civil society perspectives on biodiversity and waste management in uganda’s oil and gas sector

7/27/2019 Civil Society Perspectives on Biodiversity and Waste Management in Uganda’s Oil and Gas Sector

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Biodiversity & Waste Management

in Uganda’s oil and gas Sector. A

civil society perspective/concerns

Twebaze Paul,

Deputy Executive Director PROBICOU

Chairperson – Environment, Land and other Natural Resourcescluster , CSCO - 0776340666

A Paper presented at the National Conference on oil and Gas – Imperial Golf View Hotel – Entebbe 20 th -22nd Oct 2013



Outline

• Key concepts

• The Challenge

• Aspects and biodiversity Impacts

• Waste management

• Governance concerns and observations

• Summary of Recommendations



Key concepts/Definitions

Impact – deviation from baseline situation

Environment”- broadly interpreted: Physical factors of the surrounding of human beings including land,

water, atmosphere, climate and the biological factors of animals and plants and the social factor of

aesthetics of both the natural and built environment

Biodiversity – has three components – species diversity, genetic diversity and ecosystem diversity. Thus

mitigating the potential impacts of oil and gas on biodiversity basically address environmental concerns.

Waste - Remains of raw materials, substances or articles that are no longer of economic value to the waste

generator and are intended or required to be recycled, reused, treated or disposed of.

"waste" includes any matter prescribed to be waste and any matter, whether liquid, solid, gaseous or radioactive, which is discharged, emitted or deposited in the environment in such volume, composition or manner as to cause an alteration of the environment ;

"hazardous waste" means any waste which has been determined by the authority to be a hazardous wasteor to belong to any other category of waste provided for in section 53 of the National Environment (WasteManagement) Regulations, 1999; Source: National Environment (Waste Management) Regulations, 1999;

For oil and gas, the major potential environmental concerns are: Atmospheric impacts, ecosystem

impacts – aquatic and terrestrial; impacts on species; human, socio-economic impacts



The Challenge

•The O&G deposits and the sensitive ecosystemare in the same place at the same time!

– The Albertain Graben (Arua-Kanungu) is the most

important eco - region in Africa as it hosts the

continent's most endemic vertebrate species: - – 14% of all African reptiles

– 19% of all African amphibians

– 35% of African butterflies

– 52% of all African birds

– 39% of all African mammals

– 70% of all Ugandan Protected areas are in the Graben



Wildlife Protected Areas



Wild life (The Institute of Resource Assessment (IRA) and The Pan-African

START Secretariat (PASS) University of Dar es Salaam, Tanzania (2007)



Wildlife Protected Areas

• 39 wildlife protected areas including National

Parks, wildlife reserves, community wildlife

areas, and sanctuaries in Uganda.

• 22 out of the total of 39 protected areas are

national parks and wildlife reserves.• 10 out of these are found in the Albertine

region.

• N/Parks in the Albertine Rift include Murchison

Falls, Queen Elizabeth, the Rwenzori Mountains,

Kibale, Semliki, Bwindi and Mgahinga.



Wildlife Reserves

• Ajai

• East Madi

• Bugungu

• Karuma

• Tooro-Semliki

• Kabwoya

• Kyambura

• Kigezi



Aquatic Resources

• Water and Fish resources in Lake Albert, Lake

Edward, Lake George and rivers -Albert Nile, Waki,

Wambabya, Semliki and Kazinga Channel.

• Lake Albert is the richest in terms of the fishbiodiversity.

• 53 fish species, about ten of which are endemic,

eg Alestes baremose (angara), Hydrocynus

forsnkkahlii (ngasia).



Further-Reading

The sensitivity of this area and its detailed biodiversity is well

articulated;-

• Plumptre, Behangana et al (2003), The biodiversity of the

Albertine rift. Albertine rift technical reports no. 3 (Wild Life

Conservation Society),

• The Institute of Resource Assessment (IRA) and The Pan-

African START Secretariat (PASS) University of Dar es Salaam,

Tanzania (2007) Building African Capacity for Conserving

Biodiversity in a Changing Climate in the Albertine Region

Baseline Assessment Report.

• NEMA (2009), Sensitivity Atlas etc



Biodiversity - Aspects and impacts from oil and

gas operations

Decommissioning

Refining

License

Acquisition &

divesting

Exploration

Seismic

Drilling

Operations

Production &

Export

Development



Seismic Acquisition - Impact

• Physical Presence

−Impact on local population / Wildlife

−Habitat destruction

−Impact on crops / sacred ground −Opening previously inaccessible areas

−Large workforce – up to 600 on large shoots

−Visual / Noise

−Health

−Damage to buildings



Seismic operations – Impact

• Frightening fauna, particular importance duringbreeding and nesting

• Marshes and coastal areas bird breeding andmigration resting locations

• Crushing of small invertebrates and plants byvehicles

• Vibration (vibrator truck generating vibrations of 8-28 mm/sec at source) Ground shaking causingphysical disruption of small burrows

–waking

hibernating animals

• Explosions frightening animals – nesting birds;indirect impacts greater exposure to predators



Exploration - Drilling

What are the Aspects and Impacts ?



Drilling – Impact

• Penetration of aquifer

• Cuttings and Mud discharges

•

Atmospheric Emissions• Other Wastes & Discharges

• Oil Spills



Drilling – Impact

• Proximity to human habitation and sensitivehabitats/ species

• Visual Impact

• Noise (24 hours) - Drilling ops are very noisy

• Emissions• Transport - Increase in traffic volumes

• Workforce (100+)

−Itinerant workforce

−Local workforce

• Site restoration (Usually a license condition to ‘leaveit as you found it’ )



Drilling – Emissions

Main emissions sources

• Flaring

• Power Generation (Rig

/ vessels)

• Flaring from Well

Testing

•

Vehicles



Mud cuttings



Production - Impact

• Oil well – what do we do with the gas ?

• Flaring / gas gathering Oil/water separation waste water (formation

water)

• spills / leaks Location: Is the site rural or urban?

•Habitat: Where is it (e.g. forest, bush, marsh)?

• Footprint (Landtake): What is the size of site area (including temporary

construction)?

• Noise Issues – especially in rural environment

• Lighting issues – especially in rural environment

• Traffic –

increase in volumes and in size of vehicles (i.e. more trucks)



Production - Impact

With such light pollution what would be the Impact on aquatic life?



Production Export Operations – Pipelines



Export Impact

R fi Wh t th A t d



Refinery What are the Aspects and

Impacts?

• Heating of oil toseparate thehydrocarbon

fractions• Fractional

distillation

gasolinekerosene heavyfuel oil



Decommissioning

What are the aspects and Impacts?

• Must plan ahead

• Plan for life-cycle

• Plan for decommissioning

• Not just engineering



Waste ManagementWaste Classification

• Non-Hazardous Wastes

e.g.,

− food waste,

−plastic,

−wood..

• Hazardous Wastes:

−Used oil,

−medical waste,

−explosives...

• Bio-degradable

• Non-biodegradable



Specific Waste from petroleum refining

• Desalter sludges;

• Tank bottom sludges;

• Acid alkyl sludges;

• Oil spills;

• Oily sludges from maintenance operations of the plant or equipment;

• Acid tars;

• Sludges from on-site effluent treatment containing dangerous substances;

• Sludges from on-site effluent treatment

• Wastes from cleaning of fuels with bases;

• Oil containing acids;

• Boiler feed water sludges;

• Wastes from cooling columns;

• Spent filter clays;

• Sulphur-containing wastes from petroleum desulphurization;

• Bitumen;

• Emissions from oxides of carbon, nitrogen and sulphur, particulates (mainly

• Generated from combustion processes).

• Volatile organic carbons are the main air pollutants generated by both sectors.



Further Breakdown of Waste

• Liquid Waste from

O&G:• Produced water

• Hydrostatic testing water

• Cooling and heating systems

• Sewage

• Drainage and storm water

• Tank bottom water

• Firewater

• Wash water

• General oily water

Solid Waste from O&G• Food

• Plastic

• Paints

• Oils and greases/ oily rags

• Metal scrap

• Batteries

• Tyres

• Wood

• Paper / cardboard

• Light bulbs• Drums and containers

• Drill cuttings

• Produced sand

• Medical waste



International frameworks-Waste

Basel Convention

• Uganda gained accession to the Basel Convention in 1999 and must comply with all the requirements of

the Convention.

• protects human health and the environment against the adverse effects resulting from the generation,

management, movement and disposal of hazardous waste.

• obliges producers of hazardous waste to therefore dispose of their waste in an environmentally

responsible manner close to where it is generated.

• Provides Strong controls on the movement, storage, transport, treatment, reuse, recycling, recovery and

final disposal of hazardous waste are imposed.

• regulates the trans-boundary movement of hazardous waste using the Prior Informed Consent Procedure.

Bamako Convention

• Uganda is party to the 1991 Convention: Ban of the Import into Africa and the Control of Trans-boundary

Movement of Hazardous Wastes within Africa.• Supplementary to the Basel Convention and covers movement of hazardous waste into or between

signatory African countries.

• Analogous function to Basel Convention.



Waste Management – status and updates

Currently, all drilling waste is collected at approved waste holding locations as the

Government develops the necessary standards and policies on drilling waste disposaland treatment.

• Temporary waste storage facilities are located in Exploration Area 1 and Exploration

Area 2:

• Permitted through EIA process and corresponding licenses

• Monitored by NEMA

Planned engineered Land fill in Bulisa

Waraga D appraisal well to be drilled with closed loop system to reduce amount of

waste produced

Tullow currently undertaking Best Practical Environmental Option (BPEO) to

determine most efficient methodology for treatment, transportation and disposal of

waste including production waste and inform a Basin Wide strategy with Partners

and the GoU.



Summary impact of Waste

• Wastage of resources

• Ground contamination

• Groundwater contamination• Visual impact

• Health issues/vermin



Waste Management Hierarchy

• Reduce –Generate less waste (be more

efficient e.g. packaging return policies)

• Reuse – Select materials / products that

are reusable in their original form.

•

Recycling and Recovery –

Convert wastesinto useable materials and/or extract

energy or materials from them.

• Treatment – Destruction, detoxification

and/or neutralisation of residues.

•

Disposal –

Depositing wastes usingmethods appropriate to a given situation.



Waste Management



Further Reading• OGP. Garland, E., Kerr, et al , (2008) Guidelines for waste management - with special focus on

areas with limited infrastructure. The International Association of Oil & Gas Producers.

Report number: 413.

• Valeur, J. R. (2010) Environmental Impacts of Different NORM Disposal Methods. Middle East

Health, Safety, Security, and Environment Conference and Exhibition. 01/01/2010, Manama,

Bahrain, Society of Petroleum Engineers.

• Douglas A, H. (2002) The acute and chronic effects of wastes associated with offshore oil and

gas production on temperate and tropical marine ecological processes. Marine Pollution

Bulletin. 44 (3), 185-203.

• Frost, T. K., Johnsen, S. & Hjelsvold, M. (2002) Environmental Risk Management of Discharges

from E&P Activities in the North Sea. SPE International Conference on Health, Safety and

Environment in Oil and Gas Exploration and Production. 01/01/2002, Kuala Lumpur,

Malaysia.

• Olsgard, F. & Gray, J. S. (1995) A comprehensive analysis of the effects of offshore oil and gas

exploration and production on the benthic communities of the Norwegian continental shelf.Marine Ecology Progress Series, Oldendorf. 122 (1), 277-306.



GOVERNANCE -CAPACITY AND CURRENT

PREPREDNESS

Governance – Tools

• National policies, legislations and their scope andreviews;

• Implementation of international conventions,agreements protocols;

• Technical measures in place involved;• Infrastructure and team work;• Means and measures;•

Enforcement;• Duties, responsibilities and rights (Govt, private sector,

CSO);• Research and data gathering.



Governance -Technical Measures

•

Preventive and protective measures – Hazard analysis (identification and evaluation);

– Risk assessment;

– Identification of Specific categories of operators, handlersetc;

– Setting Standards and exposure limits; – Surveillance and monitoring of the environment;

– Identification and implementation of Best Practices;

– Notification, authorisation, prohibition and control;

–

Classification and labelling; – Personal protective equipment;

– Safe methods for the handling, collection, recycling anddisposal of hazardous substances.



Governance - Infrastructure

Aspects• Competent authority

– Organizational frameworks, mechanisms andmeasures (lead agencies, departments etc);• Mandates, powers, responsibilities, training ;

– Team work• Inter-agency consultation, coordination, cooperation,

collaboration;

– Inspection services• Type of system, functions of inspectors, duty facilitating

resources; – Environmental services

• Presence of – in various sectors.



Governance - Means and

Measures• Surveillance - of public health in relation to

emissions;

• Documentation and Records - establishment andmaintenance of surveillance records, accidents and

diseases arising from emissions;• Emergency Preparedness and response;

• Studies and Research. Scope and frequency;

• Data, information gathering. Dissemination

awareness;• Transfer of information from operators to agencies

and communities.



LEGAL FRAMEWORK

• The National Environment Management Policy,1994;

• The National Water Policy 1999;

• The National Oil and Gas Policy, 2008;

• The Energy Policy, 2001;

• Petroleum (Exploration and Production) Act Cap150;

•Petroleum Exploration and Production (Conductof Exploration Operations) Regulations, 1993;

• The Investment Code Act, Cap 92;



CURRENT LEGAL FRAMEWORK

• The Land Act Cap 227;

• The Local Government Act, Cap 243;

• The National Environment Act Cap 153;

• The National Environment (Noise Standards

and Control) Regulations, 2003;

•

The National Environment (Standards forDischarge of Effluents into Water or Land)

Regulations,1999;



CURRENT LEGAL FRAMEWORK

• The National Environment (Waste Management )Regulations, 1999;

• The National Environment (Wetlands, River Banks, andLake shore Management) Regulations, 2000;

• The Occupational Safety and Health act, 2006;

• The Public Health Act , Cap 281;

• The Traffic and Road Safety Act, Cap 361;

•

The Uganda Wildlife Act, Cap 200;• The Water Act Cap, 152;

• The National Guidelines on EIA;



Current legislative Effort• Review of the existing legislation and development of new

legislation is in progress: - – The review and/or update of the following legislation has been initiated, to

be completed by end of 2013:

– National Environment (EIA) Regulations, Statutory Instrument No. 153-1

– National Environment (Waste Management) Regulations, StatutoryInstrument No. 153-2

– National Environment (Standards for Discharge of Effluent into Water or onLand) Regulations, Statutory Instrument No. 153-3

– National Environment (Audit) Regulations, Statutory Instrument No. 12 of 2006

– National Environment (Noise Standard and Control) Regulations, StatutoryInstrument No. 30 of 2003, to incorporate vibration pollution

– National Air Quality standards (NAQS) being developed

– Draft Oil Spills Regulations and Guidelines

– National Environmental Act Cap. 153.

– The National Biodiversity Strategy and Action Plan (NBSAP) under review toinclude strategies and action plan for oil and gas

– Compliance and enforcement strategy being developed



OTHER EFFORTS

• A draft General Management Plan for Queen ElizabethNational Park has been prepared incorporating oil &gas issues;

• A draft General Management Plan for Murchison Falls

National Park is being prepared;

• A forest Management Plan for Maramagambo CentralForest Reserve has been finalized;

• Fisheries frame surveys on Lake Albert & Albert Nile toestablish fisheries baseline have been carried out

• Physical Planning in areas facing intense pressure fromoil and gas has been initiated



Institutional Framework

• The National Environment Management Authority (NEMA),

Uganda Wildlife Authority (UWA) and the Petroleum

Exploration and Production Department (PEPD) are the core

institutions.

• Others include: -

• •Directorate of Water Resources Management

• •National Forestry Authority

• •Directorate of Environmental Affairs

• •Directorate of Physical Planning and Land use

• •The Department of Fisheries Resources

• •Districts in the Albertine Graben



OBSERVATIONS

• On Legislation: – Significant level of effort;

– When overlaid, there are Gaps and Patches;

–

Lack of the rule of law: Inadequate enforcement; – Inadequate linkages between institutions

established in the laws; and

– Lack of specificity on O&G: subject and substance.

• The legislation should be reviewed in a harmonisedcoordinated way, and strengthened.



OBSERVATIONS

• On Institutional Framework

– Inadequate linkages, consultation, and cooperation – compartmentalised -no team work ;

–

Insufficient staffing; – Inadequate facilitation.

• Additional measures still required to improve

performance, eg capacity and team building.



OBSERVATIONS

• On Data, Information, etc: – There is some data on O&G from different

sources.

• It is not enough, Often unavailable to the public,

inaccurate and not disseminated enough to cause publicchange;

• There is a need for generation of Adequate

information



OBSERVATIONS

• On Technical Infrastructure: – Inadequate;

– Inadequate attention to biological and ecomonitoring; incompetent laboratories

• There is a need to develop: -

– Technical capabilities of existing institutionallaboratories with a view to competently

implement a mitigation programme.



OBSERVATIONS• On Technical Personnel:

– Inadequate number of trained personnel;

– Inadequate training for experts;

– There are gaps in the scope of required disciplines;

– Inadequate team work across sectors.

• There is need to produce more experts in the relevantdisciplines: - – Clinical, Environmental and Industrial toxicology

– Control technology and safety engineering

– Risk assessment

– Technological Disasters

– Waste Disposal

– Ecotoxicology

– Analytical Chemistry (trace analysis).



OBSERVATIONS

•On Research Capability: – Research capability is inadequate and largely

ignored;

– There is no concerted research programme

dedicated to establish the full impact of O&Gindustry;

– Epidemiological research is minimal.

• There is a need to establish ecologicalcharacteristics of the sensitive interaction betweenO&G and the ecosystem that we have.



OBSERVATIONS

•

On Information and Awareness: – Awareness of impacts and this will lead to suprises;

– Responsible institutions are weak, and operationallyurban;

–

The information that is available is in a form that is not consumable by the majority of community members and thewaste operators;

• There is a need for: -

– A massive awareness campaign to be mounted (allstakeholders) through an IEC programme aimed atvulnerable communities.

– Complete information and a user-friendly communicationsystem operational at community level



OBSERVATIONS- ON OIL AND GAS WASTE

MANAGEMENT

Storage – Storage for waste is still inadequate;

– Safety data sheets unavailable down the chain;

– Inadequately supervised;

– Not reasonably covered in law.• There is a need for subject and substance specific legislation

covering among others:-

– Good design, construction and location;

–

Separation of incompatible materials; – Physical conditions of storage (temp, humidity etc);

– Provision of local and general ventilation;

– Safe methods of work.



OBSERVATIONS

•

On Transport: – Concerned about transportation of hazardous materials;

– Carriers inadequately labelled for hazard identification;

– Inadequately supervised - loading, unloading, transit;

– Not reasonably covered in law.

• Need for subject and substance specific legislationcovering: -

– Integrity of packaging especially bulk goods;

– Criteria of classification of wastes and substances; – Training and informing of operators;

– Segregation of dangerous goods and decontamination of carriages.



OBSERVATIONS• On Emergency Response and Preparedness:

– No preparedness on the ground; Limited supervision;

– Major Hazard Installations - not registered/monitored;

– Ill defined, unfunded emergency services other than Fire Brigade;

– No legal provisions managing emergence and operation of Major Hazard Installations.

• There is a need for: - – Explicit, comprehensive and strictly enforced legislation;

– Establishment of efficient Major Accident Preparedness and

response System operational at national, district and plantlevels; and

– Establishment of a registry and inventory of dangerousprocesses, goods, and wastes.



Upcoming Studies related - Operators

Biodiversity Baseline Study (Phase II): To close the gaps identified in Phase I i.e.

confirmation of the presence and extent of critical habitats and determination of the criteria

and level of criticality i.e. tier 1 or tier 2, presence and type of threatened species or habitats.

Ecosystem Services Study : To identify existing ecosystem services in EA 2, those on which

the project will depend and those most likely to be affected by the project.

Ground Water Mapping: To determine presence and extent of both shallow and deep water

aquifers to guide development planning and issues related to water abstraction for use by

the project.

Re-colonisation and Invasive Species Study: To determine level of success of site

restoration for both natural and enhanced methods as well as identification of evasive

species and recommend methodology for control.

Lake ecology and fisheries: in 2014



Summary of Needed Actions

• Improve management systems;

• Review and strengthen legislation,enforcement;

• Carry out research;• Mount information and awareness;

• Develop technical capacity;

• Develop Preparedness and response fortechnological disasters; and

• Establish economic justification for action.



CONCLUSION

• There is recognisable effort towards O&Gimpacts.

• However legislative, technological andadministrative measures in place are still

inadequate for protecting human health and theenvironment

– The risk is high: vulnerability is high; manageability isstill low .

• Main constraint is inadequate funding

W t t f thi !



We want to go away from this!



This is not good, for a country with oil

These people also wanted



These people also wanted

something better



End

Thank you

civil society perspectives on biodiversity and waste management in uganda’s oil and gas sector

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