Professional Documents
Culture Documents
Ibama - 04 - 2008
Ibama - 04 - 2008
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
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
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 (*)
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)
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