Biodiversity & Waste Management in Ugandas oil and gas Sector.

A civil society perspective/concerns

Twebaze Paul,
Deputy Executive Director PROBICOU Chairperson Environment, Land and other Natural Resources cluster , CSCO - 0776340666
A Paper presented at the National Conference on oil and Gas Imperial Golf View Hotel Entebbe 20th -22nd Oct 2013

Outline
Key concepts The Challenge Aspects and biodiversity Impacts Waste management Governance concerns and observations Summary of Recommendations

Key concepts/Definitions

Impact deviation from baseline situation Environment- broadly interpreted: Physical factors of the surrounding of human beings including land, water, atmosphere, climate and the biological factors of animals and plants and the social factor of aesthetics of both the natural and built environment Biodiversity has three components species diversity, genetic diversity and ecosystem diversity. Thus mitigating the potential impacts of oil and gas on biodiversity basically address environmental concerns. Waste - Remains of raw materials, substances or articles that are no longer of economic value to the waste generator and are intended or required to be recycled, reused, treated or disposed of. "waste" includes any matter prescribed to be waste and any matter, whether liquid, solid, gaseous or radioactive, which is discharged, emitted or deposited in the environment in such volume, composition or manner as to cause an alteration of the environment; "hazardous waste" means any waste which has been determined by the authority to be a hazardous waste or to belong to any other category of waste provided for in section 53 of the National Environment (Waste Management) Regulations, 1999; Source: National Environment (Waste Management) Regulations, 1999;

For oil and gas, the major potential environmental concerns are: Atmospheric impacts, ecosystem impacts aquatic and terrestrial; impacts on species; human, socio-economic impacts

The Challenge
The O&G deposits and the sensitive ecosystem are in the same place at the same time!
The Albertain Graben (Arua-Kanungu) is the most important eco - region in Africa as it hosts the continent's most endemic vertebrate species: 14% of all African reptiles 19% of all African amphibians 35% of African butterflies 52% of all African birds 39% of all African mammals 70% of all Ugandan Protected areas are in the Graben

Wildlife Protected Areas

Wild life (The Institute of Resource Assessment (IRA) and The Pan-African START Secretariat (PASS) University of Dar es Salaam, Tanzania (2007)

Wildlife Protected Areas

39 wildlife protected areas including National Parks, wildlife reserves, community wildlife areas, and sanctuaries in Uganda. 22 out of the total of 39 protected areas are national parks and wildlife reserves. 10 out of these are found in the Albertine region. N/Parks in the Albertine Rift include Murchison Falls, Queen Elizabeth, the Rwenzori Mountains, Kibale, Semliki, Bwindi and Mgahinga.

Wildlife Reserves
Ajai East Madi Bugungu Karuma Tooro-Semliki Kabwoya Kyambura Kigezi

Aquatic Resources
Water and Fish resources in Lake Albert, Lake Edward, Lake George and rivers -Albert Nile, Waki, Wambabya, Semliki and Kazinga Channel. Lake Albert is the richest in terms of the fish biodiversity. 53 fish species, about ten of which are endemic, eg Alestes baremose (angara), Hydrocynus forsnkkahlii (ngasia).

Further-Reading
The sensitivity of this area and its detailed biodiversity is well articulated; Plumptre, Behangana et al (2003), The biodiversity of the Albertine rift. Albertine rift technical reports no. 3 (Wild Life Conservation Society), The Institute of Resource Assessment (IRA) and The PanAfrican START Secretariat (PASS) University of Dar es Salaam, Tanzania (2007) Building African Capacity for Conserving Biodiversity in a Changing Climate in the Albertine Region Baseline Assessment Report. NEMA (2009), Sensitivity Atlas etc

Biodiversity - Aspects and impacts from oil and gas operations

Decommissioning License Acquisition & divesting

Refining

Exploration Seismic

Production & Export Development

Drilling Operations

Seismic Acquisition - Impact

Physical Presence Impact on local population / Wildlife Habitat destruction Impact on crops / sacred ground Opening previously inaccessible areas Large workforce up to 600 on large shoots Visual / Noise Health Damage to buildings

Seismic operations Impact

Frightening fauna, particular importance during breeding and nesting Marshes and coastal areas bird breeding and migration resting locations Crushing of small invertebrates and plants by vehicles Vibration (vibrator truck generating vibrations of 8-28 mm/sec at source) Ground shaking causing physical disruption of small burrows waking hibernating animals Explosions frightening animals nesting birds; indirect impacts greater exposure to predators

Exploration - Drilling What are the Aspects and Impacts ?

Drilling Impact
Penetration of aquifer Cuttings and Mud discharges Atmospheric Emissions Other Wastes & Discharges Oil Spills

Drilling Impact
Proximity to human habitation and sensitive habitats/ species Visual Impact Noise (24 hours) - Drilling ops are very noisy Emissions Transport - Increase in traffic volumes Workforce (100+) Itinerant workforce Local workforce Site restoration (Usually a license condition to leave it as you found it )

Drilling Emissions
Main emissions sources Flaring Power Generation (Rig / vessels) Flaring from Well Testing Vehicles

Mud cuttings

Production - Impact
Oil well what do we do with the gas ? Flaring / gas gathering Oil/water separation waste water (formation water) spills / leaks Location: Is the site rural or urban? Habitat: Where is it (e.g. forest, bush, marsh)? Footprint (Landtake): What is the size of site area (including temporary construction)? Noise Issues especially in rural environment Lighting issues especially in rural environment Traffic increase in volumes and in size of vehicles (i.e. more trucks)

Production - Impact

With such light pollution what would be the Impact on aquatic life?

Production Export Operations Pipelines

Export Impact

Refinery What are the Aspects and Impacts?

Heating of oil to separate the hydrocarbon fractions Fractional distillation gasoline kerosene heavy fuel oil

Decommissioning What are the aspects and Impacts?

Must plan ahead Plan for life-cycle Plan for decommissioning Not just engineering

Waste Management
Waste Classification Non-Hazardous Wastes e.g., food waste, plastic, wood..
Bio-degradable

Hazardous Wastes: Used oil, medical waste, explosives...

Non-biodegradable

Specific Waste from petroleum refining

Desalter sludges; Tank bottom sludges; Acid alkyl sludges; Oil spills; Oily sludges from maintenance operations of the plant or equipment; Acid tars; Sludges from on-site effluent treatment containing dangerous substances; Sludges from on-site effluent treatment Wastes from cleaning of fuels with bases; Oil containing acids; Boiler feed water sludges; Wastes from cooling columns; Spent filter clays; Sulphur-containing wastes from petroleum desulphurization; Bitumen; Emissions from oxides of carbon, nitrogen and sulphur, particulates (mainly Generated from combustion processes). Volatile organic carbons are the main air pollutants generated by both sectors.

Further Breakdown of Waste

Liquid Waste from O&G:
Produced water Hydrostatic testing water Cooling and heating systems Sewage Drainage and storm water Tank bottom water Firewater Wash water General oily water

Solid Waste from O&G

Food Plastic Paints Oils and greases/ oily rags Metal scrap Batteries Tyres Wood Paper / cardboard Light bulbs Drums and containers Drill cuttings Produced sand Medical waste

International frameworks-Waste
Basel Convention Uganda gained accession to the Basel Convention in 1999 and must comply with all the requirements of the Convention. protects human health and the environment against the adverse effects resulting from the generation, management, movement and disposal of hazardous waste. obliges producers of hazardous waste to therefore dispose of their waste in an environmentally responsible manner close to where it is generated. Provides Strong controls on the movement, storage, transport, treatment, reuse, recycling, recovery and final disposal of hazardous waste are imposed. regulates the trans-boundary movement of hazardous waste using the Prior Informed Consent Procedure. Bamako Convention Uganda is party to the 1991 Convention: Ban of the Import into Africa and the Control of Trans-boundary Movement of Hazardous Wastes within Africa. Supplementary to the Basel Convention and covers movement of hazardous waste into or between signatory African countries. Analogous function to Basel Convention.

Waste Management status and updates

Currently, all drilling waste is collected at approved waste holding locations as the Government develops the necessary standards and policies on drilling waste disposal and treatment. Temporary waste storage facilities are located in Exploration Area 1 and Exploration Area 2: Permitted through EIA process and corresponding licenses Monitored by NEMA Planned engineered Land fill in Bulisa Waraga D appraisal well to be drilled with closed loop system to reduce amount of waste produced

Tullow currently undertaking Best Practical Environmental Option (BPEO) to determine most efficient methodology for treatment, transportation and disposal of waste including production waste and inform a Basin Wide strategy with Partners and the GoU.

Summary impact of Waste

Wastage of resources Ground contamination Groundwater contamination Visual impact Health issues/vermin

Waste Management Hierarchy

Reduce Generate less waste (be more efficient e.g. packaging return policies) Reuse Select materials / products that are reusable in their original form. Recycling and Recovery Convert wastes into useable materials and/or extract energy or materials from them. Treatment Destruction, detoxification and/or neutralisation of residues. Disposal Depositing wastes using methods appropriate to a given situation.

Waste Management

Waste Management

Further Reading
OGP. Garland, E., Kerr, et al, (2008) Guidelines for waste management - with special focus on areas with limited infrastructure. The International Association of Oil & Gas Producers. Report number: 413. Valeur, J. R. (2010) Environmental Impacts of Different NORM Disposal Methods. Middle East Health, Safety, Security, and Environment Conference and Exhibition. 01/01/2010, Manama, Bahrain, Society of Petroleum Engineers. Douglas A, H. (2002) The acute and chronic effects of wastes associated with offshore oil and gas production on temperate and tropical marine ecological processes. Marine Pollution Bulletin. 44 (3), 185-203. Frost, T. K., Johnsen, S. & Hjelsvold, M. (2002) Environmental Risk Management of Discharges from E&P Activities in the North Sea. SPE International Conference on Health, Safety and Environment in Oil and Gas Exploration and Production. 01/01/2002, Kuala Lumpur, Malaysia. Olsgard, F. & Gray, J. S. (1995) A comprehensive analysis of the effects of offshore oil and gas exploration and production on the benthic communities of the Norwegian continental shelf. Marine Ecology Progress Series, Oldendorf. 122 (1), 277-306.

GOVERNANCE -CAPACITY AND CURRENT PREPREDNESS

Governance Tools National policies, legislations and their scope and reviews; Implementation of international conventions, agreements protocols; Technical measures in place involved; Infrastructure and team work; Means and measures; Enforcement; Duties, responsibilities and rights (Govt, private sector, CSO); Research and data gathering.

Governance -Technical Measures

Preventive and protective measures
Hazard analysis (identification and evaluation); Risk assessment; Identification of Specific categories of operators, handlers etc; Setting Standards and exposure limits; Surveillance and monitoring of the environment; Identification and implementation of Best Practices; Notification, authorisation, prohibition and control; Classification and labelling; Personal protective equipment; Safe methods for the handling, collection, recycling and disposal of hazardous substances.

Governance - Infrastructure Aspects

Competent authority
Organizational frameworks, mechanisms and measures (lead agencies, departments etc);
Mandates, powers, responsibilities, training;

Team work
Inter-agency consultation, coordination, cooperation, collaboration;

Inspection services
Type of system, functions of inspectors, duty facilitating resources;

Environmental services
Presence of in various sectors.

Governance - Means and Measures

Surveillance - of public health in relation to emissions; Documentation and Records - establishment and maintenance of surveillance records, accidents and diseases arising from emissions; Emergency Preparedness and response; Studies and Research. Scope and frequency; Data, information gathering. Dissemination awareness; Transfer of information from operators to agencies and communities.

LEGAL FRAMEWORK
The National Environment Management Policy, 1994; The National Water Policy 1999; The National Oil and Gas Policy, 2008; The Energy Policy, 2001; Petroleum (Exploration and Production) Act Cap 150; Petroleum Exploration and Production (Conduct of Exploration Operations) Regulations, 1993; The Investment Code Act, Cap 92;

CURRENT LEGAL FRAMEWORK

The Land Act Cap 227; The Local Government Act, Cap 243; The National Environment Act Cap 153; The National Environment (Noise Standards and Control) Regulations, 2003; The National Environment (Standards for Discharge of Effluents into Water or Land) Regulations,1999;

CURRENT LEGAL FRAMEWORK

The National Environment (Waste Management ) Regulations, 1999; The National Environment (Wetlands, River Banks, and Lake shore Management) Regulations, 2000; The Occupational Safety and Health act, 2006; The Public Health Act , Cap 281; The Traffic and Road Safety Act, Cap 361; The Uganda Wildlife Act, Cap 200; The Water Act Cap, 152; The National Guidelines on EIA;

Current legislative Effort

Review of the existing legislation and development of new legislation is in progress: The review and/or update of the following legislation has been initiated, to be completed by end of 2013: National Environment (EIA) Regulations, Statutory Instrument No. 153-1 National Environment (Waste Management) Regulations, Statutory Instrument No. 153-2 National Environment (Standards for Discharge of Effluent into Water or on Land) Regulations, Statutory Instrument No. 153-3 National Environment (Audit) Regulations, Statutory Instrument No. 12 of 2006 National Environment (Noise Standard and Control) Regulations, Statutory Instrument No. 30 of 2003, to incorporate vibration pollution National Air Quality standards (NAQS) being developed Draft Oil Spills Regulations and Guidelines National Environmental Act Cap. 153. The National Biodiversity Strategy and Action Plan (NBSAP) under review to include strategies and action plan for oil and gas Compliance and enforcement strategy being developed

OTHER EFFORTS
A draft General Management Plan for Queen Elizabeth National Park has been prepared incorporating oil & gas issues; A draft General Management Plan for Murchison Falls National Park is being prepared; A forest Management Plan for Maramagambo Central Forest Reserve has been finalized; Fisheries frame surveys on Lake Albert & Albert Nile to establish fisheries baseline have been carried out Physical Planning in areas facing intense pressure from oil and gas has been initiated

Institutional Framework
The National Environment Management Authority (NEMA), Uganda Wildlife Authority (UWA) and the Petroleum Exploration and Production Department (PEPD) are the core institutions. Others include: Directorate of Water Resources Management National Forestry Authority Directorate of Environmental Affairs Directorate of Physical Planning and Land use The Department of Fisheries Resources Districts in the Albertine Graben

OBSERVATIONS
On Policy:
Significant level of effort; Lack of substance and subject specificity on O&G in the NEMP; Patchy coverage and inadequate implementation in other related policies; Silence in the major planning policies, and Inadequate linkages between Policy and Implementing Laws. The Policies should be reviewed, harmonised and strengthened.

OBSERVATIONS
On Legislation:
Significant level of effort; When overlaid, there are Gaps and Patches; Lack of the rule of law: Inadequate enforcement; Inadequate linkages between institutions established in the laws; and Lack of specificity on O&G: subject and substance. The legislation should be reviewed in a harmonised coordinated way, and strengthened.

OBSERVATIONS
On Institutional Framework
Inadequate linkages, consultation, and cooperation compartmentalised -no team work ; Insufficient staffing; Inadequate facilitation.
Additional measures still required to improve performance, eg capacity and team building.

OBSERVATIONS
On Data, Information, etc:
There is some data on O&G from different sources.
It is not enough, Often unavailable to the public, inaccurate and not disseminated enough to cause public change;

There is a need for generation of Adequate information

OBSERVATIONS
On Technical Infrastructure:
Inadequate; Inadequate attention to biological and eco monitoring; incompetent laboratories

There is a need to develop: Technical capabilities of existing institutional laboratories with a view to competently implement a mitigation programme.

 On Technical Personnel:

OBSERVATIONS

Inadequate number of trained personnel; Inadequate training for experts; There are gaps in the scope of required disciplines; Inadequate team work across sectors. There is need to produce more experts in the relevant disciplines: Clinical, Environmental and Industrial toxicology Control technology and safety engineering Risk assessment Technological Disasters Waste Disposal Ecotoxicology Analytical Chemistry (trace analysis).

OBSERVATIONS
On Research Capability:
Research capability is inadequate and largely ignored; There is no concerted research programme dedicated to establish the full impact of O&G industry; Epidemiological research is minimal. There is a need to establish ecological characteristics of the sensitive interaction between O&G and the ecosystem that we have.

OBSERVATIONS
On Information and Awareness:
Awareness of impacts and this will lead to suprises; Responsible institutions are weak, and operationally urban; The information that is available is in a form that is not consumable by the majority of community members and the waste operators;

There is a need for: A massive awareness campaign to be mounted (all stakeholders) through an IEC programme aimed at vulnerable communities. Complete information and a user-friendly communication system operational at community level

Storage

OBSERVATIONS- ON OIL AND GAS WASTE MANAGEMENT

Storage for waste is still inadequate; Safety data sheets unavailable down the chain; Inadequately supervised; Not reasonably covered in law.

There is a need for subject and substance specific legislation covering among others: Good design, construction and location; Separation of incompatible materials; Physical conditions of storage (temp, humidity etc); Provision of local and general ventilation; Safe methods of work.

OBSERVATIONS
On Transport:
Concerned about transportation of hazardous materials; Carriers inadequately labelled for hazard identification; Inadequately supervised - loading, unloading, transit; Not reasonably covered in law.

Need for subject and substance specific legislation covering: Integrity of packaging especially bulk goods; Criteria of classification of wastes and substances; Training and informing of operators; Segregation of dangerous goods and decontamination of carriages.

OBSERVATIONS
On Emergency Response and Preparedness:
No preparedness on the ground; Limited supervision; Major Hazard Installations - not registered/monitored; Ill defined, unfunded emergency services other than Fire Brigade; No legal provisions managing emergence and operation of Major Hazard Installations.

There is a need for: Explicit, comprehensive and strictly enforced legislation; Establishment of efficient Major Accident Preparedness and response System operational at national, district and plant levels; and

Establishment of a registry and inventory of dangerous processes, goods, and wastes.

Upcoming Studies related - Operators

Biodiversity Baseline Study (Phase II): To close the gaps identified in Phase I i.e.

confirmation of the presence and extent of critical habitats and determination of the criteria
and level of criticality i.e. tier 1 or tier 2, presence and type of threatened species or habitats. Ecosystem Services Study : To identify existing ecosystem services in EA 2, those on which the project will depend and those most likely to be affected by the project.

Ground Water Mapping: To determine presence and extent of both shallow and deep water
aquifers to guide development planning and issues related to water abstraction for use by the project.

Re-colonisation and Invasive Species Study: To determine level of success of site restoration for both natural and enhanced methods as well as identification of evasive species and recommend methodology for control.

Lake ecology and fisheries: in 2014

Summary of Needed Actions

Improve management systems; Review and strengthen legislation, enforcement; Carry out research; Mount information and awareness; Develop technical capacity; Develop Preparedness and response for technological disasters; and Establish economic justification for action.

CONCLUSION
There is recognisable effort towards O&G impacts. However legislative, technological and administrative measures in place are still inadequate for protecting human health and the environment
The risk is high: vulnerability is high; manageability is still low .

Main constraint is inadequate funding

We want to go away from this!

This is not good, for a country with oil

These people also wanted something better

End
Thank you