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MINISTRY OF ENVIRONMENT

BRAZILIAN INSTITUTE FOR THE ENVIRONMENT AND RENEWABLE NATURAL RESOURCES


ENVIRONMENTAL LICENSING DEPARTMENT
OIL AND GAS GENERAL COORDINATION

TECHNICAL NOTE CGPEG/DILIC/IBAMA No. 04/08

POLLUTION CONTROL PROJECT


Guidelines for the presentation, implementation and preparation of reports in the
environmental licensing proceedings of offshore operations for the exploration and
production of oil and gas

SUMMARY: ...................................................................................................................... page


I – INTRODUCTION ................................................................................................................. .... 2
II– PREMISES FOR THE ESTABLISHMENT OF THE POLLUTION CONTROL PROJECT (PCP) .. .... 2

11.1- Initial considerations ............................................................................................... .... 2


11.2– Objectives ............................................................................................................ .... 3
11.3– Expected results .................................................................................................... .... 4
11.4– Goals .................................................................................................................. .... 4
11.4.1- Goal to reduce the generation of onboard wastes ............................................... ....5
11.4.2- Onshore final discharge goals ......................................................................... ....6
11.5– Indicators ............................................................................................................. .... 7
11.6- Interrelation and integration with other licensing mitigating measures .............................. .... 8
III– GUIDELINES FOR THE IMPLEMENTATION OF PCP .............................................................. .... 8
111.1- Activities onboard the units and vessels .................................................................... .... 8
111.1.1– Equipment ................................................................................................. ....8
111.1.2- Onboard packaging and storage of solid wastes and liquid effluents ..................... ....8
111.1.3- Onboard incineration .................................................................................... ....9
111.1.4- Atmospheric emissions ................................................................................. ....9
111.1.5- Discharge of solid wastes and liquid effluents in the sea ..................................... .... 9
111.1.5.1– Solid wastes .................................................................................. ... 9
111.1.5.2– Liquid effluents ............................................................................... ... 10
a) Oily effluents .................................................................................... .... 10
b) Sanitary effluents and waste waters ..................................................... .... 10
c) Other liquid effluents .......................................................................... .... 11
111.2 - Activities carried out outside the units and vessels ..................................................... .... 11
111.2.1– Collection, maritime transportation, disembarkation and earth transportation of wastes 11
111.2.2- Temporary storage and onshore final disposal .................................................. .... 11
IV- GUIDELINES FOR THE PRESENTATION OF THE GOALS OF PCP AND REPORTS ................ ......11
IV.1 – Documentation setting forth the PCP and the reports ................................................... ....11
IV.1.1 - Seismic survey ............................................................................................. ....12
a) Presentation of PCP goals ........................................................................... .... 12
b) Presentation of report .................................................................................. .... 12
MINISTRY OF ENVIRONMENT
BRAZILIAN INSTITUTE FOR THE ENVIRONMENT AND RENEWABLE NATURAL RESOURCES
ENVIRONMENTAL LICENSING DEPARTMENT
OIL AND GAS GENERAL COORDINATION

IV.1.2 – Drilling ........................................................................................................ ....13


a) Presentation of PCP goals ........................................................................... .... 13
b) Presentation of report .................................................................................. .... 13
IV.1.3 – Production & Flowing .................................................................................... ....13
a) Presentation of PCP goals ........................................................................... .... 13
b) Presentation of report .................................................................................. .... 14
IV.1.4 – Transition period .......................................................................................... .... 14
IV.2 – Documentation proving traceability and information on discharge at sea and atmospheric emissions
.................................................................................................................................15
V – INSPECTION AND FOLLOW-UP .......................................................................................... .... 15
V.1 - Technical Inspection (before license granting) .............................................................. .... 16
V.2 - PCP Follow-up (post license stage) ............................................................................ ....16
VI – FINAL CONSIDERATIONS ................................................................................................. ....16
VII – ANNEXES
Annex 1 – SEISMIC SURVEY – PCP- Technical Note 04-08
Annex 2 – DRILLING – PCP- Technical Note 04-08
Annex 3 - PRODUCTION & FLOWING – PCP- Technical Note 04-
MINISTRY OF ENVIRONMENT
BRAZILIAN INSTITUTE FOR THE ENVIRONMENT AND RENEWABLE NATURAL RESOURCES
ENVIRONMENTAL LICENSING DEPARTMENT
OIL AND GAS GENERAL COORDINATION

I – INTRODUCTION
This Technical Note consolidates the guidelines of CGPEG for the implementation of the
Pollution Control Project (PCP) required in the environmental licensing proceedings of the offshore
operations for the exploration and production of oil and gas, as well for the presentation of said
project and the relative implementation reports.
The Pollution Control Project consists in one of the mitigating measures required by CGPEG
that should be presented by the company and approved by this General Coordination prior to the
granting of a license. Likewise, upon license granting, the immediate implementation of the Project
and submission of reports on such implementation are required, as frequently as defined in this
document.
The implementation of the guidelines set forth in this Technical Note shall occur on a gradual
manner, as described below:
st
1 STAGE - Presentation of this Technical Note for any considerations by the companies.
nd
2 STAGE - One month after the presentation, meetings between CGPEG and the
companies shall be held in order to discuss the content of this document. The
meetings shall be held separately, each with companies carrying out the same
activity (Seismic survey; Drilling; and Production & flowing).
rd
3 STAGE - A new Technical Note with the rectifications that may be agreed upon at such
meetings may be produced. If there is no rectification, the version herein shall be
kept.
th
4 STAGE - During the period of one year (transition period), the version of the Technical
Note defined at the stage above shall be applied and each company shall send
implementation reports, with the quantities generated and disposed onshore.
During such period, the company shall estimate final disposition goals and the
reduction of the generation of the wastes disposed onshore, according to the
specifications in this document, to present them at the stage described below.
th
5 STAGE - At the end of the first year, the companies shall present the goals. Thereafter,
the Technical Note shall be applied one more year, taking into consideration
these goals.
th
6 STAGE - After the two first years, the Technical Note may be reviewed, based on the
observation of the applicability of guidelines.
II – PREMISES FOR THE ESTABLISHMENT OF THE POLLUTION CONTROL PROJECT
(PCP)
II.1 - Initial considerations
A priori, the following considerations shall be observed for clarifications on the PCP:
• Depending on the specificities of the operation, as well as the area intended to its
installation and/or operation, CGPEG may require other actions not listed in this Technical
Note;
• For a consultation to the history of the guidelines and procedures of valid analysis at
CGPEG up to the publication of this document, please consult Technical Note
CGPEG/DILIC/IBAMA No. 03/2008;
• This Technical Note is based on the applicable law;
• The Drilling, Production & flowing units shall follow the procedures described in this
Technical Note, with respect to the solid wastes, liquid effluents and atmospheric
emissions generated by the same;
• The Seismic survey vessels and support vessels, whether or not dedicated to the
operations of the three activities, authorized to transport more than ten people, shall follow
the procedures described in this Technical Note, with respect to the solid wastes and liquid
effluents generated by the same;
TECHNICAL NOTE CGPEG/DILIC/IBAMA no. 04/08 2/17
MINISTRY OF ENVIRONMENT
BRAZILIAN INSTITUTE FOR THE ENVIRONMENT AND RENEWABLE NATURAL RESOURCES
ENVIRONMENTAL LICENSING DEPARTMENT
OIL AND GAS GENERAL COORDINATION

• The support vessels, whether or not dedicated to the operations of the three activities,
authorized to transport up to ten people, shall follow the procedures described in this
Technical Note, with respect to the segregation, collection and onshore final disposition of
the wastes generated by the same;
• The drilling fluids and debris are not addressed in this Technical Note. Although the
mitigation of the impacts arising from the discharge of these effluents continues within the
scope of the Pollution Control Project, CGPEG will issue a specific Technical Note on the
matter;
• The discharge of production water (process water or produced water) is not addressed in
this Technical Note. Although the mitigation of the impacts arising from the discharge of
such water continues within the scope of the Pollution Control Project, compliance with
Resolution CONAMA 393/2007 is required for such discharge. Besides, the monitoring of
the production water treatment process and the verification of the efficacy of that system
shall be implemented by CGPEG by means of a specific Technical Note on the matter, also
to be issued;
• The theme concerning the PCP set forth in the Seismic Environmental Control Plan —
PCAS — is consistent with the content of this Technical Note. Therefore, the companies
having the PCAS approved by CGPEG shall also follow these guidelines;
• Whenever CGPEG licenses operations involving other geophysical methods, such as
Electromagnetic Logging, for example, the requirements to the PCP shall be the same
associated to the Seismic survey;
• The classification of the solid wastes in accordance with standard NBR 10.004/2004, by
ABNT: Class I, hazardous wastes; Class II A, non-inert and non hazardous wastes; and
Class II B, inert and non-hazardous wastes;
• The recycling of the materials that are present in Classes II A and II B solid wastes, such
as paper, plastic, glass and metal (not contaminated with oil or other substances having
any hazardous characteristic), is deemed herein as a type of final disposition. Both the one
performed by companies that proceed with the final transformation of the materials present
in a certain waste and the one performed by companies and (recyclers, collectors, etc.)
cooperatives that receive the wastes, make their screening and transfer to other
intermediary companies or to companies performing final transformation of materials;
• The transformation that takes place with Class I wastes is not deemed as recycling herein,
as a type of final disposition. Depending on what is being transformed, the final disposition
may be classified as decontamination, re-refine or co-processing, for example.
II.2 - Objectives
The fundamental objectives of the PCP are as follows:
a) Generate as less as possible of solid wastes, liquid effluents and atmospheric emissions;
b) recycle as much as possible of the disembarked wastes;
c) proceed to the suitable final disposition, that is to say, according to the legal rules in force, of
all wastes disembarked and non-recycled;
d) seek procedures that minimize the pollution generated by the atmospheric emissions and
solid wastes and liquid effluents that may be discharged into the sea; and
e) continuously improve the procedures listed in the previous items.
11.3 - Expected results
The main expected results of the PCP are as follows:
a) Reduction of atmospheric pollution and alteration and/or degradation of the sea
environment caused by pollutants from offshore operations for the exploration and
production of oil and gas;
TECHNICAL NOTE CGPEG/DILIC/IBAMA no. 04/08 3/17
MINISTRY OF ENVIRONMENT
BRAZILIAN INSTITUTE FOR THE ENVIRONMENT AND RENEWABLE NATURAL RESOURCES
ENVIRONMENTAL LICENSING DEPARTMENT
OIL AND GAS GENERAL COORDINATION

b) Reduction, by means of a suitable final disposition, the pollution that could be


caused onshore by the wastes arising from these operations; and
c) Long-term management of the solid wastes and liquid effluents from the
operations of the company located or arising from a same region.
11.4 - Goals
The company should establish goals for its operations and they shall be consistent with
the previously mentioned objectives and expected results. The goals refer to:
• the reduction of the generation of each type of waste to be disposed onshore;
• the final disposition of each type of disembarked waste.
The goals should take into consideration the Region where the operations are located,
according to the regionalization adopted in Chart 1. Alternatives to such regionalization may
be studied by CGPEG throughout the licensing processes, depending on the peculiarities of
the operations.
Chart 1 – Regionalization of operations

Region Member basins States


1 Pelotas Basin RS
2 Santos Basin (area facing the coast of Santa Catarina, Paraná and São SC, PR, SP
Paulo)
3 Santos Basin (area facing the coast of Rio de Janeiro) RJ, ES
Campos Basin
Espírito Santo Basin
4 Mucuri Basin BA
Cumuruxatiba Basin
Jequitinhonha Basin
Camamu-Almada Basin
Recôncavo Baiano Basin
5 Sergipe-Alagoas Basin SE, AL, PE, PB
Pernambuco-Paraíba Basin
6 Potiguar Basin RN, CE
Ceará Basin
7 Barreirinhas Basin PI, MA, PA, AP
Pará-Maranhão Basin
Foz do Amazonas Basin

The goals shall be approved by this General Coordination.


While there is no statement of CGPEG with respect to the new goals presented, the
company should continue adopting the previously established goals, even upon the expiration of
the validity term thereof.
For the solid wastes and liquid effluents that may be discharged into the sea, as well as for
the atmospheric emissions, the company should seek continuous improvement in the management
processes.
II.4.1 - Goal to reduce the generation of onboard wastes
• Seismic survey
In the Seismic survey, the goal to reduce the generation of wastes should be established at
each operation to which the license is being requested. The reference point for such goal is the
figure achieved in the operation of the same company closed before, regardless of the Region
where the previous operation was installed. If such figure is greater than the one achieved in the
penultimate operation, CGPEG may require the adoption of the penultimate one as reference point.
TECHNICAL NOTE CGPEG/DILIC/IBAMA no. 04/08 4/17
MINISTRY OF ENVIRONMENT
BRAZILIAN INSTITUTE FOR THE ENVIRONMENT AND RENEWABLE NATURAL RESOURCES
ENVIRONMENTAL LICENSING DEPARTMENT
OIL AND GAS GENERAL COORDINATION

If it is a new company in the country, in the operation to which the license is being requested,
it suffices the commitment with the implementation of the PCP according to the guidelines set forth
in this Technical Note, without the need of presenting the goal to reduce generation. Upon license
granting, one should proceed to the implementation of the PCP and submit the relative report with
the figure of wastes generated and disembarked.
• Drilling
The evolution of the date on the generation of wastes in each Drilling operation shall be
followed by this General Coordination, which will study the manner of presenting the generation
reduction goals for this activity. Although it is not mandatory to present generation reduction goals
for this activity, CGPEG will observe the procedures that the company is adopting to seek reduction
in the generation of wastes in its operations.
• Production & flowing
As to Production & flowing, the generation reduction goals are annual and should be
established to each operation for 4-year periods. The goals of all operations in a Region should
respect the same sequence of 4-year periods, in such a way to be valid during the same period.
The figure reached by the operation at the end of the 4-year period in force is the reference point of
the goals set for the subsequent 4-year period.
In the event of a new operation — even for a company already established in the country —,
it suffices the commitment with the implementation of the PCP according to the guidelines set forth
in this Technical Note, without the need of presenting the generation reduction goals. Upon license
granting, one should proceed to the implementation of the PCP and, after one year, the first report
should be submitted. That report shall include the figure of the wastes generated and disembarked.
It shall also include, based on such figure, generation reduction goals for the operation for the
years remaining from the 4-year period in force in the Region. If the submission of the first report
falls upon the third or fourth year of the 4-year period in force, the goals for the remaining time of
such period and the goals for the four subsequent years should be concomitantly established.
It should be observed that the generation reduction goals for both activities having such
requirement (Seismic survey and Production & Flowing) should be defined by the operation. Even
though, the consolidation of the wastes generated and disembarked by all operations is the
procedure used to prove compliance with the final disposition goals, theme of the next item.
Therefore, even with respect to the information on generation reduction goals, it is necessary to
identify the location of the operations, according to the regionalization presented.
II.4.2 - Onshore final discharge goals
Differently from what happens with the onboard generation reduction goals, the
establishment of the final disposition goals is not restricted to a single procedure. For this case, the
measure to be adopted depends on the potentialities of each region, at any time.
The company should care so that each waste is disposed as close as possible to the
disembarkation site. Besides, care should be taken for consistency between the several types of
final disposition and the availability of these services in the Region where the operation is located,
always in compliance with the capacity of the services to generate jobs and use the installed, local
and regional labor force. Therefore, the following priority order should be observed:
i) Return to manufacturer; reuse; recycling; reconditioning; and re-refine.
ii) Other kinds of final disposition (co-processing, decontamination or similar activities; sanitary
landfill; industrial landfill; onshore incineration).
• Seismic survey
With respect to the Seismic survey, the final disposition goals should be established for each
operation, having as reference point the figure achieved in the operation of the same company
closed, in the same Region, prior to the one to which a license is being requested.
In case it is the first operation of the company in the Region, it suffices the commitment with
the implementation of the PCP according to the guidelines set forth in this Technical Note, without
the need of presenting the final disposition goals. Upon license granting, one should proceed to the
TECHNICAL NOTE CGPEG/DILIC/IBAMA no. 04/08 5/17
MINISTRY OF ENVIRONMENT
BRAZILIAN INSTITUTE FOR THE ENVIRONMENT AND RENEWABLE NATURAL RESOURCES
ENVIRONMENTAL LICENSING DEPARTMENT
OIL AND GAS GENERAL COORDINATION

implementation of the PCP and the relative report with the figure of each type of final disposition
should be submitted. The subsequent operations, in the Region, follow the routine explained in the
previous paragraph.
• Drilling
With respect to drilling, for operations having a continuous character, the final disposition
goals are annual and should be established at every 2-year period for the company’s set of
operations in the Region. The figure achieved by the set of operations at the final of the period in
force is the reference point of the goals for the subsequent 2-year period.
Thus, the company should present the final disposition goals for the set of its operations in
the Region for two years rather than at every new operation. Even if upon defining the final
disposition goals it comes to constitute new operation in the Region, the wastes generated by the
same and disembarked should be considered in the general sum of such goals.
In case it is the first operation of the company in the Region, it suffices the commitment with
the implementation of the PCP according to the guidelines set forth of this Technical Note, without
the need of presenting the final disposition goals. Upon license granting, one should proceed to the
implementation of the PCP and the first report should be sent. This report should include the figure
of each type of final disposition, as well as the operation goals for the period of the two subsequent
years, based on such figure. The subsequent periods, in the Region, follow the routing explained in
the previous paragraphs.
In the case of Drilling that do not have a continuity character, the final disposition goals
should be established for each operation, having as reference point the figure achieved in the
operation of the same company closed, in the same Region, prior to the one to which the license is
being requested.
• Production & Flowing
With respect to Production & Flowing, the final disposition goals are annual and should be
established at every 4-year period for the company’s set of operations in the Region. The figure
achieved by the set of operations at the end of the 4-year period in force is the reference point of
the subsequent 4-year period goals. The 4-year period should be the same established for the
waste generation reduction goals of the operations in the Region.
Thus, the company should present the final disposition goals relative the set of its operations
in the Region for the four years rather than at every new operation. Even if upon defining the final
disposition goals it comes to constitute a new operation in the Region, the wastes generated by the
same and disembarked should be considered in the general sum of these goals.
In case it is the first operation of the company in the Region, at the time of applying for
licensing — for any type of license —, it suffices the commitment with the implementation of the
PCP according to the guidelines set forth in this Technical Note, without the need of presenting the
final disposition goals. Upon license granting, one should proceed with the implementation of the
PCP and the first report should be sent. This report should mention the figure of each type of final
disposition, as well as the operation goals for the subsequent 4-year period, based on such figure.
The subsequent periods, in the Region, follow the routine explained in the previous paragraphs.
II.5 - Indicators
The goals should be established values based on the absolute and relative figures described
below. The company may apply other indicator in addition to these, provided that it presents the
advantages and disadvantages of its use.
1.Absolute figures:
a) Total of each type of solid waste and liquid effluent generated in the unit or vessel and
discharged into the sea;
b) Total of each type of waste generated in the unit or vessel and disembarked;
c) Total of each type of waste generated in the set of the company’s operations and
disembarked;
TECHNICAL NOTE CGPEG/DILIC/IBAMA no. 04/08 6/17
MINISTRY OF ENVIRONMENT
BRAZILIAN INSTITUTE FOR THE ENVIRONMENT AND RENEWABLE NATURAL RESOURCES
ENVIRONMENTAL LICENSING DEPARTMENT
OIL AND GAS GENERAL COORDINATION

d) Total of each type of final disposition for each type of waste.


2. Relative figures:
a) Indicator of onboard generation (based upon which the generation reduction goal
should be established):
Total generated and disembarked of each type of waste, divided by the number of
workers of the unit or vessel and by the number of days of the activity informed in the
report (g/man, day);
Although this indicator is not fully suitable to qualitatively evaluate some kinds of
wastes generated, for the purposes of simplifying parameters, this is the relation
adopted herein.
b) Indicator of onshore final disposition (based upon which the final disposition goal
should be established):
Total of each type of final disposition for each type of waste, multiplying by 100 and
divided by the relative total generated and disembarked (percentage).
II.6- Interrelation and integration with other licensing mitigating measures
The control of pollution is directly and indirectly related to other licensing mitigating
measures, and such relation should be taken into consideration in the decision-making processes
during the preparation of the PCP.
With the Workers’ Environmental Education Project (PEAT), the relation is direct. To the
extent the workers incorporate the teachings received from PEAT regarding the control of pollution
generated at units/vessels, the implementation of the PCP becomes more effective, since these
workers are fundamental in the management of solid wastes, liquid effluents atmospheric
emissions onboard.
As examples of indirect relation we could mention the Environmental Monitoring project
(PMA) and the Environmental Education Project (PEA). One of the factors that may contribute to
the degradation of the sea environment is an increase in the level of pollutants that may be caused
by the discharges into the sea of liquid effluents and solid wastes from the operations and such
increase may be detected by the PMA. With respect to the PEA, its guiding principle is the
education for environmental management. Thus, in the municipalities of the influence area of the
operations where, through the PEA, there might be demands related to improvements in the
systems for the recycling and/or treatment of wastes, the PCP actions may be used as boosting
instruments, integrating both mitigating measures.
III – GUIDELINES PARA IMPLEMENTATION OF THE PCP
For the implementation of the PCP, the guidelines described in the items below should be
followed.
III.1 - Activities onboard of units and vessels
111.1.1 - Equipment
The Seismic survey vessels, Drilling, Production & flowing units, as well as the other vessels
involved in the activities shall have the equipment necessary to compliance with the guidelines set
forth in this Technical Note.
111.1.2 - Onboard packaging and storage of solid wastes and liquid effluents
During the onboard storage, the liquid effluents and solid hazardous wastes should be
packaged in containers resistant to pollutant material. The containers should be protected against
sun and rain and positioned at places that shall not cause any risk to the crew and visitors, as well
as to the sea environment by accidental leakage.
For solid wastes, collectors should be installed to promote and make it easy the separation of
these wastes by crew and visitors. The collectors should be positioned at easy access places and
distributed in such a way to contemplate the several generation points. Each collector should
present a color corresponding to the type of waste that should be kept in it, according to the color
TECHNICAL NOTE CGPEG/DILIC/IBAMA no. 04/08 7/17
MINISTRY OF ENVIRONMENT
BRAZILIAN INSTITUTE FOR THE ENVIRONMENT AND RENEWABLE NATURAL RESOURCES
ENVIRONMENTAL LICENSING DEPARTMENT
OIL AND GAS GENERAL COORDINATION

code prescribed in Resolution CONAMA no. 275/2001.


Besides the color, each collector should be identified with the name of the type of waste,
written in Portuguese, even if it already has such identification in foreign language. If the collector
has a plastic bag, where the waste is put for future transportation and disembarkation, plastics
bags should also be used with the relative colors mentioned above.
The packaging of infectious-contagious perforating-cutting wastes should be carried out in
packages specific for such purpose (e.g.: descarpak boxes).
The packaging of used fluorescent lamps, for subsequent discharge, should be made in
containers that provide safety to those handling them and that do not place a risk of contamination
to the environment.
The wastes should be weighed in equipment providing accuracy to the assessed
measurements. Such precision should also be observed for the measurements in volume.
111.1.3 - Onboard incineration
CGPEG requests that the onboard incinerator is always sealed, since it does not recommend
the thermal treatment (incineration) of the onboard wastes of units and vessels.
If it chooses the onboard incineration, the company should prove compliance with the
provision established in Resolution CONAMA no. 316/02. Therefore, the onboard incineration may
only take place upon approval by this General Coordination.
It is also necessary to remind that the wastes generated during the activity may never be
burned outdoors.
111.1.4 - Atmospheric emissions
A half-year inventory of the atmospheric emissions should be performed (with estimated
values) for every Drilling unit and for every Production & flowing unit.
During the transition period described in this Technical Note, CGPEG intends to establish a
discussion with the industry to analyze, among the provisions set forth in Resolution CONAMA no.
382/2006, which of them are applicable to the fixed Drilling, Production & flowing units.
111.1.5 - Discharge of solid wastes and liquid effluents into the sea
III.1.5.1 – Solid wastes
Food wastes, provided that they are triturated and have a 25 mm maximum size, they may
be discharged:
· as from a distance of 12 nautical miles from the coast, by offshore Drilling, Production &
flowing units;
· as from a distance of 3 nautical miles from the coast, by Seismic Survey vessels, as well
as support vessels, whether or not dedicated, o the operations of the three activities.
At every discharge, the measurement of the quantity of these wastes should be made.
No other type of solid waste may be discharged into the sea.
III.1.5.2 – Liquid effluents
a) Oily effluents (deck water and dirt areas, such as engine rooms, for example) may be
discharged, provided that the TOG is equal to or lower than 15 ppm.
At every discharge, the measurement of the volume of these effluents should be made.
b) Sanitary effluents and waste waters (water from toilet bowls, urinals, wash basins,
showers and clothes washing, for example)
With respect to discharge, the following items should be observed:
• Discharges shall not be made less than the distance of 4 nautical miles from the coast;
• For any vessel, discharges may be made at a distance between 4 and 12 nautical miles
TECHNICAL NOTE CGPEG/DILIC/IBAMA no. 04/08 8/17
MINISTRY OF ENVIRONMENT
BRAZILIAN INSTITUTE FOR THE ENVIRONMENT AND RENEWABLE NATURAL RESOURCES
ENVIRONMENTAL LICENSING DEPARTMENT
OIL AND GAS GENERAL COORDINATION

from the coast, only after passing by a treatment system;


• For offshore units, discharges may be made as from a distance of 4 nautical miles from the
coast, only after passing by a treatment system.
With respect to monitoring, the following items should be observed:
• For the offshore units and for all vessels for which treatment of liquid effluents is required,
the volume of these effluents should be measured at every discharge;
• For the offshore units and the line or anchor launching vessels, support diving vessels and
ROV operation support vessels, operating on a continuous base in the Region, such as
those included in the continuous project, the parameters listed below should be measured
on a quarterly basis, under the standard operating condition of the treatment system:
- When entering and leaving the treatment system, DQO parameter;
- When leaving out the treatment system, the parameters: TOG; DBO; total
coliforms; pH; free chloride; organochloride composts (include chlorobenzenes,
dichloroethene, trichloroethene, chloroform, carbon tetrachloride, PCB’s).
• For the other vessels, it is not necessary to measure such parameters.
The residual mud resulting from the treatment of these effluents should be forwarded for
onshore final disposition.
c) Other liquid effluents
For the offshore Production & flowing units, the volume of discharge of the effluents arising
from the sulfate removal units should be measured. Such measurement should be presented
separately for the periods with and without addition of biocide (chock).
III.2 - Activities carried out outside the units and vessels
III.2.1 – Collection, maritime transportation, disembarkation and earth transportation of
wastes
The activities of collection and maritime transportation of wastes should be performed by
vessels certified by the maritime authority.
The wastes should be weighed at every disembarkation or at the temporary storage site,
wherefrom they are transported to later final disposition.
The packages used for disembarkation and transportation of wastes, such as big bags,
buckets and liquid waste tanks should be identified with the type of waste it holds.
The earth transportation of (Classes I, IIA and IIB) wastes should be performed by a
company or cooperative with an environmental license or corresponding authorization, depending
on the determinations of the relative environmental entities of States where such transportation
takes place.
III.2.2 - Temporary storage and onshore final disposal
The following final disposition activities should be performed by a company or cooperative
with environmental license or corresponding authorization, depending on the determinations of the
state environmental entity: temporary storage, reuse, recycling, repackaging, re-refine,
decontamination, co-processing, onshore incineration and disposition in sanitary landfills and
industry landfills.
In the municipality where there is environmental licensing for any of said activities, a
company or cooperative having a municipal environmental license or corresponding authorization,
depending on the determinations of the relative environmental entity.
IV - GUIDELINES FOR THE PRESENTATION OF THE GOALS OF PCP AND REPORTS
All documents concerning the PCP to be presented to CGPEG should be written in
Portuguese.
If the company is subdivided into managing units, it is up to it to present the PCP and the
TECHNICAL NOTE CGPEG/DILIC/IBAMA no. 04/08 9/17
MINISTRY OF ENVIRONMENT
BRAZILIAN INSTITUTE FOR THE ENVIRONMENT AND RENEWABLE NATURAL RESOURCES
ENVIRONMENTAL LICENSING DEPARTMENT
OIL AND GAS GENERAL COORDINATION

relative implementation reports, according to one of the following alternatives:


• of all its operations; or
• of the operations under the responsibilities of each managing unit.
IV.1 – Documentation setting forth the PCP and the reports
The models of documentation the presentation of which is necessary both for the granting of
environmental license and the sending of the project implementation reports, are shown in
Annexes 1, 2 and 3 of this Technical Note. These Annexes, together with this Technical Note, in
addition to the Technical Note CGPEG/DILIC/IBAMA no. 03/2008, are available in the following e-
mail: http://www.ibama.gov.br/licensing
The signature and identification of the technician responsible for the implementation of PCP
should appear in the place indicated in the model of the standard text to be included in the
environmental study.
When presenting the PCP goals and of each of its occasional Revisions, the company shall
send a digital copy (CD) of the full file — with the filed out Tables (concerning the goals) and those
not filled out yet (concerning the relative report). This file should be kept by the company, since it
will serve to subsequent filling out of the report.
Also when presenting the PCP goals and of each of its occasional Revisions, a printed copy
should be sent, in such case, only of the filled out Tables. Each page of these Tables should be
initialed by the technician responsible for the implementation of PCP.
When presenting the report, a digital copy (CD) of the same file used to complete the goals
should be sent, now with all Tables completed (those concerning the goals, filled out at the
previous time, and those concerning the report). With respect to the printed copy, it suffices to send
the Tables concerning the report, with all pages initialed by the technician responsible for the
implementation of PCP. It is possible to present the considerations on the implementation of the
project in the place indicated in the report model.
In the Tables, as well as in all communication between the company and CGPEG involving
information on the quantity of wastes, the weight values should be expressed in kilos (kg) and the
3
volume values, in cubic meters (m ). Even the quantity of the countable wastes, such as lamps and
cartridges, for example, should be informed in one of these two measurement units, the most
convenient one, in view of the type of waste. The onboard generation reduction indicator should be
presented in gram per man per day (g/man, day). The final disposition indicator should be
presented in percentage (%). The units and relations of units applied to parameters not measured
in volume and weight should be informed as indicated in their relative fields of the Tables.
IV.1.1 - Seismic survey
The Seismic survey models are shown in Annex 1.
a) Presentation of PCP goals

Time of
presentation to Document to present
CGPEG
Together with the Table 1 - PCP Goal to reduce the generation of wastes at the seismic ship
environmental study, at
each new operation Table 2 - PCP Final disposition goals

Included in the
environmental study, at Environmental study standard text
each new operation
b) Presentation of report (*)

TECHNICAL NOTE CGPEG/DILIC/IBAMA no. 04/08 10/17


MINISTRY OF ENVIRONMENT
BRAZILIAN INSTITUTE FOR THE ENVIRONMENT AND RENEWABLE NATURAL RESOURCES
ENVIRONMENTAL LICENSING DEPARTMENT
OIL AND GAS GENERAL COORDINATION

Time of
presentation to Document to present
CGPEG
Table 3 - PCP Report set of vessels
Table 4 - PCP Report disembarkation and terrestrial transportation places
Table 5 - PCP Report companies belonging to PCP
Within up to one month
after the end of the Table 6 - PCP Report quantities of generated and disembarked wastes
Seismic survey activity
Table 7 - PCP Report final disposition
Table 8 - PCP Report discharge into the sea
Considerations on the implementation of the project (optional filing out)

(*) In the events of Seismic survey wherein the activity is continuously extended throughout
more than one Region, the company shall send a partial report for activity period, to be
predefined by CGPEG in said licensing. Together with the report, the generation reduction
goals for the subsequent period shall be based on the figures recorded in the same report.
Also in these cases of continuous activity, the final disposition goals, following the
specifications set forth in item II.4.2, should be established for each return of the company
in a given Region, having the figure achieved in the period prior to the activity in the same
Region as a reference point.
IV.1.2 – Drilling
The Drilling models are shown in Annex 2.
a) Presentation of PCP goals
Time of presentation to
Document to present
CGPEG
Every 2-year period for the
group of operations in the Table 2 - PCP Final disposition goals
Region
Included in the environmental
study, at each new operation Environmental study standard text
in the Region

b) Presentation of report
Time of
presentation Document to present
to CGPEG
Table 3 - PCP Report Set of operations, offshore units and vessels
Table 4 - PCP Report Disembarkation and terrestrial transportation places
Table 5 - PCP Report companies belonging to PCP
Annually Table 6 - PCP Report quantities of generated and disembarked wastes
Table 7 - PCP Report final disposition
Table 8 - PCP Report discharge into the sea
Considerations on the implementation of the project (optional filling out)

TECHNICAL NOTE CGPEG/DILIC/IBAMA no. 04/08 11/17


MINISTRY OF ENVIRONMENT
BRAZILIAN INSTITUTE FOR THE ENVIRONMENT AND RENEWABLE NATURAL RESOURCES
ENVIRONMENTAL LICENSING DEPARTMENT
OIL AND GAS GENERAL COORDINATION

IV.1.3 – Production & Flowing


The models for Production & Flowing are shown in Annex 3.
a) Presentation of PCP goals
• Licensed operations (with Installation License, Operations License, Production Previous License
for research) or under regularization, located in the Region, and locations for which one of said
Licenses is required, in the same Region:

Time of presentation to
Document to present
CGPEG

At every 4-year period, for the set of Table 1 - PCP Goal to reduce the generation of wastes *
operations in the Region Table 2 - PCP Final disposition goals **
Included in the environmental study, at
Environmental study standard text
each new operation in the Region
Together with the first report, for the
Table 1 - PCP Goal to reduce the generation of wastes ***
recently licensed operation
Together with the first report, for the
Table 2 - PCP Final disposition goals ****
recently licensed operation

(*) Line or anchor launching vessels, support diving vessels and ROV operation support
vessels, continuously operating in the Region, such as those included in the Continued
project, should be identified in Table 1 – PCP, together with the set of operations. At every
four years, the generation reduction goals of such vessels should be presented. The
operations with Installation License should be identified in Table 1 – PCP, however, the
fields concerning the goals should not be filled out, because a generation reduction goal
is not required for that stage of the operations.
(**) There aren’t final disposition goals specific for the vessels, since the wastes
generated by the same are computed in the final disposition of the set of operations in the
Region.
(***) The first operation report is made up of Tables 3, 6 and 8 - PCP Report. As mentioned
in item II.4.1, a completed version of Table 1 – PCP should be sent together with this first
report. If the submission of the first report falls upon the third or fourth year of the 4-year
period in force, two versions of Table 1 – PCP should be concomitantly presented: the
first with the goals for the remaining time of the 4-year period in force and the second one
with the goals for the four subsequent years. For the new vessel of the continued project,
that same procedure for the submission of goals should be followed.
(****) Only if it there isn’t yet final disposition goals in the Region.
b) Presentation of report
· • Licensed operations (with Installation License, Operations License, Production Previous
License for research) or under regularization, located in the Region:
Time of presentation to Document to present
CGPEG
Annually, for the set of Table 3 - PCP Report set of operations, offshore units and vessels *
operations in the Region
Table 4 - PCP Report disembarkation and terrestrial transportation places
Table 5 - PCP Report companies belonging to PCP
Table 6 - PCP Report quantities of generated and disembarked wastes
Table 7 - PCP Report final disposition
Table 8 - PCP Report discharge into the sea **
TECHNICAL NOTE CGPEG/DILIC/IBAMA no. 04/08 12/17
MINISTRY OF ENVIRONMENT
BRAZILIAN INSTITUTE FOR THE ENVIRONMENT AND RENEWABLE NATURAL RESOURCES
ENVIRONMENTAL LICENSING DEPARTMENT
OIL AND GAS GENERAL COORDINATION

Considerations on the implementation of the project (optional filling out)


One year after the license Table 3 - PCP Report set of operations, offshore units and vessels
granting, for recently
licensed operation Table 6 - PCP Report quantities of generated and disembarked wastes
Table 8 - PCP Report discharge into the sea
(*) The unoccupied platforms, whatever their licenses might be, should be identified in
Table 3 - PCP Report. The wastes generated in this type of platform should be
consolidated with those generated in the (occupied) central Units of the Region for the
purposes of totaling the final disposition. Therefore, there isn’t, for unoccupied platforms,
generation reduction goal and, thus, these platforms are not listed in Table 6 - PCP
Report. If there isn’t an occupied Unit in the Region, CGPEG will establish, together with
the company, the better manner of presenting the data on the wastes disembarked.
(**) Line or anchor launching vessels, support diving vessels and ROV operation support
vessels, operating on a continuous basis in the Region, such as those included in the
Continued project should present information on discharge in Table 8 – PCP, together
with the set of operations. For the other vessels this information is not required.
IV.1.4 – Transition period
Throughout the starting period of one year of application of this Technical Note (transition
period), it will not be necessary to present goals, as already mentioned in the Introduction to this
document.
During this period, the reports mentioned in letters (b) of items IV.1.1, IV.1.2 and IV.1.3
above should be sent, according to the activity.
IV.2 – Documentation proving traceability and information on discharge at sea and
atmospheric emissions
The company should be able to prove the traceability of its wastes from the generation
onboard up to final disposition. It should also have conditions to confirm the information on the
discharge and emissions.
The copies of the documents allowing proving traceability, as well as those ratifying the
information on the discharge and emissions, should remain under the company’s custody and they
should only be submitted upon request of CGPEG. These documents are as follows:
• Wastes control manifests and cards; including digital media;
• Environmental licenses (or authorizations) of the companies participating of the PCP
issued by the sate environmental entities;
• Environmental licenses and waste management plans of ports, port terminals and other
wastes disembarkation places;
• Commitment contracts or letters of the companies participating of the PCP as recipients of
wastes;
• Laboratory reports mentioning analyses of liquid effluents;
• Results of monitoring and records of maintenance of onboard equipment;
• Oil record books and similar documents;
• Results of TOG analyses of oily effluent;
• Inventory of atmospheric emissions from the Drilling, Production & Flowing units;
• Photographic record of the PCP implementation actions. That record should include the
number of photos necessary to illustrate each of the actions (collection of wastes at unit or
vessel; offshore transportation; disembarkation at the port or support facility; temporary
storage; embarkation on trucks of terrestrial transportation; terrestrial transportation; arrival
at the final disposition); and
• Any other documents allowing proving the information presented by the company or clarify
aspects of the PCP and of the reports.
TECHNICAL NOTE CGPEG/DILIC/IBAMA no. 04/08 13/17
MINISTRY OF ENVIRONMENT
BRAZILIAN INSTITUTE FOR THE ENVIRONMENT AND RENEWABLE NATURAL RESOURCES
ENVIRONMENTAL LICENSING DEPARTMENT
OIL AND GAS GENERAL COORDINATION

V – INSPECTION AND FOLLOW-UP


The actions involving the analysis of the PCP by CGPEG are as follows:
a) Before granting the license:
a.1) Analysis of the PCP goals;
a.2) Technical inspection at Drilling, Production & Flowing units, at Seismic survey vessels
and vessels involved in the three activities, at the discretion of CGPEG.
b) At the post-license stage (verification of the implementation of the PCP):
b.1) Analysis of implementation reports of the PCP;
b.2) in loco follow-up.
Therefore, in addition to the PCP and reports that should be presented, the company should
make available, at any time, the units and vessels, as well as it should be able to demonstrate any
action, onboard and onshore, concerning the PCP, for the present action of CGPEG, both in the
technical inspection and the in loco follow-up.
V.1 - Technical Inspection (before license granting)
A technical inspection is performed at the Drilling, Production & flowing units prior to the
granting of the environmental license, involving, among other aspects, those related to the PCP.
The same may occur with the Seismic survey vessels and the other vessels involved in the three
activities.
V.2 - PCP Follow-up (post license stage)
Upon granting of the environmental license, at the discretion of this General Coordination,
the follow-up of the PCP implementation may be scheduled.
Such follow-up aims at observing if the implementation of the PCP follows the guidelines set
forth in this Technical Note, observing the equipment and the actions related to the management of
solid wastes, liquid effluents and atmospheric emissions at units and vessels, as well as the actions
occurring onshore (disembarkation, temporary storage, transportation, reuse; recycling, onshore
incineration; decontamination; repackaging, co-processing; re-refine and disposition in landfills).
VI – FINAL CONSIDERATIONS
This Technical Note presents the guidelines of CGPEG for the implementation of the PCP
and for the presentation of goals and reports on that implementation in the environmental licensing
proceedings of the offshore operations for the exploration and production of oil and gas. More
specific aspects of the project that may exist shall be studied by this General Coordination.
Although it is not possible to mitigate all impacts arising from the oil and gas exploration and
production activities at sea environment, the PCP is one of the mitigating measures required by
CGPEG in the environmental licensing proceedings of these operations. It seeks to reduce the
atmospheric pollution, the degradation of the sea environment and, by means of the suitable final
disposition, the pollution that could be caused onshore by the wastes resulting from these
operations.
Besides these matters, we should reflect upon the lack of devices and systems for the
treatment and recycling of wastes. Even caring for the obligation to which the public government is
subject in the solution of these matters, there is no way to disregard the information
systematization, to be made feasible by the PCP format established in this document, may promote
a discussion on to what extent the oil and gas industry may interfere to revert that scenery.
The regionalization adopted in this Technical Note allow the evaluation of to what extent the
companies are seeking to refrain the synergetic and cumulative impact of pollution on each of the
Regions throughout the time, in addition to allow the observation of the disembarkation routine of
wastes at ports and support facilities and the operations that use, in the whole or in the most part,
the same wastes and effluents management companies, present or not in the relative Region. The
company should care so that each waste is disposed as close as possible to the disembarkation
place, in such a way there is the lowest use or transportation energy, as well as reduction of
TECHNICAL NOTE CGPEG/DILIC/IBAMA no. 04/08 14/17
MINISTRY OF ENVIRONMENT
BRAZILIAN INSTITUTE FOR THE ENVIRONMENT AND RENEWABLE NATURAL RESOURCES
ENVIRONMENTAL LICENSING DEPARTMENT
OIL AND GAS GENERAL COORDINATION

environmental accident risks associated to that transportation.

We understand that these guidelines will contribute to a higher efficiency in the


implementation of the project and that this new format will provide, together with a higher
accomplishment of the in loco follow-up, the optimization and the quickness of the analyses by this
General Coordination. Besides, it is also expected that as from these actions it will be possible to
establish the parameters for comparison between the several aspects of the PCP, as well as
among activities and operations, in addition to cause the integration of this with the other mitigating
measures to become more consistent and effective.
Rio de Janeiro, June 13, 2008.

Ana Pingitore Correia André Souza de Oliveira, M. Sc.


IBAMA Environmental Analyst IBAMA Environmental Analyst
SIAPE Registration no. 1545680 SIAPE Registration no. 1300422
Beatriz da Silva Abrahão Clarisse Rinaldi Meyer, M.Sc.
IBAMA Environmental Analyst IBAMA Environmental Analyst
SIAPE Registration no. 1574752 SIAPE Registration no. 1331664
Daniel Salles Corrêa de Oliveira Fabiane Borges Lino Campos, M.Sc.
IBAMA Environmental Analyst IBAMA Environmental Analyst
SIAPE Registration no. 1542175 SIAPE Registration no. 1572181
Gilberto Moraes de Mendonça, M. Sc. João Carlos Nóbrega de Almeida
IBAMA Environmental Analyst IBAMA Environmental Analyst
SIAPE Registration no. 0305550 SIAPE Registration no. 1572182
Leandro Lantmann Morais Lívia de Almeida Rodrigues
IBAMA Environmental Analyst IBAMA Environmental Analyst
SIAPE Registration no. 1413636 SIAPE Registration no. 1572185
Marcelo Cruz dos Santos Patrícia Maggi, Esp.
IBAMA Environmental Analyst IBAMA Environmental Analyst
SIAPE Registration no. 1510958 SIAPE Registration no. 2442042
Rafaela Rinaldi, M.Sc. Vanessa Horta da Silva
IBAMA Environmental Analyst IBAMA Environmental Analyst
SIAPE Registration no. 1513236 SIAPE Registration no. 151420

TECHNICAL NOTE CGPEG/DILIC/IBAMA no. 04/08 15/17

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