LRQA Audit Report

APPENDIX TOL-20 ISO 14001 Focus Visit Report, 5-8 January 2015

Focus Visit Report for:

Tullow Ghana Ltd

LRQA reference: Assessment dates: Assessment location: Assessment criteria: Assessment team:

LRQ4007527/0002

LRQA office:

Coventry

5-8 January 2015 Accra, Takoradi & FPSO ISO 14001:2004 Bernard Rigg

Contents 1.

Executive report ........................................................................................................ 3

2.

Assessment summary ............................................................................................... 4

3.

Assessment findings log - ISO 14001:2004 ............................................................ 10

4.

Audit Programme/Plan ............................................................................................ 13

5.

Next visit details ...................................................................................................... 14

6.

Audit Programme/Plan ............................................................................................ 15

7.

Assessment plan ..................................................................................................... 17

Attachments

This report was presented to and accepted by: Name:

Emmanuel Arthur

Job title:

Environmental Coordinator

Lloyd's Register Quality Assurance Limited, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively, referred to in this clause as "LRQA". LRQA assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant LRQA entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract. Form: MSBSF43000/3.5 - 1113

Report: LRQ4007527/0002 - 19-Mar-15

Page 2 of 19

1. Executive report Assessment outcome: The purpose of this assessment was to assess the ongoing conformance of the management system to ISO14001:2004, to assess progress made in respect of non-conformities outstanding from the previous assessment visit and to plan for the forthcoming certificate renewal assessment. All non-conformities from the previous assessment were closed and only one new minor non-conformity was raised. Based on the evidence sampled, Tullow Ghana Ltd demonstrated that it has maintained an environmental management system in conformance with ISO14001:2004.

Continual improvement: Various examples of continual improvement and good practice were noted including: • High standard of housekeeping in Takoradi shore base and on FPSO. • Improved internal communication of environmental performance information within TGL. • Survey of ozone-depleting/ greenhouse gas refrigerants completed and a phase out plan developed. • Improved tracking of how waste is treated so that recycling/recovery/disposal rates can be measured. • Changes to storage tank pressure and tank filling procedure to reduce vent vapour release. • Installation of self-cleaning oil in water analysers at 3 stages in the produced water treatment process. • Extensive community engagement in relation to oil spill response.

Areas for senior management attention: Ensure that sufficient EHS resources are provided in order so that key activities (e.g. legal compliance checks, internal audits and EMS document reviews) are conducted in accordance with planned timescales. In view of the organisation’s environmental policy commitment to preventing pollution, consider how air emissions from flaring and venting could be further reduced.

Form: MSBSF43000/3.5 - 1113

Report: LRQ4007527/0002 - 19-Mar-15

Page 3 of 19

2. Assessment summary Introduction: This ISO14001 focus visit was conducted at Tullow Ghana Ltd.’s (TGL’s) offices in Accra, port facilities and shore base in Takoradi and the Kwame Nkrumah FPSO. The visit was originally due to be carried out by LRQA Egypt in October 2014 but had to be re-scheduled following the decision to transfer certification assessments back to LRQA UK. The assessment programme was as follows:

Ghana focus visit plan Jan 2015 versio

All elements of the visit programme were completed and there were no adverse findings unless otherwise detailed below. The main purpose of this assessment was to assess the ongoing conformance of the management system to ISO14001:2004, to assess progress made in respect of non-conformities outstanding from the previous assessment visit and to plan for the forthcoming certificate renewal assessment. Opening and closing meetings were held in accordance with LRQA procedures at the Accra office with the following attendees:

Audit opening meeting - Attendanc

Audit closing meeting attendance

Assessor: Bernard Rigg

Form: MSBSF43000/3.5 - 1113

Report: LRQ4007527/0002 - 19-Mar-15

Page 4 of 19

Assessment of:

Environmental Management System elements

Auditee(s): Emmanuel Arthur, Laureen Darku

Audit trails and sources of evidence: • • • • • •

Overview of operations, organisational changes and environmental issues in 2014 Policy: TGL EHS Policy dated October 2013 Management review: 2013 environmental management review actions, presentation and attendance register 31/1/14 Environmental aspects: Environmental aspects & impacts spreadsheet Objectives and targets: environmental objectives Feb 2014, half year environmental performance review 2014, Leadership EMS awareness training Oct 2014, CFC survey Accra and Takoradi, ODS and HFC management plan Monitoring and measurement: environmental monitoring plan rev.3 30/9/13, monthly report to EPA Nov 2014, 2013 annual environmental report, annual marine mammal & turtle observation report 2013, Group environmental reporting workbook Q3 2014

Evaluation and conclusions: There have been significant organisational changes during the last year including a change of EHS leadership. The recent commencement of gas export from the FPSO has significantly reduced the need for flaring but it is too early to see what flaring rate can be achieved in steady state. The current EHS policy was signed by the TGL General Manager and conforms to ISO14001 requirements. The annual management review for 2013 was attended by top management and covered all required elements. The annual review for 2014 will be conducted soon. A new environmental aspects evaluation process and record had been established which rectifies the nonconformance identified during the previous LRQA assessment. SMART environmental objectives had been set for 2014 with clearly defined actions and responsibilities. There was an improved focus improvements relating to significant environmental aspects although some objectives related to compliance and did not therefore contribute to continual improvement. Objectives for 2015 have not yet been established for 2015 but this is reasonable as the new EHS Manager only started work this week. Documents sampled demonstrated that environmental performance continues to be measured and reported in accordance with the environmental monitoring plan. Waste management data for 2014 was more comprehensive than previously as it included a breakdown of how waste streams had been treated.

Areas for attention: Minor NC 1310MA01 (environmental aspects & impacts) – closed Opportunity for improvement: As the current environmental aspects significance evaluation takes into account the effectiveness of existing controls, it would be good practice to separate the absolute risk evaluation from the residual risk evaluation. (Absolute risk would clearly identify all significant environmental aspects which need to be managed whereas residual risk would help to identify significant aspects with operational controls that may need to be improved.)

Form: MSBSF43000/3.5 - 1113

Report: LRQ4007527/0002 - 19-Mar-15

Page 5 of 19

Assessment of:

Identification of legal requirements and compliance evaluation

Auditee(s): Emmanuel Arthur

Audit trails and sources of evidence: 2013 EPA audit corrective action plan, environmental legal register (updated Sept 2013), FPSO EHS compliance audit 30/9/14-2/10/14, operational environmental permits register (Aug 2014), well permitting status report (updated week ending 9/1/14), Jubilee Operations Environmental Certificate), well engineering environmental compliance register

Evaluation and conclusions: National and international environmental legal requirements applicable to TGL had been identified in an environmental legal register. Permit trackers had also been established for operational permits and drilling permits. It was evident that compliance with key legal requirements is being checked periodically (e.g. Jubilee operating permit compliance was checked during a recent EHS audit.) However compliance with other legal requirements identified in the environmental legal register had not been checked recently.

Areas for attention: Minor NC 1501BLR01 (legal compliance evaluation) – new Requires correction: The environmental legal register should be updated to include document control information such as a record of the revision date.

Form: MSBSF43000/3.5 - 1113

Report: LRQ4007527/0002 - 19-Mar-15

Page 6 of 19

Assessment of:

Certificate renewal planning

Auditee(s): Andy Oliver, Emmanuel Arthur

Audit trails and sources of evidence: • •

Review: LRQA assessment reports for SV1 (Oct 2012), SV2 (Oct 2013) and conclusions from current assessment; environmental performance data for 2013 and 2014. Preview & plan: overview of anticipated changes to the organisation, activities, management systems and scope.

Evaluation and conclusions: Review Monitoring data shows that oil in water content of FPSO discharges has improved during the last 2 years but the flaring rate has varied due to various factors including process interruptions and third party delays in installation and commissioning of the gas export pipeline and processing plant. The quality of waste management data has improved as it now includes how each waste stream has been treated. Oil production rates have increased significantly during the last 2 years but there have been no significant changes to activities within the current scope. Three ISO14001 assessments have been conducted in the last 2 years. Only six minor non-conformities were raised during these assessments and there is no evidence that similar findings have recurred. Preview The scope of the EMS is not likely to be expanded to include the TEN field until production operations are well established so the certificate renewal assessment will cover activities relating to the Jubilee field only. Current EMS documentation will be reviewed and simplified during 2015. The current operating permit for the FPSO is due to expire in May 2015 and a renewal application will require several key documents to be reviewed and updated (including the environmental management plan, environmental monitoring plan, waste management plan and oil spill response plan.) Five additional wells are being planned for the Jubilee phase 1A addendum development and the EIA has already been completed. Various changes are being planned regarding the management of production operations including a new OMS, revised MOC process, significant changes to the planned maintenance schedules and maintenance deferral process. Plan A certificate renewal assessment plan has been developed based on the above review and preview. Refer to section 7 of this report for details.

Areas for attention: N/a

Form: MSBSF43000/3.5 - 1113

Report: LRQ4007527/0002 - 19-Mar-15

Page 7 of 19

Assessment of:

FPSO visit

Auditee(s):

Bruce Tait, Dave Gray, Adam Philips, Jerry Narhyumu, Ajanta Awuni, Rao Chenna, Alexander Burgesson, Surendra Manocha, Fausto Tesio

Audit trails and sources of evidence: • • • • •

Tour of FPSO including waste, oil & chemical storage areas, galley, and control room. Discharges to water: Laboratory daily analysis log book and spreadsheet, oil record book Air emissions: inspection of gas turbine sampling ports, daily report including gas production/flaring data, discussion regarding flaring rate and venting, GT emissions monitoring data 2014. Audits and corrective action: EHS compliance audit report on FPSO 30/9-2/10/14 Maintenance: monthly IMR completion performance report Dec 2014, sample of PPM tasks in AMOS including OIW analyser 3M calibration and 2W inspection, sewage treatment unit annual clean and inspection

Evaluation and conclusions: Discharges to water • It was evident that oil in water levels in produced water discharges are now regularly below the average monthly legal limit of 29mg/l and the Tullow target of 20mg/l. Bilge water discharges have now been separated from produced water and pass through the vessel’s oil/water separator which is designed to comply with the 15mg/l MARPOL limit. • Although previous problems with the food waste macerator had been rectified, the existing macerator failed again and a new macerator is currently awaiting installation. Air emissions • It was evident that the GTGs are fitted with sampling ports and that annual air emissions monitoring is being conducted. • Until the gas export pipeline is fully commissioned in the next few weeks, it is not possible to assess what flaring rate will be achieved but it appears that the 2.5% average monthly target will be difficult to meet consistently until a long term solution is found to rectify the bursting disc issue. • Recent changes have been made to reduce VOC venting including changing the way in which oil is discharged into the tanks and increasing the pressure in the tanks. Results of recent analysis of the vent gas are awaited to quantify the effect of these changes. Maintenance There are known issues with the AMOS database and the way in which work is planned and a review is underway to rectify this. The completion rates for planned maintenance tasks in December 2014 was reported as 94.66% for criticality 1, 84.3% for criticality 2 and 60.42% for criticality 3. However the current criticality rating system is based on the safety case and does not take account of environmental criticality (e.g. OIW analyser and sewage treatment unit currently rated as criticality 3.) Waste, oil and chemical storage Waste containers were clearly labelled although there may be scope for further segregation and compaction before shipping to shore. During the tour it was noted that chemical and oil containers were mainly stored in bunded areas.

Areas for attention: Minor NC 1210BLR01 (corrective action) – closed Minor NC 1210BLR02 (monitoring & measurement) – closed Opportunities for improvement: • The current review of the way in which maintenance is scheduled and prioritised would be a good opportunity to identify environmentally critical tasks so that they are prioritised appropriately in the new system. • Although it is too early to assess whether an average 2.5% flaring rate will be achieved consistently now that gas export has commenced, in view of Tullow’s policy commitment to preventing pollution, the outstanding MOC to provide a long-term solution to the bursting disc issue should be progressed. • Although recent changes appear to have reduced the level of VOCs being vented, Tullow should consider conducting a BAT assessment on how venting is controlled in order to demonstrate its commitment to pollution prevention. It may be appropriate to install a vapour recovery system.

Form: MSBSF43000/3.5 - 1113

Report: LRQ4007527/0002 - 19-Mar-15

Page 8 of 19

Assessment of:

Takoradi facilities visit

Auditee(s): Joseph Klemesu, Ronnie Clughen, Jonathan Field, Emmanuel Arthur

Audit trails and sources of evidence: • • •

Takoradi EHS induction Tour of pipe yard & warehouse, overview of Sekondi port facility and fabrication yard, Baycourt offices and warehouse Waste contractor management: Zeal and Zoil gap analysis reports 29/9/14, Zeal EHS audit report 2223/4/14 and associated corrective action register

Evaluation and conclusions: During the tour of the pipe yard a high standard of housekeeping was evident. Waste containers were clearly labelled and NORM waste was being securely stored. Chemicals and oils were stored in bunded areas. Drains from the pipe storage apron pass through an oil water separator which is maintained and sampled regularly. A comprehensive range of oil spill response equipment was available. The contract with the existing waste contractor (Zeal) has been extended until end of this year and a specialist provider had conducted a gap analysis on this contractor and a new contractor (Zoil) in order to assist both contractors to improve. It was evident that the last annual audit of Zeal had been thorough and Zeal had provided honest feedback and progress with corrective actions. These annual audits are supplemented by frequent inspections of Zeal facilities by the Tullow EHS team in Takoradi.

Areas for attention: Minor NC 1310MMA02 (contractor monitoring) - closed

Assessment of:

Internal audits, incident investigation and corrective action

Auditee(s): Emmanuel Arthur, Stephen Sesi

Audit trails and sources of evidence: •

•

Internal audits: Internal audit schedule 2014, Zeal EHS audit report 22-23/4/14 and associated corrective action register, environmental management system status review report by Cares (26/11/14), Cirrus EHS audit report 7/5/14, FPSO EHS compliance audit 30/9-2/10/14, Accra office EHS audit 27-28/10/14, Takoradi action tracker, EHS inspection report Takoradi port chemical storage facility 17/10/14 Incidents: environmental incident initial notification and incident investigation report for incident 3026 (West Leo loss of containment 8/8/14)

Evaluation and conclusions: EHS audit records sampled showed that the audits had been thorough and had identified some significant non-conformities relating to environmental management of operational activities by contractors. It was evident that corrective actions identified had been tracked using a combination of action trackers (e.g. Takoradi action tracker) and individual corrective action plans for each audit. Actions from the last LRQA audit had been tracked using ATMS. Records showed that the environmental incident on the West Leo in August 2014 had been notified to the regulator. The investigation had identified root causes and corrective action had been initiated.

Areas for attention: Opportunities for improvement: • Consider using ATMS to record and track corrective actions from internal audits. • It would be good practice if the internal audit programme included periodic (not necessarily annual) audits of key functional teams whose activities can have significant indirect/direct environmental impacts (e.g. contracts and procurement, HR, well engineering.) Form: MSBSF43000/3.5 - 1113

Report: LRQ4007527/0002 - 19-Mar-15

Page 9 of 19

3. Assessment findings log - ISO 14001:2004 Grade 1

Status 2

Finding (including location if applicable) 3

Minor NC

Closed

Requirement TGL has made a policy commitment to comply with applicable legal and other requirements. Once potential non-compliances are identified, effective corrective action should be implemented in a timely manner. Deficiency 1. A recent audit identified that untreated food waste was being discharged from the FPSO as the macerator had not been functioning for some time. Although the macerator has now been repaired, it is still not able to macerate food waste containing bones. The FPSO is therefore currently unable to fully comply with the MARPOL/ environmental permit requirement for all food waste discharges to be no more than 25mm in length. 2. Because bilge water is mixed with process wastewater, the maximum oil in water content of 15ppm for bilge water cannot be achieved. Although this was identified several months ago, it has not yet been rectified. Root cause a. The inadequacy of the original macerator was not identified when the tanker vessel was converted into an FPSO. The difficulty of achieving 15ppm oil in water for bilge water treatment was also not identified at the design stage. b. The environmental significance of these issues was not fully understood by the responsible personnel when they were originally identified.

1. Grading of the finding * 6. Date of the finding * Major NC = Major nonconformity Form: MSBSF43000/3.5 -1113

2. New, Open, Closed 7. YYMMseq.# Minor NC = Minor nonconformity

Correction, root cause & corrective action review 4

Process / aspect 5

Proposed corrective action Corrective and preventive 1. The food waste macerator on the FPSO will action be upgraded or replaced so that it has the capacity to treat all food waste. Target date 31/12/12. 2. Bilge water will be re-directed through the oil separator in the engine room once it has been demonstrated that this separator is effective at achieving a maximum of 15pmm oil in water content. The separator equipment will be added to the AMOS database to ensure that it continues to be maintained regularly. Target date 30/11/12 3. These issues will be communicated to the design team to ensure that the new FPSO incorporates a suitable macerator and bilge water treatment system. Target date 30/11/12.

Date 6

Reference 7

Clause 8

24 Oct 12

1210BLR01

4.5.3

22.10.2013 MMA: Some records exist for the completion of the corrective actions .The actions could not be verified physically during this visit since offshore FPSO was not included in visit scope. To be verified next visit Corrective action review Jan 2015 1. The food waste macerator was initially repaired but following further failures, a new macerator has now been purchased. 2. Bilge water has been separated from produced water and both are now being discharged within applicable limits. 3. Lessons learned have been communicated with the TEN project team.

3. Description of the LRQA finding 8. Clause of the applicable standard

Report: LRQ4007527/0002 - 19-Mar-15

4. Review by LRQA

5. Process, aspect, department or theme

Page 10 of 19

Grade 1

Status 2

Minor NC

Closed



Proposed corrective action Requirement ISO14001 requires an organisation to monitor and measure 1. The environmental team will provide a the key characteristics of its operations that can have a specification to Modec and will communicate significant environmental impact. the need for sampling points to the FPSO design team. Target date 30/11/12 Deficiency 2. Sampling points will be installed during the There are currently no proper sampling points for analysing next shut-down. Target date 31/1/13 the GT and boiler exhaust gases so TGL is currently unable to carry out effective monitoring of air emissions from the FPSO. 22.10.2013 MMA: Root cause The need for air emission sampling points was not identified 1. Closed on the 30 10 12 when the FPSO was designed. 2. The actions could not be verified during this visit since offshore FPSO was not included in visit scope. To be verified next visit

Process / aspect 5 Monitoring & measurement

Date 6

Reference 7

Clause 8

25 Oct 12

1210BLR02

4.5.1

22 Oct 13

1310MMA0 1

4.3.1

Corrective action review Jan 2015 There are sampling ports fitted and records showed that annual monitoring is now being conducted. Minor NC

Closed

Aspect/impact analysis suffers from some findings e.g.; 1. There is some confusion/mix up in defining the aspects and impacts e.g. in SOP TGL.EHS.PRC.04.0049 Rev 1, land and groundwater contamination was identified as aspect and not impact. Also this appears in the environmental aspects register. Air pollution was identified as an aspect while air emission was identified as an Impact in page 21 of 94 2. In the above mentioned SOP the methodology of determining the significant impacts is not illustrated 3. Some terminologies of HIRA are used e.g. 'risk ' although the terminology of ISO 14001 should be used instead i.e. 'significance'. Reference is made to environmental aspects register



Corrective action review Jan 2015 Aspect/Impact Analysis A new environmental aspects identification and evaluation process has been established. Aspects and impacts have been appropriately identified and the methodology has been clearly defined.


Report: LRQ4007527/0002 - 19-Mar-15

4. Review by LRQA


Page 11 of 19

Grade 1

Status 2



Minor NC

Closed

Monitoring and measurements activities at Zeal Waste treatment facility at Takoradi suffer from some findings e.g.: 1. No documented evidence that some parameters in the Annex 4 of sector specific effluent quality guidelines for discharges, Ghana EPA and in environmental quality guidelines for the lubricants& waste oil recycling industry are measured and monitored e.g. heavy metals, cadmium, iron, zinc, lead ….etc. (in all checked daily reports)and oil& grease(in some reports) 2. In the daily effluent quality data form dated 7/10/2013 the oil in water was measured with a value of 29 mg/L while the reference value was 10 mg/L. No evidence of corrective action taken.

Minor NC

New

Process / aspect 5

Corrective action review January 2014 Monitoring and Measurements Zeal activities and facilities are not directly / Compliance with Legal & controlled by Tullow. However it was evident that Other Requirements Tullow EHS conduct regular audits and inspections on Zeal and the results communicated to them.

Statement of Non Conformity: TGL has not periodically evaluated compliance with all applicable environmental legal & other requirements.

Periodic evaluation of legal compliance

Date 6

Reference 7

Clause 8

23 Oct 13

1310MMA0 2

4.5.1& 4.5.2

08 Jan 15

1501BLR01

4.5.2

Requirement: The standard requires that the “organisation shall establish, implement and maintain a procedure(s) for periodically evaluating compliance with applicable legal requirements. The organisation shall keep records of the results of the periodic evaluations.” Evidence of Non Conformity: Compliance with key legal requirements is being checked (e.g. Jubilee operating permit compliance was checked during a recent EHS audit.) However compliance with other legal requirements identified in the environmental legal register had not been checked recently. Root cause(s): It appears that EHS resource constraints have contributed to this finding.




Report: LRQ4007527/0002 - 19-Mar-15

4. Review by LRQA


Page 12 of 19

4. Audit Programme/Plan Visit Type Due Date Start Date End Date Audit Days Any change in workforce numbers That may impact visit duration (if yes add new number) Process / aspect / location

Stage 1

Stage 2

Y/N

Y/N

Certificate Renewal

Y/N

Y/N

Y/N

Y/N

Y/N

Y/N

Final selection will be determined after review of management elements and actual performance

THIS FORM IS NO LONGER USED: REFER TO SECTION 6 BELOW

Scope Exclusion

Form: MSBSF43000/3.5 - 1113

Report: LRQ4007527/0002 - 19-Mar-15

Page 13 of 19

5. Next visit details Visit type

Certificate Renewal

Theme(s) for Next Visit

N/a

Audit days

5 (+ 2 travel)

Locations

Accra, Takoradi & FPSO

Activity codes

111103, 0003

Team

Bernard Rigg

Standard(s) / Scheme(s)

ISO 14001:2004

Due date

Oct 2015

Visit start / end dates

28/9/15-2/10/15

Remarks and instructions

Form: MSBSF43000/3.5 - 1113

Report: LRQ4007527/0002 - 19-Mar-15

Page 14 of 19

6. Audit Programme/Plan Visit Type Due Date Start Date End Date Audit Days Any change in workforce numbers That may impact visit duration (if yes add new number) Process / aspect / location

Oct 13 22/10/13 24/10/13 3

Focus visit Oct 14 05/01/15 08/01/15 4

Oct 15 28/09/14 02/10/14 5

N

N

Y/N

CTA

SV1

Oct 12 22/10/12 25/10/12 4 N

Cert Renewal

Final selection will be determined after review of management elements and actual performance

Accra office: • Management system elements • Office environmental aspects • Supply chain management • Training & competence • Emergency preparedness and response • Well engineering • Production operations FPSO • Air emissions • Waste management • Waste water discharges • Maintenance • Training & competence Takoradi Shore Base Takoradi Port Facilities: • Chemical storage • Bunkering and waste handling Sekondi Port & fabrication yard (mainly TEN project) Visit start time (approximate)

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09.00

Visit end time (approximate)

17.00

N/A

The exact start and finish times for the visit will be agreed at the pre-visit contact with the assessor and recorded in the report introduction.

Objective of the next visit ( including where applicable the theme selected) Re-assess whether all elements of the organisation’s management system continue to conform to all requirements of the standard. Scope

Activities including and associated with the production of oil and gas from the Jubilee field

Exclusion

MSBSF43015

N/a

Page 15 of 19

Revision 0, 17 January 2014

Note: if the visit involves more than one team member and/or is more than one day duration, an additional plan detailing the activities of each member of the team on each day will be required.

Date am/pm

Assessor 1

Assessor 2

Standard covered

REFER TO ASSESSMENT PLAN BELOW

MSBSF43015

Page 16 of 19

Revision 0, 17 January 2014

7. Assessment plan Assessment type Re-certification

Assessment criteria ISO 14001:2004

Assessment team Bernard Rigg

Assessment dates 28/9/15 – 2/10/15

Issue date 8 January 2015

Sunday 27/9/15 TRAVEL 13.20

Depart LHR (BA0081)

18.50

Arrive ACC

Monday 28/9/15 ACCRA (Day 1) 09.00

Opening Meeting

09.30

Meeting with top management to discuss environmental policy & objectives

10.00

Overview of changes since last visit •

Operations

•

Organisation

•

Incidents

10.30

Management system update – review of significant changes

11.00

Management review

11:30

EMS objectives, targets and KPIs

12.30

Lunch

13:15

Environmental aspects identification

13.45

Legal & other requirements and compliance evaluation

14.45

Environmental monitoring data & analysis

15.30

Report writing

17:30

Close

Tuesday 29/9/15 ACCRA OFFICE (Day 2) 09:00

Production operations (including MOC and maintenance planning/completion)

10:00

Well engineering

11:00

Drilling EHS monitoring and reporting

12.00

Lunch.

13.00

Supply chain management

14.00

Emergency preparedness & response (including oil spill response plan, exercises and corrective action)

15.00

Training & competence

16.00

Report writing

Form: MSBSF43011/0.4 – 1113Report: 4007527/0002 - 19 March 2015Page 17 of 19

Wednesday 30/9/15 FPSO (Day 3) 07:30 09:00

Flight to Takoradi Helicopter transfer to FPSO

10:00

Induction briefing

10.30

Overview of current activities and any significant environmental issues

11:30

Lunch

12.30

Facility tour

13:30

Environmental monitoring, reporting & permit compliance •

Air emissions

•

Water discharges

•

Waste management

14.15

Maintenance: planning, completion and records

15.00

Emergency preparedness: plans, exercises, corrective actions

15.30

Incident investigation and corrective action

16.00

EHS inspections: trends and corrective action

16.30

Waste management (including storage arrangements and transfer records)

17.00

Feedback on findings

17.30

Report writing

Thursday 1/10/15 TAKORADI SHORE BASE & PORT (Day 4) TBC

Helicopter transfer to Takoradi

11.00

Site tour including oil and chemical storage, waste segregation & storage, drainage

12:30

Lunch

14:00

Tour of port facilities including bunkering and waste reception facilities

15.00

Community liaison (including response to complaints)

16.00

Environmental records including:

17.00

•

EHS inspection reports

•

Wastewater discharge monitoring

•

Waste transfer records

Report writing


Friday 2/10/15 ACCRA OFFICE (Day 5) TBC

Flight to Accra

10:30

Accra office environmental aspects and controls

11:30

Internal audit, incident investigation, corrective/preventive action

12.30

Lunch.

13.00

Internal and external communication (including complaints, regulators.)

14.00

Report writing & next visit planning

16:00

Closing meeting with management to present a summary of findings and recommendations

Friday 2/10/15 - Saturday 3/10/14 TRAVEL 22.50

Depart ACC (BA0078)

06.15

Arrive LHR

08.00

Arrive home

AM

Finalise report
