plugging
and abandonment of production wells, a description of the equipment needed, and an inventory
of hazardous material and chemicals existent in facilities or required for decommissioning, and
plans for their removal.

2.2 Operators and owners should be required to maintain a decommissioned register for the field,
to track the status of assets and their decommissioning. This should be subject to regular audits
to ensure it remains up-to-date and reflects the current state of the plant. The register should be
communicated to the regulator on an annual basis to enable central mapping and tracking of
assets.

2.3 No equipment or ancillary structures should be left abandoned at the site without the explicit
approval of the regulatory authority, affected landholders and local communities. Applications
should be submitted no later than one year before closure accompanied with full testimonies and
supporting documentation from community members, and be reviewed on a case-by-case basis
and agreed with the regulatory body. This will require ongoing consultation and review of EIAs
throughout operations.

2.4 Where consultation concludes that there is local value in remaining infrastructure and/ or
facilities, and/or it is judged pertinent for the development of the area, it may be left in-situ.
Responsibility must be formally transferred to third parties. This should follow a thorough due
diligence process to ensure maintenance and operation liabilities are endowed with appropriate
parties and mitigates local conflicting interests. Under these circumstances, all remaining
structures must be emptied and cleaned.

3.2.3. Disposal of Equipment and Wastes

3.1 A DRP should identify suitable disposal sites for the equipment and materials. Where
dismantling is not possible at site, the logistics of transporting the equipment should be made
explicit in the DRP.

3.2 Operators should illustrate that recycling has been considered to the maximum extent
possible, and that dismantling and recycling prioritises the use of local labour.

3.3 Liquids and wastes must be removed and disposed in a responsible manner. The types and
volumes of liquids and wastes (whether hazardous or not) must be identified in the DRP, with
plans and methods for removal, treatment and disposal outlined for approval.

3.4 The DRP should identify as early as possible any equipment that can be used beyond service
and identify a potential buyer or market, and suitable interim storage facilities.

3.2.4. Restoration and Rehabilitation

4.1 Before decommissioning activities commence, a contaminated land assessment should be
conducted to assess the toxicity of the land – including soil, air and water pollution – to inform
the extent of remediation that is required.

4.2 There should be a reduction of in situ toxicity levels within three to six months of starting
activities. This may require biostimulation followed by bioaugmentation to restore the nutrient
content of soil and groundwater, and promote microbial activity, in an appropriate ratio based on
EIAs and scientific studies for optimum performance of the said habitat. Only approved
bioaugments listed by the regulator should be used for bioaugmentation.

4.3 The final land should be shaped and contoured as far as possible to recreate the original
landscape through the reintroduction of reserves of surface soil amassed during operation and
decommissioning to the cleaned area in the correct order. Where the resources do not permit soil
contouring, artificial banks and energy dissipating structures will be required to mitigate erosion
and flooding.
4.4 Advice from hydrologists and surface water ecologists should be sought on the development
and implementation of DRPs to ensure that the proposed rehabilitation and restoration activities
are sensitive to the predating landscape and water patterns.

4.5 Hydrological restoration should be employed to establish natural water flows to support
regeneration or revival of mangrove forests.

4.6 Selected boreholes may be exempt from plugging if suitably prepared for future use as
monitoring points for ground water toxicity post-decommissioning. Local authorities must be
formally notified.

4.7 The process of rehabilitating vegetation and biodiversity should commence no later than six
months after detoxification to the site and removal of infrastructure, and be concluded within 5
years.

4.8 Where the primary succession has been disrupted or destroyed due to operational or
decommissioning disturbance, a process of re-vegetation should be promoted through the
encouragement of a natural secondary succession process to replace the previous community of
plants and animals.

4.9 Areas that have become flattened or compacted either through operations or
decommissioning activities – such as access roads or location of equipment - should be ploughed
and scarified to enable vegetation to naturally establish.

4.10 The emphasis for species selections should be on naturally occurring indigenous species of
high economic value that will help restore local livelihood options, such as Hibiscus cannabinus,
Manihot Esculenta (cassava), Medicago Sativa (alfalfa), and Alanblackia.

4.11 All alien vegetation that has taken root during operation or decommissioning period should
be removed, and the indigenous mix of vegetation should be restored to the pre-operation levels
outlined in the EIA.
4.12 To support a self-sustaining rehabilitation programme in the long-term, DRPs should
contain activities to build the capacity for local production of vegetation in nurseries for
seedlings and other related activities that will support the ongoing process.

4.13 Owing to the threats to livelihoods, remediation in water bodies should be rapid, followed
by rapid deployment of strategies outlined in the DRP to re-stock fisheries and resuscitate
livelihoods.

4.14 The restoration and rehabilitation must illustrate that the best available scientific information
and experience has been consulted during the development of EIA and DRP.

3.2.5 Contracting
5.1 The contracting process for the DRP should follow the national tendering and procurement
procedures. This includes a forensic due diligence test of the applicants prior to any contractual
agreements.

5.2 The regulatory body should endeavour to develop a proven supply chain and advertise this to
operators so that decommissioning programmes can be supported with best practice procedures
and contract terms and conditions. This channel will be used by the regulatory body whenever
the need for a compulsory relinquishment shall arise.

5.3 It is the sole responsibility of the operator to ensure that no contractors listed on the
regulatory body’s ‘black list’ should be involved in the process of decommissioning.

3.2.6. Stakeholder Engagement

6.1 A comprehensive Environmental, Social, Health and Safety Impact Assessment (ESHSIA)
should be mandatory within submission of the first DRP to establish an understanding of social
context prior to the process. This should be reviewed and updated as part of the schedule to
inform the risk level associated with decommissioning and closure.

6.2 Operators should develop their decommissioning and closure plans with extensive
stakeholder engagement at the design, planning and implementation stages for decommissioning
and closure. Local buy-in and participation in process will ensure successful legacy.
6.3 Throughout operations, there should be a continuous process of community interactions that
inter alia acts as a consultation process for review and feedback on DRPs. This process should
build on the existing oil and gas operator approach that uses a Global Memorandum of
Understanding (GMOU) as a vehicle for effective community participation.

6.4 Operators should encourage the establishment of a community committee to engage with
throughout the process of closure, decommissioning and monitoring. This approach must be
sensitive to existing community governance structures, local power and authority hierarchies,
while illustrating efforts to be gender-sensitive and include vulnerable groups.

6.5 An allocation of decommissioning funding should be assigned locally to community-based

organisations to develop the resources required for remediation and rehabilitation, such as
seedling nurseries and replacement soils, thus stimulating local livelihood opportunities. This
should emphasise prioritisation of indigenous species and environmental management methods.

6.6 Labour-intensive remediation activities should, wherever possible, aim to create employment
opportunities locally for those whose livelihoods have been disrupted by operation and
decommissioning.

6.7 Throughout the process of DRP development and implementation, open and regular updates
should be communicated to the affected communities and other stakeholders to inform them on
what is required to achieve a positive post-closure environment and manage expectations.

6.8 As part of the DRP, the operator should outline any areas where nearby communities and
other stakeholders have become dependent on their activities or support – such as financing for
local services and other CSR activities. This should be accompanied with a clear exit strategy
that explains how these relationships will be managed following closure.

6.9 Operators should have protocol for negotiation and alternative dispute resolution to manage
grievances as and when they should arise at the community level. Local non-governmental
organisations can play a key role in this process where required.

6.10 The stakeholder engagement should encourage reporting into a regulatory feedback
mechanism so that communities can document environmental or human rights violations, and be
used as the basis for improving the process or prosecuting liable parties.
3.2.7. Relinquishment
7.1 Operators should submit a close-out review of all decommissioning activities to the regulator
within four months of the completion, with details of performance targets that meet the protocol
developed for final site inspection, prior to relinquishment. This will include a detailed physical
examination of the site against the EIA and socioeconomic plan, and other commitments
pertaining to the DRP.

7.2 Operators – or other liable parties – should not be relinquished from liabilities until the
objectives, targets and indicators outlined in the DRP have been met and maintained. This
includes progressive rehabilitation.

7.3 A final sign-off process should be introduced to assess performance targets three years after
remediation, which ensures that residues of chemicals have reduced to the required levels,
infrastructure has been removed, land has been returned to the natural state, and that there clear
evidence of a return of previous biodiversity and ecosystem function in line with the EIA and
DRP.

7.4 An independent third party should be commissioned to complete a final audit evaluating
performance in relation to the targets outlined in the DRP, which should be submitted to the
regulator for evaluation prior to final relinquishment. The regulator should retain the right to
withhold relinquishment of liability until it is satisfied that expected milestones and
commitments outlined in the DRP have been met.

7.5 The independent third party should be able to verify that there is no immediate or future
direct, secondary or cumulative threat to the environment, ecological integrity, social, public
health or safety, and where such a threat is envisaged that appropriate mitigation measures will
be instituted.

7.6 Owing to the threats to livelihoods, the operator should be responsible for ensuring that land
farming processes and fishing activities do not resume until after detoxification and/or an
increase in bioavailablity has been confirmed in a toxicity test.

7.7 Where decommissioning activities have not commenced within two years of the end of
operation, or been completed within ten, the regulator should reserve the right to issue a
Compulsory Relinquishment Order for the field. In this scenario, the field owner would forfeit all
rights of ownership to the regulatory body. The regulatory body then undertakes the
responsibility of decommissioning, restoration and rehabilitation, which it can charge to the
liable party.

3.2.8. Post-Relinquishment Monitoring, Auditing and Reporting

8.1 A suitable long-term monitoring and evaluation program should be developed and submitted
to the regulatory body with the final DRP for approval. This should be conducted annually for at
least three years post-relinquishment to ensure that rehabilitation has been progressive and there
is no longer a threat to the surrounding environment, biodiversity or communities.

8.2 To strengthen self-regulation, the burden of monitoring should be vested with the operator
and affiliated third parties and reports will be evaluated and audited by the regulator for
effectiveness and verification of activities and progress.

8.3 Operators must explain how they intend to monitor the environmental impacts of operations
and decommissioning post-relinquishment, such as surface water, groundwater, oxygen levels in
subsurface zones, presence of hydrocarbons, vegetation growth, species abundance and diversity,
basal or canopy cover (whichever is more appropriate), surface erosion, biomass yield, and
fertility status of rehabilitated land.

8.4 Reporting should contain a systematic index of plant species diversity and coverage,
supported by a photo register, to document the rehabilitation of the plant community. 8.5
Socioeconomic impact of rehabilitation should be submitted to the regulator to illustrate that the
activities have avoided negative impact on surrounding communities and that the rehabilitation
undertaken has had a net positive effect and is now supporting sustainable livelihood options
locally beyond closure.

8.6 All reporting and documentation pertaining to decommissioning, including monitoring of

rehabilitation, should be released following relinquishment of the license to enable communities
and other interested operators to take an informed view about the potential for future (re)
development of the area. 8.7 The community committee or representatives engaged throughout
operation should be made part of the monitoring process to ensure that the reporting is inclusive
and valid.
3.2.9. Forums on Improving Decommissioning
9.1 Operators and associated stakeholders should be encouraged to participate in an annual
national decommissioning conference, facilitated by the Federal Ministry of Environment. This
forum would give counterparts a platform to refine the optimal legal, technical, financial,
environmental and social arrangements related to closure and decommissioning of assets

9.2 External actors – such as non-governmental organisations and academic institutions – should
be encouraged to participate in the conferences. Integrating input from other stakeholders will
continually improve decommissioning practices.

9.3 The conferences should serve as a place to discuss and encourage the adoption of voluntary
international practices, such as the Global Reporting Initiative (GRI),

3.2.10. Managing Uncertainty

10.1 Due to the cyclic nature of the oil and gas industries, fluctuations in commodity prices and
other exogenous economic factors, activities necessary to mitigate negative impacts should be
made for temporary shutdowns and be covered in the DRP. This includes securing the well head,
ensuring that all hazardous materials are removed from the site, and secured enclosures
surrounding the facilities are adequate to restrict trespassing.

10.2 Where future field activity can be demonstrated to be feasible, for example with less
extraction undertaken by a smaller company, the DRP should demonstrate that necessary
planning has been made to enable exploration.

10.3 Where ownership of a field is transferred through a merger or acquisition before the LoF has
been reached, closure agreements should be transferred to the new operator. There should be an
initial period in which the new operator can update the plan in line with their capacity, and
resubmit to the regulator for approval. They should then take on the responsibility to schedule
frequent updates.
3.3 Site rehabilitation
The final phase of most oil- and gas-related pipeline and well pad development is reclamation.
The success of a reclamation project has many variables, but the primary causes of difficulties
are a lack of knowledge of surface owners’ rights and poor planning before signing an easement
that pertains to an oil- and gas-related project. When negotiations occur to develop a pipeline,
well pad, or any oil- and gas-related project, discuss the reclamation component while you
discuss an easement or contract for construction. You don’t need to agree upon who performs the
reclamation task, but you should agree on what the land should look like once the project is
complete and who is responsible for achieving that outcome. This publication provides a
checklist for landowners and companies to promote trust and cooperation. The checklist provides
a list of procedures that should be addressed to assure the land will be returned, as close as
possible, to its agronomic productivity level and ecological function.

For cropland: Soil layers (top soil, subsoil, etc.) need to be replaced in the proper order and the
original depths if possible.

For range and pasture land: The plant community ecological function should include reseeding
of appropriate plant species, reconstructing soil layers and landscape grade, and developing a
proper, weed-free seed bed.

The checklist will allow landowners and mineral developers to segregate land type and use.
Examples of land type and use include cropland, rangeland, pastureland and hay land. The
checklist should be used to determine types of information to consider in a reclamation project.
We recommend that baseline data be collected. Any reclamation project also should include a
description of the soil and plant community (when applicable), presence of noxious and invasive
weeds, areas of potential erosion, and landscape (drainage patterns and slope).

Rehabilitated petroleum activity sites should be physically safe to humans and animals,
geotechnically stable, non-polluting and capable of sustaining the post activity land use. Planning
for closure should start in the project feasibility stage. Post petroleum activity land use should be
identified and agreed upon through consultation with stakeholders before approval of any new
projects. The decommissioning, rehabilitation and closure of the Operations Environment Plan
should be developed by a suitably qualified person and:

a) specify the post petroleum activity land use;

b) demonstrate that the agreed post activity land use is ecologically sustainable without posing
unacceptable liability to the State;

c) include a structured risk assessment process to identify, assess and manage the potential risks
associated with decommissioning, rehabilitation and closure, taking into consideration the
baseline environmental data, local climatic conditions, impact sources, pathways and
environmental receptors;

d) include rehabilitation objectives and completion criteria relevant to each of the environmental
factors impacted by the activity. Objectives may include but should not be limited to landforms,
revegetation, fauna, groundwater, surface water, waste and infrastructure. Completion criteria
must be S.M.A.R.T, (specific, measurable, achievable, relevant to the post activity environment
and time bound);

e) detail the project’s decommissioning and rehabilitation activities and timeframes;

f) provide for progressive decommissioning and rehabilitation of disturbed areas not required for
current or future activities, within 12 months of the cessation of the activity;

g) demonstrate that appropriate systems are in place for rehabilitation performance monitoring
and maintenance:

i. with at least annual monitoring of rehabilitation areas;

ii. with trigger levels for intervention and adaptive environmental management;

iii. with threshold levels of acceptable impact beyond which there is likely to be a significant
effect on the environment; and iv. include a commitment that if contamination is detected,
remediation will commence immediately.

h) demonstrate that appropriate reporting systems are in place referencing trends against
predicted performance based on completion criteria; and i) include adaptive environmental
management strategies to be implemented if monitoring results are not trending towards
compliance with completion criteria