A New Produced Water Management Policy for the Energy Sector of Trinidad and Tobago

A Produced Water (PW) Management framework is presented, forming part of an Upstream Effluent Management (UEM) Policy. It addresses the minimization and ultimate elimination of treated and untreated PW discharge by utilization of an integrated management approach to ensure Zero Harmful Discharge (ZHD) to the environment. This approach targeted legislative reform, sustainable PW management practices, monitoring and evaluation, research and development and sustainable production patterns. A Cabinet-appointed Upstream Effluent Management Committee was established for evaluating the status of the upstream, oil and gas, effluent management practices including that of PW and providing recommendations on the way forward. This included determining the challenges in meeting relevant environmental standards; evaluating Best Available Technology (BAT) or Best Practicable Environmental Options (BPEO) for local use and benchmarking local standards against international best practices. Ultimately, a UEM Policy, inclusive of a PW Management Policy, and a revised Water Pollution Rules 2019 (WPR) were developed, submitted and approved by the Cabinet of Trinidad and Tobago. Emerging from data evaluation and committee consultations, it was found that parameters from PW streams, such as Chemical Oxygen Demand (COD), Phenols and Ammoniacal Nitrogen were regularly out of compliance with local permissible limits. Additionally, it was noted that PW management was known to be generally costly, in terms of monitoring, treatment and disposal operations. As such the UEM Committee recommended that measures be taken to facilitate better PW management including, amendments to the Water Pollution Rules 2001 (as amended) and the TTS 547:1998, Specification for the Effluent From Industrial Processes Discharged into the Environment; to focus more on toxic components such as BTEX (Benzene, Toluene, Ethylbenzene and Xylene) and PAH (Polycyclic Aromatic Hydrocarbons); improvement of the chemical evaluation and approval process by the Ministry of Energy and Energy Industries (MEEI) to include a pre-screening step; and the establishment of National Ambient Water Quality Standards, which have been included in the revised WPR. The WPR also encourages re-use as a beneficial discount through the revised annual permit calculation. In addition, Environmental Risk Assessments (ERA) are to be utilized to evaluate the physical, biological and socio-economic environmental standing of the marine environment of Trinidad and Tobago, so as to comprehensively deduce the full impacts of effluent discharge. Trinidad and Tobago has been in oil and gas operations for over 100 years and this integrated management approach for PW introduces a set of novel strategies and tools, geared towards moving in a more environmentally sustainable direction. The approach envisages the use of a more industry-specific regulation that focuses on the toxic components. Furthermore, this method acknowledges that "not-one-size-fits-all" and so, based on the ERA results for the specific geographic marine jurisdictions surrounding Trinidad and Tobago; it encourages more environmentally sustainable and cost effective management.