Environmental Review

Veba Oil Libya GmbH - VOO
Report
Site Environmental
Review
Genesis Job Number J-04131/B
Aug 2003
Prepared by:
Genesis Oil & Gas Consultants Ltd
3 Queens Gate, Aberdeen, AB15 5YL
Tel. +44 (0) 1224 201201, Fax. +44 (0)1224 201222
www.genesisoilandgas.com
[Page Left Intentionally Blank]
Prepared by:
Genesis Oil & Gas Consultants Ltd
3 Queens Gate, Aberdeen, AB15 5YL
Tel. +44 (0) 1224 201201, Fax. +44 (0)1224 201222
www.genesisoilandgas.com
CLIENT: VOO
PROJECT/JOB TITLE: Review of Libyan Sites: Overseas

Element
DOCUMENT TYPE: Report
DOCUMENT TITLE: Generic Site Environmental

Liabilities Review
GENESIS JOB NUMBER: J-04131/B
DOCUMENT NO./
FILE NAME: J04131-B-A-RE-003-R2.doc
R2 12/8/03 Final report IS IS

R1 20/03/03 Draft report for comment TH IS
Rev Date Description Issued By Checked Approved Client
By By Approval
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File name: J04131-B-A-RE-003-R2.doc Revision: R2
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Draft Site Environmental Review
Review of Libyan Sites: Overseas Element
Table of Contents
1. EXECUTIVE SUMMARY ......................................................................................1
2. INTRODUCTION...................................................................................................2
2.1. GENERIC REVIEW...................................................................................................... 2
2.2. SITE SPECIFIC REVIEWS ............................................................................................ 3
3. GENERIC REVIEW AND DISCUSSION OF KEY ISSUES .................................5
3.1. GROUNDWATER/AQUIFER CONTAMINATION................................................................ 5
3.1.1 Possible Sources of Groundwater Contamination............................................................................ 5
3.1.2 Recommendations .............................................................................................................................. 6
3.2. DISPOSAL OF RADIOACTIVE MATERIAL ....................................................................... 6
3.2.1 VOO Practice..................................................................................................................................... 7
3.2.2 Recommendations .............................................................................................................................. 7
3.3. LIQUID DISCHARGE TO THE DESERT........................................................................... 8
3.3.1 Use of Seep/Evaporation Pits & Historic Oil Contamination from Spills ....................................... 8
3.3.2 Discharge of Aquifer Water............................................................................................................... 9
3.3.2.1. Ion Exchange............................................................................................................................................ 9
3.3.2.2. Reverse Osmosis ...................................................................................................................................... 9
3.3.2.3. Saline Water Disposal .............................................................................................................................. 9
3.3.3 Sewage .............................................................................................................................................10
3.3.4 VOO Practice...................................................................................................................................11
3.3.5 Recommendations ............................................................................................................................11
3.4. STORAGE AND DISPOSAL OF HAZARDOUS MATERIAL ................................................ 12
3.4.1 Storage of Materials ........................................................................................................................12
3.4.1.1. On Site .................................................................................................................................................... 12
3.4.1.2. Impacts from Improper Storage .............................................................................................................12
3.4.7 Hazardous Waste .............................................................................................................................17
3.4.7.1. Regulatory and Licensing Requirements...............................................................................................17
3.4.7.2. Recommendations ..................................................................................................................................18
3.4.8 Chlorofluorocarbons (CFCs) and Halons ......................................................................................19
3.4.8.1. Legislative Background .........................................................................................................................20
3.4.9 Polychlorinated Biphenyls (PCBs)..................................................................................................23
3.4.9.1. Legislative Background .........................................................................................................................24
3.4.9.2. PCB Practice at VOO Sites.................................................................................................................... 24
4. AMAL ..................................................................................................................27
4.1. SITE HISTORY ......................................................................................................... 27
4.1.1 Summary of Site Activities ...............................................................................................................27
4.2. ATMOSPHERIC EMISSIONS ....................................................................................... 28
4.2.1 Nature of Atmospheric Emissions ...................................................................................................28
4.2.2 Summary Recommendations............................................................................................................28
4.3. LIQUID EFFLUENTS .................................................................................................. 30
4.3.1 Nature of Liquid Effluents ...............................................................................................................30
4.3.1.1. Sewage.................................................................................................................................................... 30
4.3.1.2. Oily water ...............................................................................................................................................31
4.3.2 Legislation/Discharge Consents......................................................................................................32
4.4. WASTE MANAGEMENT ............................................................................................. 32
4.4.1 Nature of Wastes..............................................................................................................................32
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4.4.2 Waste Management Practices .........................................................................................................33

4.5. STORAGE OF MATERIALS......................................................................................... 35
4.5.1 Storage Arrangements .....................................................................................................................35
4.6. MISCELLANEOUS NUISANCE .................................................................................... 35
4.6.1 Site Nuisance Potential....................................................................................................................35
4.7. CONTAMINATED LAND AND ENVIRONMENTAL LEGACIES ............................................ 36
4.7.1 Potential for Contamination from Current and Historical Operations .........................................36
4.7.2 Legislation/Best Practice.................................................................................................................37
5. GHANI AND JOFRA ..........................................................................................39
5.1. SITE HISTORY ......................................................................................................... 39
5.1.1 Summary of Site Activities ...............................................................................................................40
5.2.1 Venting and Fugitives ......................................................................................................................44
5.3. LIQUID DISCHARGES ............................................................................................... 46
5.3.1 Oil.....................................................................................................................................................46
5.3.2 Water................................................................................................................................................46
5.3.2.1. Ghani ...................................................................................................................................................... 46
5.3.2.2. Jofra ........................................................................................................................................................ 47
5.3.3 Sewage .............................................................................................................................................47
5.4.3 Special Wastes / Liabilities..............................................................................................................50
5.4.3.1. Polychlorinated Biphenyls (PCBs) ........................................................................................................50
5.4.3.2. LSA Scale...............................................................................................................................................51
5.5.1 Storage Arrangements .................................................................................................................51
5.6. SITE NUISANCE POTENTIAL ..................................................................................... 51
5.7.1 Potential for Contamination from Current and Historical Operations ..................................52
6. RAS LANUF TERMINAL....................................................................................53
6.1. TERMINAL HISTORY ................................................................................................. 53
6.1.1 The Tank Farm ..............................................................................................................................53
6.1.2 The Main Station ...........................................................................................................................53
6.1.2.4. Ballast Water ..........................................................................................................................................55
6.1.2.5. Harbour...................................................................................................................................................55
6.1.3 Temperature, Winds, Waves and Currents .....................................................................................55
6.2.1 Flaring .............................................................................................................................................56
6.2.2 Power Generation............................................................................................................................56
6.2.3 Venting and Fugitives ......................................................................................................................56
6.3. LIQUID DISCHARGES ................................................................................................ 57
6.3.1 Oil.....................................................................................................................................................57
6.3.2 Water................................................................................................................................................59
6.3.3 Sewage .............................................................................................................................................59
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6.4.2 Hazardous Wastes / Liabilities........................................................................................................61
6.4.3 Regulatory Controls.........................................................................................................................62
6.5.1 Storage Arrangements .....................................................................................................................62
6.6. SITE NUISANCE POTENTIAL ..................................................................................... 63
6.7.1 Potential for Contamination from Current and Historical Operations .........................................63
7. TIBISTI ................................................................................................................64
7.1. SITE HISTORY ......................................................................................................... 64
7.1.1 Summary of Site Activities...........................................................................................................65
7.2.1 Flaring .............................................................................................................................................67
7.2.2 Power Generation .........................................................................................................................67
7.2.3 Venting and Fugitives...................................................................................................................67
7.2.4 Summary Recommendations .....................................................................................................67
7.3. LIQUID DISCHARGES ................................................................................................ 69
7.3.1 Oil.....................................................................................................................................................69
7.3.2 Water ...............................................................................................................................................70
7.3.3 Sewage ...........................................................................................................................................70
7.4. SOLID WASTE ......................................................................................................... 70
7.4.1 Waste Management Practices....................................................................................................71
7.4.2 Summary Recommendations .....................................................................................................71
`
APPENDIX A CONSTANTS AND EMISSION FACTORS 73
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1. EXECUTIVE SUMMARY
This report sets out the generic findings from the VOO site environmental review carried out by
Genesis between the 19th of October and 12th of November 2002.
The report is in two main sections. The first part deals with identified generic issues
concentrating on what we consider to be potential environmental liabilities and compliance with
International Protocols to which Libya is, or may become, a signatory. The Environmental
Liabilities identified during the visits, also fall into two main categories: those which may have a
direct impact on the environment and staff (for instance, inadequate storage facilities for waste
and materials on site); and those which are potentially longer term issues such as groundwater
contamination, radioactivity and the discharge / dumping of wastes in the desert. The section
deals with site specific issues. There is some repetition between generic and site specific issues
and between the sites. Wherever practical, rather than repeat text we have referenced earlier
discussion.
The review identified management, storage and disposal of waste as a key issue across all sites,
particularly hazardous waste such as surplus chemicals and PCBs. The continued discharge of
oily water to the desert and atmospheric emissions at some sites were also identified as issues
that needed to be addressed. Within these topics, there were examples of good practice which
did not appear to be communicated across the business.
The main conclusions from the review are that, as a priority, VOO should introduce a waste
management system into its business. This will lead to a better understanding of the nature of
the wastes produced and help identify common needs and solutions.
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2. INTRODUCTION
This report sets out the findings from the VOO site environmental reviews carried out by Genesis
between the 19th of October and 12th of November 2002.
This report, like the health and safety review (J04131-B-A-RE-001-R1), primarily sets out the
identified risks which are common to all, or most locations visited (Section 3), and then discusses
the site specific issues identified for Amal, Ghani/Jofra, Ras Lanuf and Tibisti (Sections 4, 5, 6,
and 7 respectively). Therefore, to obtain a full environmental description for any one site it is
recommended that the Generic Section 3, is read in parallel with the site specific Section.
However, unlike the Health and Safety Review, the issues identified during the corresponding
Environmental Review are not necessarily acute (i.e. a chemical spill killing fish in Ras Lanuf
Harbour), but are generally chronic, that is they may cause the slow degeneration of ecosystems,
and may even take considerable time to reveal their full environmental impact. The report
therefore concentrates on the way in which current practice may be contributing to future
environmental liabilities. It also provides a baseline of environmental emissions and discharges
at each site which can serve as the basis for future reporting.
2.1. GENERIC REVIEW

The Generic Environmental Issues identified fall mainly in two areas: compliance with
International Protocols to which Libya is, or may become, a signatory; and potential
environmental liabilities (Table 2.1). In addition, to support the development of an environmental
management system, this review also addresses current emissions and discharges at the sites
and the management of waste.
Table 2.1 Identified Environmental Issues
Chlorofluorocarbons (CFCs)
International Protocol
Polychlorinated Biphenyls (PCBs)
Groundwater Contamination
Radioactivity
Potential Liabilities
Discharge to the Desert
Storage and Disposal of Hazardous Material
Libya is a signatory of both: The Montreal Protocol on Substances that Deplete the Ozone Layer;
and The United Nations Environment Programme (UNEP) global treaty on Persistent Organic
Pollutants (May 2001). These treaties require Libya to phase out its use of ozone depleting
substances (e.g. CFCs, HCFCs & Halons) and persistent organic pollutants (e.g. PCBs).
Currently VOO does not appear to have a management plan setting out how it intends to meet
these commitments, although some initial steps were taken to identify current Ozone Depleting
Substances (ODS) and PCBs in use and, in the case of PCBs, to remove PCB containing
equipment from service. However, this has now reached a standstill, and the PCB storage areas
are inadequate.

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The Environmental Liabilities identified during the visits, also fall into two main categories. Those
which may have a direct impact on the environment and the staff (e.g. storage of waste and
materials on site); and those which are potentially longer term (e.g. groundwater contamination,
radioactivity and the discharge / dumping of wastes in the desert).
2.2. SITE SPECIFIC REVIEWS

Each of the site specific review provides, where available to the team, a brief history of the site,
description of its activities, followed by information on the main emissions and discharges to the
air, water and ground.
Where identified, atmospheric emissions from flaring, power generation, fugitives and venting are
provided. Figures relating to oil, water and sewage discharge are provided along with details of
waste, both disposal and storage. Where site specific details are available, or the topic requires
greater attention than was provided in the previous generic description, the site specific review
expands on these topics. Table 2.2 summarises the result from an analysis of atmospheric
emissions. Amal and Ghani are the largest contributors to carbon dioxide emissions making up
96% of all CO2 emissions and 82% of the global warming gas emissions. Whereas Ras Lanuf
contributes almost 70% to the methane and nonmethane VOC emissions.
Table 2.2 Summary of VOO Atmospheric Emissions (tonnes per annum)
Site Source CO2 CO NOx SO2 CH4 NMVOCs
Fuel 177,419 180 375 63 38 16

Amal
Venting / 471,200 1,126 202 168 2,270 909
Flaring
Fuel 156,575 35 243 64 3.1 4.2

Ghani and
Jofra Venting / 443,677 1061 190 158 2,137 856
Flaring
Fuel 9,174 2.6 39 6 0.09 0.9

Ras Lanuf
Venting / - - - - 350 20,569
Flaring
Fuel 26,598 7.7 112 16.6 .03 2.5

Tibisti
Venting / 19,896 47.6 8.5 7.1 96 38
Flaring
Total Emissions 1,304,539 2,459.9 1169.5 482.7 4,894.22 22,395.6

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Table 2.3 Summary of VOO Aqueous Discharge (bbls per day)
Site/Source Oily Water Sewage Saline Water
Amal 50,000 716 4,000
Ghani & 5,0001 1060 5,500

Jofra
Ras Lanuf n/d 770 n/d
Tibisti 260 140
3
Table 2.4 Summary of VOO Waste Disposal (m per annum)
Site/Source Waste to Desert
Amal 4,500
Ghani & Jofra 6,400
Ras Lanuf 4,500
Tibisti n/a
The discussion and recommendations set out in the proceeding Sections (both Generic and Site
Specific) are designed to highlight the issue, discuss the potential consequence and to enhance
organisational ability to respond to them.

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3. GENERIC REVIEW AND DISCUSSION OF KEY ISSUES
3.1. GROUNDWATER/AQUIFER CONTAMINATION

Groundwater contamination can be defined as the addition of elements, compounds, and/or
pathogens to water that alter its composition. Generally contamination of groundwater occurs
from the accidental or deliberate discharge of soluble material.
One of the major difficulties with groundwater contamination is that it occurs underground, out of
sight. The pollution sources are not easily observed nor are their effects often seen until damage
has occurred. There are no obvious warning signals such as fish / animal kills, discoloration, or
stench that typically are early indicators of surface-water pollution. Where contamination affects
pumping wells, some indications may occur, although many commonly found contaminants are
both colourless and odourless and occur in low concentrations. The tangible effects of
groundwater contamination usually come to light long after the incident causing the contamination
has occurred. This long lag time is a major problem.
Once in the aquifer, a contaminant will move with the groundwater at a rate depending on the
properties of the pollutant, forming, under certain idealized conditions, an elliptical plume of
contamination with well-defined boundaries. This dispersion process causes a spreading of the
solute in a longitudinal flow direction and also transverse to the flow path, thus the plume will
widen and thicken as it travels.
Attenuation of the contaminants in the aquifer may take place through dilution, volatilization,
mechanical filtration, precipitation, buffering, neutralization, and ion exchange. Diffusion and
dispersion will bring contaminants into contact with material that may retard their progress; thus
attenuation may vary with the time and distance travelled.
Unless the plume is blocked it will usually reach points of groundwater discharge such as
streams, wetlands, lakes, and tidal waters. The shape of the plume will vary according to the
continuity and duration of the source of contamination. Dispersion tends to dilute the
contaminants; however, concentrations of contaminants are typically much higher in groundwater
than in surface water.
3.1.1 Possible Sources of Groundwater Contamination

Whilst visiting the VOO sites, there were several routine practices that may lead to groundwater
contamination. These were:
• Disposal of radioactive material;
• Use of seep / evaporation pits and other historic oil contamination from spills;
• Discharge of potentially contaminated water particularly from potable water supply and
sewage disposal;
• Storage and disposal of hazardous materials such as PCBs, insecticides and carbon
tetrachloride.

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The potential for contamination is relative to the aquifer depth, which varies greatly between sites
(i.e. Amal – 100 m, Ghani – 350 m Ras Lanuf – 10 m), and the rate and nature of the material.
Although not all of the above sources occurred at each site, the majority do, and therefore they
have all been included for completeness.
3.1.2 Recommendations
1. Sampling programme to look for indicators of ground water contamination in aquifer
water abstracted for potable water. Depending on the results; a programme for future
monitoring and possibly additional studies.
The issue of groundwater contamination by specific pollutants is discussed further in the following
sections.
3.2. DISPOSAL OF RADIOACTIVE MATERIAL

Although they are "natural" all radioactive emissions are potentially dangerous to living things.
On the sites, known radioactive sources are located in safe areas, have adequate warning signs
and are used only by trained personnel (i.e. X-ray machine in the clinics). However, concern
exists over a number of radioactive sources that had not been identified, and for which
management systems appeared not to be in place. These sources are:
• NORM and LSA Scale;

• Americium-241.
Naturally occurring radioactive materials (NORM), which have a half life of approximately 1700
years, have been known to be present in varying concentrations in hydrocarbon reservoirs in a
number of areas of the world, and can give rise to radioactive scales (and sludges), which are
usually referred to as Low Specific Activity (LSA) scale.
The scales tend to be barium and strontium sulphate, which co-precipitate with naturally occurring
radium leached out of the reservoir rock; such scales emit alpha, beta and gamma radiation and
this, together with the physical properties of the LSA scale, can give rise to problems if such
scales or sludges have to be removed, handled or disposed of.
The results of an E&P Forum survey into this problem would suggest that the LSA scale
phenomenon is most commonly observed in the development of Jurassic reservoirs where the
well fluids are wet, particularly at locations in the production system where there are sudden
changes in well fluid stream conditions. Very recent test results suggest that the problem is more
widespread than was originally indicated by the survey.
The form of the LSA material can vary from sludges, through soft, easily removed scales, to very
hard and tenacious scales; levels of radioactivity can vary from just above background radiation
to those requiring restricted areas and handling by classified workers.
LSA scale is classed as a radioactive substance and the handling and disposal of it could give
rise to occupational health and hygiene problems.

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Americium-241, which has a half life of 430 years, is a radioactive element best known for its use
in smoke detectors.
3.2.1 VOO Practice

Low Specific Activity (LSA) scale and Naturally Occurring Radioactive Material (NORM) is known
to occur in the pipework from both drilling workover and production operations. Current practice
is for LSA contaminated material to be buried in the desert leaving open the potential for
radioactive material to enter ground water via percolation as the pipes corrode, and for the
formation of localized hot spots, which may prove a hazard to future activity in the area and, from
re-use of discarded material, may cause health problems in the local population.
For example, the recovery of oil from sand at Amal is an example of good environmental practice
and one we would like to see adopted elsewhere. However, although we have no evidence,
there is the potential that the waste sand has retained higher than background concentrations of
NORM and as such may be hazardous. This should be investigated.
At Ghani, the presence of LSA scale in a pipe used to transport water for desalting raises the
possibility that elevated levels of NORM are present in water from the aquifers. This may be
accumulating in the potable water system (i.e. the ion exchange bed), and again this possibility
should be investigated.
None of these possible sources of NORM or LSA scale may be a problem for VOO, but until it
can be proved otherwise, a precautionary approach should be taken.
Currently it is believed that old smoke detectors which contain americium-241 are disposed of to
the desert or may be incinerated with other site generated wastes. Although the disposal of
individual detectors to the desert would not have an impact on the environment, there is the
potential for the accumulation of radioactive material in the ground water via percolation from the
disposal of large numbers of detectors. In addition, if the detectors are incinerated they may pose
a risk to staff from inhalation of radioactive material.
The issue of LSA and NORM associated with drilling was addressed in the major hazards review
(J04131-B-A-RE-001-R2.doc).
2. Survey and investigation into LSA Scale and NORM on the sites, to identify, where and
when it is occurring, and to ensure its containment and management.
3. No longer dumping or incinerating old smoke detectors. Need to review options for safe
and environmentally friendly disposal.
4. If NORM and LSA are found to be present, VOO must develop and impose safe systems
of work and proper procedures which recognise the hazards, protect the workers from
harmful exposure, minimise interference with the environment and ensure that
government and international regulations are followed.
5. Development of policy and procedures for dealing with radioactive material. Note: For
drinking water the recommended World Health Organization (WHO) radioactivity reference level of

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committed effective dose is 0.1 mSv from 1 year’s consumption. For practical purposes, the
recommended guideline activity concentrations are 0.1 Bq/litre for gross alpha and 1 Bq/litre for
gross beta activity. Below this reference level of dose, the drinking water is acceptable for human
consumption and action to reduce the radioactivity is not necessary.
3.3. LIQUID DISCHARGE TO THE DESERT
3.3.1 Use of Seep/Evaporation Pits & Historic Oil Contamination from

Spills
Oil contamination to the groundwater can originate from a number of sources such as; the
leakage from oil pipelines, storage tanks and landfills / dumps. Perhaps the most likely source
being widespread use of seep / evaporation pits (See Figure 3.1). All the sites, including drilling
sites, showed signs of historic oil contamination. Potential oil contamination of groundwater is a
major issue wherever oil is extracted transported or stored. Oil contains a number of mobile
components which, if accumulated, could cause health problems. Among these are compounds
such as benzene, toluene and xylene; polyaromatic hydrocarbons; and heavy metals. Once in
the groundwater these compounds are extremely difficult to remove.
Figure 3.1 A Seep / Evaporation Pit at Amal
The use of historic seep / evaporation pits as a means of disposing of oil contaminated water
increases the likelihood of pollutants entering groundwater, and potentially potable water supplies
via abstraction of aquifer water. The current testing regime is unlikely to identify whether or not
the pollutants are present.
Discharge of waste water with high levels of H2S was apparent at Station 9, Amal. Apart from
potential health hazards to individuals in the area, this was also leading to salt scarring of the
area.
Although common practice in many North African and Middle Eastern countries, seep pits do little
to enhance the reputation of the industry. As public awareness in these regions grows there will
be increased pressure to ‘clean-up’ historical waste pits. Steps taken now to minimise oil to the
desert will ultimately be cost effective as measures at Amal have demonstrated.

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The seep pits at Ras Lanuf warrant particular mention due to their visibility from the air and the
frequency of commercial in the region.
3.3.2 Discharge of Aquifer Water

Although the aquifer well water has a relatively low salt content, it is not sufficiently low to be
suitable for potable water. To achieve the desired water quality VOO uses two treatment
operations:
• Ion exchange;
• Reverse Osmosis.
In addition water abstracted from the reservoirs is used for fire water, irrigation and wash water.
Most of this goes directly to the desert.
3.3.2.1. Ion Exchange
Ion exchange water treatment replaces, for instance, calcium ions in the water with sodium ions
held in a resin in the ion exchange column.
Ion exchange units can be supplied with cationic or anionic exchange resins for the softening of
filtered water or removal of other undesirable materials such as barium, radium or sulphates.
Therefore, as discussed above in Section 3.2, this could be a problem if it is concentrating NORM
from the water, especially when recycling the resin, because this could potentially release NORM
fluid to the environment, or if resin is disposed of to the desert, be introducing a radioactive
source to the ground.
3.3.2.2. Reverse Osmosis
In reverse osmosis, a membrane acts like an extremely fine filter to create drinkable water from
salty (or otherwise contaminated) water. The salty aquifer water is put on one side of the
membrane and pressure is applied to stop, and then reverse, the osmotic process.
Again this could this be a problem if it is constantly concentrating NORM from the water,
especially when recycling the membrane, because this could potentially release NORM fluid to
the environment, or if the membrane is disposed of to the desert, be introducing a radioactive
source to the ground.
3.3.2.3. Saline Water Disposal
No matter which of the two water treatment methods are used on the VOO sites, both produce a
saline waste product. This is typically allowed to flow to the desert (the most economical
method), where it forms ponds, some of which have established vegetation and introduced fish
stocks to keep the mosquitoes down. In areas with vegetation present the discharge of this water
could cause salt scars, as it alters the local conditions.
No matter if the site of discharge is desert or vegetated land, disposal of this saline water may
result in surface and / or ground-water contamination.

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3.3.3 Sewage
Two of the sites had sewage treatment facilities, but the remainder had septic tanks. Sewage
systems, particularly septic tanks, can be another contamination source. Typically, sewage
systems are designed to treat the sewage with activated bacteria, and to slowly drain away
treated human waste underground at a slow, harmless rate. An improperly designed, located,
constructed, or maintained sewage system can leak bacteria, viruses, chemicals, and other
contaminants into the air, soil and groundwater potentially causing problems.
A septic tank is generally a concrete or steel tank that is buried in the sand. The tank capacity
should equal a full day's flow plus an additional allowance of from 15 to 25 percent for sludge
capacity. Wastewater flows into the tank at one end and leaves the tank at the other. The tank
looks something like Figure 3.2 in cross-section:
Figure 3.2 Cross Section of a typical septic tank set up.
The solids and liquid in the tank undergo a natural treatment process. This treatment is
performed by anaerobic bacteria (bacteria that live in the absence of air).
In Figure 3.2, three layers are clearly identifiable. Anything that floats rises to the top and forms a
layer known as the scum layer. Anything heavier than water sinks to form the sludge layer. In
the middle is a fairly clear water layer. This body of water contains bacteria and chemicals
(nitrogen and phosphorous) that act as fertilizers, but it is largely free of solids. Sludge and scum
are partially digested and compacted to a smaller volume. The sludge and scum remain in the
tank and as new water enters the tank, it displaces the water that's already there. A septic
system is normally powered by gravity. Water flows down from the source to the tank, and down
from the tank to the drainage area. It is a completely passive system.
The septic tank must be cleaned of solid wastes from time to time. How often this is necessary
depends on the size of the tank and the volume of effluent entering.
Cleaning out a septic tank is a simple pumping operation carried out by a vacuum tanker.

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Failure to clean the tank will result in the solid wastes overflowing and clogging the disposal
system. The first sign of this is usually seepage of a foul smelling liquid. By the time this is
noticed the disposal system is usually clogged beyond repair and a new one must be installed.
Any seepage of sludge or untreated sewage creates a dangerous health hazard and needs
immediate attention.
3.3.4 VOO Practice

At all of the sites visited the desert is used as the main disposal route for contaminated water.
Apart from visible signs of oil contamination there was little evidence that this was causing any
problems. However, oil is known to contain highly mobile contaminants that can, and have
elsewhere, entered aquifers and groundwater and it must be assumed that this will also be the
case at some of the VOO sites.
At most of the sites visited, potable water was seen being used for irrigation purposes. Although
this watering itself does not pose a direct impact on the environment, the use of fresh water
supplies for this purpose is not recommended.
Desertification is very much an issue in Libya, with only very limited natural fresh water
resources. A number of de-salination plants of different sizes have been built in Libya near large
municipal centres and industrial complexes. The total capacity of installed plants is
approximately 140 million m3/year, but parts of them are either not in use or only partly
operational. It is estimated that only 70 million m3/year is annually de-salinated.
A number of sewage treatment plants are already in operation or planned for the near future.
When all the plants become operational, their total output will average 285 000 m3/day or about
100 million m3/year. All this treated water is currently used for irrigation. This practice is not
followed on the VOO sites were treated water is generally fed to soakaways, which may then
have associated problems as mosquitoes breeding areas.
Better use could be made of much of the saline and sewage water currently discharged. At some
sites this water could be used to aid programmes to introduce more greenery.
6. Improved oil recovery from the separators and use of secondary separator systems such
as skimmers.
7. The dissemination of information on good practice, for instance, information on the

implementation of additional separator at Amal, good use of existing oil in water
separator equipment and sumps at Station 9.
8. The use of lined pits to minimise potential groundwater contamination, similar to those
used at Ras Lanuf for the firewater ponds.
9. Investigation of produced water re-injection as a means of water disposal.

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10. Ensure that all sewage and water treatment systems are maintained, checked regularly
and are working properly. Personnel to be trained specifically in this area, and be
responsible for their efficiency.
11. Investigate the potential of using treated sewage water for irrigation purposes across all
the camps.
12. Put water conservation policies in place, i.e. ensure all plumbing and fittings working and
not leaking and minimise the use of potable water for irrigation.
3.4. STORAGE AND DISPOSAL OF HAZARDOUS MATERIAL

The control of potentially hazardous material – chemicals and waste – has become a major
element of regulatory control in many countries. The main driver for this is the prevention of
hazardous material entering the environment, the minimisation of waste and strict controls over
the way in which waste is disposed of.
In general we found that VOO had good control over the purchase and issue of chemicals but
had little control over the disposal of waste. In addition, there appeared to be no systems in place
for managing waste. However, the waste produced at the sites was typical of that expected at an
industrial oil and gas operation and in general the sites themselves were very tidy.
3.4.1 Storage of Materials
3.4.1.1. On Site
In general storage arrangements for chemicals and other material on the sites was good.
Although not assessed in depth, warehouses kept excellent records of goods received and
issued. Currently all the warehouses at the VOO sites visited operate two means of tracking
stock: the original cardex system and a computer based system. The computer based system
was old and we were informed that it had not been updated with older information, and could not
be used without reference to the original paper based system.
3.4.1.2. Impacts from Improper Storage
The improper storage of chemicals can lead to unintended leakage potentially causing harm to
staff, contamination of topsoil and, possibly contamination of groundwater (Figure 3.3 and 3.4).

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Figure 3.3 Improper Storage of Fire Fighting Foam at Ras Lanuf (Note one of the drums has become punctured
and is leaking).
Figure 3.4 Storage of Drums at Amal, with visible spillage below.
All of the warehouses inspected had some concreted areas for the storage of chemicals,
minimising the likelihood of offsite contamination. However, warehouses also retained out of date
surplus stock, for which no safe disposal route had been identified. This material was generally
neglected and, as a result, drums were found to be leaking and markings were fading (Figure
3.5). In addition it was often stored on sand or in unbunded areas.

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Figure 3.5 Typical out of date / surplus stock 45 Gallon Drum Leaking with Faded Markings.
By allowing these drums to erode and markings to fade, VOO could be left in the situation where
they are required to sample the barrels to identify the contents, and subsequently an
environmentally safe route of disposal.
3.4.2 Material Safety Data Sheets

There appeared to be no single policy for the storage and distribution of Material Safety Data
Sheet (MSDS) information at the site. The information contained on these is essential when
responding to an incident such as a chemical spill or a fire and, therefore, they need to be readily
accessible. On most sites there was also confusion over who was responsible for keeping and
maintaining master copies of up to date safety data sheets, Tripoli, the warehouse, safety and
corrosion were all mentioned as being primarily responsible, but on further investigation none
held complete copies for all chemicals in use on the site.
3.4.3 Domestic Waste

Domestic waste is collected from around the camps and site offices at regular daily intervals by the
camp contractor (Services). Domestic waste is also collected from a designated area to the rear of
the kitchens (putrescibles, paper, plastic, tins, glass and card) and from individual site offices (paper,
plastic and card).
At all sites there is a burn pit for all food and general waste. However, some (i.e. Ghani) have
constructed a metal containment system that improves the combustion of the waste.

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3.4.4 Desert Dumping

Solid wastes (both hazardous and non hazardous) appear to be dumped in the desert (See Figure
3.6). Disposal areas ranged from what seemed to be relatively small unmarked sites, to large
sprawling dumps. In some areas, historic dump sites were evident as was random disposal of
waste. However, with no control or cataloguing of waste it is possible to neither ascertain the full
coverage of waste nor differentiate historic from current waste. For instance, it is known that spent
acid batteries and pyrophoric iron scaled pipelines are buried in the desert at random locations.
Figure 3.6 Desert Dumping of both hazardous and non hazardous, historic and new waste.
In discussions with staff it is likely that asbestos waste, ‘hot’ / radioactive pipelines and old smoke
detectors are also deposited in the desert. Given their size, it is likely that some discarded smoke
detectors have also been burned with the domestic waste.
The worst control of waste was observed at abandoned contractor camps, where contractors left
leaving chemical drums in varying states of decay, old accommodation units, scrap metal and other
miscellaneous wastes scattered over the locale.
The tendency to deposit material anywhere by both Veba and its contractors, was not helped by the
fact that there appeared to be no marked, purpose built compound for waste or designated area nor
a tracking system. As a consequence material could be seen scattered over the desert and
ownership was generally unattributable.
Old air conditioner units are scrapped and also deposited in the desert. Whether or not the
refrigerants (containing CFCs and HCFCs) are emptied before the old ac units are removed to the
desert was not ascertained. The potential environmental impacts from this are discussed in Section
3.4.8.
3.4.5 Medical
Swabs, bandages and other (solid) clinical wastes generated at the clinic are disposed on a
regular basis by the camp doctor. This includes used sharps and needles (placed in a sharps box
VOO
before disposal), and expired medicines. In the majority of cases the doctor ensures the
destruction of clinical waste by taking it personally to the burn pit and supervising its destruction.
Procedures are in place for this.
3.4.6 Waste Management Practices

None of the sites operated a formal waste management system. There was no recording of
waste arising and little control over the production of waste. As discussed above, domestic,
kitchen and medical waste accumulation at the site is controlled regularly by burning at a
specified area. Tyres are segregated and either used as markers or burned, and the possibility
that old smoke detectors are also burned could not be excluded. Inspection of the burn pits
indicated that combustion was generally effective, though there were signs that material tended to
smoulder rather than burn (See Figure 3.7). A member of the fire and safety team is in
attendance to light the material. This is achieved by dousing the waste with condensate or diesel
and lighting it. On occasion, the ashes and other debris are mixed into the ground.
Figure 3.7 Smouldering Burn Pit at Amal.
Some scrap is segregated in the facility before disposal to the desert. For instance there
appeared to be general areas for old pipes and vehicles.
We were informed that many of the used drums were cleaned, collected and reused, those that
had been used for toxic chemicals often had holes punched in them to prevent their use as
containers for potable water.
Whilst visiting Amal, wells were observed (around Station 9), which had been interfered with by
the local farmers, who were looking for pipelines and valves for their farms to aid in irrigation. We
were informed that Amal have previously made some of their old pipelines etc available to the
local farmers, but this had not stopped material being removed.
Re-use of material is good practice and, once waste has been thoroughly checked that it is safe
(i.e. no chemical residue and not radioactive etc), allowing it to be used by the locals helps VOO’s
waste management/minimisation, improves relations with the local communities and reduces the
chance of an accident due to their interference with the live wells.
Much of what the sites currently dispose of to the scrap heaps, and waste pits can be
reused/recycled by the locals, and allows them the opportunity to improve their farm / home
facilities and standard of life. Plus the reuse/recycling of waste is the ultimate goal of any waste
management system.

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3.4.7 Hazardous Waste

Hazardous or special waste is generally defined as waste that could cause serious harm or death
to individuals and/or harm to the environment. Waste is normally classed as hazardous on the
basis of toxicity, flammability or its potential to explode (see Section 3.4.7.1). In addition to
chemicals, some material in general use around the site is classed as hazardous waste, this
includes used batteries (containing lead or cadmium) and fluorescent bulbs / tubes (containing
mercury) which could lead to heavy metal contamination of groundwater, soil or local flora and
fauna.
At all sites vehicle batteries were routinely dumped in the desert, for example, in one year alone
~400 car / truck batteries were dumped at Amal. Batteries contain lead and sulphuric acid, and
are therefore hazardous, and over time the lead may make its way into the aquifer, leading to
contamination.
Fluorescent lamps and Mercury Bulbs are disposed of in the dumps / incinerators or at some
sites with poorer house keeping, where they fall. Mercury is a toxic heavy metal and
bioaccumulator, and in sufficient doses it can cause damage to the central nervous system, birth
defects, and other adverse health effects. Therefore, concerns are often raised about the
mercury in compact fluorescent lamps. According to the European Lighting Council, mercury
from all lamps represents 0.2% (5.2 tonnes/year) of the mercury contained in consumer products
sold in Europe. The dumping of these lights in the desert may not be problematic, given the small
amount of mercury in each lamp, however, if there is a continuous long term source of mercury
reaching the aquifer, it may accumulate. Additionally it is worth noting, that incineration of even a
low-dosed mercury lamp results in more mercury being released into the environment than
dumping lamps with higher mercury levels.
3.4.7.1. Regulatory and Licensing Requirements
With the exception of VOO procedures on medical waste, none were identified, however Libya is
a signatory to the Basel convention and best practice would categorise waste under three main
headings:
• Domestic and Municipal Waste;
• Non-hazardous Industrial Waste; and
• Hazardous Waste
Domestic and municipal waste refers to the type of waste normally produced by households such
as those in the townships. The type of waste produced at the sites comes under the category of
industrial (controlled) waste (non hazardous and hazardous). Guidance would normally be given
on the manner in which waste, hazardous and non-hazardous, should be segregated and stored.
Waste is normally controlled by a manifest system (consignment note) covering each stage of
disposal. As a minimum best practice would use this approach for hazardous waste produced at
the sites which:
is dangerous to life and property;
has a flash point less than or equal to 21°C;

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is a medicinal product available only on prescription;
is radioactive waste
and for detailed records to be kept on the quantity, nature and disposal of this waste. Currently,
only the handling of clinical/medicinal waste meets this standard.
3.4.7.2. Recommendations
13. VOO should develop a waste management system which will include: storage and
segregation of waste; waste minimisation; and tracking of waste.
14. Ensure contractors are required to implement a waste management plan and that the
contract is not complete until the site is deemed to be in a safe and clean state.
15. As a priority, out of date and surplus drums should be clearly labelled and, if safe to do
so, the contents of leaking drums transferred to new drums.
16. Where chemicals in leaking drums can not be transferred, they should be stored over drip
trays in the short term and ideally put in sealed containers until a safe disposal route has
been identified.
17. As stated, some these chemicals are surplus rather than out of date. A survey should
also be made to see whether or not the surplus chemicals are in date and could be used
at other locations or, in the case of fire fighting foam, for practice. For the remainder a
safe means of disposal should be identified.
18. Clear guidelines be developed on the keeping, maintaining and distribution of MSDS
sheets.
19. Chemicals should be stored in bunded areas to prevent leakage and ground
contamination.
20. Review of waste disposal at the sites, special wastes (batteries, lights etc) need to be
segregated and dealt with specifically. Look at routes of recycling / reuse or
environmentally friendly and safe means of disposal.
21. Clearly defined areas for disposal and storage of waste.
22. Incinerators similar to that in use at Ghani, to be installed at each site to help ensure
efficient combustion of waste.
23. Encourage relations with local farmers, and allow them to take any of the non hazardous
site waste they can use (old pipes etc) thereby reducing occurrence of theft noted at
some sites.
24. Remediation efforts to clean the existing historical waste from the desert.
25. VOO should consider the practicality and issues around installing composters at the sites
for the disposal of organic waste.

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3.4.8 Chlorofluorocarbons (CFCs) and Halons

Chlorofluorocarbons (CFCs), along with other chlorine- and bromine-containing compounds, have
been implicated in the accelerated depletion of ozone in the Earth's stratosphere. CFCs were
developed in the early 1930s and are used in a variety of industrial, commercial, and household
applications. These substances are non-toxic, non-flammable, and non-reactive with other
chemical compounds, making them ideal for many applications; as coolants for commercial and
home refrigeration units, aerosol propellants, electronic cleaning solvents, and blowing agents.
Halons are compounds consisting of bromine, fluorine, and carbon and are used as fire
extinguishing agents, both in built-in systems and in handheld portable fire extinguishers and also
contribute to ozone depletion.
Information on the amount of CFCs and Halons imported and used by VOO between 1995 and
1999 was provided during the site visits and is reproduced in Table 3.1 and 3.2 below. Although
no information is available for subsequent years it was apparent during the site visits that many of
these compounds are still in use, including those whose use may now be prohibited.
Table 3.1 Imported Quantities of CFCs and Halons (kg) for all VOO sites 95-99.
95 96 97 98 99 Total Average
CFC 11 982 None None 854 None 1836 367
CFC 12 626 391 1944 2741 2695 8397 1679
CFC 22 1968 814 2001 5042 3253 13078 2616
CFC 502 - - 659 27 548 1234 247
Halon 1211 50 - 16.5 - 27.5 94 14
Table 3.2 Used Quantities of CFCs and Halons (kg) for all VOO sites 95-99.
95 96 97 98 99 Total Average
CFC 11 280 - - - - 280 56
CFC 12 1415 1058 1388 2979 2987 9827 1965
CFC 22 2029 2056 2125 5027 4060 15292 3058
CFC 500 116 58 29 - - 203 41
CFC 502 23 138 213 760 328 1462 292
Halon 1301 - - - - 246 246

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The CFCs and halons imported and used at the VOO sites are used mainly for one of two
purposes:
1. CFCs - Air Conditioning Refrigerants
2. Halons - Fire Extinguishers
CFCs are used in air conditioners as the refrigerant gas. The air conditioners are regularly
serviced at all sites, and are recharged from a pressurised bottle.
Discussions indicate that, at most sites, units are decommissioned by releasing spent CFCs to
atmosphere and disposing of the unit to the desert. Therefore VOO has three potential sources
of CFCs to the environment from these units:
1. continual low level leakage from defective air conditioners;
2. the complete release of gas from old units before disposal and
3. leakage from the bottles used to refill defective units, either during filling, or when in storage.
Of these, 1 and 2 are most likely the significant sources of emissions of CFCs to the environment
for VOO.
Some of the site fire extinguishers and key area fire fighting systems (i.e. control rooms) use
Halon gas for fire fighting. Currently these units are regularly checked onsite, and are topped up
when necessary. Old or defective bottles have the gas released from them before being
disposed of to the desert (except at Tibisti, where a halon recovery unit was used). Therefore, as
with the air conditioners, the three potential sources of release are:
1. continual low level leakage from defective extinguishers;
2. the complete release of gas from old extinguishers before disposal and
3. leakage from the bottles used to refill defective units, either during filling, or when in storage.
3.4.8.1. Legislative Background
The Montreal Protocol on Substances that Deplete the Ozone Layer is a landmark international
agreement designed to protect the stratospheric ozone layer, to which Libya is a signed party.
The treaty was originally signed in 1987 and substantially amended in 1990 and 1992. The
Montreal Protocol stipulates that the production and consumption of compounds that deplete
ozone in the stratosphere - CFCs, halons, carbon tetrachloride, and methyl chloroform - are to be
phased out by 2000 (2005 for methyl chloroform).
Despite rapid phaseout of CFCs and halons, ozone levels are expected to be lower than pre-
depletion levels for several decades due to their long tropospheric lifetimes.
Under the Montreal protocol, CFC 11, CFC 12, CFC 500 and CFC 502 were primarily prohibited
to be supplied (either for payment or for free), and from the 1st of January 2001 they were no
longer to be used for the maintenance and servicing of refrigeration and air conditioning
equipment.

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Likewise HCFC 22 (Hydro chlorofluorocarbon 22), which it is believed has been labelled
incorrectly in the tables provided by VOO as CFC 22, is also to be phased out. HCFC’s
stratospheric ozone depletion potential is roughly one-fifth of the ozone depletion potential of
CFCs. Therefore, HCFCs are viewed as “transitional” alternatives to CFCs as chlorine-free
alternatives are sought and being introduced. However, from 1st January 2001, most new
equipment cannot be built with ozone depleting refrigerants, and therefore consideration needs to
be given for decreasing HCFC use.
Halon 1211 (CBrCIF2) and halon 1301 (CBrF3) have been listed in the Montreal protocol as
important potential ozone depleters. Globally their current releases to the atmosphere are small
compared to the CFCs but they possess relatively high ozone depleting potentials compared to
the CFCs. European regulations regarding halons stipulate that virgin halons can no longer be
used to refill existing fire protection systems and recovered, recycled or reclaimed halons may
only be used in existing fire protection systems until 31st December 2002. A mandatory
decommissioning of fire protection systems and fire extinguishers containing halons must be
carried out and completed before the 31st December 2003. This information is summarized in
Table 3.3 and 3.4, below.
Table 3.3 Summary of Current Refrigeration and Air Conditioning Phase Out Requirements.
CFCs and HCFCs Requirement

CFC 11
October 1st 2000 – No more Supply
CFC 12
January 1st 2001 Ban on use for Maintenance
CFC 500
of existing equipment
CFC 502
Banned for manufacture of new equipment
from 1st January 2001.
Ban of the use of Virgin HCFCs from 1st
HCFC 22
January 2010.
Ban on the use of all HCFCs, including
recycled materials from 1st January 2015.
Table 3.4 Summary of Current Halon Based Fire Protection Systems Phase Out
Halons Regulation
Halon 1211 Virgin Halons cannot be used for refilling

existing fire protection systems.
Recovered recycled or reclaimed halons may
Halon 1301 only be used in existing fire protection
systems until the 31st December 2003.
Production and consumption of CFCs, halons and other ozone depleting chemicals have been
phased out in developed countries as described above, however, developing countries have been
given a grace period, and are allowed to operate under different phase-out schedules (See Table
3.5), in recognition of their need for industrial development and their relatively small production
and use of ozone depleting substances (ODS).

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Developing countries have agreed to freeze most CFC consumption as of 1 July 1999 based on
1995-97 averages, to reduce this consumption by 50% by 1 January 2005 and to fully eliminate
these CFCs by 1 January 2010. Other control measures apply to ODS such as halons, carbon
tetrachloride and methyl chloroform. For methyl bromide, used primarily as a fumigant,
developed countries froze their consumption at 1995 levels and will eliminate all use by 2010,
while developing countries have committed to freeze consumption by 2002 based on average
1995-98 consumption levels.
Table 3.5 Phase Out Schedule for Developing Countries under the Montreal Protocol
Substance Consumption Freeze Phase-Out
Chlorofluorocarbons
1 July 1999 1 January 2010
(CFC)
Halons 1 January 2002 1 January 2010
Other Fully
--- 1 January 2010
Halogenated CFCs
Carbon Tetrachloride --- 1 January 2010
Methyl Chloroform 1 January 2003 1 January 2015
Hydro-
chlorofluorocarbons 1 January 2016 1 January 2040
(HCFCs)
Methyl Bromide 1 January 2002 1 January 2015
Under the protocol, developed countries also have to transfer environmentally safe substitutes
and related technologies to developing countries under fair and most favourable conditions.
Export of CFCs and carbon tetrachloride is prohibited from 1st October 2000, except those
produced for the basic needs of developing countries. Export of bulk halons is also prohibited
from that date.
HCFCs can still be exported to states identified in the Montreal Protocol until 31st December
2009. After that date the export of products and equipment containing HCFCs is prohibited.
States not identified by the Montreal Protocol shall be prohibited from 1st January 2004.
From the site review, it is clear that VOO continues to use CFCs and halons. In itself, given the
nature operations this may not pose a serious problem however, methods of housekeeping of a
very high standard would be expected in order to minimise losses in line with International
requirements. There was no evidence that, as required under the Montreal Protocol, VOO was
managing its current stocks to minimise losses and was operating against a phase out plan. The
current methods of maintenance and especially disposal viewed on the sites fall short of the
international requirements.
26. A site by site review of current stocks, use and purchase of CFCs and Halons be
undertaken and the information collated to provide an accurate and up to date summary
of the current status.

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27. Any fixed equipment with a refrigeration fluid charge greater than 3 kg must be checked
annually for leakage.
28. All measures practicable must be taken to prevent and minimise leakages of CFC and
HCFC refrigerant gases.
29. During servicing and maintenance of refrigeration and air-conditioning equipment any
ozone depleting substance must be recovered for destruction, by an environmentally
acceptable technology, or recycled or reclaimed. It is recommended that VOO reuses
material wherever practical and, as part of larger grouping of companies, seeks means of
safely disposing of CFCs.
30. Use of many of the CFCs on the sites should be phased out and, replaced by HCFCs.
This may be a reasonable response to older equipment that will be replaced by 2040 but
should be avoided if the plant is still likely to be operating after this date.
31. Virgin halons cannot be used for refilling existing fire protection systems. Recovered,
recycled or reclaimed halons may only be used in existing fire protection systems until 1st
January 2010. After this date systems cannot be refilled.
32. All halons and other ozone depleting substances contained in fire protection systems and
fire extinguishers must be recovered during servicing and maintenance of equipment or
prior to dismantling or disposal of equipment. Recovery must be for destruction by an
environmentally acceptable technology
3.4.9 Polychlorinated Biphenyls (PCBs)

Polychlorinated biphenyls (PCBs) are mixtures of up to 209 individual chlorinated compounds
(known as congeners). All PCBs consist of two benzene rings linked by a carbon-carbon
bond. PCBs are either oily liquids or solids that are colourless to light yellow, although some
can exist as a vapour in air. PCBs have no known smell or taste.
The value of PCBs for industrial applications was related to their technical properties:
• chemically inert;
• non-flammable;
• heat resistant;
• non-corrosive;
• excellent electrical insulators (i.e. they have a high dielectric constant);
• low acute toxicity.
These properties made them particularly suitable for applications such as:
• oil in transformers;
• dielectrics in capacitors;
• hydraulic fluids in hydraulic tools and equipment;
• heat exchange liquids.
They also found wide-spread use as lubricants for turbines and pumps, in the formulation of
cutting oils for metal treatment and as ingredients in a range of sealants, adhesives, paints and
carbonless copying paper.
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PCBs have long been recognised as posing a threat to the environment because of their toxicity,
persistence and tendency to bio accumulate (i.e. to build up in the bodies of animals, particularly
at the top of the food chain).
Although the use of PCBs has been reduced greatly since the 1970s when legislation first sought
to control their use and supply, it is recognised that those still remaining in existing equipment
pose a continuing environmental threat.
3.4.9.1. Legislative Background
The use of PCBs in open applications such as printing inks and adhesives was banned in the
European Community in 1976 (Directive 76/403/EEC). Use of PCBs as a raw material or
chemical intermediate has been banned in the EU since 1985. In 1996 the 1976 directive was
replaced by Directive 96/59/EC, which set a deadline of 2010 for complete phase-out or
decontamination of equipment containing PCBs.
The United Nations Environment Programme (UNEP) global treaty, adopted at the Stockholm
Convention on Persistent Organic Pollutants (May 2001) stipulates that the use of PCBs in
equipment shall be eliminated by 2025. This date is a minimum requirement and does not
prevent individual governments, or groups of governments, from maintaining earlier phase-out
dates. The Stockholm Convention will come into force after ratification by 50 states. So far (May
2002), only eight states have ratified the Convention. The Basel Convention (May 1992) adopted
Technical Guidelines for PCB handling, disposal and destruction.
Although Libya is not yet signatories to the Stockholm Convention on Persistent Organic
Pollutants, they are signatories to the Basel Convention.
The Basel Convention strictly regulates the transboundary movements of hazardous wastes and
provides obligations to its Parties to ensure that such wastes are managed and disposed of in an
environmentally sound manner. The main principles of the Basel Convention are:
• Transboundary movements of hazardous wastes should be reduced to a minimum

consistent with their environmentally sound management;
• Hazardous wastes should be treated and disposed of as close as possible to their source
of generation;
• Hazardous waste generation should be reduced and minimized at source.
In order to achieve these principles, the Convention aims to control the transboundary movement
of hazardous wastes, monitor and prevent illegal traffic, provide assistance for the
environmentally sound management of hazardous wastes, promote cooperation between Parties
in this field, and develop Technical Guidelines for the management of hazardous wastes.
3.4.9.2. PCB Practice at VOO Sites
In the late 1980s Veba undertook a survey of PCB’s across their sites and all identified PCB
material was transported to Ghani or Ras Lanuf, where they have remained. It is understood that
VOO, with NOC and others, is currently seeking a safe means of disposal.

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The PCB’s in Ghani are stored in a large wooden container, within a locked metal cage with
warning signs. However, it was not possible to inspect the PCB containers themselves and
ascertain their condition.
At Ras Lanuf there is an open, fenced storage area with both transformers and 45 gallon drums,
the majority of which are stored on a tray arrangement open to the environment (See Figure 3.8
and 3.9). Most were seen to be badly corroded, and many are leaking. The storage area is only
a few hundred metres from the shoreline, and possibly only a few metres above the water table.
Figure 3.8 PCB Storage at Ras Lanuf.
If the worst is assumed, the PCB containers in Ghani may be in a similar state to those is Ras
Lanuf.
Figure 3.9 PCB Storage at Ras Lanuf.
Although the VOO collection and storage of its PCBs was a good first step, the manner of storage
does not meet best practice. At Ras Lanuf it is likely that PCB containing oil may be
contaminating a wider area. PCBs can be carried long distances in the air (they remain in the air
for approximately 10 days), therefore the leaking containers could be the source of surface PCB
contamination to a much wider area.

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PCBs may also be entering the water table as the store is a couple of hundred meters from the
shore, and only a few meters above the water table. In water, a small amount of the PCBs may
remain dissolved, but most sticks to organic particles and sediments. PCBs in water
bioaccumulate in fish and marine mammals and can reach levels thousands of times higher than
background concentrations in the water.
33. Improvement of the storage facilities for PCBs particularly at the Ras Lanuf Terminal.
Ensure there is no longer the potential for leaking oil to be washed into the sand. Clearly
label the PCB areas and storage vessels. Specialist advice may be required.
34. For PCB containing equipment that may still be in use, best practice is that this should
only be in sealed equipment (e.g. transformers and capacitors) in good operating
condition which is regularly inspected for leakage, and appropriately labelled. The PCBs
should be left in place until the equipment reaches the end of its service life. At this point
it is essential to deal with its PCB content in an environmentally sound manner.
35. That, with others, VOO should investigate Environmentally Safe Destruction of PCBs
using proven and approved destruction methods.
Several destruction methods exist for PCBs such as incineration, gas-phase chemical
reduction, molten metal technology and plasma energy pyrolysis.
Incineration is currently the favoured method. High-temperature incineration results in

almost total oxidation of organic products into carbon dioxide, water and safely
disposable oxidation products. Any chlorine present is converted to hydrogen chloride
gas which is removed and either neutralised or recovered for further use.
UNEP Chemicals in co-operation with the Secretariat of the Basel Convention have
prepared a document "Inventory of Worldwide PCB Destruction Capacity" (December
1998). This states that "The most widely used and proven technology for destroying
PCBs is high-temperature incineration. Properly done, this has been shown to destroy
PCBs at a destruction removal efficiency of at least 99.9999 percent."
This document also states that Europe alone has sufficient incineration capacity to
dispose of all the world’s PCB wastes and there is also under-utilised capacity in North
America (the US). The issue is thus one of logistics and inventories in order to bring the
wastes to the sites where they can most safely be destroyed. There is also a political
issue of ensuring that developed countries, which have the capacity to destroy PCBs in
an environmentally sound manner, make that capacity available to other countries that
need it. This issue may need consideration in the development of the Stockholm treaty.
A study on incineration technologies and their applications in developing countries by

WHO, UNEP and the World Bank states: "Indeed, for compounds such as PCBs,
incineration is the only disposal route that can safely and adequately cope with the
volumes of waste arising." The study concludes "High-temperature incineration is likely to
remain the best practical environmental option for a significant portion of hazardous
wastes."

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4. AMAL
4.1. SITE HISTORY

The Amal concession is located in the Sirte basin enveloping a large area measuring about 35 x
120 km and extending between latitudes N28o 45’ and N29o 50’ and longitudes E20o 55’ and Eo21
20’.
The Amal field consists of four different sub fields comprising 15 reservoirs ranging in minimum
depth from 2,300 feet to12,000 feet, namely:
1. Amal field comprising 8 different reservoirs (Amal B, N and E, Buddaffar, Mesdar U,

Upper Sabil and Gialo) all producing into stations 1 through 8.
2. RAKB field consisting of 5 reservoirs (Rashda, RAKB1, RAKB 2, Gialo CC and Gialo GG)
all producing into Station 9.
3. Farigh field (AA area) consisting of one reservoir producing into station 10.
Oil was first discovered in the B reservoir by well B-1 in 1959 and approximately 212 wells have
been drilled in the Amal field since 1959.
Natural flow accounts for approximately 10% of Amal’s production with the remainder requiring
gas lift (about 70%) or electric submersible pumps (20%).
4.1.1 Summary of Site Activities

Amal’s production is subgrouped into 10 satellite stations with almost identical processing
facilities. At the satellite station, crude is flowed via the flowline to the production manifold where
demulsifier and corrosion inhibitor is injected and the crude enters the separator. The streams
from the separator are then split into three streams:
1. The gas stream from the separators is routed to the compressors with excess gas flared
and/or transferred.
2. The water stream from the separator is fed to the station skimmer with oil returned to
process and water discharged to a seep pit in the desert.
3. Crude oil from the separator goes to the gas boot for degassing and then to the settling
tank. From the settling tank, oil flows to the surge tank and then to the crude oil heaters
before pumping to the central pumping station. Water is discharged to the desert.
A gas oil extraction plant (GOE) receives crude from station 1 at a rate of 1800-1900 bbls/day
and can produce 600 bbls of diesel per day. Two grades of diesel can be produced, workover
and fuel quality. At the time of the review only fuel diesel was in production. Crude for the GOE
can also be received from stations 3, 5 and 6.
Power for the export compressors as well as electrical supply for the pump station, the camp and
the outlying stations is provided by two General Electric Frame 5 gas turbines (type M5001L) with
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diesel start, and an ABB/Stal GT-35 gas turbine. The Frame 5’s generate a maximum output of
10.75 MW, and the GT-35 a maximum turbine output of 17MW.
4.2. ATMOSPHERIC EMISSIONS
4.2.1 Nature of Atmospheric Emissions

Atmospheric emissions from the Amal site are typical of those normally associated with oil and
gas operations. At a typical station, high pressure gas is taken from the separator and used as
fuel gas to the heaters and compressors. Gas is also used for gas lift on some of the wells. Amal
operates a gas ring main allowing gas to be transported and shared across the stations ensuring
maximum use of the gas. The station also has an electrical grid system providing electricity to all
the sites. The site is remote and, other than as fuel or as gas lift, there is currently no useful
disposal route for surplus gas. As a result, the majority of the gas produced at Amal is flared
(See Table 4.1).
In general all High Pressure (HP) gas is flared; Low Pressure (LP) is vented. Main exception is
sour gas where current practice is to flare all the gas. Flaring of gas during shutdown of gas
turbines, heaters etc.
4.2.2 Summary Recommendations

Currently, gas flaring and venting accounts for approximately 73% of the total gas produced with
no useful route for the gas. It is known that studies are currently underway to investigate ways in
which the gas could be exported / used.
It is recommended that VOO investigates alternative ways of utilising this gas which may include
assessment of the following options:
A-1. In discussions with staff we believe that Amal is currently investigating the cost and
feasibility of installing a pipeline to export gas to a nearby industrial complex.
A-2. It is believed that, at its closest point Station 7 is approximately 3 km from the National
Power Transmission System. The cost and feasibility of installing an inverter to export
excess power directly to the national grid system should be investigated. Developments in
this area have significantly reduced the cost of invertors. Alternatively, it may be economic
to retrofit the GT-35 to produce electricity at 240 V / 50 Hz for export or to install a
dedicated generator.
A-3. Gas or NGLs could usefully be used at Ras Lanuf if it could safely be transported to, and
separated at the Terminal. VOO should investigate the practicability and cost of injecting
the gas into the oil export line and separating it out at Ras Lanuf.
A-4. It may be practical to re-inject unused gas into the reservoir for use later in field life.

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Table 4.1. Gas Usage and resultant Emissions at Amal
Amal Gas Usage CO2 CO NOx SO2 CH4 NMVOC

mmscfd Tones/year
Turbines 3.000 23,568 67,404 70.7 143.8 23.6 15.2 6.8
Compressors
8 cyl 1.710 13,434 38,420 40.3 82 13.4 8.7 3.5
Cooper bess 1.788 14,047 40,173 42.1 85.7 14.1 9.1 3.6
Ingersol 1.055 8,288 23,704 24.9 50.6 8.3 5.4 2.1
Heaters
Duey Heater 0.100 786 2,247 0.5 1.9 0.8 0.05 0.02
Other heaters 0.140 1,100 3,146 0.66 2.6 1.1 0.07 0.03
Dehydration 0.024 189 540 0.1 0.45 0.19 0.01 0.0
Diesel Usage - 558 1,787 0.5 7.54 1.12 0.02 0.17
Flaring 20.000 157,119 440,374 1,053 188.5 157 2,121 849
Uncontrolled flaring 1.400 13,286 30,826 74 13.2 11 149 60
Totals 277,269 648,620 1,306 576 230 2,308 924
Notes: Gas density assumed to be 26 tonnes/mmscf. Sulphur concentration in gas assumed to be 0.1%. Turbine factors used for compressors.
Hydrocarbon content of gas assumed to 67.5% methane, 27% non methane VOC, remainder carbon dioxide.

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4.3. LIQUID EFFLUENTS
4.3.1 Nature of Liquid Effluents

By far the largest liquid effluent is water arising from shallow water wells and from produced water
associated with the oil. Almost all of this water ends up being discharged to the desert either via
seep/evaporation pits or as irrigation water.
Water is extracted from a total of 24 shallow water wells (18 around the stations and 6 at the
potable water facility). The aquifer for this water sits approximately 300 feet below the surface
and is used as fire water, washing water and for irrigation. It is also used to produce potable
water for the camp. The shallow well water has a relatively low salt content, however not
sufficiently low to be suitable for potable water which is therefore produced onsite using a reverse
osmosis plant. Approximately 9,200 barrels of water are extracted from shallow wells every day to
produce 4,000 barrels of potable water.
The major aqueous waste is produced water. At the Amal site approximately 50,000 barrels of
produced water is discharged to the desert per day along with any entrained oil. Most of the
water discharged appeared to have a relatively low free-oil content and, on one site, a skimmer
was being used to recover additional oil from the aqueous stream prior to discharge. At Station 9,
the aqueous discharge had a high H2S content and, as a result, there was evidence of salt
deposition forming a scar on the desert though there was little evidence of oil in the water.
Table 4.2 Water Production and Discharge at the Amal Site (bbls/day).
Potable Water
Site Produced Water Sewage Total
Production
Produced 50,000 9,200 n/a 59,200
Discharged 50,000 4,000 716 54,716
Notes: 1. The amount of water discharged from the waste water treatment plant is taken from the maintenance manual.
4.3.1.1. Sewage
The Amal site has a waste water treatment (WWT) plant designed to treat domestic wastes in hot
climates. The WWT plant is designed around a standard aeration type of activated sludge tank
and is designed to meet the 20/30 International standard (BOD5/Suspended Solids(SS):20/30).
The plant was designed around the following criteria:

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Input raw sewage conditions:
Population equivalent 400 person equivalents (PE)
Average daily flow (280l/PE day) 112 m3/d
Average hourly flow 4.66 m3/hour
BOD5 loading (256 mg BOD5/l) 30 kg/d
Peak hourly flow rate 16.31 m3/h
Hydraulic loading 1.12 m3/m2.h
At the time of the site visit the WWT plant was found to be in poor condition having not been
maintained and was operating anaerobically. There was also evidence that the area around the
pump room had been subject to flooding.
4.3.1.2. Oily water
In addition to these major sources of aqueous discharge, oily water, sludge, oil and chemicals are
discharged to the desert a number of sources including:
• Water drained from storage tanks;
• Oil drained during maintenance operations;
• Oily waste from pig receivers
• Accidental discharges from pipelines, valves and flanges; and
• Chemical injection skids.
Currently most of the controls on the Station are manual so that, if a high high level alarm triggers
on a separator, someone has to drive to the field to investigate and repair. Any overflow from the
separator is discharged to the skimmer with oily water to the seep pit.
A new separator has been installed to treat water effluent from the oil export storage tanks but
this appeared, at the time of the review, to be operating at well below optimum performance.
Water from the separator discharges directly to the desert.
A potential future source of water discharge is the planned waterflood project. This involves
abstraction and treatment of water with chemicals (oxygen scavenger) before re-injection at the
periphery of the fields to pressurise the wells increasing recovery. Inevitably re-injection projects
can lead to discharges to the desert when, for instance, sand blocking occurs or the injection
systems trips. No information was available on this project at the time of writing.

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4.3.2 Legislation/Discharge Consents

No legislative requirements were identified however best practice calls for better control over the
discharge of liquid effluent to the desert and, at the least, an understanding of the nature of the
material discharged and its potential impacts.

A-5. Efforts are taken to improve and expand the current practice of recovering oil before
discharge of the remaining water to the desert.
A-6. In discussions with staff at Amal it was stated that Amal were considering the installation of
an integrated ESD system to avoid unnecessary losses and that a system had already
been installed at Station 5. This should be extended to all sites.
A-7. When draining equipment prior to maintenance, VOO should wherever practicable,
discharge the oil to a sump pit and recover the oil. A good example of this arrangement
was seen at Station 9.
A-8. Recommend a review of performance of the separator for treating oily water from the
export storage tanks.
A-9. There needs to be a better understanding of the nature of the water discharged to the
desert, as the potential for contamination of aquifer water cannot be ruled out. It is
recommended that VOO undertakes a small study at one of the sites to determine the
nature of the aqueous waste and undertakes a baseline analysis of aquifer water.
A-10. Urgent and immediate repairs are made to the Waste Water Treatment (WWT) plant, and
that responsibility and maintenance of the plant be prioritised.
A-11. It is known that Amal would like to introduce more greenery around the site, particularly on
the road from the airport to the site. We recommend that consideration be given to using
water from the waste water treatment plant for some or all of the water required and that
solid material from the WWT is used as a fertiliser. We believe that apart from the
environmental benefit, this would be a good public relations exercise.
4.4. WASTE MANAGEMENT
4.4.1 Nature of Wastes

The waste produced at the sites was typical of that expected of an industrial oil and gas
operation. In general, the Amal site was very tidy.
Domestic waste is collected from around the camp and site offices at regular daily intervals by the
camp contractor (Services). Domestic waste is also collected from a designated area to the rear
of the kitchens (putrescibles, paper, plastic, tins, glass and card) and from individual site offices
(paper, plastic and card).

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The waste is bagged in polythene bin liners. On average Amal generates between 25 and 30
bags per day: 20-25 from the kitchen; one from each of the accommodation areas; and 1 from
each of the workshops. These are collected each day and taken to the site tip for disposal by
combustion in a waste pit. In all, it was estimated that the site consumes between 9,000 bags per
6 to 8 months equating to some 4,500 m3 per year.
Swabs, bandages and other (solid) clinical wastes generated at the clinic are disposed on an
infrequent basis by the camp doctor. This includes used sharps and needles, though these are
placed in a sharps box before disposal, and expired medicines. The doctor ensures the
destruction of clinical waste by taking it personally to the burn pit and supervising its destruction.
Table 4.2 provides a summary of the major wastes produced on the Amal site based on
information provided during discussions at the site.
Table 4.2 Waste for disposal at the burn pit (bags per week)
Site Galley Domestic Industrial Clinical Total

Amal 25 3 2 0.5 30.5
Solid wastes (both hazardous and non hazardous) appear to be stored randomly in the desert.
For instance, spent acid batteries are buried in the desert at random locations. Much of this was
attributed to historic waste from Mobil operations and contractors. However the tendency to
deposit material anywhere was not helped by the fact that there appeared to be no marked,
purpose built compound for waste. As a consequence material could be seen scattered in the
desert over a wide area. Lying over a large area surrounding the camp were assorted wastes
including old cars and machinery, pipework and spent drums. In discussions with staff it is likely
that asbestos waste and old smoke detectors are also deposited in the desert. Given their size, it
is likely that some discarded smoke detectors have also been burned with the domestic waste.
refrigerants (containing freons) are emptied to atmosphere before the old ac units are removed to
the desert was not ascertained, however, it is known that this is the practice at one other site.
Refrigerants use and discharge was discussed in Section 3.4.8.

None of the sites operated a formal waste management system. At Amal, there was no recording
of waste arising and little control over the production of waste. As discussed above domestic,
kitchen and medical waste accumulation at the site is controlled regularly by burning at a
specified area. Tyres are segregated and either used as markers or burned and the possibility
that old smoke detectors are also burned could not be excluded. Inspection of the burn pit
indicated that there was insufficient fuel/air for combustion leading to a strong smell of rotting
vegetation. A member of the fire and safety team is in attendance to light the waste. This
seemed to be achieved by partly filling a bucket with diesel from a nearby storage tank, dousing
the waste and lighting it. On occasion, the ashes and other debris are mixed into the ground.
appeared to be a general area for the disposal of old cars.

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were used for harmful chemicals often had holes punched in them to prevent their use as
containers for potable water though we were told that drums are often removed without prior
permission for use by nearby camps.
Liquid waste produced on the site mainly consists of sewage water, oily water, sludge from the
bottom of separators and sand contaminated with oil. In respect of the sludge and contaminated
sand, the introduction a separator to recover the oil to export is a good example of best practice.
Although we have some concerns over the potential presence of contamination by normally
occurring radioactive material (discussed below under NORM and LSA) in this material.

There is currently little control over the waste at the Amal site, both in terms of the quantity
produced and how it is ultimately disposed of.
Although there are currently no regulations the site could be severely impacted by a country wide
waste management plan affecting the industry.
The majority of solid waste produced at Amal falls is non-hazardous industrial waste. The method
of disposal normally involves combustion for the kitchen and general waste, including material for
which combustion is inappropriate (eg plastics and empty paint cans) and dumping of non-
hazardous industrial waste. In addition, there appears to be routes for disposal of scrap material
which could be recycled or re-used.
The management of waste could be significantly improved if there was better control and
segregation of the waste including; an assessment of the quantity produced, where it is produced
and implementation of steps to reduce the amount produced. The management of waste at all of
VOO sites could be improved by:
A-12. Implementation of a waste management system covering all of VOO’s operations

addressing waste minimisation, storage and disposal.
A-13. The introduction of consignment notes in line with best practice.
A-14. Waste sites should be improved by designating areas for storing/disposal of wastes and
better policing of contractors to ensure that only designated areas are used.
A-15. Liquid chemical and oily waste, which could spill and contaminate the area, should be
stored in bunded areas on a concrete base.
A-16. A single source of information for the disposal of waste be set up within VOO -possibly this
should be based in the field rather than in Tripoli possibly at Ras Lanuf.
A-17. The potential to produce best in class waste disposal facilities for certain types of
hazardous waste in co-operation with other operators should be explored. The area
around Ras Lanuf, with nearby petrochemical facilities is a potential area for such a facility.

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4.5. STORAGE OF MATERIALS
4.5.1 Storage Arrangements

In general storage arrangements for chemicals and other material on the Amal site was good.
Although not assessed in depth, the warehouse kept excellent records of goods received and
issued. Currently the warehouse, in common with all the warehouses at the VOO sites visited,
operates two means of tracking stock: the original cardex system and a computer based system.
Good use was made of the available space available with adequate separation between
chemicals. Hazardous chemicals were segregated and safely stored. However, the warehouse
currently stores chemical drums containing out of date and surplus chemicals. The markings on
these have mostly faded and many of the drums are in poor condition and are leaking directly to
the desert. As a priority, whilst the contents of these drums are known, they should be clearly
labelled and, if safe to do so, the contents of leaking drums transferred to new drums. As stated,
some these chemicals are surplus rather than out of date and the potential for their use at other
locations should be investigated. For the remainder a safe means of disposal should be
identified.
There is no national system for the identification of gas cylinders similar to that in use elsewhere.
As a consequence, the wrong gas may be used with potential dire consequences. VOO should
adopt a standard system for marking cylinders, perhaps as part of an industry or pan industry
project.

A-18. Storage areas should drain to a closed drain system to prevent escape of chemicals and oil
to the desert.
A-19. All chemical drums should be clearly labelled and damaged and leaking drums dealt with
as a matter of urgency. The cost of disposal for chemicals increases significantly if the
nature of the chemical is not known and if container is leaking.
A-20. VOO should develop a standard method for marking and identifying gas cylinders.
4.6. MISCELLANEOUS NUISANCE
4.6.1 Site Nuisance Potential

The site is not near any major populated areas and, therefore, offsite noise is not a major issue. It
was noted that the noise levels at the camp, from the site, were not excessive.
The visual impact of the site is poor due to the flaring of gas but, again, due to it's location, this is
not a significant issue.

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4.7. CONTAMINATED LAND AND ENVIRONMENTAL LEGACIES
4.7.1 Potential for Contamination from Current and Historical Operations

The area around the Amal site is littered with waste consisting of mainly scrap metal but also
other items such as old flowlines, processing equipment, air conditioning units and domestic
waste. Of all the sites reviewed, Amal suffers worst from random dumping of waste. Should a
regulatory body be formed then waste management and proper disposal of waste will almost
certainly be among its first priorities. The task of cleaning the area will not be a speedy one but it
need not be expensive. As a priority, it is recommended that a waste management plan be put in
place and designated areas be assigned for the disposal/safe storage of certain wastes. Once in
place an attempt should be made to recover waste from the surrounding area and transfer it to
the new sites. In respect of waste generated by contractors, they should not be allowed to
decamp before VOO are satisfied that any waste generated is properly disposed of.
The continuous discharge of oil waste (and other hazardous material described above) to the
desert can lead to the migration of pollutants into aquifers. In the Amal region water is abstracted
from saline water lying at a depth of approximately 100m for use as general process water and
for the production of potable water.
Whilst at Amal, an opportunity to visit workover operations was taken. There were visible signs
that all waste from drilling was dumped in the desert (Figure 4.1).
Figure 4.1 Typical Workover Waste Viewed at Amal
Drilling waste is problematic in that all waste (contaminated cuttings, used tins, metal pipework
etc) is thrown into the seep pit, covered with sand and left. In discussing this with the drilling
contractor, we were told that all waste from drilling was the responsibility of VOO and standard
procedures were for disposal to the desert.

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Discussions with drilling indicated that low specific activity scale (LSA scale) was a problem in
terms of immediate hazard to drilling staff and, due to the nature of disposal a long term problem
for VOO. On completion of drilling, waste, including LSA contaminated pipework is buried in the
desert. It is known that farmers in the vicinity remove piping to use for irrigation water and it was
stated that on at least one occasion LSA contaminated pipework was dug up by farmers. This
represents a potentially major liability for VOO.
The clinic has an old X-Ray machine which is currently not in use. At some stage this will need to
be removed from the surgery and decommissioned in a safe manner. Although the nature of the
source was not discussed, these machines often operate by using a Co-60 or Cs-137 source to
generate X-rays. Both of these are strong X-ray emitter and will need to be removed from the
machine for safe storage and disposal. Similarly, the machine itself will need to be disposed of to
a specialist facility.
4.7.2 Legislation/Best Practice

In discussions with staff currently there appears to be no legislation dealing with contaminated
land. Libya is a signatory to the IAEA and, as such, has obligations to use, store and dispose of
radioactive material in a safe manner.

It is essential that VOO take steps to put in place controls over the handling, storage and disposal
of waste as outlined in Section 4.4. This is not primarily a problem at Amal but impacts on the
whole business across all the sites.
A-21. Steps should be taken to map out current waste sites including areas around well heads for
indications of contamination in order to determine the scale of the problem.
A-22. Designated areas should be set up for the disposal of waste and, in the case of hazardous
waste; these should be secure and built in a manner that minimises the potential for
spillage of material.
A-23. VOO should, within their waste management system, adopt a system for the control of
radioactive material.
A-24. Future contamination should be minimised by adopting the recommendations set out in
Sections 4.1 – 4.6.

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5. GHANI AND JOFRA
5.1. SITE HISTORY

The Ghani field is located in the Western Sirte Basin, covering an area measuring approximately
35 x 80 km and extending between Latitudes N28o 50’ and N29o 27’ and Longitudes E17o 18’ and
E17o 42’.
The Jofra field is also located in the Western Sirte Basin (North East of Ghani) and covers a
smaller area of 35 x 55 km extending between Latitudes N29o 07’ and N29o 32’ and Longitudes
E17o 54’ and E18o 12’.
The Ghani field is surrounded by 7 concessions (e.g.

Zueitina and Waha) and Jofra is surrounded by 6
concessions (e.g. Waha and Agoco). Ghani and Jofra
tie in with Zueitina (Zella) crude via a 20” pipeline
which subsequently ties in with Tibisti crude to the Ras
Lanuf Terminal.
Oil was first discovered in Ghani by the well RRR-1-11

in January 1978. The Ghani Main Station was initially
commissioned in 1980 and reached a peak production
of 44,000 bbls / day in April 1981.
Oil was first discovered in Jofra by the well 0000-1-11

in August 1989. The Jofra area has undergone a
reactivation project in 1987, and the Main Station was
commissioned in 1989, and is presently producing 300
bbls/day from 3 wells.
Jofra receives oil from the JJ station and YY area (the

YY area has been largely decommissioned since 2000). JJ-station oil was first discovered by the
well JJ-1-11 in 1964. Through the reactivation project JJ-station was commissioned in 1987 with
an initial production of 3,000 bbls/day from 17 wells. Currently the production is 2,500 bbls / day
from 14 wells.
At present, Ghani main station is producing 21,000 bbls / day from 26 wells. In addition Ghani
Main Station receives oil from its field stations and outlying reservoirs. The typical production for
each is listed below in Table 5.1.

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Table 5.1 Typical Daily Production from Ghani, it’s Field Stations, Outlying Reservoirs and the Jofra Field. From
Daily Production Report Dated 30/10/2002.
Location No. of Wells Production (bbls/day)

Ghani Main Station 26 21,000
Zenad 9 6,600
Tagrifet 5 2,400
Facha 6 1,000
Gir Facha 20 9,500
Ed Dib 9 4,000
Total Ghani 75 44,500

Jofra 14 2,500
Zenad was first discovered by the well VVV-1-11 in 1978, with an initial production rate of 12,000
bbls / day after commissioning in 1987, and 7,000 bbls / day after re-commissioning in 1990.
Tagrifet was first discovered by the well LLL -1-11 in 1975, and was initially commissioned in
1990, with a production rate of 5,500 bbls / day, that has now dropped to the present level of
2,400 bbls / day.
Facha was first discovered by the well L-1-11 in 1963, the field was initially commissioned in 1991
at a production rate of 1,000 bbls / day, which it is still producing today.
Natural flow production accounts for part of the Ghani field’s reservoir wells, however, pumps
(ESP) have been installed as water breakthrough occurs, and water injection in being used in a
number of wells.
Crude is received from all the oil gathering stations via transfer lines (vary from 6-12”) into the
Ghani Main Station crude tanks. All transfer lines between the satellite stations and are regularly
being pigged on a monthly basis. The three tanks have a combined storage capability of 120,000
bbls. This crude is pumped from Ghani, ties in with Jofra, then Tibisti and travels to the Ras
Lanuf tank farm.

The Ghani and Jofra stations and outlying fields have similar processing facilities with some site
specific differences which will be discussed below.
Crude is flowed via the flowline to the production manifold where demulsifier and corrosion
inhibitor is injected prior to the crude entering the separators. The stream from the separators is
then split into three streams:

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1. The gas stream from the separators is routed to the fuel gas drying plant / scrubber, with
excess gas flared.
2. The water stream from the separator is fed to the station main water drain into the water
pit.
3. Crude oil from the separator goes to the heaters and desalters for further gas and water
separation then into the gas boot where more gas can be extracted before entering the
storage tank. Water accumulated at the bottom of the storage tank is recycled back into
the heaters and desalters for further water separation.
Typical Ghani / Jofra equipment consists of the following:
1. Production manifold and production & test separators;
2. Heaters and desalters;
3. Fuel gas dryer/scrubber;
4. Gas boots,and storage tanks;
5. Booster pumps, shipping pumps and metering area.
6. Skim tank, transfer pumps and injection pumps
5.1.2 Site Specific Differences:

Ghani Main Station
Water Injection Plant – water injection pilot project started in 1985. It is supplied by
approximately 32 water wells which produce roughly 50,000 bbls / day. This water is re-injected
in a number of wells (13?) in Ghani to provide pressure in the reservoir and increase production.
A percentage of the water injected is produced water.
Gas Drying Plant
Installed and commissioned in 1988. Wet natural gas from the separators is compressed and
dehydrated by chilling using propane gas as a refrigerant. This processed dry natural gas is then
used mainly for power turbines and heater burners fuel gas. Dry gas production from this plant is
approximately 6.5 mcfd. Propane gas annual consumption is approximately 500 bbls.
Gas Oil Extraction Plant
Installed and commissioned in the later part of 1980. It can produce around 600 bbls of diesel
per day. Processed diesel fuel is supplied mainly for power generation turbine fuel, transportation
fuel and workover rig consumption.
Zenad Station
All the Ghani fields sour wells production flows into Zenad Station, where sweet and sour crude
flows through separate flowlines into the production manifold where demulsifiers and corrosion
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inhibitor are injected prior to the crude flowing separately into the sweet and sour crude
production separators. Both the sweet and sour crude streams are then split into the three
streams as described previously, with the only difference being the use of a sour gas scrubber
after the crude leaves the heater / desalter.
Tagrifet Station
Has additional settling tank prior to export to Zenad storage tanks.
Jofra Field
Due to the high concentration of H2S gas (2000 ppm) in some of the Jofra wells, an Amine plant
was installed and commissioned in 1990 to sweeten the sour gas. H2S is extracted by absorption
when in contact with amine / water solution. Steam from the re-boiler further extracts H2S when
in contact with the H2S saturated amine / water solution and the extracted H2S vapour is then
flared. The sweetened gas is used as fuel gas for the gas engines at well sites and also for gas
blanketing purposes.
5.1.3 Power Supply

Ghani Main Station
The current power plant was commissioned in 1994 to increase the generation capacity of the
field and was designed to include the equipment required for the water injection.
The power generation plant consists of 4 identical European Tornado gas turbines driven
generators; all designed for dual fuel and are capable of achieving 4.5 MW at peak. Turbines are
normally run on gas fuel, switching automatically to liquid if there is an interruption of the dry gas
supply. With the current maximum load 9 MW, power is supplied by 2 units, with the other two as
stand-by.
Additionally there are two Ruston TB-5000 gas turbines / generators. Capable of producing 2.6
MW each at peak these turbines can now only be run on liquid fuel as the gas fuel system has
been decommissioned. They are left offline, but designed to start automatically if there is a
power outage.
Finally there is a portable diesel engine driven Caterpillar D398 generator capable of producing
500 KW. This is used as a stand-by unit used for black start for the Tornado turbines after a
complete power outage.
Electrical power is supplied to the stations and wells from the main power generation plant by
means of electrical power ‘high line’.
Zenad
One diesel engine driven Siemens 285 KVA generator serves as stand-by power generator which
starts automatically in case of ‘high line’ power outage.

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Tagrifet
A diesel engine driven Siemens 850 KVA generator serves as stand-by power generator which
starts automatically in case of ‘high line’ power outage.
Facha
Electrical power is supplied to the station and wells by a local portable diesel engine driven
Caterpillar 500 KW generator. Two diesel engine driven Siemens 285 KVA generators serve as
stand-by power generators in which one generator is set to start automatically in case of main
power generator breakdown.
Jofra Main Power Station
This power generation plant consists of two gas driven Kato 300 KW generators both running in
parallel during normal operation. Two further diesel engine driven Kato 500 KW generators serve
as stand by units.
Jofra JJ Station
Electrical power is generated by a local portable gas engine driven Kato 500 KW generator
producing a load of 300 KW which feeds the local sub-station. A diesel engine driven Kato 500
KW generator serves as stand-by. Synchronization facilities are provided for each generator.
The main generator provides power to all the station equipment.
Table 5.2 Typical Gas Production
Station Gas production MCF/D
Ghani 13,176
Zenad 3,463
Tagrifet 140
Facha 30
Gir Facha 755
Ed Dib 160
Ghani total 17,724
Jofra 1,128

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Atmospheric emissions from the Ghani and Jofra sites are typical of those normally associated
with oil and gas operations. The sites are remote and, currently there is no useful route for any
gas produced, other than as fuel gas and as gas lift on some of the wells. In Jofra, due to the low
levels of production, 60% of the produced gas is used as fuel, but at Ghani the majority of the gas
produced (85 %) is flared. Some 17.724 mmscfd of gas is produced at Ghani.
At a typical station, high pressure gas is taken from the separator and used fuel gas to the
heaters and compressors. Any excess HP gas is flared. All low pressure gas is flared. Table 5.3
summarises gas use across all the sites.
During the site visit the flare at Ghani was the most prominent feature and could be seen from
miles around the site. Combustion was not efficient as was evident from the smoky nature of the
flare.
The majority of producing wells at Joffra are sour and the JJ station has an amine unit for sulphur
removal, the acid gas from unit is flared locally.
5.2.1 Venting and Fugitives

In addition to emissions from power generation and flaring, Ghani, Joffra and the outlying sites all
vent gas to the atmosphere either continuously from storage tanks or intermittently from, for
instance, sphere receivers. In addition, oil and gas sites are known to lose fugitive gas to the
atmosphere from leaks across flanges and pump seals. At this stage it has not been possible to
estimate the total amount of gas vented.
At Joffra, the aquifer water is sour and, therefore, the potable water system includes a degasser
to remove H2S which is vented locally. No odour could be detected on the day of the review.

G-1. As at Amal, the majority of the gas is flared and, therefore, similar means of making use of
the gas should be explored including greater use of gas as fuel, re-inject unused gas into
the reservoir for use later in field life and potential export routes fro the gas

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Table 5.3. Gas Usage and resultant Emissions at Ghani
Combustion product/gas emitted/tonne/year

CO2 CO NOx SO2 CH4 NMVOC
Fuel gas Use Use (t/yr)
Ghani 2.25 mmscfd 17675.93 50553.15 10.61 42.42 17.68 1.14 0.46
Heaters 1.5 mmscfd 11783.95 33702.10 7.07 28.28 11.78 0.76 0.30
Sour gas stripping 1.25 mmscfd 9819.96 28085.09 5.89 23.57 9.82 0.63 0.25
Zenad 0.5 mmscfd 3927.98 11234.03 2.36 9.43 3.93 0.25 0.10
Total fuel gas 123574.38 25.92 103.70 43.21 2.79 1.12
Diesel Usage 215 bbls 10312.66 33000.52 9.49 139.22 20.63 0.34 3.09
Gas flared (controlled)

Ghani 10.926 mmscfd 85834.31 240576.39 575.09 103.00 85.83 1158.76 464.02
Zenad 2.963 mmscfd 23277.23 65241.43 155.96 27.93 23.28 314.24 125.84
Tagrifet 0.14 mmscfd 1099.84 3082.62 7.37 1.32 1.10 14.85 5.95
Facha 0.03 mmscfd 235.68 660.56 1.58 0.28 0.24 3.18 1.27
Gir Facha 0.755 mmscfd 5931.26 16624.12 39.74 7.12 5.93 80.07 32.06
Ed Dib 0.16 mmscfd 1256.95 3522.99 8.42 1.51 1.26 16.97 6.80
Jofra 1.128 mmscfd 8861.53 24837.10 59.37 10.63 8.86 119.63 47.91
Gas flared
4.048 mmscfd 31800.96 89131.73 213.07 38.16 31.80 429.31 171.92
(uncontrolled)
Total flare 443676.95 1060.59 189.96 158.30 2137.02 855.76
Overall total 600251.84 1096.01 432.88 222.13 2140.15 859.97
Notes: Gas density assumed to be 26 tonnes/mmscf. Sulphur concentration in gas assumed to be 0.1%. Turbine factors used for compressors. Hydrocarbon content of gas assumed
to 67.5% methane, 27% non methane VOC, remainder carbon dioxide.

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5.3. LIQUID DISCHARGES
5.3.1 Oil
At Ghani and Jofra, oily liquid waste produced on the site comes from similar sources to those at
Amal, namely:
• Water drained from storage tanks and separators;
• Sludge from the bottom of storage tanks and separators;
• Sand contaminated with oil;
• Oily waste from pig receivers;
• Accidental discharges from pipelines, separators, valves and flanges.
The majority of oily waste from all these sources is disposed of directly to the desert. Either to
sizable seep pits, holes in the sand or directly onto the desert surface. Periodically these sites of
discharge are altered, and old holes are covered, seep pits left, forming historical indicators of oil
and gas activity in the area.
Some of the oil contaminated sand is used for the creation of bund walls, or road surfacing, but
most is left in place. Around the sites at Ghani and Jofra there were observable signs of oily
waste.
Currently in Amal there are two oil recovery units, one purpose built, and one homemade on site.
These recovery units (especially the homemade one) have allowed Amal to recover the waste oil
for export (even from historic seep pits), and is a good example of best working practice.
However, there seemed to be no such systems at Ghani and Jofra.
5.3.2 Water
5.3.2.1. Ghani
By far the largest liquid effluent is water arising from Aquifer wells and from produced water
associated with the oil. Almost all of this water ends up being injected to maintain reservoir
pressure, but a significant volume is also discharged to the desert.
Water is extracted from a total of 32 aquifer wells. The aquifer for this water sits approximately
1200 feet below the surface and is used to maintain reservoir pressure, provide fire water,
washing water and for general site irrigation. It is also used to produce potable water for the
camp.

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Although the aquifer well water has a relatively low salt content, it is not sufficiently low to be
suitable for potable water. To achieve the desired water quality Ghani uses ion exchange water
treatment, which adds and removes ions from water. In general a plastic bead (called resin) is
used as the exchange site. The bead is permanently charged and attracts ions of the opposite
charge. Each ion in the water has a different affinity for the resin. Those with greater affinity will
replace those with less affinity.
Approximately 4,000 to 6,000 barrels of water are extracted from aquifer wells every day (See
Table 5.4). This is used to produce potable water (800 bbls per day) with the remainder used
untreated for watering trees and grass, desalting oil, drilling and other purposes.
Table 5.4 Water Production and Discharge at the Ghani Site (bbls/day).
Aquifer Produced Potable Water

Site Injection Water Total
Water Water Production
Produced 4,000 – 6000 5,000 50,000 800 61,000
Injected 6,500 45,000 -
Discharged 4,000 - 6,000 - 5,000 800 11,000
5.3.2.2. Jofra
Water is extracted from 2 water wells. The aquifer for this water sits approximately 300 feet
below the surface and is used to provide fire water, washing water and for general site irrigation.
It is also used to produce potable water for the camp.
Approximately 400 barrels of water are extracted from the aquifer wells at Jofra every day for use
at the reverse osmosis plant (See Table 5.5). From this the plant produces 260 bbls/day of
potable water, and 140 bbls/day of concentrate flows to the desert.
Table 5.5 Water Production and Discharge at the Jofra Site (bbls/day).
Produced Potable Water

Site Sewage Total
Water Production
Produced 5,000 400 5,400
Discharged 5,000 140 260 5,400
5.3.3 Sewage
The Ghani site unlike Amal and Ras Lanuf, does not have a waste water treatment (WWT) plant.
Instead it relies upon 12 septic tanks. These septic tanks are spread to cover the whole site,
with:
• 3 at the Ghani Camp
• 6 at the Ghani Maintainance Area
• 1 at Zenad, Tagrifet and Facha (3 in total)

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It is believed that the septic tanks in Ghani are not routinely emptied of solids / sludge, and
therefore may no longer be operating correctly, and could pose a threat to human health.
All sewage (from both the main site and contractor camps) liquid is sent to seep pits. The area
around the seep pits is generally densely vegetated for the locale, and tends to attract
mosquitoes. To counter this associated vegetation growth and mosquito breeding the Ghani /
Jofra fire service regularly sets fire to the flora. Although it is believed this only occurs on those
generated by Ghani / Jofra sewage, and not from the contractors.
The Jofra sewage treatment was not viewed in depth, but a septic tank is also used, and it is
assumed it will be managed using a similar method to Ghani. Vegetation at Jofra showed signs
of previous burning.

Water production and use at Ghani is dominated by the extraction and re-injection of aquifer
water. Water discharge to the desert was lower that in Amal due mainly to the re-injection of a
significant fraction of the produced water with aquifer water. Of principal concern at Ghani is the
potential condition of the septic tanks. As discussed in Section 3.3.3, septic tanks work if the
level of sludge in the tank is controlled. Information from Ghani would suggest that the tanks are
drained annually (September) but we are uncertain whether the drained material is sent for safe
disposal or drained locally. We have therefore assumed that the sewage is being discharged to
the desert untreated. We recommend the following:
G-2. Samples of the effluent from the septic tanks are analysed for activity to demonstrate that
the unit is still active.
G-3. Depending upon the results from 1, a local contractor is sought to empty and reactivate the
tanks and that a contract be placed for regular emptying.
G-4. The contractor be obliged to further treat the sewage before disposal.
G-5. Better use is made of the liquid effluent from the septic tanks, possibly for general irrigation
rather than forming seep pits.

The waste produced at the sites was typical of that expected at an industrial oil and gas
operation.
In general, the Ghani and Jofra sites were very tidy.
Domestic waste is collected from around the camps and site offices at regular daily intervals by
the camp contractor (Services). Domestic waste is also collected from a designated area to the
rear of the kitchens (putrescibles, paper, plastic, tins, glass and card) and from individual site
offices (paper, plastic and card).
The waste is bagged in polythene bin liners. On average Ghani generates approximately 50
bags per day, while Jofra generates proportionally less waste, in the order of 20 bags per day.

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These are collected each day and taken to the site tips for disposal by combustion in a waste pit.
In all, it was estimated that the Ghani site consumes 18,250 bags per annum, while Jofra
consumes 7,300 bags per annum. This is a combined volume of approximately 6,400 m3 per
annum.
As in Amal, there is a burn pit for all food and general waste. However, Ghani has constructed a
purpose built incinerator within the pit, to improve the combustion of the waste. The waste is
doused in hydrocarbons from a condensate line with the control valve beside the road
(approximately 100 m from the incinerator). Combustion appeared more efficient than seen
previously at Amal, and the general area around the incinerator was fairly tidy. However, good
working practise needs to be in place for controlling the condensate line.
Although not viewed, it is assumed that the burn pit at Jofra will be of a similar design to those
seen at the other Veba sites. With the relatively small volumes of waste produced by the station
and the good house keeping standards visible at Jofra, it is expected that combustion would be
relatively efficient, and that the area would be kept tidy.
regular basis by the camp doctor at Ghani and Staff Nurse at Jofra. This includes used sharps
and needles (placed in a sharps box before disposal), and expired medicines. The doctor
ensures the destruction of clinical waste by taking it personally to the burn pit and supervising its
destruction.
Solid wastes (both hazardous and non hazardous) appear to be dumped in the desert. These
areas seemed to be relatively small, but are not marked as designated disposal sites. However,
with the burying of waste without management it is not possible to ascertain the full coverage of
waste. For instance, spent acid batteries and pyrophoric iron scaled pipelines are buried in the
desert at random locations.
In discussions with staff it is likely that asbestos waste and old smoke detectors are also
deposited in the desert. Given their size, it is likely that some discarded smoke detectors have
also been burned with the domestic waste.
The worst control of waste was observed at abandoned contractor camps, where contractors left
leaving chemical drums in varying states of decay, old accommodation units, scrap metal and
other miscellaneous wastes scattered over the locale.
However the tendency to deposit material anywhere by both Veba (although more controlled than
Amal) and its contractors, was not helped by the fact that there appeared to be no marked,
purpose built compound for waste. As a consequence material could be seen scattered over the
desert.
refrigerants (containing freons) are emptied to atmosphere before the old ac units are removed to
the desert was not ascertained, however, it is known that this is the practice at one other site.
Table 5.6 provides a summary of the major wastes produced on the Ghani and Jofra sites based
on information provided during discussions at the sites.

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Table 5.6 Waste for disposal at the burn pit (bags per week)
Galley, Domestic and

Site Clinical Total
Industrial
Ghani 350 0.25 350
Jofra 140 0.125 140

None of the sites operated a formal waste management system. At Ghani and Jofra, there was
no recording of waste arising and little control over the production of waste. As discussed above
domestic, kitchen and medical waste accumulation at the site is controlled regularly by burning at
a specified area. Tyres are segregated and either used as markers or burned and the possibility
that old smoke detectors are also burned could not be excluded. Inspection of the burn pit
indicated that there was sufficient fuel / air for combustion leading unlike Amal. A member of the
fire and safety team is in attendance to light the waste. This is achieved by dousing the waste
with condensate and lighting it. On occasion, the ashes and other debris are mixed into the
ground.
appeared to a general area for old pipes.
were used for toxic chemicals often had holes punched in them to prevent their use as containers
for potable water.

The majority of solid waste produced at Ghani and Jofra falls into three main categories, domestic
(from the camp), medical waste and non-hazardous industrial waste. The methods of disposal
normally involves combustion for the domestic and medical waste, including material for which
combustion is inappropriate (eg plastics and empty paint cans) and dumping of non-hazardous
industrial waste.
In addition, there appears to be available routes for the disposal of scrap material for recycling or
reuse. These are currently not used by the sites, although it is understood that some empty
drums are reused as markers or rubbish bins etc.
5.4.3 Special Wastes / Liabilities
5.4.3.1. Polychlorinated Biphenyls (PCBs)
Veba undertook a survey of PCB’s across their sites in the late 1990’s with all identified material
transported to Ghani and Ras Lanuf. The PCB’s in Ghani are stored in a large wooden container,
within a locked metal cage with warning signs. However, it was not possible to inspect the PCB
containers themselves and ascertain their condition. This issue was discussed in more detail in
Section 3.4.9.

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5.4.3.2. LSA Scale
In discussions with staff it was ascertained that Ghani has found LSA scale in a number of
systems, and that, in some areas, the high H2S content of the reservoir fluids has led to plugging
of lines with iron sulphide.
The disposal of contaminated pipework does not meet current industry best practice, nor the
requirements of, for instance, IAEA. In many instances, the waste is potentially hazardous.

There is currently little control over the waste produced at the Ghani and Jofra sites, both in terms
of the quantity produced and how it is ultimately disposed of.
The management of waste could be significantly improved if there was better control and
segregation of the waste including; an assessment of the quantity produced, where it is produced
and implementation of steps to reduce the amount produced. The management of waste at all of
VOO sites could be improved by:
G-6. Implementation of a waste management system covering all of VOO’s operations and the
introduction of consignment notes in line with best practice.
G-7. Waste sites should be improved by designating areas for storing/disposal of wastes and
better policing of contractors to ensure that only designated areas are used.
G-8. Liquid waste, which could spill and contaminate the area, should be stored in bunded areas
on a concrete base.
G-9. A single source of information for the disposal of waste be set up within VOO -possibly this
G-10. The potential to produce best in class waste disposal facilities for certain types of

In general storage arrangements for chemicals and other material on the Ghani and Jofra sites
site was the same as that at Amal and the comments and recommendations made there are
applicable here.
5.6. SITE NUISANCE POTENTIAL

The site is not near any major populated areas and, therefore, offsite noise is not a major issue.
It was noted that the noise levels at the camp, from the site, were not excessive.

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The visual impact of the site is poor due to the flaring of gas (See Figure 5.1) but, due to its
location, this is not a significant issue. However, smoking flares are often seen as an indicator of
‘bad’ oil and gas practice. Should a regulatory body be formed, this may be an area that needs
addressed.
Figure 5.1 Flaring at one of Ghani’s Outlying Stations.

Similar to Amal, and therefore, the comments and recommendations made there are applicable
here with the exception of PCBs previously discussed in Section 5.4.6.1.

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6. RAS LANUF TERMINAL
6.1. TERMINAL HISTORY

Ras Lanuf is situated at a low and arid site on the Mediterranean coast of North Africa in the Gulf
of Sirte. It is approximately 122 miles from the port of Benghazi and 110 miles from the port of
Sirte, with a Latitude of 30° 30’ 52” North and a Longitude 18° 34’ 18” East. Ras Lanuf came into
service roughly 40 years ago, although the final tank was not completed until 1969.
The Ras Lanuf Terminal can be split into three sections;
• The Tank Farm;
• The Main Station;
• The Port / Offloading Facilities.
6.1.1 The Tank Farm
Ras Lanuf receives all of the VOO crude oil production and also crude oil from two other
operators (a total of ~ 270,000 bbls / day). Oil is received into one or more of thirteen, 500,000
bbl storage tanks, with a diameter of 80 m, and a height of 17 m (See Figure 6.1).
The 13 tanks are sited within a tank farm, 9.5 kilometres from the port and approximately 100 m
above sea level.
VOO uses six tanks (No.s 5, 6, 7, 8, 9 & 12). Third party oil from AGOCo is stored in 3 dedicated
storage tanks (No.s 10, 11 & 13), from which it is transferred to a refinery approximately 12
kilometres distant. Additional third party oil from Sirtica is stored in one of 4 dedicated storage
tanks (No.s 1, 2, 3 & 4). All VOO and Sirtica oil is transferred to marine tankers for export.
The altitude (See Figure 6.2) of the tank farm allows oil from storage to be supplied either to the
adjacent refinery or into sea going tankers under gravity flow.
6.1.2 The Main Station
The VOO Ras Lanuf Main Station is located on a ridge parallel with the coast line some 20 m
high, 1.5 km from the coast and 8 km from the tank farm.
The Main station is where the two storey VOO office block is located, and surrounding this area is
the staff accommodation, mess halls, surgery, fire station, camp amenities, warehousing,
laboratory, maintenance workshops, petrol station, metering station and an oil recovery tank of
10,000 bbls capacity.

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Figure 6.1 Ras Lanuf Tank Farm Looking E Parallel to the Coast.
6.1.2.1. Power Supply
The power is supplied to the Terminal from two sources:
• 1.5 MW supplied from RASCo
• Two D-399 Caterpillar, 500 KV on stand by (Rated at 900 KV but operated at a maximum
of 600 KV)
6.1.2.2. Water
There are two fresh water storage tanks of 760 m3 each, and a single water tower.
Potable water is currently supplied by the nearby RASCo refinery. Previously this was produced
onsite using 3 UNIHA gmb Reverse Osmosis units, with a maximum capacity of 150 m3 / day.
However, this system is currently mothballed.
Figure 6.2 The Elevated Tank Farm Looking from the Metering Area in the Main Station.

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6.1.2.3. The Port / Offloading Facilities
There are four submarine loading pipelines which terminate at 4 separate berths, two marked by
an unlit spar buoy and two marked by a single point mooring (SPM) buoy.
Berths 1 and 2 are approximately 1.5 km offshore, and are conventional submarine loading
berths of the seven point type. These berths can handle tankers from 19,000 to 130,000 D.W.T
at a gravity loading rate of 60,000 bbls/hr.
The two SPM moorings are approximately 3 km offshore, and are designed to handle tankers up
to 2,555,000 D.W.T in berth 4, and up to 3,000,000 D.W.T in berth 3. The SPMs are large
cylindrical buoys (250 tons), divided by steel bulkheads into 4 watertight compartments, through
the centre of which emerges the loading hose. The perimeter of the buoy is turn-able, allowing
the tankers to ‘weather vane’.
The recovery tank at the Main Station has both pressure and vacuum pumps which can be
applied to a single berth or all berths at the same time. This system enables the loading lines to
be emptied of oil prior to disconnection, preventing any oil spillage, and also allows the recovered
oil to still be exported.
6.1.2.4. Ballast Water
Ras Lanuf does not have any facilities for the disposal of dirty ballast. In addition to the
International Convention Laws (MARPOL 74/78) concerning pollution of the sea, the Terminal
regulations state that only segregated and / or permanent ballast will be allowed to be
discharged, and that no ballast will be allowed to be discharged from any cargo tanker.
6.1.2.5. Harbour
A new harbour with main breakwater and lee breakwater was built in 1983.
The harbour consists of an old small quay, and a 5 year old 200 m long quay with all essential
utilities. It is used to shelter the mooring launches and work barge, as well as an area for
maintenance of the floating equipment. An in-house constructed slipway is used to dry dock the
berths, buoys and other sea craft.
Additionally used hawsers and loading hoses are stored on the seabed in the harbour.
6.1.3 Temperature, Winds, Waves and Currents

In summer, coastal temperature near sea level can exceed 43°C, but in winter these can fall
below zero. High temperatures experienced in the coastal zones reduce with altitude in the hills,
and on rare occasions, snow has been recorded on the hills.
Winds of up to 35 m/s have been recorded in the vicinity of the Terminal in recent years. Winds
in the area are generally unpredictable in direction or force, and precautions are necessary to
avoid difficulties.
In spring and autumn, strong Southerly winds (up to 25 m/s), called Ghiblis, blow from the desert,
filling the air with sand and dust (severely reducing visibility) and raising the temperature to about
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50°C. These strong winds are a major erosion factor in the desert, transporting sand from one
place to another.
Tides are minimal, the largest observed in recent years being approximately 45 cm, but the
average is closer to 25 cm.
Currents are not predictable, but appear to be greatly influenced by wind direction. They vary in
strength from 0.5 m/s to 1.5 m/s and tend to persist for 12 – 24 hours after the wind ceases.
The specific gravity of the sea water is approximately 1.027, as in the open Atlantic.

Atmospheric emissions from fuel usage at the Ras Lanuf Terminal are minimal compared to
those at the other sites with emissions to air arising mainly from venting and fugitive emissions.
6.2.1 Flaring
There is no flaring.
6.2.2 Power Generation

The power is supplied to the Terminal from two sources:
• 1.5 MW supplied from RASCo
• Two D-399 Caterpillar, 500 KV on stand by (Rated at 900 KV but operated at a maximum
of 600 KV)
Diesel is used to power the fire water pumps both at the tank farm and the seawater lift pumps.
Estimated diesel usage is an average of 6350 litres per day for the standby generators and 3000
litres per day for the various firewater pumps and the WWT plant. Emissions from diesel
combustion are summarised in Table 6.1
Table 6.1 Emissions from Diesel Usage

Total Diesel
Consumption CO2 CO NOx SO2 CH4 NMVOC
2667 9,173 2.64 38.70 5.73 0.09 0.86

The major venting and fugitive emissions at Ras Lanuf are from the main tank farm and from
tanker loading operations.
All the tanks have floating roofs, with tanks 11, 12 and 13 having a pantagraph seal system with
scrapers for the wax; tanks 5, 6, 7 and 8 have kerosene filled tube seals with foam seals on the
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remaining tanks. Of these, the foam seals provide the least barrier to fugitive emissions
particularly when the tanks is full as it does not seal to the walls at the top of the tank.
Table 6.2 summarises annual emissions of fugitives.
Table 6.2 Annual Fugitive Emissions from Main Oil Storage Tanks and Tanker Loading
Emission Source Emission Emissions per
factors (t/t) annum
CH4 0.0000000675 1.4
Tank farm
VOC 0.000000607 12.5
CH4 0.000017 350
Tanker Loading
VOC 0.001 20,557
Notes: Daily export of 450,000 bbls assumed. Emission factors taken from UKOOA EEMS

R-1. Emissions to air from combustion processes at the Ras Lanuf terminal are relatively small
and any improvements would lead to a small reduction in atmospheric emissions.
Emissions from tanker loading form the main source of emissions to air and we would
recommend that Ras Lanuf consider the introduction of a vapour recovery system.

The main liquid discharges at Ras Lanuf are those of oily water from the storage tanks, water
from the waste water treatment system plant and oil from leaks.
6.3.1 Oil
Oily liquid waste produced on the site comes from a number of different sources:
• Water drained from storage tanks;
• Sludge from the bottom of storage tanks;
The majority of oily waste from all these sources is disposed of directly to the desert. Either to
one of two historic seep pits at the Tank Farm (See Figure 6.3), holes in the sand or directly onto
the desert surface. Periodically these sites of discharge are altered, and old holes are covered,
seep pits left, forming historical indicators of oil and gas activity in the area.
Figure 6.3 One of the Seep Pits at Ras Lanuf Tank Farm.
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Figure 6.4 Oily Waste Pits Beside the Scraper Catcher
Some of the oil contaminated sand is used for the creation of bund walls, or road surfacing, but
most is left in place. Around the Tank Farm there were observable signs of oily waste.

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During the site review, we were informed that the practice of discharging oily water to the area
around the tank farm was to cease soon, however we are not aware of alternative plans for
disposal of the water.
6.3.2 Water
The main water discharges at the terminal are oily water, discussed above, seawater from the
firewater system and treated water from the sewage treatment plant.
6.3.3 Sewage
The Ras Lanuf Terminal has a waste water treatment (WWT) plant designed to treat domestic
wastes in hot climates. The WWT plant is designed around a standard aeration type of activated
sludge tank and is designed to meet the 20/30 International standard (BOD5/Suspended
Solids(SS):20/30). The plant was designed around the following criteria:
Input Raw Sewage Treated Sewage
Population equivalent 400 person After Biological Treatment

equivalents (PE)
Average daily flow 120 m3/d BOD5 30 mg/l
Peak flow 15 m3/hour SS 30 mg/l
BOD5 loading .06 kg/cap/d After Sand Filter
Total BOD5 24 kg/d BOD5 10 mg/l
Average BOD5 200 mg/l SS 10 mg/l
At the time of the site visit the WWT plant was found to be locked, and the only key holder was on
their field break, therefore the actual plant could not be viewed except through the fence, from
where it appeared to be well run and in good condition.
The final treated water is used for irrigation around the WWT plant.

R-2. The main waste stream at Ras Lanuf is oily water from the tank farm. Current practice is to
empty water from the tanks into a drainage ditch and from there to one of (currently) two
large offsite seep pits (Figure 6.3). This practice is unacceptable by modern standards and
we strongly recommend that steps are taken to improve upon current arrangements. Any
oily water should be drained via a purpose built drainage system to a separator/skimmer
tank. Water from the skimmer should be treated prior to discharge to the sea with oil being
returned for export.
R-3. Systems to contain oil drained from, for instance slug catchers, should be introduced to
prevent oil contamination of the ground. Ideally, the area around drains should be

VOO
concerted with any hydrocarbon drained to a sump and recovered back to the export
system. .

In general, the Ras Lanuf Terminal was very tidy.
Domestic waste is collected from around the camps and site offices at regular daily intervals by
the camp contractor (Services). Domestic waste is also collected from a designated area to the
rear of the kitchens (putrescibles, paper, plastic, tins, glass and card) and from individual site
offices (paper, plastic and card).
The waste is collected in 45 gallon drums. On an average day, Ras Lanuf generates in the order
of 45 drums from the kitchen, one per accommodation block (15) and an unknown quantity from
the workshops. These are collected each day and taken to the site tip for disposal by combustion
in a waste pit. In all, it was estimated that the Ras Lanuf Terminal consumes 4,500 m3 of waste
per annum.
As in Amal, there is a burn pit with no incinerator (to improve the combustion of the waste), for all
food and general waste. However, Ras Lanuf although lacking a purpose built incinerator,
appeared to be better organised than Amal, and although there was still rubbish surrounding the
area, the actual combustion seemed to be more efficient. The pit was lit using diesel, with a
member of the fire team present.
regular basis by the camp doctor at Ras Lanuf. This includes used sharps and needles (placed in
a sharps box before disposal), and expired medicines. The doctor periodically ensures the
destruction of clinical waste by taking it personally to the burn pit and observing its destruction.
Solid wastes (both hazardous and non hazardous) appear to be dumped in the desert. These
areas seemed to be relatively small compared to those seen at Amal and Ghani, but are not
marked as designated disposal sites. However, with the burying of waste without management it
is not possible to ascertain the full coverage of waste. As with other sites, spent acid batteries
are buried in the desert at random locations and it is likely that asbestos waste and old smoke
detectors are also deposited in the desert and possibly burned with the domestic waste.
refrigerants (containing freons) are emptied to atmosphere before the old AC units are removed
to the desert was not ascertained, however, it is known that this is the practice at one other site.
CFC and HCFCs are discussed in more detail earlier.
Ras Lanuf currently disposes of old crude oil loading hoses in the vicinity of the loading buoys. In
addition, the harbour area was being used for the temporary storage of used loading hoses.
Although these may act as artificial reefs, we believe that no work has been undertaken to
demonstrate that this is the case, or that it is an acceptable practice. VOO may need to find an
alternative final disposal route which may include, for instance, using the hoses as part of
bunding.

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None of the sites operated a formal waste management system and this included Ras Lanuf.
There was no recording of waste arising and little control over the production of waste. As
discussed above domestic, kitchen and medical waste accumulation at the site is controlled
regularly by burning at a specified area. Tyres are sometimes segregated and either used as
markers or burned and the possibility that old smoke detectors are also burned could not be
excluded. This is achieved by dousing the waste with diesel and lighting it. On occasion, the
ashes and other debris are mixed into the ground.
6.4.2 Hazardous Wastes / Liabilities

The methods for identification, storage and disposal of hazardous waste at Ras Lanuf were
similar to those practised at the other sites: waste of all types is mixed and either burned on
dumped in the surrounding area. However, Ras Lanuf, with Ghani, is used to store equipment
and chemicals containing PCBs
PCBs were discussed in more detail in the VOO generic environmental description (Section 3).
However, special attention needs to be given to the storage at the Terminal because the
containers observed were seen to be badly corroded, and leaking.
In Europe, storage of PCBs on site is limited to one year (the PCBs in Ras Lanuf have been there
for a number of years). They also require a waste manifest system to track the movement of
PCB waste from the point of generation to the point of disposal. PCB fluids are disposed by
incineration in specially licensed incinerators, and PCB equipment must be disposed of in
specially licensed landfills. Due to their hazardous nature cleanup of PCB contaminated sites
requires special handling and disposal of contaminated media.
At the Ras Lanuf Main Station the laundry facility also provides a dry cleaning service. For dry
cleaning they use carbon tetrachloride, which, at the time of the review, was stored in two 45
gallon drums lying on their side. Discussions with staff identified that use equates roughly to one
drum per month. At the time of the site survey, one of the drums was slightly damaged. The
liquid recovery from the dry cleaning units forms a sludge which is disposed of along with the
general waste into the empty waste drum outside.
High exposure to carbon tetrachloride can cause liver, kidney, and central nervous system
damage. These effects result from either eating, drinking, or breathing it, and possibly from
exposure to the skin. If exposure is low and then stops, the liver and kidneys can repair the
damaged cells and function normally again.
If exposure is very high, the nervous system, including the brain, is affected. People may feel
intoxicated and experience headaches, dizziness, sleepiness, and nausea and vomiting. These
effects may subside if exposure is stopped, but in severe cases, coma and even death can occur.
It has been determined that carbon tetrachloride may reasonably be anticipated to be a

carcinogen.
Due to its harmful effects, the use of carbon tetrachloride is now banned and it is only used in
some industrial applications.

VOO
Additionally when carbon tetrachloride enters the environment, and it does break down, it forms
chemicals that can destroy ozone in the upper atmosphere. It is responsible for 17 percent of the
ozone-destroying chlorine now in the stratosphere due to human activities.
Carbon tetrachloride contamination of groundwater has also been a major source of litigation in
the US and Europe.
6.4.3 Regulatory Controls

The Fourth meeting of the Montreal Protocol led to further amendments which came into force 14
June 1994. The Copenhagen Amendment advanced the phase out schedule for CFCs, halons,
carbon tetrachloride and methyl chloroform. The timetable set for carbon tetrachloride was for a
complete phase out by 2000 or by 2010 for developing countries.
There is currently little control over the waste produced at the Ras Lanuf Terminal, both in terms
of the quantity produced and how it is ultimately disposed of.

R-4. The majority of solid waste produced at Ras Lanuf falls into three main categories,
domestic (from the camp), medical waste and non-hazardous industrial waste. The
common method of disposal of waste involves combustion for the domestic and medical
waste, including material for which combustion is inappropriate (eg plastics and empty
paint cans) and dumping of non-hazardous industrial waste. In addition, material (for
instance, used hawsers) is deposited on the sea bed within the harbour.
R-5. A single source of information for the disposal of waste be set up within VOO -possibly this
R-6. The potential to produce best in class waste disposal facilities for certain types of

In general storage arrangements for chemicals and other material on the Ras Lanuf Terminal was
good. Although not assessed in depth, the warehouse kept excellent records of goods received
and issued. Currently the warehouse, in common with all the warehouses at the VOO sites
visited, operates two means of tracking stock: the original cardex system and a computer based
system. The computer based system appeared old and we were informed that it was not up to
date.
There was an area for the storage of gas cylinders but many of the cylinders had not been
chained. Flammables, paints etc were stored in secure buildings; however there was no fire
detection system in place although a sprinkler and foam system was on order.

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As with other sites, surplus and out of date chemicals were stored, though in the case of Ras
Lanuf, storage was within the compound area.

R-7. Systems are introduced to control the storage and disposal of surplus and out of date
chemicals.
6.6. SITE NUISANCE POTENTIAL

Of all the sites visited, Ras Lanuf is the one that has the closest large communities and therefore
has the potential to cause nuisance. Particularly since the terminal’s air field is also used by
other company’s and internal civilian flights.
Site nuisance commonly addresses issues such as odour, visual impact, noise and interference
with normal activities (for instance increased traffic movement). Perhaps the most obvious
impact from the terminal is the seep pits close to the tank farm which are clearly visible from the
air. Although we believe that no complaints have been received regarding this, or other potential
site nuisance, industry best practice is for minimal impact and, therefore, cessation of the use of
seep pits at this site.

Ras Lanuf presented a number of areas that could potentially lead to land contamination. These
included the storage of material (surplus and new); the use and disposal of carbon tetrachloride;
and the current method storage of PCB contaminated material. This has been discussed above
in Section 3, where recommendations for improvements have been made. In addition, it is likely
that contaminants from the seep pits would be detectable in the surrounding area.

R-8. VOO should undertake sampling and analysis for oil contamination in the land and water
around the tank farms, particularly around the seep pits.

VOO
7. TIBISTI
7.1. SITE HISTORY

The Tibisti field is located in the Western Sirte Basin, covering an area measuring approximately
35 x 80 km and extending between Latitudes N28° 50’ and N29° 27’ and Longitudes E17° 18’ and
E17° 42’ (See Figure 7.1).
Figure 7.1 Location of Tibisti and its pipelines to Ras Lanuf.
The Tibisti station, receives oil from two satellite stations. The accumulated Tibisti crude ties in
with Ghani, Jofra and Zueitina (Zella) crude via a 20” pipeline which travels to the Ras Lanuf
Terminal on the North Coast of Libya.
Oil was first discovered in Tibisti in January 1978. The Tibisti Main Station was initially
commissioned in 1980 and reached a peak production of 44,000 BOPD in April 1981.
At the time of the site visit, Tibisti was producing ~8,000 bbls / day from 23 wells (Tibisti and Dor
Marada fields). However, there is a total of 35 wells available to the fields.
Crude is received from all the two oil gathering stations via transfer lines (vary from 6-12”) into the
Tibisti Station crude tanks. All transfer lines between the satellite stations and are regularly being
VOO
pigged on a monthly basis. The three tanks have a combined storage capability of 120,000 bbls.
This crude is pumped from Tibisti and ties in with Ghani and Jofra then travels to the Ras Lanuf
tank farm.
The Tibisti station and outlying satellites have similar processing facilities with some site specific
differences which will be discussed below.
General Site Description

Crude is flowed via the flowline to the production manifold where demulsifier and corrosion
inhibitor is injected prior to the crude entering the separators. The stream from the separators is
then split into three streams:
• The gas stream from the separators is routed to the fuel gas drying plant / scrubber, with
excess gas flared.
• The water stream from the separator is fed to the station main water drain into the water
pit.
• Crude oil from the separator goes to the heaters and desalters for further gas and water
separation then into the gas boot where more gas can be extracted before entering the
storage tank. Water accumulated at the bottom of the storage tank is recycled back into
the heaters and desalters for further water separation.
Typical Tibisti equipment consists of the following:
1. Production manifold and production & test separators;

2. Heaters and desalters;
3. Fuel gas dryer/scrubber;
4. Gas boots,and storage tanks;
5. Booster pumps, shipping pumps and metering area.
6. Skim tank, transfer pumps, injection pumps, etc….
Airfield
The hangers and workshops at Tibisti airfield provide the facilities within which company aircraft
are housed and maintained, and from which they operate on a daily basis. The Chief Aircraft
Engineer, his support staff and all flying crew are normally accommodated at Tibisti.

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Site Specific Differences:

The HH station was visited and appeared to be well maintained when visited, and all critical
valves were serviced and operable. The station has an additional two settling tanks prior to
export to the Tibisti storage tanks (See Figure 7.2).
Figure 7.2 HH Satellite Station
Power Supply
Tibisti Main Station
A 4.5 Mw Sulzer, crude oil fired turbine driven generator provides the principal source of power at
Tibisti main station. Sub main generation is provided by three diesel engine driven Caterpillar
generators.
The fuel oil system for the main generator consists of a storage tank from which the oil is pumped
to the turbine engine. Two pumps are available, one in service and the other available on ‘Auto
Start’.
Electrical power is supplied to the stations and wells from the main power generation plant by
means of electrical power ‘high line’.

Atmospheric emissions from the Tibisti site are typical of those normally associated with oil and
gas operations. The site is remote and, currently there is no useful route for any gas produced.
At a typical station, high pressure gas is taken from the separator and used fuel gas to the
heaters and compressors. Any excess HP gas is flared. All low pressure gas is flared.

VOO
7.2.1 Flaring
Currently 100 % of the gas is flared at Tibisti, which is approximately 20,000 tonnes of carbon
dioxide per year (Table 7.1).
7.2.2 Power Generation
A 4.5 Mw Sulzer, crude oil fired turbine driven generator provides the principal source of power at
Tibisti main station. Sub main generation is provided by three diesel engine driven Caterpillar
generators. A summary of emissions from power generation is given in Table 7.1, below.
During the inspection of HH Station it was noted that oil was passing through Oil Heater 1 from
which, although not on, offgas was being vented locally.
Note that Tibisti was the only site where a refrigerant recovery system was seen.
T-1. Emissions to air at Tibisti are amongst the lowest at VOO sites with flaring levels
comparable to levels offshore in the UK. Notwithstanding this fact, when replacements are
sought for the current generators consideration should be given to the installation of dual
fuel units. This would reduce the need to import diesel from Ghani.

VOO
Table 7.1. Gas Usage and Resultant Emissions at Tibisti

Annual
Units Quantity Usage CO2 CO NOx SO2 CH4 NMVOC
Gas produced mmscfd 0.904
Gas used Mmscfd 0
Gas flared (controlled) mmscfd 0.408 3,204 8,981 21.47 3.85 3.20 43.26 17.32
Gas flared (uncontrolled) mmscfd 0.496 3,894 10,914 26.09 4.67 3.89 52.57 21.05
Total flaring emissions 19,896 47.6 8.5 7.1 95.8 38.4
Crude Usage bbls 170 8,154 26,093 7.50 110.08 16.31 0.27 2.45
Diesel Usage bbls 3.3 158 505 0.15 2.13 0.32 0.01 0.05
Total fuel emissions 26,598 7.65 112.21 16.62 0.27 2.49
Total emissions 46,494 55 121 24 96 41
Notes: Gas density assumed to be 26 tonnes/mmscf. Sulphur concentration in gas assumed to be 0.1%. Turbine factors used for compressors.
Hydrocarbon content of gas assumed to 67.5% methane, 27% non methane VOC, remainder carbon dioxide.

VOO
7.3.1 Oil
Oily liquid waste produced on the site comes from a number of different sources:
• Water drained from storage tanks and separators;
• Sludge from the bottom of storage tanks and separators;
• Sand contaminated with oil;
The majority of oily waste from all these sources is disposed of directly to the desert. Either to seep
pits (See Figure 7.1), holes in the sand or directly onto the desert surface. Periodically these sites of
discharge are altered, and old holes are covered, seep pits left, forming historical indicators of oil and
gas activity in the area. The seep pits viewed at Tibisti showed levels of oil contamination
comparable to the stations viewed at Ghani and Amal, with only a minimal oily coating / scum on the
waters surface and surrounding sand.
Figure 7.1 Seep pit water at Tibisti (inflow pipe left, close up of oily scum right)
Some of the oil contaminated sand is used for the creation of bund walls, or road surfacing, but most
is left in place. Around the site of Tibisti there were observable signs of oily waste, although
compared with other sites visited they were minimal.
Currently in Amal there are two oil recovery units, one purpose built, and one homemade on site.
These recovery units (especially the homemade one) have allowed Amal to recover the waste oil for
export (even from historic seep pits), and is a good example of best working practice. However, there
seemed to be no such systems at Tibisti.

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7.3.2 Water
Approximately 500bbls/day of water is extracted from Aquifer wells to produce 300bbls/day of potable
water by ion exchange, for the camp with 200bbls/day of saline waste to the desert. Tibisti was
unique among the sites visited in that the saline water was drained to a concreted area with the
overflow discharged to the desert (Table 7.2).
Table 7.2 Water Production and Discharge at the Tibist Site (bbls/day).
Produced Potable Water
Site Sewage
Water Production
Produced - 400 -
Discharged - 140 To Desert 260 Potable
7.3.3 Sewage
Sewage at Tibisti is via septic tank though the condition of this was not discussed during the site visit,
the advice given for Ghani holds in that this needs to be maintained to ensure proper treatment of raw
sewage.
Summary Recommendations
T-2. Tibisti was a small well managed site and the water treatment was amongst the best viewed.
However, there may be room for improvement in the levels of oil recovered before discharge of
the remaining water to the desert. This should be investigated.
7.4. SOLID WASTE

The waste produced at the sites was typical of that expected at an industrial oil and gas operation.
Waste is collected from around the camps and site offices at regular daily intervals by the camp
contractor (Services). Domestic waste is also collected from a designated area to the rear of the
kitchens (putrescibles, paper, plastic, tins, glass and card) and from individual site offices (paper,
plastic and card). The waste is bagged in polythene bin liners.
Although not viewed, it is assumed that the burn pit at Tibisti will be of a similar design to those seen
at the other Veba sites. With the relatively small volumes of waste produced by the station and the
good house keeping standards visible it is expected that combustion would be relatively efficient, and
that the area would be kept tidy.
Swabs, bandages and other (solid) clinical wastes generated at the clinic are disposed on a regular
basis by the camp doctor at Ghani and Staff Nurse at Jofra. This includes used sharps and needles
(placed in a sharps box before disposal), and expired medicines. The doctor ensures the destruction
of clinical waste by taking it personally to the burn pit and supervising its destruction.
Solid wastes (both hazardous and non hazardous) appear to be dumped in the desert. These areas
seemed to be relatively small, but are not marked as designated disposal sites. However, with the
burying of waste without management it is not possible to ascertain the full coverage of waste. For
instance, spent acid batteries and pyrophoric iron scaled pipelines are buried in the desert at random
locations.
Old air conditioner units at Tibisti have the refrigerant gas removed and retained before disposal.

VOO
In keeping with the other sites, Tibisti does not operate a formal waste management system.
T-3. Waste disposal appeared less of a problem at Tibisti than it was at the other sites. However,
this may reflect the fact that it is a relatively small site rather than the existence of a waste
management system. This will become apparent when a waste management system is
introduced.

Apart from oily water discharges, Tibisti appeared a tidy and well organised site and no major
potential liabilities were identified.

VOO

VOO
1 APPENDIX ‘A’ CONSTANTS AND EMISSION FACTORS
Table A-1. Global warming potential of common gases

Global Warming
Emission Gas Potential (tonnes of
CO2 equivalents)
CO2 1
CO 3
NOx 40
SO2
CH4 21
VOC 11
Table A-2 Emission factors used to calculate emissions (tonnes per tonne)1
Source CO2 CO NOx SO2 CH4 NMVOC
Gas
2.86 0.003 0.0061 0.001 0.0006453 0.00025812
Turbines
Gas
2.86 0.0006 0.0024 0.001 0.00006453 0.000025812
Heaters
Diesel
Engines 3.2 0.00092 0.0135 0.002 0.000033 0.0003
Flaring 2.8028 0.0067 0.0012 0.001 0.0135 0.005406
1. Taken from UKOOA 2000
Waste: Volume of one black bag is roughly 0.25 m3


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Veba Oil Libya GmbH - VOO

Genesis Job Number J-04131/B

PROJECT/JOB TITLE: Review of Libyan Sites: Overseas

DOCUMENT TYPE: Report

DOCUMENT TITLE: Generic Site Environmental

GENESIS JOB NUMBER: J-04131/B

R2 12/8/03 Final report IS IS

Genesis Oil and Gas Consultants Ltd Page i Date: Aug 03

Genesis Oil and Gas Consultants Ltd Page ii Date: Aug 03

1. EXECUTIVE SUMMARY ......................................................................................1

4.4.2 Waste Management Practices .........................................................................................................33

Genesis Oil and Gas Consultants Ltd Page iv Date: Aug 03

6.4. WASTE MANAGEMENT ............................................................................................. 60

Genesis Oil and Gas Consultants Ltd Page v Date: Aug 03

[Page Left Intentionally Blank]

Genesis Oil and Gas Consultants Ltd Page vi Date: Aug 03

Genesis Oil and Gas Consultants Ltd Page 1 of 73 Date: Aug 03

2.1. GENERIC REVIEW

Table 2.1 Identified Environmental Issues

Genesis Oil and Gas Consultants Ltd Page 2 of 73 Date: Aug 03

2.2. SITE SPECIFIC REVIEWS

Table 2.2 Summary of VOO Atmospheric Emissions (tonnes per annum)

Site Source CO2 CO NOx SO2 CH4 NMVOCs

Fuel 177,419 180 375 63 38 16

Fuel 156,575 35 243 64 3.1 4.2

Fuel 9,174 2.6 39 6 0.09 0.9

Fuel 26,598 7.7 112 16.6 .03 2.5

Total Emissions 1,304,539 2,459.9 1169.5 482.7 4,894.22 22,395.6

Genesis Oil and Gas Consultants Ltd Page 3 of 73 Date: Aug 03

Table 2.3 Summary of VOO Aqueous Discharge (bbls per day)

Site/Source Oily Water Sewage Saline Water

Amal 50,000 716 4,000

Ghani & 5,0001 1060 5,500

Ras Lanuf n/d 770 n/d

Tibisti 260 140

Site/Source Waste to Desert

Ghani & Jofra 6,400

Ras Lanuf 4,500

Genesis Oil and Gas Consultants Ltd Page 4 of 73 Date: Aug 03

3. GENERIC REVIEW AND DISCUSSION OF KEY ISSUES

3.1. GROUNDWATER/AQUIFER CONTAMINATION

3.1.1 Possible Sources of Groundwater Contamination

• Disposal of radioactive material;

Genesis Oil and Gas Consultants Ltd Page 5 of 73 Date: Aug 03

3.2. DISPOSAL OF RADIOACTIVE MATERIAL

• NORM and LSA Scale;

Genesis Oil and Gas Consultants Ltd Page 6 of 73 Date: Aug 03

3.2.1 VOO Practice

Genesis Oil and Gas Consultants Ltd Page 7 of 73 Date: Aug 03

3.3. LIQUID DISCHARGE TO THE DESERT

3.3.1 Use of Seep/Evaporation Pits & Historic Oil Contamination from

Figure 3.1 A Seep / Evaporation Pit at Amal

Genesis Oil and Gas Consultants Ltd Page 8 of 73 Date: Aug 03

3.3.2 Discharge of Aquifer Water

3.3.2.1. Ion Exchange

3.3.2.2. Reverse Osmosis

3.3.2.3. Saline Water Disposal

Genesis Oil and Gas Consultants Ltd Page 9 of 73 Date: Aug 03

Figure 3.2 Cross Section of a typical septic tank set up.

Genesis Oil and Gas Consultants Ltd Page 10 of 73 Date: Aug 03

3.3.4 VOO Practice

7. The dissemination of information on good practice, for instance, information on the

9. Investigation of produced water re-injection as a means of water disposal.