Environmental Regulatory Requirements in E&P Upstream Sector

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Cairn Oil & Gas

Environmental Regulatory Requirements in E&P Upstream Sector K. K. Nayak, GM-HSE Dilip Bera, Sr. Mgr. – Env.

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E&P Industry Upstream Activities Exploration & Production (E&P) Upstream Business Model Upstream Funnel Stages

Exploration

Appraisal & Development

Production Operations

Field Abandonment

Exploration – Acquire seismic to image the subsurface – Understand the subsurface geology – Predict where oil and gas might be trapped – Drill wells to search for hydrocarbons Appraisal & Development – Define field size – Characterise the reservoir – Understand how to best get oil and gas out of the reservoir – Make a field development plan Operations and gas Cairn is carrying out simultaneously in to all stages of E&P Business Model

Production - Recover the oil - Optimize for

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Regulatory Requirement over Project Lifecycle

New Block

Environmental Sensitivity Analysis

Identifying Regulatory Requirements

Seismic

Forest Clearance

Drilling

Development projects

Producing assets

Environmental Clearance/ CRZ Clearance

Environmental Clearance/ CRZ Clearance

CTO & HWA

Forest & Wildlife Clearance (if required)

Forest & Wildlife Clearance

Water cess

Ministry of Defense Clearance (if applicable)

Environment Design Approvals

Regulatory Disclosures & Reporting

CGWA

CGWA

Regulatory Inspection

CTE, CTO & HWA

CTE, CTO & HWA

Annual Submissions/ Returns

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Environmental issues - Oil & Gas Sector  Major areas of environmental impacts:  Air environment  Aquatic environment  Soil & land use  Ecosystem  Socio-economic  Potential emergencies  Variety of impacts on environment depending upon:  Stage of the process  Scale & complexity  Nature & sensitivity of surrounding environment  Effectiveness of planning  Pollution prevention & control measures

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Environmental Clearance Process Submit application to EAC, MOEF&CC

60 Days Obtain Approved TOR for EIA study Takes about 120 – 150 days Depending on TOR

Commission Baseline studies & draft EIA Preparation Apply to SPCB for Conducting Public Hearing (PH)

45 Days

Obtain PH proceedings

15 Days Submission of Final EIA to EAC, MOEF&CC

15 Days 30 Days

Scrutiny at EAC, MoEF&CC

15 Days 30 Days

EAC meeting / Presentation

45 Days Grant of EC

Total EC process: about 12 - 15 months

Form – I Pre-feasibility Report Terms of Reference Certified Compliance Report to previously issued ECs

EIA report and Executive Summary (ES)

- Final EIA Form – I - Site layout - PH CD, ES

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What is CRZ? 

Coastal Regulation Zone are the coastal stretches where activities are restricted (e.g. either prohibited or permitted after obtaining clearance)

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The coastal regulation zone is defined as: 500 m from High Tide Line (HTL) on the landward side along the sea front  100 m from HTL or width of the creek, whichever is less on the landward side along tidal influenced water bodies connected to sea (bays, estuaries, rivers, creeks, backwaters, lagoons, ponds). The distance till which tidal effects are experienced shall be determined based on salinity concentration of five parts per thousand  Land area falling between ‘Hazard Line’ and 500 m from HTL landward in case of seafront, and between hazard line and 100 m from HTL in case of tidal influenced water bodies  Land area between HTL and LTL (intertidal zone)  Water and sea bed area between LTL and territorial water limit (12 Nm) in case of sea and water and bed between two LTLs of tidal influenced water bodies

12 n miles

Regulated Coastal Zones

Coastal Regulation Zone Area CRZ-IV

LTL Inter tidal zone HTL 500 m

Hazard Line

Regulated Coastal Zone

Coastal Regulation Zone Area

100 m HTL HTL

Inflow from sea 100 m 100 m

Hazard Line

Tidal Influenced Water Body Distance from sea

Salinity 5 ppt

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CRZ Clearance - Procedure

Submission of documents by PP to SCZMA

Appraisal by SCZMA and recommendation to MoEF&CC / SEIAA

Appraisal by EAC and recommendation to MoEF&CC / SEIAA

Decision by MoEF&CC / SEIAA

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Environmental Legislative Frame Work In India 

Environmental Regulations - Notifications framed by regulatory authorities (MoEF&CC, CPCB or SPCBs) under relevant Acts of Parliament  Emission & Discharge Standards  Noise Act  Waste Management Rules  Chemical Management Rules

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National Policy - Directives issued by MoEF&CC from time to time for implementation by industries

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Directions/Guidelines - Directives framed by SPCBs/MoEF&CC from time to time for implementation by industries

 International Agreements – In to force once ratified by the Central Government – Kyoto Protocol, Montreal Protocol, Basel Convention, MARPOL Acts & Rules  Water (Prevention & Control of Pollution) Act & Rules, 1974  Air (Prevention & Control of Pollution) Act & Rules, 1981  Environment Protection Act and Rules, 1986  Batteries (Management & Handling) Rules, 2001  Waste Management Rules, 2016  Hazardous & Other Waste (Management & Transboundary Movement) Rules, 2016  Solid Waste Management Rules, 2016  Plastic Waste Management Rules, 2016  Construction & Demolition Waste Management Rules, 2016  E-Waste Management Rules, 2016  Bio-medical Waste Management & Handling Rules, 2016  Manufacture, Storage and Handling of Hazardous Chemical Rules (MSIHC), 1989

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Key Obligations under the Water (Prevention and Control of Pollution), Act 1974          

Obtain Consent to Establish & Operate; Renewal of Consent before expiry; Apply for fresh consent if change in product/process, quantity of production, location of outfall and means of disposal; Comply with Inventory to Discharge; Specifies Discharge Standards; Section 33 A: SPCB has power to direct for closure, prohibition or Approval of Control System regulation of any establishment, operation or process or; power Monitor and Measure Discharge; supply Exceedence Reporting; Record Keeping; Prevention of Storm water contamination

The Water (Prevention and Control of Pollution), Cess Act, 1977; including Rules 1978 and 1991    

Specified Industries to pay Cess on water consumed (Water Cess abolished post GST) Affixing of meters to record specific category wise consumption.

Reporting (Cess return) Record keeping

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The Air (Prevention and Control of Pollution) Act 1981; Including Rules 1982 and 1983 Requirement under the ACT / RULES 

Obtain Consent to Establish & Operate;

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Renewal of Consent before expiry;

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Apply for fresh consent if change in product/process, quantity of production, new process, new emission source, modification to control systems, etc.;

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Disclose all emission sources (Temporary/Permanent);

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Comply with Emission Standards;

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Specifies Emission Standards

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Approval of Control System;

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Monitor and Measure Stack Emission / Ambient Air Quality

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Exceedence Reporting;

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Record Keeping

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The Environment (Protection) Act; 1986 OBJECTIVE:  EP Act is an umbrella legislation that provides a single focus for the protection of the environment and seeks to plug the lacunas of earlier legislation relating to the environment.  The act assigns function and powers it deems necessary for the purpose of protecting and improving the quality of the environment and preventing, controlling and abating environmental pollution.

KEY Provisions/ Requirements under the ACT / RULES  Powers to Central Government to take measures to protect and improve the environment;  Power to modify Environmental Standards;  Power to order closure - regulate operations;  Power to make Rules;  Handling Hazardous substances;  Accident Reporting;  Right to Enter and Inspect;  Power to take Samples;  Environmental Statement;  Penal Provisions;  Record Keeping

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Environmental Regulations Applicable to Ravva  Environment Protection Act and Rules • Monitoring ambient air to ensure that emissions are within NAAQ • Submission of annual environmental statement • Compliance to various notifications / rules under the Act  Hazardous & Other Waste (Management & Transboundary Movement) Rules, 2016 • Obtain hazardous waste authorization from APPCB • Identify, characterize, segregated storage and disposal to authorized agencies • Maintain manifest and submit copies to APPCB • Submit annual hazardous waste returns to APPCB (June every year) • Waste management (generation, storage, transportation, treatment, disposal) as per authorization • Waste areas to be provided with sheds, secondary containment and spill management equipment.

• Disposal only to authorized waste management facilities and approved recyclers

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Environmental Regulations Applicable to Rvvaa 

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Manufacture, Storage and Handling of Hazardous Chemical Rules (MSIHC) • Identify all hazardous chemicals, label, properly store and MSDS • Onsite and offsite emergency preparedness and response plans • Conducting annual mock drills and safety audit report to appropriate authority once in three years Noise Pollution (Regulation & Control) Rules • Ambient noise to be within specified limits for different areas during daytime and night time Environmental Clearance Conditions – Submission of six monthly compliance reports Consent Conditions – Submission of compliance reports once in year Batteries (Management & Handling) Rules – for lead acid batteries submission of six monthly returns E-Waste Rules – maintaining form 2 and disposal to authorized recyclers with 180 days of generation Diesel generator (DG Set) Rules (Related to noise & emissions) Public Liability Insurance Act & Rules • Insurance cover for damages to life and property in case of a major accident Biomedical Waste (Management & Handling) Rules • Obtain authorization • Segregated storage as per colour codes and appropriate disposal of biomedical waste • Disposal of untreated BMW within 48 hours of its generation • Submission of quarterly and annual returns Chemical accidents (Emergency Planning preparedness & Response Rules) Emission standards for motor vehicles

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Regulatory Returns Submission Requirement

Frequency

Reference

Hazardous Waste Return

Annual

HWM Rules, 2008 amended in 2016

Environmental Statement

Annual

EC Condition & EPA Rules

Bio-medical Waste Return

Annual

Bio-Medical Waste Management Rules

E-Waste Return

Annual

E-Waste Management Rules

CTO Compliance

Six-monthly

Air & Water Acts

Battery Return

Six-monthly

Battery Waste (M&H) Rules

EC Compliance

Six-monthly

EIA Notification, 2006

TSDF Return

Quarterly

HWM Rules, 2008 amended in 2016

Water Cess

Monthly

Water Cess Act

Environmental monitoring Reports

Monthly

Consent conditions

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Monitoring/Data Requirement Document /Records Requirement

Reference

Water abstraction record, Site wise & activity wise water consumption, Waste water reuse or recycling data

Water Cess

HC production, flaring, power generation & consumption, Fuel consumption etc.

Waste types and quantities generation, storage, treatment, coprocessing, recycling & disposal records

EC/Consent requirements

Environmental Monitoring records (ambient environmental conditions, stack emission, effluent quality, soil quality, ground water quality, hazardous waste characterization)

EC/Consent/HWA requirements

Greenbelt development records, Tree cut records, Compensatory plantation records

EC/Consent requirements

HWA and Consent requirement

Cairn India – 2011