Published in 17/10/2017 -
Author Mauricio Almeida
It is with great pleasure that we continue our program on the topic of "decommissioning." In this chapter, we will address environmental issues related to the decommissioning and abandonment of platforms, especially the Coral Sol platform.
For this, we invited Dr. Mauro Destri, an expert in the oil and gas market, to discuss the major environmental concerns in the decommissioning and abandonment of platforms.
Decommissioning and the Environment and the Coral Sol Platform.
Author: Mauro Destri
Part I – Introduction
Note that I have capitalized the word Environment because the importance of the topic for decommissioning activities, both in Brazil and abroad, is paramount. Between July 6th and 7th, 2016, Petrobras and ANP held a Workshop on the Decommissioning of Offshore Installations, and the main theme was: "Marine Bioinvasion – Challenges for Decommissioning" (see link below).
https://www.google.com.br/url?sa=t&rct=j&q=&esrc=s&source=web&cd=10&ved=0ahUKEwid-qG2ktjWAhVCjZAKHScyC9gQFghYMAk&url=http%3A%2F%2Fwww.anp.gov.br%2Fwwwanp%2F%3Fdw%3D81762&usg=AOvVaw0sMI8zKn6d_Dyzcw8DE4Hp
At that workshop, the problem of bioinvasion by sun coral in Brazilian waters emerged firmly, establishing strong or irreversible interactions with native species. Worse, inspections of ship and platform hulls; equipment; pipelines; Submarine lines show an unprecedented infestation and, worse, it is clear that this species is a predator of native marine life. Questions about what to do, how to combat it, how to prevent it, how to clean it up, still lack a technical solution, let alone a legal one. Therefore, I will begin this article, in which I will try to shed some light on the subject, with the conclusions of the aforementioned Workshop (available to the public via the link above), which state:
• There is no specific regulation on the transport of biofouled maritime units or equipment off the Brazilian coast;
• Underwater cleaning in offshore areas is a risky activity for divers, with high costs, low effectiveness, and which, without containment, can help spread possible invasive species;
• Recent legal and environmental licensing demands related to the sun coral are threatening the continuity of activities in sectors operating in the country's marine environment;
• These demands are leading to operational delays and a significant increase in costs;
• There is potentially interference with the competitiveness of the companies targeted by these demands;
• The sector needs legal security/environmental licensing to operate.
• It is fundamental to consider the business sector, its dynamics of activities and operations, limitations, and cost-effectiveness aspects.
Note that the issue is far from having a technical/legal/commercial/regulatory solution, both on the part of the ANP (National Agency of Petroleum, Natural Gas and Biofuels) and on the part of IBAMA (Brazilian Institute of Environment and Renewable Natural Resources).
Later, I will return to the Workshop and other news about the dilemma of Bioinvasion Versus Decommissioning of Platforms, whether SS/FPSO/FSO or Fixed, and how operators in Brazil intend to address the issue.
Let's go step by step then, contextualizing what a Bioinvasion would be, explaining how a Bioinvasion by Sun Coral occurs, and concluding with a history (timeline) of these in the country.
Bioinvasion is fundamentally a natural process that involves the arrival, establishment, and expansion of a species outside its original geographic distribution, causing environmental impacts (Carlton 1996). However, the frequency of occurrence of this process has reached unprecedented rates, mainly caused by human activities that lead to the breaking of geographic dispersal barriers (Lodge 1993; Elton 1980). In marine environments, the main forms of introduction are navigation, through the unintentional transport of exotic species by ballast water and/or biofouling, and mariculture activities involving exotic organisms and their associated species (Carlton 1987). Among the impacts, problems related to pests (pathogens and parasites) in aquaculture activities stand out, as well as damage to energy production systems due to fouling organisms and, mainly, the loss of biodiversity through competition or predation of native organisms, the formation of hybrids, or even the modification of the physical structure of environments, consequently leading to the alteration of communities and ecosystems (Crooks 2002; Whitfield et al. 2002; Chandrasekaran et al. 2008; Lesser and Slattery 2011).
In fact, biological invasions have been considered the second largest cause of biodiversity loss in the world, second only to processes involving habitat loss (Vitousek et al. 1996; Rosenzweig 2001).
Part II
Sun Coral – Chronology
The term “sun coral” refers to reef-building (stony) coral species of the genus Tubastraea. They are fast-growing, hermaphroditic colonial organisms (they also reproduce asexually) with internal fertilization; their larvae are planktonic and disperse in the water column. They probably produce chemical substances that interact negatively with predators and other competing species.
In Brazil, the occurrence of two species in natural environments has already been recorded: *Tubastraea coccinea* and *Tubastraea tagusensis*.
The risk of introducing exotic species is always considered a potential environmental impact of projects, which is reflected in Environmental Impact Assessments (EIAs/RIMAs). It is considered a negative impact and, as a rule, its importance is associated with the effective establishment of a population of the exotic species. For this type of impact, mitigating measures are usually limited to legal requirements or procedures already commonly adopted, such as ballast water management (NORMAM 20) and the use of anti-fouling paints.
The potential impact of a bioinvasion, in general, has been evaluated in a simplified way in environmental studies (EIAs/RIMAs and similar). Few studies have specifically addressed the problem of the sun coral. This is partly due to the fact that, with the exception of the sun coral, this type of impact occurs infrequently and, considering the absence of systematic monitoring along the entire Brazilian coast and the fact that there is a latency period between the establishment of a "focus" and its detection, it is difficult to identify the vector responsible for a bioinvasion.
History of bioinvasion in environmental licensing conducted by CGPEG/IBAMA (Gustavo Baez Almada, 2014):
In 1999, ELPN (now CGPEG) was created within the organizational structure of IBAMA (ten years after the creation of IBAMA). Ordinarily, bioinvasion has been treated as a potential environmental impact associated with offshore oil and gas exploration and production projects.
Until 2009, there were no demands regarding bioinvasion within the scope of environmental licensing processes or on the agenda of CGPEG/IBAMA. In 2009, a demand was received within the scope of the licensing process for the "TLD in the exploratory prospects of Tiro and Sídon, Block BM-S-40, Santos Basin".
In 2009, the Arvoredo Marine Biological Reserve (ICMBio) established as a condition of its authorization (Authorization No. 44/2009 CR9/ICMBio) for the continuation of the licensing process for the "TLD in the exploratory prospects of Tiro and Sídon, Block BM-S-40, Santos Basin" the presentation, by PETROBRAS, of an Action Plan that, among other points, contemplated the monitoring and control of the occurrence of sun coral in that protected area.
In 2009, CGPEG/IBAMA issued Technical Note CGPEG/IBAMA No. 05/09, which consolidates knowledge regarding the environmental impacts related to offshore drilling activities in oceanic waters (located more than 50 km from the coast or at depths greater than 1,000 m). In this Technical Note, the introduction of exotic species is treated as a potential impact resulting from the commissioning and mobilization of drilling units and the movement of support vessels.
The significance of this impact depends on the "success" of the exotic species in the new environment.
In 2012, CGPEG/IBAMA received a request from MPF/PRAL, based on a complaint received about the occurrence of sun coral on PETROBRAS oil platforms off the coast of the state of Sergipe, to carry out inspections on these units.
IBAMA/SUPES/SE conducted a technical inspection of the platforms in 2013, confirming the occurrence of sun coral colonies encrusted on the structure of units PCM-6 and PDO-1 (Inspection Report No. 01R/2013/SE).
As a consequence, in the licensing process for expanding production in the Sergipe fields, the opinion that supported the Preliminary License (Opinion No. 534/13 LP No. 475/13) requested that PETROBRAS present a strategy for sequential action in measures for identifying, monitoring, and controlling invasive exotic species, with a special focus on the sun coral.
This project should be included in the scope of the Environmental Management Plan (PMA) as a "Biofouling Assessment Project." This project must be approved before the issuance of the Operating License (LO) for drilling activity associated with this process. In 2012, the CGPEG/IBAMA, with logistical support from PETROBRAS, held a three-day "Workshop for Discussion of Mitigation and Control Measures for Bioinvasion Caused by Biofouling." This event was planned within the scope of PETROBRAS' Action Plan for the Arvoredo Biological Reserve. Additionally, its realization also addressed a proposal defined within the context of the complaint regarding the occurrence of sun coral on platforms off the coast of Sergipe. Approximately 80 participants attended, representing: MMA, IBAMA, ICMBio, ANTAQ, DPC-MB, IEAPM-MB, Fund. Florestal/SP, Universities, the Sun Coral Project, PETROBRAS, IBP, Syndarma, and SOBENA.
In 2012, CGPEG/IBAMA issued Technical Note No. 10/2012 – CGPEG/DILIC/IBAMA, which presents “methodological guidelines for the identification and evaluation of environmental impacts” within the scope of CGPEG/IBAMA licensing processes.
According to these guidelines, the risk of introducing exotic species should be treated as an impact associated with the normal conditions of the undertaking (that is, although of a potential nature, it is not associated with accidents or contingency situations, such as oil spills).
In 2013, CGPEG/IBAMA participated in the “1st Operation Eclipse”, organized by EsEc Tamoios (ICMBio) with the support of the Coral Sol Project. The objective of the operation was to remove as many sun coral colonies as possible from the rocky shore of one of the islands that make up this protected area, in addition to promoting integration between institutions related to coral bioinvasion.
More than 12,000 sun coral colonies were removed during approximately five hours of operation.
In conjunction with the “1st Operation Eclipse”, the “1st Workshop on Sun Coral Management in Brazilian Marine Protected Areas” was held, which also included the participation of CGPEG/IBAMA.
The objective of this workshop was to standardize information (state of the art) on bioinvasion in protected areas and to hold debates and discussions on possible actions and approaches to safeguard the integrity of marine protected areas against the threat posed by the sun coral.
In 2013, Information Note No. 01/2013 –CGPEG/DILIC/IBAMA was issued at the request of the MPF/PRM-ANGRA (official letter No. 742/2013 – PRM/ANGRA/RJ/MC). This Information Note presents information on the history of the sun coral bioinvasion in Ilha Grande Bay and on the environmental impacts and damages associated with this bioinvasion, as requested. In 2013, PETROBRAS requested authorization from CGPEG/IBAMA for the management and control of an exotic species (sun coral) encrusted on a Riser Support Buoy (RSB) in the Congro field, Campos Basin (within the scope of the Campos Basin production TAC).
Authorization was requested for the removal of the sun coral colonies in situ, within a 500 m² LDA (Long-Term Diversion Area) and 80 km from the coast, and, if the operation was unsuccessful, the RSB would be towed to Sepetiba Bay to complete the removal operation.
The CGPEG/IBAMA authorized only the attempt at on-site removal, requesting technical supplements and a statement from INEA for the operation to be carried out in inland waters. Authorization was issued in July 2013. However, to date, PETROBRAS has not submitted the requested additional information, nor the report of any operations already carried out, as requested in the opinion that supported the issuance of the authorization.
In 2013, during a trip carried out by CGPEG/IBAMA in conjunction with ANP on the P-52 production platform (Roncador Field, Campos Basin), to conduct an audit of the produced water system of that unit, the occurrence of sun coral colonies on that platform was fortuitously observed.
In February 2014, PETROBRAS urgently requested authorization from CGPEG/IBAMA for the immediate relocation of the P-27 platform (which was 100 km from the coast and at a LDA of 530 m, in the Voador Field, Campos Basin) to the São Roque shipyard (in the Bay of All Saints) for "de-scaling" of sun coral.
The P-27 was in the decommissioning process, having ceased production on December 8, 2013.
The decommissioning project, approved by CGPEG/IBAMA on March 27, 2013, made no mention of the occurrence of sun coral or structural damage to the hull of the P-27. Only in January 2014 did PETROBRAS inform CGPEG/IBAMA about the existence of structural damage to the hull of the P-27, which limited the technological and locational alternatives for managing the sun coral present on the P-27's hull, making immediate transit to sheltered waters necessary.
CGPEG/IBAMA requested an analysis of alternatives, a risk analysis, and an impact assessment on the Bay of All Saints and transit areas of the P-27 to the shipyard (coastal areas and Abrolhos Bank), to support the analysis of the request for authorization to move the P-27. Furthermore, it requested statements from INEMA and the Brazilian Navy regarding the situation.
However, due to the circumstances, PETROBRAS opted for legal action to obtain the necessary authorization, based on a report prepared by a researcher in the field, regarding "the risks and impacts on the environments of the Bay of All Saints and adjacent coastal waters resulting from the presence of sun coral on the P-27 platform." The authorization was obtained through legal means. The aforementioned report also indicates premises that must be observed and the need for subsequent monitoring and control of sun coral in the Bay of All Saints.
IBAMA, through its legal department, sought legal action to compel PETROBRAS to observe the premises considered in the researcher's report, as well as to compel the company to carry out monitoring and control actions for sun coral in the Bay of All Saints, also as recommended in the aforementioned report.
In March 2014, DILIC/IBAMA conducted a training course for its Environmental Analysts on 'Introduction to the Analysis of Marine Bioinvasion by Biofouling'. The course, with a workload of 20 hours, was taught by the Coral-Sun Project team (Marine Biodiversity Institute).
After the course, a meeting was held among the participants to define strategies and next steps regarding the issue of marine bioinvasion within the scope of federal environmental licensing.
Holding this meeting and defining strategies and guidelines for DILIC was already foreseen in the course syllabus.
The meeting resulted in the drafting of a memorandum for the Licensing Director (MEM. 004386/2014 COPAH/IBAMA), through which the respective minutes containing guidelines for DILIC were forwarded, aiming to adapt and improve the procedures adopted in licensing processes regarding the monitoring and control of invasive alien species.
Fourteen guidelines were developed, involving technical and administrative actions, the creation of a database, inter-institutional coordination, and management for the formation of a network of institutions for continuous monitoring.
The control of marine bioinvasion, in general, is a major global challenge, given the reduction or elimination of natural biogeographical barriers through maritime transport.
The problem of sun coral bioinvasion in Brazil, in its current stage, can be considered a serious threat to marine biodiversity.
Managing this problem is complex and demands a coordinated effort from a network of institutions (governmental, universities, private sector, NGOs, etc.) and civil society itself. At the current stage, the eradication of sun coral is unlikely.
Part III Sun Coral – Conclusions
It can be noted, from the brief historical summary above, that much has been thought, much has been discussed, but little has been resolved.
We still don't have answers, at least we haven't been able to find them on the IBAMA/ANP/operator websites, to questions like the following:
– There are already PDs (decommissioning plans) and PDIs (installation deactivation plans), filed with IBAMA and ANP respectively, for the decommissioning of 3 production units, but it is still unclear how the handling/cleaning/disposal of sun coral from the hull/structures/lines/pipelines/risers, etc. will be handled.
What will the process be like?
– If these units are auctioned off like the P-27 and other drilling rigs, such as the PX, for example, will they be able to sail to shipyards in the country itself, and from there continue their journeys, or will they have to be removed from their location to ports abroad?
– As UMS (maintenance and safety units), which need to go to shipyards for maintenance or decommissioning after the termination of contracts, will they be able to sail to such shipyards? Etc., etc.
Answers to these questions could be the difference between our shipyards maintaining and expanding their employment levels, or simply losing more jobs. On the other hand, if a UMS, for example, sails into sheltered waters in the country infested with sun coral, won't it leave behind a trail of these bioinvaders in sensitive areas? How can we mitigate this and find alternative, mapped routes? Is IBAMA prepared to answer these questions and monitor these operations?
On the other hand, how are the research institutions in the country structuring themselves to answer these questions? To combat such bioinvasion chemically or physically.
We have clues, but the country, the oil industry, and everyone around us are in a hurry, and it is urgent that organized society, led by ANP and IBAMA, proactively and constructively, in partnership with the industry and all its stakeholders, find a solution.
Ultimately, I want my grandchildren to have jobs in the future and also be able to eat the fruits that the seas can offer.
Rio de Janeiro, October 8, 2017.
Contacts:
Mauro Destri idestri@uol.com.br
Consultant at Sigma Consultoria
Mauricio Almeida mauricio@pinheiroalmeida.com
President ABECOON http://abecoon.org/ Executive Director at Sigma Consultoria. sigma consultoria rj