Engineering Encyclopedia: Environmental Compliance
Engineering Encyclopedia: Environmental Compliance
Engineering Encyclopedia: Environmental Compliance
Environmental Compliance
Note: The source of the technical material in this volume is the Professional
Engineering Development Program (PEDP) of Engineering Services.
Warning: The material contained in this document was developed for Saudi
Aramco and is intended for the exclusive use of Saudi Aramco’s
employees. Any material contained in this document which is not
already in the public domain may not be copied, reproduced, sold, given,
or disclosed to third parties, or otherwise used in whole, or in part,
without the written permission of the Vice President, Engineering
Services, Saudi Aramco.
CONTENTS PAGES
Terminal Department................................................................................. 20
Oil Spill Operations ....................................................................... 20
Marine Department.................................................................................... 20
Pollution Control Unit.................................................................... 21
GLOSSARY ......................................................................................................... 22
On November 10, 1988, Saudi Aramco and Texaco announced a 50/50 joint venture to create
a new company, Star Enterprise, with headquarters in Houston, Texas. Star Enterprise refines
and markets petroleum products under the Texaco brand name in 26 states of the United
States of America (U.S.). On its first day of operation, Star Enterprise was the sixth largest
gasoline marketer in the U.S.
The assets of Star Enterprise include three major refineries. These refineries are located in the
states of Louisiana, Delaware and Texas. The refineries manufacture unleaded gasoline,
diesel, aviation and marine fuels, home heating oil, lubricants, and petrochemical feed stocks.
The refineries are modern, streamlined, high-technology facilities, that are designed to
produce petroleum products in a safe and environmentally sound manner.
Star Enterprise assets also include 50 bulk distribution terminals and a distribution network of
1,400 Star-owned and 7,500 dealer-owned Texaco branded stations. Located in one of the
largest and fastest growing market areas in the U.S., Star Enterprise is poised for tremendous
growth.
In July, 1991, Saudi Aramco continued its international expansion by purchasing, through
Aramco Overseas Company, which is a wholly owned Saudi Aramco affiliate, a 35 percent
stake in the SsangYong Oil Refining Company of Korea. The purchase made Aramco
Overseas Company one of two principal shareholders in SsangYong Oil, which is Korea's
third largest petroleum refiner and a leading lubricants manufacturer.
SsangYong Oil currently operates a hydroskimming and lube oil refinery at Onsan and an
extensive domestic product distribution system. The product distribution center serves bulk
distribution terminals and more than 500 SsangYong branded service stations throughout
Korea.
Because Korea has no known petroleum resources of its own, the fact that SsangYong Oil has
agreed to purchase a minimum of 70 percent of its crude oil requirements from Saudi Aramco
means that Saudi Aramco will play a key role in Korea's economic growth. Because
SsangYong Oil has become a major product exporter that serves the fast-growing Far Eastern
market, particularly Japan, Saudi Aramco will be effectively linked to major Pacific Rim
outlets.
In March, 1994, Saudi Aramco acquired a 40 percent stake in Petron, the largest refiner and
leading petroleum products marketer in the Philippines. As the refining and marketing
subsidiary of the Philippine National Oil Company (PNOC), Petron operates throughout the
Philippines and commands a full forty percent of the petroleum products market in the
Philippines.
Petron's refinery is located in the town of Limay, about 150 kilometers from the company
headquarters in Manila. The refinery can process 155,000 barrels per day of crude oil, which
is more than the combined capacities of the Country’s other two refineries. The Limay
refinery produces a wide range of products, which include fuel oil, diesel fuel, gasoline, LPG,
jet fuel and kerosene. Industrial expansion in the Philippines, plus high market demand for
low-cost transportation fuel have driven up the refinery's production of middle distillates, such
as fuel oil and diesel. Gasul, Petron's LPG brand, is the brand with the largest sales in the
Philippines.
Petron's distribution system includes 31 product distribution terminals, about 600 delivery
trucks, and 42 marine tankers and barges. Many of the trucks and all of the marine vessels
are leased. Petron's marketing network includes approximately 900 Petron-branded retail
outlets, about half of which are owned by Petron. In addition, there are 85 Petron Gasul
dealers throughout the Philippines.
The joint ventures in the United States, Korea and the Philippines have propelled the
company well along toward becoming an integrated international oil company, as mandated
by the Saudi Arabia Government. The total refining capacity of these ventures is just over
one million barrels per day, with Saudi Aramco supplying the vast majority of this volume.
A new International operations business line has been created to market and sell crude and to
coordinate the downstream investments that the business line makes. The International
operations business line includes sales and marketing, downstream development and
coordination, and the activities of the subsidiary Vela International Marine, Ltd., which (as
mentioned below) operates Saudi Aramco’s tanker fleet.
The International operations business line sales and marketing administrative area includes
the sale of crude oil and provides for business contact through its overseas marketing support
offices, which includes the subsidiaries Saudi Petroleum International, Inc. and Saudi
Petroleum Overseas, Ltd.
In November, 1990, after separating from its New York marketing parent, which was Saudi
Petroleum International, Inc. (SPII), Saudi Petroleum Overseas, Ltd. (SPOL) was formed.
Headquartered in London, the new SPOL marketing services subsidiary established a Tokyo
branch in 1991. When the London and Tokyo branches are combined with its New York
sister subsidiary, SPOL's operations will be well placed to conduct Saudi Aramco's growing
business in international crude oil marketing services.
Like most of the world's integrated oil companies, Saudi Aramco employs a tanker fleet.
Saudi Aramco's fleet is operated through its subsidiary, Vela International Marine, Ltd.
Saudi Aramco requires shipping capacity to transport 1.4 billion barrels per day of crude oil
that is sold on a CIF (cost, insurance, freight) basis to market. To further facilitate deliveries,
Saudi Aramco will increase its fleet of Very Large Crude Carriers (VLCCs) by building 15
ships before the first quarter of 1995. All of the VLCCs will be capable of carrying a
minimum of two million barrels of crude.
The company has also added long-term storage and terminal facilities in the Bahamas (St.
Lucia), Aruba, and Rotterdam to provide further flexibility in meeting the delivery
requirements of the company's customers.
Basel Convention
Over 400 million tons of hazardous waste are generated each year. A large amount of this
hazardous waste crosses national borders. Much of the hazardous waste movement is from
industrialized countries to developing countries. The Basel Convention was adopted in 1989,
under the auspices of the United Nations Environment Programme (UNEP). The Basel
Convention represents the first step to define the means to reduce and strictly control the
movements of hazardous waste. The Basel Convention also attempts to ensure that these
wastes are disposed of in an environmentally sound manner. Along with the Convention,
there are a series of Decisions that expand the original attempt of the Convention to control
hazardous wastes. As of June, 1994, there were 68 contracting parties to the Basel
Convention and the Decisions.
The Secretariat of the Basel Convention was established in January, 1993, to publish the
Convention and the Decisions that were adopted at subsequent meetings of the contracting
parties. The Secretariat also provides technical assistance when a country lacks the resources
necessary to manage hazardous wastes in the country.
The General Obligations under the Convention are covered in Article 4. The primary
obligations of the countries that signed the Basel Convention are as follows:
• To ensure that no hazardous wastes are disposed of within the area south of 60
degrees South latitude.
The Basel Convention calls for the improvement of national capabilities to manage hazardous
waste in an environmentally sound manner. The Convention also calls for the development of
a technical and legal infrastructure, which includes needed legislation and regulations.
Training, education, and public awareness are considered to be important elements in the
development of a country's capability to handle hazardous waste.
Nothing in the Basel Convention in any way affects the sovereignty of Saudi Arabia in
accordance with international law. Current and future Decisions of the contracting parties are
voluntarily accepted by the parties.
Montreal Protocol
The Montreal Protocol is a series of international agreements that regulate the use of
chloroflourocarbons (CFCs). CFCs are a group of chemicals that include Freons, Halons and
Degreasers. CFCs have been commonly used as refrigerants, fire suppressers, and solvents.
CFCs are popular because they are nontoxic, nonflammable, noncorrosive, nonexplosive,
very stable, odor free, inexpensive to make, and have a low thermal conductivity.
Unfortunately, CFCs are believed to be responsible for the depletion of the ozone layer in the
stratosphere. The ozone layer shields the earth from the harmful effects of ultraviolet light,
which has many adverse effects on the flora and fauna that live on the earth. Ultraviolet light
is believed to cause skin cancer, suppress the human immune response system, increase
cataracts, damage crops, and damage aquatic organisms.
The Montreal Protocol bans the manufacture of CFCs after specified dates. Most of the
companies that manufacture CFCs and Halons will cease production by the end of 1994. The
use of CFCs is not regulated, but the use of CFCs will obviously decline rapidly after they are
no longer manufactured.
The Montreal Protocol has been ratified by most of the nations of Europe and North America.
The protocol has been ratified by the United Nations. On March 1, 1993, the Kingdom of
Saudi Arabia signed the Montreal Protocol. As an industrial nation, the Kingdom of Saudi
Arabia will observe the same phase-out dates for CFCs and Halons as other industrialized
nations in Europe and North America.
• Source reduction
• Process substitution
• Process material substitution
• Waste segregation
• Good housekeeping
• Reuse
• Recycling
Generally, Saudi Aramco attempts to identify low-cost options for waste minimization. The
objective of the Waste Minimization Program is to identify options where money can be
saved. The primary areas where money can be saved are the treatment and/or disposal of
waste and the loss of products.
The Waste Stream Prioritization Report is a report that is completed before the assessment
team goes to a facility. The report identifies the wastes that may be the most amenable to
waste minimization. The determination is based on the current waste streams and process
elements of the facility.
The Final Report identifies the areas where waste minimization can be accomplished and
provides a cost analysis of each waste minimization opportunity.
The EPA Program focuses on traditional aspects of air, water, and solid/hazardous waste
impacting agents. The EPA Program may extend beyond this scope, depending on the
facility. The EPA Program Manual used during the survey contains a written description of
the survey's scope. The manual is tailored for the specific facility that is surveyed.
The periodic assessments are conducted by a survey team that consists of two to five
members. The team members are chosen because of their ability to provide broad experience
and expertise. The team members are also selected because of their independence from the
facility being reviewed. The independence of the team members is important to ensure the
credibility and effectiveness of the assessment. The Chief Environmental Engineer develops
and coordinates the compliance review program in conjunction with the Chief Process
Engineer and the Chief, Preventive Medicine Services.
SAEP-13 specifies that the topics that must be included in a project environmental assessment
are as follows:
• Environmental standards
The specific requirements of SAEP-13 are discussed in ENV 101.04. The extent of
documentation of a project environmental assessment depends on the scope of the subject
project. Large-scale projects require more extensive documentation that incorporates formats,
categories, and data required in the formal Environmental Impact Evaluation Reports required
by MEPA (Meteorological Protection Administration Ministry of Defense and Aviation,
Kingdom of Saudi Arabia). MEPA’s requirements are discussed below. It should be noted
that SAEP-13 specifies the procedures for the preparation and submittal of Project
Environmental Assessments within Saudi Aramco; it does not specify how documentation is
to be prepared for submittal to MEPA.
However, PCBs have been found to cause increased eye discharge, systemic gastrointestinal
systems with jaundice, edema, abdominal pain, changes in liver function, and possibly cancer.
In addition, when PCBs are burned, the by-products of the combustion include dioxins and
furans. Dioxins and furans are lethal at low doses to aquatic organisms, birds, and mammals.
Dioxins and furans also can cause many other adverse effects on mammals. The other effects
they can cause include cancer, mutations, and weakening of the immune system. The process
of cleaning a facility that has been exposed to a PCB fire is so costly that it is can be less
expensive to abandon the facility and build a new one.
Because of the environmental impacts associated with PCBs, Saudi Aramco has decided to
phase out the use of all equipment that contains PCBs. To remove equipment that contains
PCBs, the EED has developed the PCB Identification and Disposal Plan (PIDP). This plan
provides for the identification and removal of PCB items in a rational and cost effective
manner. The plan has three phases that are executed sequentially. The phases are as follows:
• PCB Presentation
• PCB Identification
• PCB Equipment Listing
The PCB Presentation was developed by EED to familiarize affected groups with the PIDP.
The presentation includes a video and pieces of equipment that contain PCBs.
The PCB Identification phase involved all responsible groups surveying their areas to
determine the amounts and locations of contaminated items. The plan also presents a range of
replacement priorities for PCB capacitors that is based on the environmental sensitivity of the
affected installations.
The PCB Equipment Listing phase involves listing, in a database, all the equipment that
contains PCBs.
More important than the regulatory phase-out dates are the dates by which the manufacturers
plan to stop making significant quantities of CFCs and Halons. European manufacturers,
from which Saudi Aramco buys most of its supplies, will stop making CFCs as well as Halons
by the end of 1994. HCFCs will be manufactured in limited quantities after the year 2010.
Only very limited supplies of CFCs and Halons will be available in the late 1990s for critical
applications where no substitutes are available.
The use of “closed CFC systems,” which neither consume nor release CFCs to the
atmosphere, are acceptable under the Montreal Agreement. Saudi Aramco, as is the case with
many other companies, is currently dependent on CFCs for many important operations. As an
example, chillers that use R-11 (a CFC) will have to be scrapped when there are no more
CFCs because there is no reasonable replacement for R-11. The retrofit and replacement of
R-11 chillers will cost hundreds of millions of dollars. The Tower Building (Dhahran) is an
example of a chiller that uses R-11.
With replacements for CFCs and Halons still under development, it is important to recycle,
recover, and conserve Saudi Aramco’s supplies of current CFCs and Halons.
To assist in the CFC phaseout program, Saudi Aramco has created a CFC replacement team.
The replacement team is as follows:
The Equipment Retrofit/ Replacement Subcommittee will retire and replace all 21 R-11
chillers. Plans will be made to retrofit 128 R-12 chillers.
The CFC Solvents Subcommittee will monitor existing supplies, identify replacement
compounds, and work with the Saudi Aramco Laboratory Department to qualify replacement
compounds.
A major turning point in the environmental activities of the Kingdom of Saudi Arabia came
with the development of MEPA, the Meteorological and Environmental Protection
Administration, and the issuance of the Ambient Air Quality Standards and the Receiving
Water Guidelines in August, 1982. These standards require that industries monitor and report
on air and water impacting agents; that limits for air and water impacting agents be attained;
that Best Available Control Technology be utilized; and that the marine environment and
ground water resources be protected.
In June, 1991, the President and Chief Executive Officer of Saudi Aramco, Mr. Ali I. Naimi,
signed a company-wide environmental awareness policy (INT-5), which was re-issued in
August, 1993. INT-5 defines the Company's present mandate for environmental protection.
"The Company will assure that its operations do not create undue risks to the health of
employees or the general public or to the environment and will conduct its operations with
full concern for the protection of public health and property from harmful pollution of land,
air and water.
In all its activities, the Company will meet the standards specified by the Kingdom's
environmental regulations. Where there are no established standards, guidelines will be
developed which are compatible with the Kingdom's objective of environmental conservation.
The Company will cooperate and participate with government and industry, as appropriate, in
the development of effective environmental control programs and regulations.
It is the responsibility of each organization to assure that its facilities are designed and
operated in compliance with established policy and that they don't present unnecessary risks
to employees, the general public or the environment."
• To set up the proper criteria and procedures for the evaluation and regulation of
developmental activities in the Kingdom.
• To assist in the plan, design, execution and operation of facilities, projects and
programs.
• To ensure that projects are be constructed in a manner that will prevent harm
to the health, safety and well-being of man, that will promote economic and
social life, and that will protect the Kingdom's environment in general to secure
continuous development.
General development activities that may require the preparation and presentation of an
Environmental Impact Evaluation Report include the following:
• Projects that may impact areas of high environmental value from the
environmental protection perspective. These areas include the following:
– Mountainous areas
– Wet areas
– Valleys
– Coastal areas
– Islands
– Coral reefs
– Shallow bays
– Valley mouths
– Areas of unique flora and fauna groups
• Facilities with enough capacity to cause tangible effect on the ambient air
quality. Examples of such facilities include oil refineries and facilities in which
petroleum products are stored in tanks with a capacity of 2000 cubic meters or
facilities in which used oil is purified or in which lubricants are made.
It should be noted that the Environmental Impact Evaluation Reports required by MEPA are
not the same as the Project Environmental Assessments specified by SAEP-13, discussed
earlier.
Three types of hazardous materials not covered by GI 355.001 are covered by other
regulations. These hazardous materials and the applicable regulations are as follows:
GI 150.001 Asbestos Regulation assigns responsibilities and establishes measures for the
regulation, identification and usage of asbestos and asbestos-containing materials. This
regulation includes general policy that governs asbestos materials, regulation and
identification of the materials, employee training, work practices, housekeeping, disposal,
personal protective equipment and clothing, caution signs and labels, and medical
examinations.
GI 355.001-3 and GI 2.717 outline additional precautions that are required when PCBs are
handled and stored for disposal. These two sets of instructions specify the procedures that
regulate the management of PCBs for all electrical equipment that contains PCB contaminated
fluids. Guidelines for the response to PCB-related incidents and the responsibilities of units
that respond to such incidents are also discussed in these instructions.
The CFC Phaseout Program, which was discussed previously, seeks to control the release of
CFCs into the atmosphere by the use of "closed CFC systems" that neither consume nor
release CFCs. CFC conservation and the minimization of operational loss will spread out
supplies that exist in order to defer capital expenditures for retrofit and replacement
equipment while new replacement compounds are developed and field tested.
The Preventive Medicine Services Division has three organizations that are concerned with
environmental issues. These three organizations are: Occupational Medicine, Environmental
Health, and Industrial Hygiene. The functions of these divisions are discussed below.
Occupational Medicine
Occupational Medicine monitors employee exposure to toxic and hazardous chemicals.
Occupational Medicine operates the following programs:
• Physical examination
• Hazardous materials protection
• Oil byproducts protection
• Occupation pulmonary protection
• Hearing conservation
• Vision conservation
• Ionizing radiation protection
• Diving decompression accident
Environmental Health
Environmental Health monitors the impact of food facilities, drinking water, and waste water
disposal on public health. The Saudi Aramco Sanitary Code contains the requirements for
Environmental Health. Four of the more important Environmental Health programs cover
the following:
Industrial Hygiene
Industrial Hygiene is responsible for the operation of the asbestos program. In this capacity,
Industrial Hygiene performs the following activities:
Government Affairs
The two Government Affairs Departments that address environmental issues are the
Environmental Affairs Division (EAD) of the Industrial and Environmental Affairs
Department (I&EAD) and the Loss Prevention Department. These two departments are
discussed in this section.
Exploration
The Exploration Department includes the Hydrology Division, which is concerned with
hydrological regimes in areas where exploration is to be conducted. This section discusses
the operations of the Hydrology Division that are relevant to environmental compliance.
Hydrology Division
The Hydrology Division of the Geological Department conducts preliminary hydrogeological
surveys, advises on hydrogeological concerns before drilling, interprets conditions during
drilling, and advises drilling crews. To assist Saudi Aramco in protection of the environment,
the Hydrology Division also performs the following activities:
• Determines ground water conditions and obtains ground water samples for
analysis.
• Advises on the location, design, and operation of solid waste landfill sites for
environmental acceptability.
Terminal Department
The terminal department is concerned with oil spill operations. Oil spill operations are
discussed in this section.
The organizations that are part of the Oil Spill Operations are responsible for the following:
Marine Department
The marine department includes the pollution control unit. The operations of the pollution
control unit are discussed in this section.
• Assists in the organization of oil spill training exercises and participates in their
implementation.
glossary