This commitment is evident in the contents and the intent of the submitted Environmental Impact Assessment (EIA) for proposed offshore exploratory drilling in the Bain, Cooper, Donaldson and Eneas lease areas.
The completion of such an assessment is consistent with the original licence obligations and requires close collaboration with a number of government agencies and departments across a multitude of disciplines. The EIA systematically identifies, predicts and evaluates as many of the potential environmental impacts as is possible from the drilling of an exploratory well at a simulated location in the Donaldson block.
The simulated well location is at least 15 miles from land and over 25 miles from the nearest inhabited island in waters between 300m and 600m deep. The drilling is estimated to take approximately 100 – 130 days and is targeted to be drilled outside the hurricane season. In the unlikely event that a hurricane were to occur during the course of and in the immediate vicinity of drilling it is planned that, depending on circumstances, all operations would be suspended and the rig moved to a harbour of safety away from risk. At all times, industry standard guidelines (i.e. IADC) for operations in the vicinity of hurricanes will be followed. The Company intends to assure compliance with the highest of either national or international standards, environmental rules or codes of practice that apply to the drilling operations, inclusive of operational integrity, safety and environmental standards of API as well as safety and environmental guidelines issued by the International Oil and Gas Producers Forum (OGP – www.ogp.org.uk) and the International Petroleum Industry Environmental Conservation Association (IPIECA – www.ipieca.org).
In addition, the Company will comply with three international treaties that relate to maritime traffic, vessel collision prevention and environmental protection. These are COLREGs (1972), SOLAS (1974) and MARPOL (1973/1978). The Bahamas is one of 166 IMO member countries. The Company will communicate with local port, marine navigation and fishing authorities in advance of drilling activities, advising them of the rig mobilisation routes, rig locations, exclusive zones and scheduling of events to ensure to the maximum degree possible coordinated and safe simultaneous operations. With the specific intent of protecting all vessels and the health and safety of members of the public in the project vicinity, a safety zone up to 1km radius will be established around the drilling rig with verbal warnings provided by the drill rig captain to approaching vessels.
US Gulf of Mexico
Many thousands of wells have been completed safely in the Gulf of Mexico and drilling has long since been deemed safe enough to resume.
But whilst the economic benefit of this activity is often compelling, a single incident has served a s a salient reminder there is no room for complacency; not even in a single well exploration programme, notwithstanding materially different rock-types, pressures and water depths.
In ensuring the protection of the entire marine ecosystem, a high resolution sea bottom survey has been completed across the whole potential drilling area, including the simulation site. A combination of 3D seismic techniques and 5,000 line kms of high-resolution multibeam, back scatter and sea bottom profile dataset were used to capture a detailed and accurate description of the sea bottom for analysis. Any significant anomalies identified will be assessed immediately, but once the drill rig arrives, to further corroborate the findings of this sea bottom survey/analysis, a remote operated vehicle (ROV) will be used to conduct a visual inspection ahead of commencing drilling operations and again at the completion of the project to ensure minimal impact including the discharge of rock cuttings.
The intent of the Company is to select environmentally-friendly drilling fluids to be used in all aspects of the operation, aligned with the OSPAR principles. OSPAR classifies all common chemicals and additives on a priority listing based on their ecotoxicological data as described in the OSPAR Harmonised Offshore Chemical Notification Format. The chemicals to be used offshore are assessed on toxicity and classified as ‘green’, ‘yellow’, ‘red’ or ‘black’. The Company intends to exclusively use the least impactful green and yellow classified chemicals.
Oil based mud will not be utilised for any aspect of drilling the exploration well. Further, there are no plans to use synthetic drilling fluids and even if their use does become necessary then a strict policy of ‘total containment’ will be followed. All fluids and cuttings associated with the synthetic fluid will be contained upon the rig and at the end of operations, the fluids will be returned to the vender for recycling and the cuttings will be disposed of at a licenced landfill site onshore.
In the normal course of operations, rock chip cuttings will pass through solids control equipment and dryers prior to being discharged overboard. Neither cuttings nor anchors will be placed near sensitive areas (i.e. coral reefs, sea grass beds, submerged archaeological). Industry practices will be utilised to ensure any oil carried on discharged cuttings after washing and drying will be reduced to less than 1% of oil liberated during contained drilling through hydrocarbon bearing zones.
All water draining from decking will be treated prior to finding its way back to the sea to ensure any fluids do not pick up any inadvertent contamination. The discharged fluids, in compliance with industry standards, will have a maximum of 15 parts per million of hydrocarbons in the normal course of operations. Produced water from the well bore aquifer or reservoir will be treated in accordance with the International Finance Corporation (IFC) guidance whereby an absolute maximum oil content of 42mg/l is acceptable, but in the further context where any 30 day average does not exceed 29mg/l.
The Company or operator will develop a project-specific waste management plan, to ensure that all wastes from the drilling activities are properly managed, in accordance with applicable laws and regulations, Company policies and international standards relevant to the oil and gas industry. This objective is to be facilitated by the initial selection of the least hazardous materials available for the project duration. All hazardous materials will be labelled and transported in appropriate containers and stowed as necessary to avoid release to the marine environment by exposure to wind, rain or any other event. Storage areas, containing hazardous liquids, will have secondary containment, such as bounded areas and/or closed loop drainage systems such that even in the event of an incident, no spill overboard is allowed to occur.
Areas of direct and indirect impact studied for the EIA
The Company intends to assure compliance with the highest of either national or international standards, environmental rules or codes of practice implementing fully the lessons learned from previous incidents. Given the experience and expertise held within Bahamas Petroleum Company, the Company is anxious, ready and willing to participate actively in future processes to determine appropriate environmental regulations in whatever manner the Government deems appropriate.
As a final precaution, both the support vessels and the drilling rig will be equipped with equipment and personnel trained to respond quickly and safely. Standard procedures for refuelling, handling and managing wastes and monitoring any potential discharges will be followed during all aspect of operation to ensure protection of the environment is maximised at all times. To minimise the contribution from the project to global greenhouse gas emissions, the Company will implement a series of mitigation measures. A rig audit will be conducted prior to contracting or before the commencement of drilling. It will include a check of all primary diesel engines to confirm that the equipment is in good working order and within manufacturer specifications. The Company will strive to minimise the amount of flaring required and will use modern ‘green burner’ type flares that maximise the complete combustion of all hydrocarbons, which minimises any fallout and/or harmful emissions. The amount of gas flared (if any) will be monitored and the volumes recorded.
Areas of direct and indirect impact studied for the EIA An extensive monitoring process will be implemented for the life of the project to prevent and minimise the contamination of the marine eco-environment involving:
- All running equipment and flaring activities;
- Types of drilling mud, additives and any discharged cuttings;
- Sewage, deck drainage, bilge and ballast water;
- Waste (kitchen, human etc.); and
- Any and all spills along with all mitigation and clean up measures.
If marine mammals (i.e. dolphins, porpoises, seals, sea turtle, whales) are spotted near the path of the support vessels and/or the drilling rig then either speed will be reduced or, based on the distance from the animal, a watch will be posted to monitor and track its path. In the event that hydrocarbons are encountered then offshore oil drilling operators have a responsibility to ensure there is no potential impact on the environment through the loss of well control, containment or a blow out. However, in the extremely unlikely event that a spill were to occur then to properly mitigate and manage effects of this type of incident an assessment has to be made of how any spilt fluid may be transported away from the spill site by the combined affects of tide, current, wind and waves.
To this end a projection has been made by an independent third party through the construction of an oil spill model (OSM). Nowadays the response to the potential impact of any incident needs to be benchmarked against the scale of the Macondo incident in the Gulf of Mexico in 2010 – regardless of the likelihood of such a spill and in the event that absolutely no mitigation measures are undertaken at all.
Thus a long-term simulation covering the sea state and weather conditions prevailing each day over a 7-year duration (from January 2, 2004 to December 31, 2010) was performed, where the release of oil particles was simulated each and every day, so the largest variability in daily conditions could be simulated.
The goal of this simulation was to detail the evolution and movement of an oil spill in any permutation of prevailing conditions during the 2004-2010 period. This extended period enables the inclusion of not only seasonal variations, but also more rapid changes, like those in the ambient Florida Current, as well as the extreme impact of hurricanes, especially given the inclusion of data from the intense 2005 season.
The key output that will help educate the fastest and most efficient response showed spill model trajectories (see map) being highly influenced by the bathymetry of the region (i.e. the natural guidelines of the Great Bahama Bank shelf break). Modelled oil dispersion tended to follow with the currents in deeper waters and less towards the shallow waters. Hurricanes have a noticeable effect on prevailing conditions but only when the epicentre passes directly over the release location.
Given that the drilling programmed to ensure the hurricane season will be avoided makes the probability of the conjunction of each and all of these events at the same time vanishingly small. The projected minimum time to shoreline impact varies depending on the location but is anticipated to exceed 2 days giving a realistic time to mobilise all required equipment from inside and outside of The Bahamas.
To prevent and mitigate the likelihood and impact of any oil spill – whatever the size – the Company is in the process of planning what will constitute maximum response readiness. This involves organising the contracting of spill containment operators and their equipment both in the region and specifically in The Bahamas as well as engaging the Cuban authorities in the requirements of an active spill response.
An environmental sensitivity map has been created prioritising areas of mangroves, coral reefs and other environmental and socioeconomic sensitive areas in the vicinity of the project for accelerated response.
The Company will provide all staff directly involved in the project with the relevant training to promote high standards of competence in the management of health, safety and the environment and in particular pollution control. Incident and emergency response training of appropriate personnel would be conducted prior to drilling. The Company will ensure that the established measures and controls are applied effectively and consistently throughout all applicable phases of the project in order to minimise the impact to the environment.
Blow Out Preventer (BOP)
A large, specialised valve used to control excessive well bore pressures by either closing valves or by more dramatically using steel shearing surface (rams) to cut through drill pipe.
This control equipment has multiple fail-safe systems and more recently can be deployed as a double BOP which is effectively mounting two BOPs sitting above the well bore.