Professional Documents
Culture Documents
SPE 27091 Environmental Issues in Oil and Gas Development in Malaysia
SPE 27091 Environmental Issues in Oil and Gas Development in Malaysia
SPE 27091
This paper was prepared lor presentation at the Second International Conference on Health, Safety & Environment in Oil & Gas Exploration & Production held in Jakarta, Indonesia,
25-27 January 1994.
This paper was selected for presentation by an SPE Program Committee Iollowing review of information contained in an abstract submitted by the author(s). Contents of the paper,
as presented, have not been reviewed by the Society of Petroleum Engineers and are subject to correction by the author(s). The material, as presented, does not necessanly reflect
any position of the Society of Petroleum Engineers, its officers, or members. Papers presented at SPE meetings are subject to publication review by Editorial Committees of the Society
of Petroleum Engineers. Permission to copy is restricted to an abstrect of not more than 300 words. Illustrations may not be copied. The abstract should contain conspicuous acknowledgment
of where and by whom the paper is presented. Write Librarian, SPE, P.O. Box 833836, Richardson, TX 75083-3836, U.S.A. Telex, 163245 SPEUT.
113
2 ENVIRONMENTAL ISSUES IN OIL AND GAS DEVELOPMENTS IN MALAYSIA SPE 27091
the onshore processing facilities and distribution (a) Oil and gas fields development.
network. (b) Construction of off-shore and on-shore
pipelines in excess of 50 kilometres in
ENVIRONMENTAL LEGISLATION length.
(c) Construction of oil and gas separation,
The principal legislation relevant to onshore and processing, handling and storage facilities.
offshore petroleum developments in Malaysia are (d) Construction of oil refineries.
the: (e) Construction of products depots for the
storage of petrol, gas or diesel (excluding
• Environmental Quality Act, 1974 (EQA) service stations) which are located within
and amendments 3 kilometres of any commercial, industrial
or residential areas and which have a
Exclusive Economic Zone Act, 1984 combined storage capacity of 60,000
(EEZ) barrels or more.
The Environmental Quality Act, 1974 The EQA and associated Orders and Regulations
(Amendments) 1985 was enacted for the prevention, are not, strictly speaking, applicable outside
abatement, and control of pollution and Malaysian territorial waters. Malaysia's territorial
enhancement of the environment. The Act specifies waters is generally 12 nautical miles, subject to
that waste is not permitted to be discharged into the certain adjustments in relation to the Straits of
environment in contravention of · acceptable Malacca and in other areas adjacent to Singapore
conditions. Industrial facilities are required to and Indonesia.
comply with bQth air emission and effluent
discharge standards · which are stipulated in Offshore installations which are situated outside
subsidiary legislation enacted under the 1974 Act. Malaysian territorial waters are governed by the
These standards are regarded as acceptable Malaysian Exclusive Economic Zone Act which
conditions of emission and discharge. Under the was enacted in 1984 for the preservation and
EQA, fifteen sets of Regulations and Orders have protection of the marine environment. The EEZ of
been introduced and enforced to date. Malaysia is an area beyond and adjacent to the
territorial sea of Malaysia and, subject to certain
Additional relevant regulations enacted under the clarifications extends to a distance of two hundred
EQA include: nautical miles from the baselines from which the
breadth of the territorial sea is measured. Under
Environmental Quality (Clean Air) this Act, Malaysia bas the sovereign right to exploit
Regulations 1978; her natural resources in the EEZ pursuant to her
environmental policies and in accordance with her
Environmental Quality (Sewage and duty to protect and preserve the marine
Industrial Effluent) Regulations 1979; environment.
• Environmental Quality (Scheduled Wastes) A new Act on marine pollution, shippers' liabilities
Regulations 1989; and compensation for oil spills is likely to be
enforced next year. The Merchant Shippers (Oil
• Environmental Quality (Prescribed Pollution) Act, 1993, will enable Malaysia to
Activities) (Environmental Impact implement two major International Maritime
Assessment) Order 1987. Organisation (IMO) conventions - the Civil
Liability Convention 1969 and the Fund Convention
Under the Environmental Quality (Prescribed 1971. The Act confers wide powers on the Director
Activities) (Environmental Impact Assessment) of Marine Department to take action to prevent or
Order 1987, all developments classified under a reduce the extent of pollution through the escap,e of
Prescribed Activities List requires an Environmental oil or other harmful substances. Currently legal
Impact Assessment (EIA) to be submitted before action against errant shippers could only be taken
the proposed project can be considered for approval through civil suits.
by the relevant federal or state authorities.
Petroleum developments are included under the Malaysia has not ratified the MARPOL 73{78, the
Prescribed Activities List which covers: most well known of the Oil Pollution Prevention
Conventions. The primary reason cited for its
114
SPE27091 D EVANS & E F YONG 3
failure to do so is lack of adequate waste disposal development (in particular sour service installations)
and reception facilities required to implement the with respect to the provisions for process venting
Convention. However the country is in the process and system depressurisation facilities.
of amending certain maritime regulations to enable
ratification, implementation and enforcement of the Noxious and Offensive Substances
MARPOL Convention.
The occupier of any industrial facility is required to
ATMOSPHERIC EMISSIONS use Best Practicable Means (BPM) to prevent the
emission of noxious or offensive substances; these
The Malaysian Government has not yet established substances are listed in the Third Schedule of these
standards for air quality but has adopted guideline Regulations and includes fumes from petroleum
levels [1] (Recommended Malaysian Air Quality works.
Guidelines RMAQG); for a number of pollutants as
shown in Table 2. Department of Environment (DOE) Approval
Emissions of pollutants to atmosphere are covered Written approval from the Director-General is
under the Environmental Quality (Clean Air) required prior to the installation, re-siting or
Regulations, 1978. Particular relevant emissions alteration of incinerators, fuel burning equipment,
that are covered by these Regulations are smoke, flares and chimneys.
hydrogen sulphide, noxious and offensive
substances. Since there are no specific emission limits stated for
the above emission sources, assessment of the
There are currently no emission limits specified for impact of combustion process emissions on local air
oxides of sulphur and nitrogen from combustion quality must be undertaken during the project EIA
sources such as gas turbines, process heaters and to ensure ground level pollutant concentrations are
flares. within acceptable limits and will not result in
exceedance of air quality objectives (fable 2). A
Smoke thorough assessment of potential air quality impact
during the EIA will enable the requirements for
Emissions of smoke are covered under Part N of mitigation/abatement plant to be identified; this
the Regulations, smoke emissions during normal mmnmses the likelihood of expensive and
and upset operational conditions must not be darker disruptive retrofitting of abatement equipment when
than that designated as Shade No.1 on the the installation is fully operational. Conducting an
Ringelmann Chart. Emissions of smoke from an environmental assessment during the initial design
installation are permitted to exceed Ringelmann stage is therefore recommended.
Shade No.1 for an aggregate of less than 5 minutes
in any period of one hour providing the total period Contravention Licence
of such emissions does not exceed 15 minutes in
any period of 24 hours. The Director-General can Under Regulations number 49, an operator can
direct operators to provide a monitoring system apply to the Director General for a licence for the
such that potential emissions of smoke from the purpose of contravention of acceptable conditions.
process can be detected from within the control A licence to contravene acceptable conditions will
room. be granted by the Director General providing:
115
4 ENVIRONMENTAL ISSUES IN OIL AND GAS DEVELOPMENTS IN MAI.AYSIA SPE 27091
These Regulations do not currently apply beyond Director General for a licence for the purpose of
Malaysian territorial waters; this is currently under contravention of acceptable conditions (effluent
review and in the near future the jurisdiction of discharge limits). A licence to contravene
these Regulations may be extended to include the acceptable conditions will be granted by the
EEZ. Director General providing:
116
SPE 27091 D EVANS & E F YONG 5
complying with discharge limits may still result in lead to the conclusion that any hydrocarbons not
deteriorations in water quality at the point of separated in the caissons will usually become
discharge. rapidly dispersed in the water body.
Marine Water Quality Standards Under the EEZ Act, any accidental discharge or
escape of mixture containing oil or pollutant from
The Malaysian Government has not yet established an offshore installation shall immediately be
standards for marine water quality but has adopted reported to the Director General of the Department
interim guideline levels [2]. These interim of Environment or any other public officer to whom
guideline levels are based the standards adopted in the Director General has delegated such power in
the Peoples Republic of China and Japan. Levels writing.
of water quality have been established according to
water body uses. Type 1 water quality is for the The contractor is required to employ every practical
conservation of marine and aquatic resources and means to contain, cleanse or abate the spill or
safe utilization by humans. Type 2 water quality is accidental discharge and to recover the substances
for recreation purposes and Type 3 water quality is involved in the spill or·accidental discharge. The
for industrial processing, ports and harbours and waste generator shall also be required to produce
offshore development The interim marine water the technical expertise and supporting assistance in
quality standards are presented in Table 4. the clean-up operation. The law also requires the
contractor to undertake studies to determine the
The Malaysian EEZ Act 1984 requires all aqueous impact of the accidental discharge on the
effluent from process units and operational environment over a period of time which is
discharges to be treated prior to discharge to the determined by the Director-General or any public
marine environment. The 100 ppm oil limit officer delegated by him in writing.
stipulated under this Act therefore applies to drill
mud/cutting, produced water and drainage There are no specific legislative instruments
discharges from offshore installations. Compared to controlling the discharge of drill muds/cuttings
the discharge limits for oil contaminated effluent (providing oil content does not exceed the EEZ
enforced on offshore operators in other countries, limit of lO0ppm) and hydrotesting fluids during
an effluent oil concentration of lO0ppm is relatively pipeline hydrotesting.
straightforward to achieve and a number of oil
companies have adopted more stringent Generally, two types of drilling muds are used in
specifications (eg 40 ppm) with future targeted offshore drilling operations in Malaysia, water
limits in the region of 10 ppm. based mud and oil-based mud. Drill cuttings are
typically discharged overboard while drill muds are
Produced water is either re-injected via a dedicated recovered and recycled.
disposal well or passed through oil separation
equipment prior to discharge to the marine The heavier fraction of the drill cutt":Igs will
environment. Both corrugated plate interceptors accumulate in the surrounding sediments. Various
(CPI) and hydrocyclones provide sufficient oil studies have shown that the concentrations of lead,
separation efficiency to meet the regulatory nickel, vanadium, zinc and especially barium
requirement (100 ppm of oil in the effluent). increase in bottom sediments after drilling,
especially in the direction of the dominant currents
Other potentially contaminated effluent streams [3][4].
arise form rainfall run-off, washdown water, vessel
flushing and draining and the platform drainage Drilling muds and cuttings discharged overboard
system. Discharges from non-contaminated areas may change the seabed environment, by physically
are routed directly to the sea. Contaminated smothering the benthic organisms. In addition
effluent streams are typically routed either to the changes in the particle size distribution of the
closed drain system which discharges into a process sediment can result in changes to the effective
caisson; or the open drain system flowing into an habitat types of the area. The extent of changes in
atmospheric caisson. The caissons are intended to the macrobenthic community is dependent on the
act as oily water separators. number of wells drilled, the speed of drilling and
the current regime in the area. The effects due to
The intermittent nature of discharges and the the discharge of drilling muds and cuttings on the
dilution capabilities of the receiving water body benthic community are sometimes very severe but
117
6 ENVIRONMENTAL ISSUES IN OIL AND GAS DEVELOPMENTS IN MALAYSIA SPE 27091
The drilling muds and cuttings can contain high Storage of Waste
dissolved salts with high pH values and higher than
ambient temperatures. Studies on various water Scheduled wastes must be stored in containers
quality parameters such as suspended solids, light which are sufficiently durable to prevent spillage or
transmittance, dissolved oxygen, pH, temperature leakage into the environment. Waste storage areas
and salinity around platforms have shown that most and containers must be clearly identified/labelled.
water quality parameters are not affected, with the Incompatible wastes must be segregated for storage.
exception of suspended solids and light
transmittance [11][12]. Effects of discharges to the Transport of Waste (Consignment Note System)
marine environment tend to be minimised naturally
due to the buffering capacity of the seawater and Transportation of waste from the waste generator to
the rapid dilution of the discharges by ocean the treatment and disposal facilities must conform
currents. with the consignment note · system. The
consignment note system provides a documented
WASTE HANDLING, STORAGE AND record of the movement of waste from the generator
DISPOSAL to its approved destination.
The handling and disposal of hazardous and toxic The waste generator is responsible for monitoring
waste materials is covered under the Environmental the transport of waste to its approved destination
Quality (Scheduled Wastes) Regulations 1989. and must also inform any transport contractor as to
Under the First Schedule of these Regulations, 107 the nature of the waste and the actions to be taken
categories of toxic and hazardous waste have been in the event of an accident during transportation.
classified as scheduled wastes.
Disposal of Waste
These Regulations introduce the "cradle to grave"
waste management concept whereby a historical Under the Environmental Quality (Prescribed
record must be maintained providing documented Premises)(Scheduled Waste Treatment and Disposal
details of the life-cycle of the waste from its Facilities) Order 1989, scheduled wastes can only
generation through to its ultimate disposal. This be disposed of at licensed premises. At present,
management concept is implemented by the since the Department of Environment has not
following requirements specified by these licensed any disposal facilities for the disposal of
Regulations: scheduled wastes, the waste generator is allowed to
safely contain and store on-site or offsite scheduled
Notification of Waste Generation waste arisings until such premises are identified.
Any scheduled waste generated after the The possibility of exporting waste to foreign
Regulations came into force must be notified to the countries does exist subject to obtaining prior
Department of Environment in writing (scheduled approval from the Department of Environment and
waste is any waste falling within the categories of also the importing governmental authorities.
waste listed in the Schedule) within one month of
its generation. Domestic and Industrial wastes generated on
offshore platforms are transported to shore for
Waste generators must immediately notify the dispo·sal in local dumping sites or recycled (eg.
Department of Environment of new categories and paper and metal scrap). Sewage and perishable
changes in the quantities of waste which are or food wastes are macerated and discharged direct to
which may be generated as a result of any alteration the marine environment.
in the operation conducted at the plant.
The disposal of scheduled waste ansmgs is a
problem due to the absence of approved disposal
facilities. As a result some operators currently store
118
SPE 27091 D EVANS & E F YONG 7
Scheduled wastes such as spoilt chemicals, spent oil the nearest communities.
or grease, solvents and sludges on site.
In Malaysia, legislation has been enacted to limit
Petronas and other operators have licences to carry personnel noise exposure levels (Factories and
out land farming to biodegrade oil sludge at their Machinery (Noise Exposure) Regulations, 1989),
premises. The disposal of sludge must comply with enforced by the Factories and Machinery
scheduled waste regulations. Department (FMD). These Regulations place a
number of duties on employers with the overall aim
The presence of Technologically Enhanced of controlling noise in the workplace. One primary
Naturally Occurring Radioactive Material requirement is that no employee shall be exposed to
(TENORM) (i.e. uranium, thorium and their noise levels exceeding an equivalent continuous
respective daughters) in oil and gas installations has sound level of 90 dBA; if personnel noise exposure
been recognised in Malaysia. The Atomic Energy levels exceed this limit, noise levels must be
Licensing Act 1984 requires authorization by the reduced by engineering and/or administrative
appropriate authority prior to any accumulation or means.
disposal of radioactive material. The Atomic
Energy Licensing Board has issued Guidelines on Although the FMD regulations do not currently
Radiological Monitoring for Offshore Oil and gas apply offshore, many operators are applying the
facilities Operators associated with TENORM. standards as minimum standards to be achieved on
Sludges collected must not be accumulated or their offshore platform.
disposed of without prior approval of the Board if
the activity · exceeds 0.1 Bq/g for radioactive In fact, because the problem of noise on offshore
nuclides in the uranium or thorium series. The oil and gas installations is now one of great concern
transportation of any scales, sludges, contaminated to the operators more attention is being given to
tubing, or equipment must be in accordance with the assessment of noise levels at the design stage -
the requirements of the Radiation Protection so-called "acoustic design" work. Although, clearly
(fransport) Regulations 1989. not an environmental issue, on a number of recent
offshore projects, a preliminary acoustic analysis
NOISE has been carried out as part of the EIA. Such
design work allows potential problems to be
Noise levels generated by the construction and identified and solutions to be developed while the
operation of onshore facilities fall within the installation is still "on paper"; this provides
responsibility of two government departments. considerably greater flexibility in the control
Environmental noise levels (noise· levels at or measures considered.
outside the boundaries of the plant) generated by
the plant are covered by the Department of Most of the major noise sources will be common to
Environment and stipulated in 'Guidelines for the both offshore and onshore plants. It is good practice
Siting and Zoning of Industries' whilst protection of to include remedial treatment from an early stage.
site personnel from the effects of excessive
exposure· to . noise is the subject of the 'Factories It is important to consider simultaneously the
and Machinery (Noise Exposure) Regulations, 1989 environment and occupational · aspects when
[13). Many operators also have their own internal addressing equipment noise limits. and possible
standards. noise control measures. A measure which reduces
on-plant (occupational) noise levels significantly
Guidelines for the Siting and Zoning of Industries may have little benefits in terms of environmental
noise levels at remote.locations; noise levels will be
Department of Environment (DOE) guidelines [14), influenced by
state that noise levels at the boundary of an
industrial site must not generally exceed the 1) Size and elevation of source
following levels: 2) Frequency content of noise
3) Presence of intervening barriers/screening.
Daytime (0700 - 2200) 65 dBA
Night-time (2200 - 0700) 55 dBA The large number of sources and complexity of
modem installations mean that,, inevitably,
The DOE may vary these levels if it can be computer-based prediction methods have to be used
demonstrated that there is no significant impact at for such assessments.
119
8 ENVIRONMENTAL ISSUES IN OIL AND GAS DEVELOPMENTS IN MALAYSIA SPE 27091
120
SPE27091 D EVANS & E F YONG 9
TABLE 1: OIL AND GAS PRODUCTION FOR MALAYSIA FROM 1980 TO 1992
Year
Source: Petronas
0 10 I
133
mglm2/day
121
TABLE 3: THIRD SCHEDULE STANDARD B EFFLUENT DISCHARGE LIMIT VALUES
PARAMETERS
E.COU
UNIT
MPNIlOO ml(l)
STANDARD
100 .
REMARKS
..
ESCHERIClllA COLIFORM
LEGEND
122