ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (dEMP):
Drilling Operations associated with the PSA
Development and LPG Project, Inhambane
Province, Mozambique
Final - English version
Revision 12, August 2014
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
DOCUMENT INFORMATION
Title
ONSHORE DRILLING ENVIRONMENTAL MANAGEMENT PLAN
(d-EMP): Drilling Operations associated with the PSA
Development and LPG Project, the Inhambane Province,
Mozambique.
Based on and adapted
from:
• Mark Wood Consultants and Impacto (2001). Environmental
Impact Study: Temane and Pande Gas Fields, Seismic
Exploration, Exploratory and Development Drilling.
• Metago Environmental Engineers (Pty) Ltd (2002). Environmental
Management Plan: Construction of the Temane Wellheads,
Flowlines, Access Roads and the Central Processing Facility,
Inhambane Province. Renamed “Sasol Petroleum Temane
Limitada
(2006).
CONSTRUCTION
ENVIRONMENTAL
MANAGEMENT PLAN (cEMP) – Construction of the
Infrastructure associated with the Extraction of Natural Gas,
including well sites, flowlines, trunklines and access roads
(excluding well drilling) in the Sasol Exploration Block in
Inhambane and Sofala Provinces, Mozambique” after review
in March 2006
Past reviewers
•
•
•
•
•
•
Present Reviewer
Golder Associates
Comments
None.
Keywords
Environmental, Management, Plan, Drilling, Mozambique, Gas, Oil,
Sasol, Onshore
Status
Final version – English - Revision 12
Issue Date
August 2014
Final - English version Revision 12
Michaela Cosijn, SPI Environmental Co-ordinator
Ian McIlwaine, SPI Drilling Manager
Dallas Bell, Drilling Officer
Hector Magagule, Snr. Petroleum Engineer
Stephen Boyle, SPI S&H Officer
Jeff Wood, SPI Technical Advisor.
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CONTENTS
1. INTRODUCTION ...............................................................................................................................1
1.1.
TIMELINE FOR THE PSA DEVELOPMENT & LPG PROJECT AND OTHER CPF PROJECTS ....................3
1.2.
PURPOSE OF THE ENVIRONMENTAL MANAGEMENT PLAN ................................................................4
1.3.
SCOPE OF THE EMP.....................................................................................................................4
1.4.
REVISIONS TO THE DRILLING EMP (D-EMP) ..................................................................................6
2. ENVIRONMENTAL POLICY ............................................................................................................8
2.1.
COMMUNITY ENGAGEMENT PRINCIPLES .........................................................................................8
3. ENVIRONMENTAL MANAGEMENT STRUCTURE ........................................................................9
3.1.
ORGANISATIONAL STRUCTURE AND RESPONSIBILITIES ...................................................................9
3.2.
LIAISON, CO-ORDINATION AND REPORTING ...................................................................................13
4. ENVIRONMENTAL MANAGEMENT PLAN ...................................................................................15
4.1.
PRE-CONSTRUCTION REQUIREMENTS ..........................................................................................17
4.2.
ADMINISTRATION AND GENERAL ISSUES .......................................................................................17
4.3.
COMMUNITY, STAKEHOLDER AND GOVERNMENT LIAISON ...............................................................24
4.4.
MANAGEMENT OF POPULATION INFLUX ........................................................................................27
4.5.
EMPLOYMENT AND LABOUR MANAGEMENT ...................................................................................29
4.6.
GENERAL ASPECTS RELATING TO CONSTRUCTION .......................................................................33
4.7.
EMERGENCY RESPONSE .............................................................................................................33
4.8.
SITE ESTABLISHMENT AND MANAGEMENT .....................................................................................34
4.9.
SITE WATER MANAGEMENT .........................................................................................................36
4.10.
SOLID WASTE MANAGEMENT: GENERAL ISSUES AND NON-HAZARDOUS WASTE ............................36
4.11.
HAZARDOUS MATERIALS MANAGEMENT AND DISPOSAL ................................................................39
4.12.
VEHICLE AND MACHINERY USE & MAINTENANCE ..........................................................................42
4.13.
DRILLING OPERATION .................................................................................................................43
5. PERFORMANCE ASSESSMENT, REVIEW & CORRECTIVE ACTION .......................................48
5.1.
ENVIRONMENTAL MONITORING STRATEGY ...................................................................................48
5.2.
SITE INSPECTIONS ......................................................................................................................52
5.3.
AUDITS ......................................................................................................................................52
5.4.
CORRECTIVE AND PREVENTIVE ACTION ........................................................................................54
5.5.
REVIEWS ...................................................................................................................................54
6. COMPETENCY, TRAINING AND AWARENESS CREATION ......................................................56
7. EMERGENCY PREPAREDNESS AND RESPONSE ....................................................................57
8. IMPLEMENTATION SCHEDULE AND COST PROVISIONS........................................................60
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LIST OF TABLES
TABLE 4-1.SUMMARY
OF ACTIVITY CATEGORY AND SUB-CATEGORIES INCLUDED IN THE
ENVIRONMENTAL
MANAGEMENT PLAN. ........................................................................................................................ 15
TABLE 5-1.MONITORING REQUIREMENTS................................................................................................... 50
TABLE 5-2. MINIMUM AUDITING REQUIREMENTS FOR DRILLING PROJECT. ................................................... 52
TABLE 7-1: TYPICAL CONTENT OF A WELL CONTROL CONTINGENCY PLAN (WCCP)................................. 58
LIST OF FIGURES
FIGURE 1-1: CONCEPTUAL OVERVIEW OF THE PROJECT IN RELATION TO SASOL'S EXISTING PRODUCING ASSETS
.......................................................................................................................................................... 2
FIGURE 1-2: LOCATION OF PROPOSED INFRASTRUCTURE FOR THE PSA DEVELOPMENT AND LPG PROJECT .. 3
FIGURE 1-3: TIMELINE FOR THE APPROVED AND PROPOSED PROJECTS BETWEEN 2014 AND 2022 ................. 4
FIGURE 1-4: FLOW DIAGRAM INDICATING THE ENVIRONMENTAL IMPACT STUDIES APPROVED BY MICOA FOR THE
SASOL EXPLORATION BLOCK ............................................................................................................... 7
LIST OF APPENDICES
APPENDIX 1: ............................................................................................................................................ 61
APPENDIX 2: ............................................................................................................................................ 63
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DEFINITIONS AND ACRONYMNS
Communication Liaison Team (CLT) – Team employed by Sasol whose main purpose is liaison with
authorities and the local communities regarding the activities and presence of Sasol in the project area.
CLO - Community Liaison Officer
CFP – Chance Find Procedure
CPF – Central Processing Facility
CPF Complex – The integrated Central Processing Facility for gas and oil, consisting of the CPF and
all of the upgrades for gas and condensate production, including the original facility constructed in 2008,
the NATGAS 183 Expansion, the CPF Facilities Upgrades Project and the PSA 5th Gas Train, together
with the PSA Liquids and LPG Plant for oil production.
c-EMP rev 1 (2006) – this refers to the previous revision of the Sasol Petroleum Temane Lda (2006):
“CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN (cEMP) – Construction of the
Infrastructure associated with the Extraction of Natural Gas, including well sites, flowlines, trunklines
and access roads (excluding well drilling) in the Sasol Exploration Block in Inhambane and Sofala
Provinces, Mozambique” as reviewed in March and approved in July by MICOA in 2006.
d-EMP rev 11 (2010) – this refers to the previous revision of the Sasol Petroleum Temane Lda
“DRILLING ENVIRONMENTAL MANAGEMENT PLAN (d-EMP): Drilling Operations in the Sasol
Exploration and Development Blocks, Inhambane and Sofala Provinces, Mozambique” as per this
document.
EIA – Environmental Impact Assessment.
EIS – Environmental Impact Study.
Environmental Co-ordinator (EC) – Any senior Sasol environmental personnel with medium to long
term experience whose role is to co-ordinate environmental aspects of the Project and ensure
compliance with the EMP.
Environmental Site Officer (ESO) – A person with environmental training who is responsible for the
day-to-day environmental management of construction/drilling activities
Environmental Specialists – Either Sasol personnel or external specialists called in for specific
environmental aspects as defined by the environmental co-ordinator
Environmental Management Plan (EMP)
(i)
Defines the measures to be taken during the life of a project, including design, construction,
operation and decommissioning to prevent and/or manage adverse environmental impacts;
(ii)
Defines the actions needed to implement these measures; and
(iii)
Describes how this will be achieved.
Environmental Audit – A systematic, documented and objective evaluation of the environmental
performance of a project by objectively obtaining and analysing evidence to determine whether the
implementation of the EMP conforms to its defined requirements.
Environmental Management System (EMS) – The part of the overall management system that
includes organisational structure, planning activities, responsibilities, procedures, processes and
resources for developing, implementing, achieving, reviewing and maintaining an environmental policy.
SHE Officer – Health and Safety Representative
GOM – Government of Mozambique.
MICOA – Ministry for the Co-ordination of Environmental Affairs.
MSDS - Material Safety Data Sheet
Re-instatement - this entails filling in any pits on the well site and levelling the site for future use.
Regional Environmental and Social Assessment (RESA): This document was prepared by Mark
Wood Consultants (2003) for the World Bank to “look beyond the immediate zone of direct social and
economic impacts of the Project to address induced and cumulative impacts in the geographic areas of
the eight project components”
Sasol – Refers to Sasol (Pty) Ltd and all its affiliate organisations.
SHEQ – Safety, Health, Environment and Quality
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SPI – Refers to Sasol Petroleum International Ltd.
SPM – Refers to Sasol Petroleum Mozambique Lda, which is a subsidiary of Sasol Petroleum
International (Pty) Ltd. The company, is based in Mozambique, having its principle place of business at
Avenida 25 de Setembro, 420, Predio JAT, 2 Andar, Sala L4, Caixa Postal 4356, Maputo, República de
Moçambique.
SPT – Refers to Sasol Petroleum Temane Lda, which is a subsidiary of Sasol Petroleum International
(Pty) Ltd. The company, Sasol Petroleum Temane Lda, is based in Mozambique, having its principle
place of business at Avenida 25 de Setembro, 420, Predio JAT, 2 Andar, Sala L4, Caixa Postal 4356,
Maputo, República de Moçambique.
The Works – All areas within which Sasol’s and the drilling sub-contractors’ activities will take place,
including the construction right of way, access roads, well sites, campsites, borrow pits and the like.
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INTRODUCTION
In October 2000, Sasol Petroleum Temane Limitada (Sasol), Empresa Nacional de Hidrocarbonetos de
Moçambique, E.P. (ENH), Companhia Moçambicana de Hidrocarbonetos S.A.R.L. (CMH) and the
Government of Mozambique signed a Petroleum Production Agreement (PPA) for the production and
processing of the Temane and Pande gas fields in Inhambane Province, Mozambique. The main
outcome of these agreements was the production and processing of natural gas resources and the
export of the processed natural gas to Secunda in South Africa via an underground pipeline. In addition,
a Petroleum Production Tax levied by the Mozambique Government is taken in kind, which has
encouraged the development of gas supply offtakes from the Temane - Secunda pipeline.
The key Operations elements of this first phase of the project were as follows:
1. Exploration activities to determine the extent of the gas reserves and optimal locations for
extraction.
2. Development of a network of production wells and gas flowlines within the Temane and Pande
gas fields and the construction and operation of a Natural Gas Plant (known as the Central
Processing Facility or ‘CPF’) for the cleaning, drying and compression of the gas.
3. Transportation of the gas from Temane to Secunda (South Africa) and Maputo (Mozambique)
via underground transmission pipeline.
4. Upgrading and conversion of Sasol’s plant infrastructure at Secunda and Sasolburg (South
Africa) to accommodate the natural gas as feedstock.
Sasol has since expanded the CPF and has brought further gas wells on stream in the Temane and
Pande gas fields. At present, the CPF consists of four gas processing trains, supplied by twenty four
(24) onshore production wells, twelve (12) of which are in the Temane field and twelve (12) of which are
in the Pande field.
Sasol proposes to further expand the CPF to process additional gas, condensate and oil from the area
defined in the Production Sharing Agreement (PSA) with the Mozambique Government. The PSA
licence covers all other formations in the Temane and Pande geographical areas that are currently being
considered for development, and also includes other fields and prospects where exploration and
appraisal wells have been drilled but have not as yet been declared commercial. The project will
significantly increase Sasol’s capacity to process gas and liquids, and will include the facility to produce
Liquefied Petroleum Gas (LPG), which would provide the local capacity to substitute much of the 15,000
to 20,000 tonnes per annum that are currently imported at significant cost to Mozambique.
The new scope of work (Error! Reference source not found. and 1-2) consists of two main
components, which are referred to as the ‘PSA Development and LPG Project’:
1. PSA Gas Development: involving six production wells in the Temane Field and an additional
5th gas train at the CPF, designed to process the additional gas and condensate from the
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wells and situated within the existing plant boundaries. Production of gas at the CPF is
expected to increase by up to 150 MMscfd (million standard cubic feet per day) to
approximately 600 MMscfd; and
2. PSA Liquids Development, involving twelve oil production wells and one data-gathering well
(not connected to the CPF) in the Inhassoro field, and a new Liquids Processing plant and
Liquefied Petroleum Gas (LPG) plant, situated adjacent to north east side of the CPF. This
project component is referred to as the ‘PSA Liquids and LPG Plant’. The plant is expected
to produce 15,000 stock tank barrels of oil per day (stbopd1) and 20,000 tonnes per annum
of LPG.
All of the gas and oil wells will be connected to the CPF and PSA Liquids and LPG Plant by buried
pipelines known as ‘flowlines’, similar in design to those which currently supply the plant with gas. The
new flowlines are intended to follow existing lines of access as far as possible, and in the section across
the Govuro River, the pipes will be connected to existing pipes laid across the channel during the
construction of the Natural Gas Project, so as to avoid the disturbance caused by further crossings.
Figure 1-1: Conceptual overview of the project in relation to Sasol's existing producing assets
1
A stock tank barrel refers to the volume occupied by sales oil (i.e. after stabilisation to meet sales specification) and measured
in barrels at standard conditions of 1.01325 bara (14.7 psia) and 15.56°C (60°F).
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Figure 1-2: Location of proposed infrastructure for the PSA Development and LPG Project
1.1.
TIMELINE FOR THE PSA DEVELOPMENT & LPG PROJECT AND OTHER CPF PROJECTS
The timeline for the PSA Development and LPG Project is shown in Figure 1-3. The implementation of
the project will be preceded by the 'IOP project', which is the subject of a separate Environmental
Assessment, and which involves the production of oil from two existing wells, I-9z and I-4, both of which
are already connected to the CPF by an existing flowline. The IOP project will run as long as possible
before the wells are shut in and the flowlines are re-configured to connect into the PSA oil project.
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Main construction works for the PSA Development and LPG Project is scheduled to start in early 2016
and be operational by the last quarter of 2018. It is noted that a number of PPA activities take place at
the CPF between and at the same time as the PSA development (Figure 1-3). This work consists of the
installation of four LP compressors at various times between 2014 and 2021 in order to increase the
pressure of incoming fluids into the CPF, as the well pressures begin to reduce, and the installation of
an additional power generator (GTG). These upgrades have already been approved by MICOA
(Environmental License Nr 08/MICOA/GM/189/2014).
Figure 1-3: Timeline for the approved and proposed projects between 2014 and 2022
1.2.
PURPOSE OF THE ENVIRONMENTAL MANAGEMENT PLAN
The d-EMP aims to present management measures that will eliminate, offset or reduce adverse
environmental impacts, as well as to provide a framework for environmental monitoring. The primary
purpose of the d-EMP is to ensure that negative environmental impacts of the project are effectively
managed within acceptable limits and that the positive impacts are enhanced.
1.3.
SCOPE OF THE EMP
The Drilling EMP (this document) contains environmental management specifications for all activities
related to the drilling of10 production wells and 1 development well for the PSA Development and LPG
Project. Activities relating to the construction of the well sites, flowlines and associated access roads
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and infrastructure are covered by the CONSTRUCTION EMP (c-EMP) for project infrastructure. Since
Sasol intends to accommodate all personnel for the PSA Development and LPG Project at the CPF, the
requirements for the management of personnel camps has been removed from this document and now
resides in the c-EMP (CPF), which covers all construction – related activities at the CPF, including the
accommodation of all construction personnel.
Furthermore, the d-EMP has been developed to include:
•
Definitions of the responsibilities of the environmental representatives, communication and
reporting structures;
•
Programming and scheduling requirements;
•
Requirements for performance evaluation (performance indicators are only specified where
there may be additional requirements to the verification that the specification has been met.
Note that number of incidents; audit findings etc. shall also be used as indicators of
performance.); and
•
Training will be specified only where it is not clearly a specified requirement elsewhere in the
EMP, e.g. all drilling sub-contractors will be required to ensure the necessary training of all
employees to avoid environmental impacts and ensure their awareness of the requirements of
the EMP.
In addition the following documents need to be read and taken into account when implementing the
EMP:
1. Sasol Onshore SHE Drilling Manuals and Procedures
2. Sasol Emergency Response Procedures
1.3.1.
LIMITATIONS OF THE D-EMP
1. Issues related to compensation, resettlement and relocation are not addressed in this document. The
reader is referred to the document “Resettlement and Damage Compensation Procedure for Sasol’s
activities in Mozambique (Revision 3, 2014)”
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Any queries should be addressed directly to:
Title
THE PRINCIPAL MINERAL RIGHTS OFFICER
Organisation
Sasol Mining Rights & Properties Department (SMRD)
Postal address
PO Box 699; Trichardt; Mpumalanga, 2300; RSA
Contact Name
Mr Piet-Nel de Vos
Telephone
+27 17 638 8029 (office-hours)
Cellular phone
+27 82 499 4376
Fax
+27 17 614 8050 / +27 11 522 5364
E-mail
[email protected]
2. This EMP does not include specifications regarding occupational health, hygiene or safety
requirements. Sasol and all drilling sub-contractors’ obligations in this regard are governed by
legislation. Sasol’s requirements are specified in the relevant Drilling and Drilling Service Contract
documentation.
1.4.
REVISIONS TO THE DRILLING EMP (D-EMP)
The d-EMP is a dynamic document which has been developed and revised over the years of Sasol’s
operations in Mozambique. The background to the development of the document is indicated in the
organogram in Figure 1-3. The current revision is specifically intended for the PSA Development and
LPG Project although many of the specifications are common to all of the past drilling EMPs.
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Figure 1-4: Flow diagram indicating the environmental impact studies approved by MICOA for the Sasol
exploration block
Note: this flow diagram is only for upstream activities and does not include the EMP for the pipeline from the CPF to South Africa.
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ENVIRONMENTAL POLICY
As the project owner, Sasol has implemented the following environmental policy that shall set the
framework for environmental management for the project. All visitors, Contractors and employees are
required to comply with the requirements of the policy.
We, the people of Sasol, striving for excellence in all we do, recognise the impact that our activities can
have on people and the environment. Safety, health and protection of the environment will form an
integral part of our planning and decision-making. We will manage our company, wherever we do
business, in an ethical way that strikes an appropriate and well-reasoned balance between economic,
social and environmental needs.
We are committed to:
-
Conducting our business with respect and care for people and the environment
-
Responsible utilisation of natural resources
-
Implementing responsible care for all Sasol’s chemical and associated businesses. Non-chemical
businesses will implement appropriate, recognised codes of practice
-
Continually improving our safety, health and environmental performance
-
Complying, as a minimum, with all applicable legal and other agreed requirements
-
Promoting dialogue with stakeholders about safety, health and environmental performance
We will achieve these by:
-
Implementing internationally recognised safety, health, environmental and quality management
systems
-
Developing and implementing inherently safer and cleaner technologies
-
A “cradle and grave” approach to the products we develop, manufacture, use distribute and sell
-
Informing and appropriately training all employees and contractors on safety, health and
environmental matters
-
Responding effectively to safety, health and environmental emergencies involving our operations
and products
-
Engaging with relevant authorities and institutions on the formulation of legislation, standards and
the implementation thereof
-
Benchmarking internationally on best safety, health and environmental practices
-
Sharing safety, health and environmental risk reduction best practices throughout Sasol
-
Providing appropriate resources required to implement the above.
2.1.
COMMUNITY ENGAGEMENT PRINCIPLES
Sasol’s community engagement principles are centred on:
-
Community involvement and ownership
Strengthen community leadership
Targeted impacts-driven interventions
Addressing key community priorities
Strategic research informed interventions
Monitoring and evaluation
Building capacity through partnership
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3.
ENVIRONMENTAL MANAGEMENT STRUCTURE
3.1.
ORGANISATIONAL STRUCTURE AND RESPONSIBILITIES
The overall organisational structure for environmental management on the Project identifies and defines
the responsibilities and authority of the various organisations and individuals involved in the project. The
Project structure and associated personnel shall be sufficient to ensure the required standard of
environmental performance.
SPI is the holding company for SPT and SPM. For the purposes of this document there shall be no
distinction between SPI, SPT or SPM and they shall be referred to collectively as Sasol.
With regard to environmental management during the drilling and completion phase of the project, the
principal responsibilities of each party within this structure will be as follows:
The Sasol Environmental Site Officer (ESO) shall have a good understanding of pollution-related
issues and also:
•
Possess a tertiary qualification in a natural science discipline;
•
Be employed by Sasol on a full time basis for the duration of the contract, based in the field;
•
Report directly to and liaise closely with the Owner’s Representative (Field Superintendent);
•
Liaise regularly with Sasol’s Environmental Co-ordinator on specialist environmental issues (e.g.
rehabilitation, archaeological sites, graves), non-compliance, and in relation to the preparation of
the monthly environmental reports;
•
Liaise, where necessary with specialist consultants;
•
Liaise with the Community Liaison Officer (CLO) about environmental issues affecting surrounding
communities;
•
Be thoroughly familiar with existing information about habitat and social sensitivities as described in
the EIA;
•
Be thoroughly familiar with the specifications in the Drilling EMP with which the Drilling subContractors are obliged to comply;
•
Perform all day-to-day tasks necessary to monitor the performance of the Drilling sub-contractors
with respect to the specifications in the Drilling EMP;
•
Report non-compliance by the Drilling sub-Contractors to the Owner’s Representative (i.e. The
Sasol’s Field Superintendent) and Sasol’s Environmental Co-ordinator and participate in the actions
necessary to ensure that the Drilling Contractor rectifies any non-compliance as rapidly and
effectively as possible; NOTE: Only the Owner’s Representative (i.e. Sasol’s Field Superintendent)
can issue site instructions to rectify non-compliance by the Drilling sub- Contractors.
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Keep accurate records of monitoring for the purposes of audit. These records shall provide a
systematic account of the Drilling Sub-Contractors’ performance with respect to environmental
management of the site. As part of standard reporting procedures, the ESO shall utilise weekly and
monthly checklists to assist in formalising the approach to the monitoring;
•
Assist Sasol’s Environmental Co-ordinator to prepare formal monthly monitoring reports. These
reports shall be presented at the monthly meetings and shall be circulated, together with the agreed
Action List to the following individuals/organisations (amongst others):
•
♦
The Drilling sub-Contractors;
♦
The Owner’s Representative (i.e. The Sasol Field Superintendent);
♦
Sasol’s Environmental Co-ordinator;
♦
Sasol Drilling Manager.
Prepare monthly compliance certificates that shall be discussed with the Owner’s Representative
(i.e. The Sasol Field Superintendent) and signed by the Owner’s Representative and the ESO. The
compliance certificates shall contain a brief description of any areas of non-compliance with the
contract specification, the responsible party, the result/consequence, the corrective action taken and
any necessary follow up required; and
•
Prepare, in association with the Environmental Co-ordinator, a checklist that includes a snag list of
outstanding items that need to be addressed by the Drilling sub-Contractors before all environmental
obligations have been met with respect to the contract at the completion of the contract. The list
shall take into consideration any items that require action to meet the contract specification before
the Drilling Contractor demobilised. Once these items have been rectified to the satisfaction of the
Owner’s Representative, in consultation with the ESO and the Environmental Co-ordinator, sign-off
shall occur.
•
Prepare the Rehabilitation Plan, in conjunction with Sasol Environmental Co-ordinator and specialist
consultants where necessary. The ESO shall be responsible for the implementation of the Plan.
Sasol’s Environmental Co-ordinator (EC) shall:
•
Be a full time appointment for the duration of the drilling contracts, based on site;
•
Have a tertiary education in the natural sciences and a proven track record in environmental contract
management on large projects. He/she may be employed by Sasol or be an independent consultant;
•
Provide support to the ESO by means of regular site visits (preferably monthly) during the project
and by assisting with the formulation of the most effective and structured monitoring and reporting
strategy, tailored to the conditions of the contract;
•
Prepare monthly monitoring reports in conjunction with the ESO and 6 monthly report to MICOA;
•
Report to and discuss with the Owner’s Representative any significant non-compliance by the
Drilling and sub-Contractors and the steps to be taken to rectify this; and
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Prepare the Rehabilitation Plan, in conjunction with the ESO. The EC shall be responsible for the
final sign off on any rehabilitation. A list shall be prepared of any areas where remedial measures
are necessary and these measures shall be implemented before a Closure Certificate is issued. The
EC shall actively oversee the re-instatement of sites and provide the final sign-off.
•
Actively participate in the monthly site meetings.
•
Assist with internal and external audits.
•
Ensure that the environmental procedures of the Drilling Project are consistent with Sasol’s other
projects.
•
Be responsible for the review of the d-EMP (as per Section 3.2.2).
•
Prepare a project close-out report.
Sasol shall initiate, co-ordinate and manage all communication with the Government (local, provincial
and national) via their environmental representative based in Maputo, except where specified otherwise
in contract documentation.
The Environmental Specialist: may include more than one specialist. He/she shall:
•
Be employed by Sasol as and when required to ensure compliance with the requirements of the
EMP.
•
Be either an internal Sasol employee where the expertise is available or be an external consultant
where the expertise for the specific issue is not available, as determined by the Scope of Work
prepared by the Environmental Co-ordinator.
•
Have a demonstrated track record in the specific environmental aspect he/she is appointed to
consider and shall preferably have experience on drilling projects. The environmental specialist shall
advise Sasol and the relevant Drilling sub-contractors as to the appropriate actions to be taken to
minimise the impacts on the environment.
•
Support Sasol’s Environmental Co-ordinator. Responsibilities of the Environmental Specialist shall
be set by Sasol and may include the following:
o
Monitoring the impact of the project on the environment with particular emphasis on areas of
environmental sensitivity.
o
Auditing compliance by the drilling sub-contractors with this environmental standard. Preparing
environmental audit reports documenting the effectiveness of environmental management,
problem areas, remedial actions proposed and taken and compliance/non-compliance by the
drilling sub-contractors with the project standard.
o
Calling on specialist sub-consultants, as required for input, advice and to verify the effectiveness
of impact management.
o
Preparation of an integrated report on social and environmental aspects of the project.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Sasol Petroleum Temane Lda (SPT)
o
Page 12
Preparation of method statement for drill mud/cutting disposal or review of Sasol’s method
statement if prepared internally.
Community Liaison Officer (CLO)
o
Sasol shall appoint at least two Community Liaison Officers (CLO) during construction, reporting
to the Sasol Public Relations Officer (PRO). The CLOs shall comply with all requirements for
ongoing communication with affected communities during the construction period.
Responsibilities of the CLOs shall be set by Sasol and may include the following:
o
Support the Sasol PRO in meeting the regular communication requirements of the c-EMP
o
To keep communities informed about upcoming construction activities and progress with
construction
o
To arrange occasional visits to drilling and other construction sites for District Government,
community leaders and other senior community leaders.
o
To teach traffic safety to those communities near or on access routes that will be used by
construction vehicles
o
To support Sasol in development of the Project Labour Agreement by supporting development
of a transparent recruitment process in consultation with village leaders and government for
recruitment of unskilled temporary construction workers from the affected villages, and to
communicate this process widely
o
To liaise between Sasol, the EPCM Community Liaison Officers, the community and
NGOs/service providers implementing community projects for the construction phase
o
To communicate and manage the Sasol Compliments and Complaints Register
o
To communicate and manage the Sasol Grievance Procedure.
o
To report any transgressions of foreign construction workers in the communities to Sasol.
The CLOs shall act as guides and advisors to Contractors in respect of the EMP on communication and
local community issues during the construction phase of the project. This will be achieved by ongoing
liaison with and monitoring of relations with communities, identification of problem areas and supporting
their resolution.
The CLOs shall be hired from the Inhassoro District, shall have knowledge of the proposed project,
experience in communication with communities and local and district authorities and shall be able to
communicate in local languages. They shall be capable of evaluating the effectiveness of specified
social management measures. They shall be able to propose solutions to problems identified as regards
the implementation of the plans.
The Owner’s Representative (i.e. Sasol’s Field Operations Superintendent) shall be the single
communication channel for the ESO and Environmental Co-ordinator, whom shall report to him/her on
environmental issues relating to the drilling operations. Any site instructions to rectify non-compliance
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Sasol Petroleum Temane Lda (SPT)
Page 13
by the Contractor with respect to environmental management shall be issued by the Owner’s
Representative. The Sasol SHEQ Manager shall be informed of the environmental issues relating to the
rectification of non-compliance and any other relevant environmental management aspect.
3.2.
LIAISON, CO-ORDINATION AND REPORTING
The structure for all communication, correspondence and reporting between project stakeholders will
be defined at the beginning of the Project with the Contractors. The EMP will be an item on the daily site
meeting agenda, which will be attended by the HS Representatives, including the Environmental Coordinator. If, at any time, the Owner’s Representative (Field Superintendent) is uncertain in any respect
of the implementation of any aspect of the EMP, he shall consult with the Environmental Co-ordinator.
The ESO and Environmental Co-ordinator shall report directly to the Owner’s Representative (Field
Superintendent). All reports concerning non-compliance by any of the drilling sub-contractors shall be
routed through the Owner’s Representative (Field Superintendent) and shall be discussed at the monthly
site meetings. The Sasol SHEQ Manager shall be informed of the environmental issues relating to the
rectification of non-compliance and any other relevant environmental management aspect. The ESO
shall provide a daily report to the EC and the Field superintendent layout out environmental actions
undertaken during the day. These reports will act as a basis for the monthly report to be prepared by
the EC for Sasol management.
3.2.1.
COMMUNICATION WITH COMMUNITIES AND AUTHORITIES
Sasol has a full-time Public Relations Officer (PRO) that will be supported by at least two Community
Liaison Officers (CLOs) to be hired for the duration of construction. This Communication Liaison Team
(CLT) will be actively involved in the project area (as updated for the current project – refer to the c-EMP
for construction at the CPF complex) and shall liaise with the local communities regarding the activities
and presence of Sasol in the project area, including:
•
The proposed project goals and activities in the area;
•
How these activities will be conducted to minimise the impacts on surrounding communities;
•
Employment requirements and the employment policy; and
•
Contact details should the residents have questions, concerns or complaints.
This CLOs shall be an important source of information for the day-to-day communication with affected
communities. The CLOs will report to the Sasol Field Superintendent about any community issues
relating to the drilling programme but the direct manager will be the Manager of the Community Liaison
Team who is based in Maputo.
The negotiation and monitoring of compensation is outside the field of responsibility of the CLO. This
will be managed by Sasol’s Mineral Rights Division (SMRD) and its consultants. Monitoring of
compliance with the procedures “Resettlement and Damage Compensation Procedure for Sasol’s
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Sasol Petroleum Temane Lda (SPT)
Page 14
activities in Mozambique (Revision 3, 2014)” will be the responsibility of the Government. All
communication with the Government regarding environmental management matters will be via the Sasol
Environmental Specialists based in Maputo.
Note: All communication with the Mozambique Government regarding environmental management matters shall be
via Sasol. All communication with local structures shall be undertaken in conjunction with the Sasol Community
Liaison Officer(s) (CLO). All communication with regards to resettlement and compensation shall only be
undertaken by the Sasol Compensation Officers and not by Contractors.
3.2.2.
CO-ORDINATION AND REVIEW OF THE EMP
The EMP forms the basis for environmental management on site. Based on the results of the
performance assessment and review process, the EMP may be modified as the project progresses.
Modifications will only be permitted by the Sasol Environmental Co-ordinator. The Master copy shall be
retained at the CPF and in Rosebank once it has been approved by MICOA. Changes to the EMP will
only be allowed:
a) If alternative measures with equal or improved outcomes have been identified subsequent to
the compilation of the report.
b) Prior to non-compliance, therefore requiring pro-active evaluation.
All changes shall be made as per SPI’s Document Control Procedure to which all affected parties shall
comply. This procedure defines document distribution, retention and management of EMP revisions.
All changes shall be tracked, including details of the change, date of the change and name of the
reviewer. The Sasol’s Environmental Co-ordinator shall ensure that any modifications are
communicated, explained to and discussed with all affected parties (i.e. the authorities, the drilling subcontractors, the HS Representative, SHEQ Manager, Sasol’s Field Superintendent, ESO, the Sasol
Drilling Manager and any directly affected party who requests this information).
All changes to the d-EMP shall be submitted to MICOA for approval. The World Bank shall be notified
of any material changes to the d-EMP.
3.2.3.
REPORTING
In addition to all reporting requirements identified in the EMP, records shall be kept by the Sasol
Environmental Co-ordinator of all monitoring results, monitoring reports, incident records, audit reports
and management reviews. Minutes of all environmental project meetings shall be submitted to the
Environmental Co-ordinator.
All report requirements shall be agreed at the beginning of the Project with sub-Contractors but in
general shall be as follows: the sub-contractor site supervisor(s) shall report environmental matters to
the ESO, who shall report to the Sasol Environmental Co-ordinator and the Field Superintendent. The
Sasol Environmental Co-ordinator shall ensure reporting to the Sasol Project Manager, Sasol Drilling
Manager and SHE Manager, as well as clear communication about activities to the Field Superintendent.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Sasol Petroleum Temane Lda (SPT)
4.
Page 15
ENVIRONMENTAL MANAGEMENT PLAN
This section of the report presents specific environmental management requirements for the drilling and
completions operations for the Sasol PSA Development and LPG Project. The activities, sub-categories,
page and specification references for each activity and impact management measures specified in this
section are summarised in Table 4-1.
TABLE 4-1.SUMMARY OF ACTIVITY CATEGORY AND SUB-CATEGORIES INCLUDED IN THE
ENVIRONMENTAL MANAGEMENT PLAN.
Activity
category
Pre-construction
requirements
Administration
and general
issues
Activity sub-categories
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ƒ
ƒ
ƒ
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ƒ
ƒ
ƒ
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Community,
ƒ
stakeholder and ƒ
government
ƒ
liaison
ƒ
ƒ
Management of ƒ
population influx ƒ
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ƒ
ƒ
Employment and ƒ
labour
ƒ
management
ƒ
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General aspects
relating to civils
Emergency
ƒ
Response Plan ƒ
ƒ
Site
ƒ
establishment
ƒ
Page reference
Specification
reference
17
4.1
17
4.2
24
4.3
27
4.4
29
4.5
33
4.6
33
4.7
34
4.8
Emergency response plan
Award of contracts
Compliance with legislation
Working period and work hours
Personnel management
Personnel management cont
Equipment use
Collecting or harvesting of plant material
Hunting and harassing of wild animals
Dust generation and other air pollutants
Lighting
Noise management
Vehicle, machinery and drilling rig movement
Safety
General activities on site
Movement of abnormal loads
Welding
Water extraction from surface waters
House-keeping
Demining
Access to sites
Access to roads
Access routes
General
Communication/liaison
Respect for local people
Access to property
Reporting
Communication of Sasol recruitment strategy
Appointment of personnel
Communication with authorities, community
leaders and employees
Information meetings
Record keeping
Employment
Employee supervision
Health management
Sex worker management
Spill classification
Emergency response to a well control incident
Communication in an emergency
Establishment of temporary accommodation
on the well sites
Effluent management including sewage
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Sasol Petroleum Temane Lda (SPT)
Activity
category
and
management
Site water
management
Solid waste
management
Hazardous
materials
management
and disposal
Page 16
Activity sub-categories
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ƒ
ƒ
ƒ
ƒ
ƒ
Vehicle and
machinery
maintenance
(and refuelling)
Drilling operation ƒ
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Page reference
Specification
reference
36
4.9
34
4.10
39
4.11
42
4.12
42
4.13
Non potable water supply
Potable water
Mosquito control
Obstruction of water flow
Stormwater management
Flood management
General
Waste storage and transport
Waste disposal for base camp
Recycling of waste
Incineration of waste
Transportation of waste and off-site disposal
Borrow pit management
General
Management of hazardous materials
Storage and handling of hazardous materials
Disposal of hazardous waste
Hazardous waste storage areas
Contaminated soils
Disposal of medical waste
Incineration of waste
Contaminated soils
Disposal of medical waste
Used oil and fuel
Vehicle maintenance
rig washing
Refuelling
General
Community consultation
Casing of wells
Drilling muds
Use of oil-based drilling muds
Disposal of completion fluid
Disposal of condensate / oil
Flaring of condensate / oil
Spill management
Vegetation cutting behind burn pit
Formation pressure control
Waste management
Re-instatement of well site at Inhassoro
Securing of the well sites
Rehabilitation of well site
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Sasol Petroleum Temane Lda (SPT)
4.1.
Ref.
4.1.1.
4.1.2.
4.2.
Page 17
PRE-CONSTRUCTION REQUIREMENTS
Activity
Objective
Emergency
Response
Plan
Minimization of
impacts of a
loss of well
control
Produced
Water Well
Avoidance of
groundwater
impacts
Requirements/ specifications
Responsibility
Sasol’s Emergency Response Plan shall be updated to cover the
Sasol
prevention and management of major oil spills. The update shall be
prepared (or if internally prepared, shall be reviewed) by
internationally recognised oil spill prevention and management
consultants. As a minimum, the plan shall cover the following:
•
Risk Assessment Update – an update of the assessment
prepared for the EIA, with specific reference to wells I-G6-PX-1
and I-G6PX-6, where critically important environmental
resources could be affected with potential consequences
affecting the coastal drainage lines, mangroves and the
Bazaruto Archipelago National Park.
•
Immediate Response Plan – covering the immediate short term
actions that are to be taken in the event of a loss of well control
•
Well Control (Blowout) Contingency Plan (regional for most
wells but site specific for wells I-G6-PX-1, I-G6PX-6, Provision
shall be made for Tier 2 and Tier 3 response capability (refer to
Section 7).
If a further produced water well is required, over and above T-22
Sasol
and T-25, the well is to be sited, drilled and operated according to
best industry practice, with particular reference to the minimisation
of risk to aquifers. Sasol shall prepare a method statement for
approval by MICOA which demonstrates that suitability of the
formations proposed for reinjection.
Scheduling
Before drilling
Performance
indicator(s)
Training
Requirements
Emergency
Response Plan
including updates as
specified.
Incident reports
Regular
training and
emergency
drills for drilling
personnel and
emergency
staff as per
requirements
of the
Emergency
Response
Plan
Before final siting Biannual water
and drilling
quality testing at a
minimum of two
monitoring
boreholes
Records of well
performance
Drilling subcontractor
training on
EMP
requirements.
ADMINISTRATION AND GENERAL ISSUES
Ref.
Activity
4.2.1.
Award of
contracts
Objective
Avoidance of
impacts.
Compliance to
dEMP
Final - English version Revision 12
Requirements/ specifications
Responsibility
The EMP shall be included as part of tender documentation and
shall form part of all new contracts.
Should a contract already be awarded the d-EMP requirements
shall be included as a change / variation to the contract.
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Sasol
All Drilling subcontractors
August 2014
Scheduling
At release of
requests for
quotation.
Performance
indicator(s)
Inclusion of EMP
as part of all
contracts and
orders
Training
Requirement
s
Drilling subcontractor
training on
EMP
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Procurement
4.2.2.
Objective
Page 18
Requirements/ specifications
Responsibility
Maximise local In terms of Decree 24 of 2004 on Petroleum Operations
SC Manager
procurement
Regulations SPT has developed its own Local Content Policy,
focused on stimulating economic growth throughout the value
chain and creating opportunities for those who do not work at
the CPF plant. It In line with Sasol’s local content policy, which
covers a range of categories, from highly specialised to the
commoditised. Local content is an integral part of tender
evaluation criteria in major projects. Thus goods and services
should be procured whenever possible and whenever these
meet established requirements in communities and the District
and Province
Scheduling
Ongoing
Local suppliers in
service provider
list
Register and
percentage of
procurement in
communities, the
District and
Province, and
nationally
Internal and
external audit
findings.
Absence of legal
warnings /
prosecutions.
ESO and EC’s
weekly reports with
reference to noncompliances
Internal and
external audit
findings.
Absence of
complaints.
ESO and EC’s
weekly reports with
reference to noncompliances
Contractors’ reports
on weekly hours
worked by
employees
Requirements of Mozambican and other relevant legislation shall
be met (see Appendix 1 for a list of relevant Mozambican
environmental legislation).
Sasol shall be immediately notified of any breach, or pending
breach. Notification must be accompanied by full details of the
contravention or pending contravention and a corrective action
plan.
Sasol
All Drilling subcontractors
At all times.
4.2.3.
Compliance
Avoidance and
with legislation Prevention of
legal
contravention.
Work hours for the Drill Rig and Service Rig shall be in two shifts
– daytime and night-time. Surrounding communities shall be
informed about drilling activities, including operating hours.
Due to the night-time working hours, specific noise mitigation
measures detailed in Section 4.2.11 are required.
Sasol
All Drilling subcontractors
At all times.
4.2.4.
Working period Avoidance and
and work
prevention of
hours
noise
disturbances.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Performance
indicator(s)
Training
Requirement
s
requirements.
Drilling subcontractor
training on
relevant legal
and lender
requirements
and
international
standards.
None.
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
4.2.5.
Personnel
management
4.2.6.
Personnel
management
4.2.7.
4.2.8.
Objective
Avoidance and
prevention of
environmental
impacts
Avoidance of
impacts
including
personnel
discomfort and
fire risks.
Equipment use Prevention of
introduction of
alien plants/
weeds.
Collecting or
harvesting of
plant material
Prevention of
impact.
Final - English version Revision 12
Page 19
Requirements/ specifications
Responsibility
A site and project specific HSE induction shall be drafted prior to
commencement of drilling and be presented to all drilling subcontractors before they start to work on the Project. Issues that
shall be addressed include, but are not restricted to:
•
Possession of firearms.
•
Use of alcohol on duty.
•
Use / possession of drugs.
•
Hunting of wild animals / collection of plant life.
•
Persecution of wild animals
•
Respect for the rights of local communities / inhabitants.
Sasol shall approve the content of the induction. A register shall
be kept by the drilling sub-contractors and Sasol of all personnel
who attend the induction.
On all the drilling rigs and the service rigs, smoking is permitted
ONLY in designated areas, where there is no risk of starting a
bush fire, subject to operational procedures at the specific well
site.
All equipment involved in vegetation removal shall be washed
down before use on site or on the advice of the ESO of EC when
work has occurred in areas where alien plants are present.
Sasol
All times
All Drilling
contractors and
sub-contractors
Sasol
All Drilling subcontractors
Sasol
All Contractors
The harvesting or collection of fruits, vegetables, grains and other Sasol
plant material by Sasol employees or Contractors shall be
All Drilling subprohibited
contractors
Appropriate disciplinary procedures shall be taken against
offenders by the contractor’s management and notification given
to Sasol of the actions taken.
In certain instances where indigenous plant material is required
for scientific purposes, permission may be obtained from the
Sasol EC to remove it.
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Scheduling
August 2014
At all times.
Training
Requirement
s
Implementation of
Employees to
induction
be provided
Inclusion in training with and
/ induction
briefed on
programme(s).
code of
Register of
conduct.
attendance of
induction
Performance
indicator(s)
Inclusion in training None.
/ induction
programme(s).
Evidence of use of
designated
smoking areas
Prior to the
As per requirement. Training of
importation of
equipment
used equipment
operators.
into the Sasol
Onshore
Exploration and
Development
Blocks.
At all times.
Inclusion in
Training of
training/ induction
employees on
programme(s).
EMP
Reference to
requirements.
harvesting or plant
collection by
contractors in the
weekly reports of
the ESO and EC.
Written permission
given by EC for
removal of plants
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Objective
Page 20
Requirements/ specifications
Responsibility
Scheduling
Performance
indicator(s)
Training
Requirement
s
for scientific
purposes.
4.2.9.
Hunting and
harassing of
wild animals
Prevention of
impact.
Dust
Minimisation of
4.2.10. generation and dust.
other air
pollutants
Final - English version Revision 12
Hunting and harassing wild animals by Sasol personnel and
Contractors shall be prohibited.
The purchase of wild animals for food by Sasol employees and
Contactors shall also be prohibited.
Sasol
All Drilling subcontractors
At all times.
Dust shall be controlled to ensure no detrimental effect to
Sasol
As required.
landowners, occupants, employees or the general public
All Construction
The contractor shall comply with the World Bank air quality
Contractors
guidelines as set out in Table 4-1. Dust suppression measures
may include dust suppression using water spray and surface
binding using ‘environmentally friendly’ products.
If instructed to do so by the EC, the contractors shall demonstrate
compliance with air quality guidelines of the World Bank as set out
in Table 4-1 by means of measurement of dust levels at receiver
points specified by Sasol. Measurements shall be undertaken in
accordance with international best practice as approved by Sasol.
The contractors shall ensure that all diesel and other mechanical
equipment is in good working order, minimises exhaust fumes and
associated air emissions.
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Inclusion in
training/ induction
programme(s).
Reference to
hunting and
purchase of wild
animals in the
weekly reports of
the ESO and EC
Lack of complaints
from communities
or employees.
Complaints
recorded in
Compliments and
Complaints
Register and
communicated by
CLOs resolved
within 48 hours.
Absence of
instruction by EC to
undertake formal
dust monitoring or
dust suppression
measures.
References to dust
in ESO and EC
weekly reports
Internal and
external audit
findings
Training of
employees on
EMP
requirements.
None.
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Lighting
4.2.11.
Noise
4.2.12. management
Vehicle,
4.2.13. machinery and
drilling rig
movement
Page 21
Objective
Requirements/ specifications
Responsibility
Prevention of
disturbance of
wildlife and
surrounding
communities.
Minimisation of
noise.
During construction and drilling operations, no spotlights shall be
pointed away from the site. All lighting shall be shielded and shall
be directed downward onto the site so as to avoid light spillage
into surrounding areas.
Sasol
All Drilling subcontractors
Minimisation of
compaction of
topsoil.
Prevention of
disturbance to
environment
outside of
construction
areas.
Final - English version Revision 12
Scheduling
Performance
indicator(s)
At all times.
Lack of complaints
Noise levels shall be controlled to ensure no detrimental effect to Sasol
landowners, occupants, employees or the general public.
All Drilling subAll vehicles and equipment must be maintained regularly to
contractors
prevent excessive emissions and noise. Silencers and noise
control devices shall be used where required.
The generator supplying power to the drilling rigs shall be
equipped with acoustic shields to ensure that sound emissions
from these sources do not exceed 85 dBA at 5 metre from source.
If necessary, additional portable acoustic shields shall be
deployed around major noise sources in order to further reduce
sound emissions.
The drilling sub-contractors shall demonstrate compliance with the
internationally accepted noise standards of the World Health
Organization (WHO), as adopted by the IFC/World Bank (refer to
Table 4-1).The noise levels (LAeq) caused by the drilling at the
households closest to the drilling activities shall not exceed:
•
Daytime: 55 dBA
•
Night-time: 45 dBA
In the event that it proves to be impractical to reduce drillingrelated noise levels to the above standards at any particular
household, following the implementation of all reasonable
measures, then alternative solutions shall be discussed with the
affected household(s) and any agreed action taken.
Night-time.
Measurements
taken at least
once per week
(refer to Table
4-1)
Transport routes to the well sites and campsites shall be clearly
Sasol
marked. All vehicles used for transportation/ construction/ drilling All Drilling subpurposes shall remain within these demarcated routes and areas. contractors
No movement off these routes shall be permitted.
In emergency situations (e.g. flooding, road damage) deviations
off-road are permitted, as long as any damage to sensitive
environments is rectified as quickly as is practically possible and
before the end of the drilling campaign. The ESO and EC shall be
notified of these deviations to evaluate the impact and to
At all times.
Lack of complaints
from communities
or employees.
Complaints
recorded in
Compliments and
Complaints
Register and
communicated by
CLOs resolved
within 48 hours.
Compliance with
noise standards in
Table 4-1.
Absence of
instruction by Sasol
to undertake formal
noise monitoring
Reference to noise
in the EC and
ESO’s weekly
reports
Internal and
external audit
findings
Route markings as
per requirement.
No new route/ track
development.
Speed testing.
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Training
Requirement
s
None.
None.
All vehicle
operators to
have valid
licences.
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Objective
Prevention of
accidents.
Safety
4.2.14.
General
4.2.15. activities on
sites
Avoidance of
accidents and
mines.
Prevention of
fires.
Minimisation of
fire damage.
Final - English version Revision 12
Page 22
Requirements/ specifications
Responsibility
determine mitigation measures and rehabilitation strategies,
where applicable.
Safe travelling speeds for each section of the route along the right
of way shall be determined and enforced. This may include, but
not be limited to, the monitoring of vehicle speeds, the erection of
speed limit signs and the installation of speed humps.
Personnel shall not stray from the designated right of way/
All persons
servitudes, access routes, public roads and well sites due to the
risk of mines.
Specific measures must be taken to prevent the spread of bush
fires caused by activities at all sites.
This shall include as a minimum the following:
•
Restricting smoking to specific identified areas, away from
high risk fire areas
•
The construction of firebreaks around the well sites, where
appropriate
•
Additional clearance of vegetation behind the flare pits if
necessary as per Appendix 2, after inspection by the ESO.
•
Installation of fire warning systems in combustible semipermanent to permanent structures
•
Instruction of employees about fire hazards
•
Complete avoidance of fires on the right of ways or access
routes, and well sites.
•
Regular fire drills
•
Regular firefighting training
•
Availability of firefighting equipment, including extinguishers
sufficient for the number of people working at the well sites
and the extent of the area, fire resistant clothing for fire
fighters and fire fighting flails.
The Sasol Environmental Co-ordinator or the Health and Safety
Officer can request additional measures at their discretion based
on the site activities.
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Sasol
All Drilling subcontractors
August 2014
Scheduling
At all times.
Ongoing.
Performance
indicator(s)
Inclusion in training
/ induction
programme(s).
No reported
evidence of
personnel using
access outside of
demined areas.
Inclusion in training
/ induction
programme(s).
Demonstrable fire
protection
measures,
including:
ƒ
Records of fire
drills and fire
fighting training
ƒ
Specific
smoking areas
ƒ
Education
material for
employees on
fire hazardous
Suitability located
fire extinguishers
Training
Requirement
s
None.
Drilling subcontractor
training on
EMP
requirements.
Education of
employees.
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Movement of
4.2.16. abnormal
loads
Welding
Objective
Prevention of
accidents.
Page 23
Requirements/ specifications
Responsibility
Abnormal loads (e.g. rigs and pipe trucks) shall be transported
with the proper escorts on the main arterial routes as decided by
Sasol and the relevant Mozambican authorities.
Any welding or other sources of heating of materials shall be
done in a controlled environment wherever possible and under
appropriate supervision, in such a manner as to minimise the risk
of bush fires and injury to staff. A HS procedure shall be
produced by the Contractor for welding that shall be approved by
Sasol HS Department.
Water
Avoidance or
Extraction of water from the barrier lakes and coastal streams in
4.2.18. Extraction from minimisation of the study area is prohibited.
surface waters impact on
Water may be extracted from the Govuro River Before any
ecosystems and extraction occurs, the Sasol Environmental Co-ordinator shall
local
approve the activity and the proposed extraction point and
communities.
volumes shall be monitored.
Permits for any freshwater abstraction must be obtained from Ara
Sul and the local administrator prior to the start of abstraction. A
Copy shall be given to ESO / EC for the environmental records.
No Interbasin transfer of water is allowed.
House-keeping Avoidance of
At all times the works shall be maintained in tidy order. No littering
impact.
shall be permitted.
4.2.19.
4.2.17.
Demining
4.2.20.
Avoidance of
uncontrolled
fires.
Avoidance of
impact
Final - English version Revision 12
If demining is required for drilling operations over and above that
for Construction, it shall be undertaken in accordance with the cEMP.
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Scheduling
Performance
indicator(s)
Training
Requirement
s
All vehicle
operators to
have valid
licences, if
not training
will be
required.
None.
Sasol
All Drilling subcontractors
At all times
Number of
accidents involving
abnormal loads
Sasol
All Drilling subcontractors
At all times.
Internal and
external audit
findings.
Sasol
All Drilling subcontractors
At all times
Records of
None
volumes
abstracted.
Records of drop in
water levels and
replenishment after
rainfall.
Sasol
All Drilling subcontractors
At all times
Inclusion in training
/ induction
programme(s).
Absence of litter on
site.
Training of
employees on
EMP
requirements.
Sasol
All Drilling subcontractors
At all times
Compliance with
indicators in cEMP
Training of
employees on
EMP
requirements
August 2014
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Objective
Access to sites Avoidance of
disturbance to
4.2.21.
surrounding
communities
and associated
social impacts.
Minimisation of
access.
Safety of
personnel
Access to
Minimisation of
roads
access.
4.2.22.
Access routes
4.2.23.
4.3.
Preservation of
indigenous
vegetation.
Page 24
Requirements/ specifications
Responsibility
Scheduling
Access to all sites shall be restricted to Sasol employees and
drilling sub-contractors’ employees.
Access to well sites shall be restricted to personnel working on
the sites.
Sasol
All Drilling subcontractors
At all times
Access along any roads leading to well sites shall not be
restricted, except as necessary to allow for construction or drilling
activity.
Sasol
All Drilling subcontractors
At all times.
Access routes to all Sasol sites shall only be along existing roads
or those being created for access to the well sites.
Sasol
All Drilling subcontractors
At all times.
Training
Requirement
s
Inclusion in training None.
/ induction
programme(s).
Site access control
measures.
Performance
indicator(s)
Inclusion in training
/ induction
programme(s).
Documentation
supporting decision
taken.
Inclusion in training
/ induction
programme(s).
Absence of new
track development.
None.
Employee
training on
EMP
requirements.
COMMUNITY, STAKEHOLDER AND GOVERNMENT LIAISON
A key management principle during drilling and well completion operations shall be that of ensuring that the rights of the inhabitants are not infringed and that all
operations are conducted in a manner that is respectful to the local residents and the land and resources that belong to them. The project area is characterised by the
following socio-economic conditions, which shall at all times be taken into consideration:
•
•
•
•
•
Subsistence living;
Extreme poverty;
Strong dependence on local natural resources;
Lack of health and education facilities, access roads; and
Very limited employment opportunities.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Page 25
Requirements / specifications
Responsibility
Scheduling
General
Access over land, the integrity of fences,
control of bush fires, littering, dust control,
noise abatement, harassment of domestic and
wild animals, sedimentation and contamination
of ground and surface waters, damage to
landscape and vegetation and all such
environmental matters, shall be controlled in
the best interests of the land owner / occupier
and the general public.
All Contractors
Sasol
At all times.
Sasol shall utilise its existing communication
forums, or re-establish these were they are
dysfunctional, and the services of its public
relations officer (PRO) and construction CLOs
to liaise with the local communities and
authorities regarding the construction activities
and presence of Sasol in the project area,
including:
• The proposed project goals and activities
in the area;
• The long-term activities and their expected
environmental impacts;
• How these activities will be conducted to
ensure environmental protection;
• Employment requirements and the
employment policy; and
• Contact details should the residents have
questions, concerns or complaints.
Sasol
Ongoing
4.3.2.
Communication
/liaison
4.3.3.
Respect for local
people
Sasol shall ensure that a Compliments and
Complaints Register about the construction
activities is in place and kept in each
Sasol
All contractors
Procedure to be
produced and
communicated to
local communities
4.3.1.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Performance
indicator(s)
Record of
compliments /
complaints.
Number of
complaints
registered
Number of
complaints
resolved
Number of
compliments
received
Nature of
complaints
analysed and
corrective actions
taken for trends in
complaints
Number and
nature of
communication
initiatives
Number of
complaints
registered
Number of
complaints
resolved
Number of
compliments
received
Nature of
complaints
analysed and
corrective actions
taken for trends in
complaints
Compliments and
Complaints
register.
Number of
Training
Requirements
Training of
employees on
EMP
requirements.
Inclusion in
training / induction
programme(s).
Training for PRO
and CLOs
Cultural awareness
workshops prior to
and
during
construction
for
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Page 26
Requirements / specifications
Responsibility
community. It should define, but is not limited
to, the following:
• Locations at which community members
can register complaints e.g. about dust,
noise, other construction nuisance or
disturbance;
• Procedure by which community members
can raise issues / complaints;
• How the community will be notified of the
opportunity and means for communication
with regard to project issues; and
• How these complaints / issues will be
captured, handled, responded to and
rectified as necessary.
4.3.4.
Access to
property
Final - English version Revision 12
The Register in each community shall be
inspected as a minimum weekly by the CLO
and complaints resolved within 48 hours.
The register should include, but not be limited
to:
• The name of the complainant /
communicator;
• Contact details of the communicator;
• Nature of the complaint or compliment with
as much detail provided as possible (time,
date, nuisance or disrespect suffered etc);
and
• Any action taken to rectify the issue.
Contractors shall not deal directly with
surrounding communities about construction–
related issues. Sasol shall bring to the
contractors’ attention any issues that are
raised by the community that require action.
When requested to do so by Sasol’s PRO,
Contractors shall attend community meetings
with Sasol in order to resolve any issues that
have arisen.
The property and rights of all persons shall be
respected at all times.
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Scheduling
prior to the
commencement of
any construction
activity.
Cultural
awareness
workshops prior to
and during
construction
All Contractors
At all times.
August 2014
Performance
indicator(s)
complaints
registered
Number of
complaints
resolved
Number of
compliments
received
Nature of
complaints
analysed and
corrective actions
taken for trends in
complaints
Training
Requirements
contractor
and
Sasol personnel
As per
requirement.
Training of
employees on
Training for PRO
and CLOs in
management of
Compliments and
Complaints
Register
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
4.3.5.
Page 27
Requirements / specifications
Responsibility
Scheduling
Access to
property
Access by Sasol, Contractors and their
employees to homesteads and associated
lands outside of the CPF shall be prohibited.
All Contractors
Sasol
At all times.
Reporting
Sasol shall report on environmental
performance for the project as part of its
annual environmental reporting.
Sasol
In the annual
report.
Reporting
Sasol shall consider placing articles related to
the project and environmental performance in
relevant reports and publications.
Sasol
Quarterly during
construction and
then annually.
4.3.6.
4.3.7.
Performance
indicator(s)
Inclusion in
training / induction
programme(s).
As per
requirement.
Inclusion in
training / induction
programme(s).
Content of annual
report.
Record of articles.
Training
Requirements
EMP
requirements.
Training of
employees on
EMP
requirements.
None.
None.
MANAGEMENT OF POPULATION INFLUX
4.4.
Ref.
4.4.1.
Activity
Requirements / specifications
Communication
of Sasol
recruitment
strategy
A comprehensive communication program
shall be prepared, including national
coverage and community communication
campaigns, starting immediately after
environmental permit issued,
communicating the following Sasol
policies:
•
No hiring of job seekers on site
•
No procurement at the gate
•
Maximising local content in
procurement i.e. from local people and
towns, whenever possible and
whenever project requirements are
met.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Responsibility
Sasol
Scheduling
From when
environmental
permit issued,
ongoing for
duration of
construction
August 2014
Performance
indicator(s)
Documented and
implemented
employment
procedure
Number of
communication
initiatives
Inclusion in
training / induction
programme(s).
Training
Requirements
Training for
contractors in
implementation of
recruitment
component of PLA
Training for PRO and
CLOs in PLA
Sasol Petroleum Temane Lda (SPT)
Ref.
4.4.2.
4.4.3.
4.4.4.
Page 28
Activity
Requirements / specifications
Appointment of
personnel
All unskilled employment shall be from
local project-affected villages, if sufficient
numbers of applicants are available who
comply with project requirements for
unskilled workers. Job applicants shall be
double verified as being local by the leader
of the community plus another respected
senior person in the community.
Sasol
Ongoing
Communication
with authorities,
community
leaders and
employees
Information
meetings
Sasol shall communicate and coordinate
with local leaders and District Government
to curb population influx, obtaining their
support and suggestions in this regard.
Sasol
In advance of
construction and
ongoing
Information meetings shall be held in all
affected villages, explaining the negative
impacts of population influx, the company’s
recruitment policy and verification process
for appointing only local people, and
harnessing their support to reduce influx of
work and opportunity seekers.
Sasol
In advance of
construction and
ongoing
Record keeping
Records shall be kept of the number of
communication initiatives nationally, in the
Province and District and in the 10 nearest
communities.
Updated records shall also be kept of the
number of construction jobs awarded to
people verified as ‘local’ from the
communities, as well as from the District,
Province and Nationally.
Survey results shall be maintained from
interviews with village leaders about
increases in numbers of new arrivals.
EPCm
contractor
Sasol
Ongoing
4.4.5.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Responsibility
Scheduling
August 2014
Performance
indicator(s)
Lists of job
seekers from
village leaders.
Percentage of
people hired from
affected local
communities
Inclusion in
training / induction
programme(s).
Training
Requirements
None
Records of
meetings
Inclusion in
training / induction
programme(s).
Number and
nature of
communication
initiatives
Records of
meetings
Number and
nature of
communication
initiatives
As per
requirement
Contractor training
on relevant
requirements.
None
Contractor training
on relevant
requirements.
Sasol Petroleum Temane Lda (SPT)
Ref.
Page 29
Activity
Requirements / specifications
Record keeping
A register shall be kept of all procurement
from the local communities, the District, the
province and country respectively. The
purpose of this register is to serve as proof
that the Sasol Local Content Policy is being
implemented and to show improvement in
the amount of local content purchased over
time
4.4.6.
4.5.
Responsibility
EPCm
contractor
Sasol
Scheduling
Ongoing
Performance
indicator(s)
As per
requirements
Training
Requirements
Contractor training
on relevant
requirements.
EMPLOYMENT AND LABOUR MANAGEMENT
Employment for the project will be undertaken and managed according to Mozambican labour law and the Sasol Project Labour Agreement approved by the
Government of Mozambique (available from Sasol on request). According to this agreement, the employment of local Mozambican employees is a critical success
factor for the project.
Ref.
Activity
Requirements / specifications
Employment
Sasol (and not the construction contractor) is
to establish a Project Labour Agreement (PLA)
with the National Department of Labour, which
shall include the process of recruitment of local
labour. The PLA should be negotiated in
consultation with Local and District authorities
and with leaders of the 10 affected
communities.
Wide and concerted communication of this
recruitment program is required so that all
members of communities and people in the
Inhassoro District understand the fairness
principles that will apply and the way the
program will operate. All jobs shall be
advertised in local communities
Contractors shall be responsible for all
negotiations with project-affected communities
regarding employment.
4.5.1.
Employment
4.5.2.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Responsibility
Scheduling
Sasol
Ongoing
All Contractors
Ongoing.
August 2014
Performance
indicator(s)
Documented and
implemented
employment
procedure
Number and
nature of
communication
initiatives
Training
Requirements
Training for
contractors in
implementation of
recruitment
component of PLA
Training for PRO
and CLOs in PLA
As per
requirement.
Training for
contractors in
implementation of
PLA
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Requirements / specifications
Employment
Employment shall be undertaken and
managed according to Mozambican labour law
and approved Project Labour Agreement
between Sasol and the Mozambican
Government (available from Sasol on request)
and following liaison with local authorities and
communities. In particular the following should
be addressed:
•
Make maximum use of local labour during
construction on activities where
construction machinery could be
dispensed of. This shall be complimented
by applicable skills training and recording
thereof.
•
All unskilled temporary construction jobs
to be for the project-affected communities,
subject to availability of sufficient workers
from these communities who qualify with
project requirements for employment.
•
The requirement to appoint unskilled
labour from the project-affected
communities’ shall be included in the PLA,
with double verification by a community
leader and another respected person in
the community that a person is indeed
local.
•
Recruitment methods for the project shall
be agreed with local authority and
community leaders but shall under no
circumstances be ad hoc recruitment at
the CPF.
•
No fees shall be levied for recruitment or
preferred status for employment
opportunities.
Contractors shall implement a formal
Employee Grievance Procedure which
provides employees with a mechanism for
raising issues with the company without fear of
victimization. Contractors shall ensure that the
4.5.3.
Employment
4.5.4.
Page 30
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Responsibility
Scheduling
Sasol
All Contractors
Ongoing
All contractors
Ongoing
August 2014
Performance
indicator(s)
Minutes of liaison
with authorities /
communities.
Established
recruitment
office/s
Register of jobseekers.
Percentage of
unskilled, semiskilled and skilled
jobs to the 10
nearest
communities, the
Inhassoro District
and the
Inhambane
Province.
Grievance
Procedure.
Induction
regarding
Grievance
Procedure.
Training
Requirements
Contractor training
on relevant
requirements.
Sasol Petroleum Temane Lda (SPT)
Ref.
Page 31
Activity
Requirements / specifications
Responsibility
Scheduling
induction of employees includes instruction on
how to use the grievance procedure
Employment
4.5.5.
4.5.6.
Employment
4.5.7.
Employment
4.5.8.
Employment
4.5.9.
For semi-skilled and skilled jobs, coordinate
with local authorities and the education sector
to identify appropriate local candidates given
that there are technical schools in the
Inhassoro District. Follow the ‘spiral’ principle
in seeking qualified candidates, i.e. start in
local communities, then the closest town , i.e.
Inhassoro, Vilanculos as the second closest
town and then rest of the Inhambane Province
and nationally
Specific unskilled jobs should be identified and
assigned to women, the disabled and older
people
Sasol
All Contractors
Ongoing.
Sasol
All Contractors
Ongoing
All Contractors shall prepare and submit a
local content plan to Sasol for approval. This
plan shall be aligned with Sasol’s Local
Content Plan in terms of petroleum legislation
All contractors will be expected to abide by this
plan. Detailed records of procurement shall be
kept for inspection by Sasol and submission to
Government.
The employer shall ensure that agreements
undertaken with employees (including
disciplinary criteria, working conditions,
payment of over-time etc.) are in line with the
Project Labour Agreement between Sasol and
the Government of Mozambique and are
properly understood by all employees.
In order to maintain a transparent labour
recruitment process, the information
concerning procedures and work requirements
shall be communicated through channels used
by local authorities and grass roots community
organisations.
Sasol
All Contractors
Plan to be
submitted prior to
award of
contracts.
Compliance to
plan ongoing.
Sasol
All Contractors
At all times.
Sasol
Ongoing
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Performance
indicator(s)
Records of
grievances and
how they were
resolved
Percentage of
employees from
local communities,
District and
Province.
Percentage of
women, disabled
and older
employees.
Prepared and
implemented plan.
Percentage of
procurement from
local communities,
the district,
province and
nationally.
As per
requirement.
Number and
nature of
communication
initiatives
Records of
communication.
Training
Requirements
Contractor training
on relevant
requirements.
Contractor training
on relevant
requirements.
Contractor training
on relevant
requirements.
None.
Sasol Petroleum Temane Lda (SPT)
Ref.
Page 32
Activity
Requirements / specifications
Responsibility
Scheduling
Employment
Contractors shall ensure that contract
employees fully understand the temporary
nature of their employment contracts.
All Contractors
Ongoing
Employee
supervision
Contractors shall ensure proper supervision of
employees at all times, including after-hours
where employees are resident on site.
All Contractors
At all times
4.5.11.
Employee
supervision
No person or persons shall make recreational
use of all-terrain vehicles or motorcycles.
Sasol
All Contractors
At all times.
4.5.12.
Health
management
Contractors shall prepare and implement a
programme and procedure(s) to minimise the
spread of HIV infection. The programme shall
be prepared with the assistance of a specialist
in the field. A typical programme would
include, among other things, the
implementation of the following measures:
• An HIV/Aids training course and on-going
education on transmission of HIV/Aids and
STDs to employees, through workshops,
posters and informal information sessions;
• Encouragement of employees to
determine their HIV status;
• Supply of condoms at the construction
site(s);
• Development of a comprehensive
construction camp management plan,
including rules for onsite behaviour,
entrance and exit policies and prohibition
of sex workers on site.
Sasol shall consider the possibility of
extending this programme to surrounding
communities
All Contractors
4.5.13.
Before site
establishment.
4.5.10.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Performance
indicator(s)
Employment
Contract and
records of
communication
Compliance to
EMP
requirements.
Audit findings.
Inclusion in
training / induction
programme(s).
No evidence of
recreational use of
off-road vehicles.
Inclusion in
training / induction
programme(s).
Implementation of
procedures and
programmes.
Development of
Camp
Management plan
Number and
nature of
communication
initiatives in
communities
Inclusion in
training / induction
programme(s).
Training
Requirements
None
None.
Training of
employees on EMP
requirements.
Contractor training
on relevant
requirements.
Training of
employees on
procedure and
programme
requirements.
Sasol Petroleum Temane Lda (SPT)
4.6.
Page 33
GENERAL ASPECTS RELATING TO CONSTRUCTION
All aspects relating to the construction of the well pads are covered in the c-EMP, and include the following:
•
Selection of the locations for the, access roads, including demining and the avoidance of sensitive areas.
•
Preparation of the site, including vegetation clearance, management of topsoil, erosion control, stormwater control and obtaining of materials from borrow pits
•
Construction of access roads, including borrow pit areas,
•
Management of disturbance of local cultural and community areas, such as graves, and local archaeological and paleontological sites
NOTE: THE c-EMP IS A LEGALLY BINDING DOCUMENT UNDER MOZAMBIQUE LAW
4.7.
Ref.
EMERGENCY RESPONSE
Activity
Spill
4.7.1. Classification
Emergency
4.7.2. Response to a
well control
incident
Objective
Requirements/ specifications
Immediate
reaction to
spills
Responsibility
Any spill during drilling shall immediately be classified in accordance
with the tiered response system included in the Emergency Plan, as
updated. The response system is as follows:
Tier 1: response is that which is immediately available on site,
geared for the most frequently anticipated spill
Tier 2: Response is for less frequently anticipated oil spills of
larger size and for which external resources will be required to
assist in monitoring and clean-up
Tier 3: Response is for very rarely anticipated oil spill of major
proportions and which will possibly require national and
international resources to assist in control clean up and
protection of vulnerable areas.
Actions taken after initial classification and spill response shall be in
accordance with the measures set out for the relevant tier in the
Emergency Plan.
Minimisation of Emergency response shall comply with the detailed requirements of
impacts of
Sasol’s Emergency Response Plan, as updated (refer to Section
blow-out
4.1.1)
All incidents shall be reported to the HS Representative.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Scheduling
Performance
indicator(s)
Sasol
Drilling subcontractors
CLT/CLO
During drilling
Sasol
Drilling subcontractors
CLT / CLO
Before and during Emergency
drilling
Response Plan.
Incident reports
August 2014
Drilling
management
Training
Requirements
Education of
employees.
Emergency
training for
employees
and
surrounding
communities.
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Page 34
Objective
Requirements/ specifications
Responsibility
Communication Minimisation of Emergency response procedures shall be communicated to the
surrounding community leaders and community through the CLO, in
4.7.3. in an emergency human and
ecological risk accordance with the requirements of the Emergency Response
Plan.
4.8.
Sasol
Drilling subcontractors
CLT / CLO
Scheduling
Performance
indicator(s)
Training
Requirements
Before and during Records of
drilling
meetings with
communities
SITE ESTABLISHMENT AND MANAGEMENT
The present planning of the PSA Development and LPG Project indicates that all construction staff, including the drilling crews, will be accommodated in existing
and/or expanded accommodation at the CPF. The management of camp impacts is therefore included under the c-EMP (CPF) which is a separate document. It is
noted that consideration is also being given to the accommodation of the drilling crews at existing facilities in Inhassoro, in order to support local business and tourism
in the town, or at a small camp in the Inhassoro area. The feasibility of these possibilities is still being evaluated. If a personnel camp is preferred that is separate from
the CPF and does not make use of existing Inhassoro facilities, the site will be investigated and a method statement will be submitted to MICOA for approval.
Personnel residing at the drilling sites will be housed in temporary mobile accommodation for 4-6 key personnel (i.e. skid-mounted living portable living/office quarters),
which will be utilised at the well sites during drilling operations due to the 24-hour/day drilling operations.
Ref.
Activity
Objective
Requirements/ specifications
Responsibility
Establishment of
4.8.1. temporary
accommodation
on the well sites
Prevention/
The methodology for the management of effluent and waste shall be Sasol
Minimisation stated in the drilling project waste management plan prepared by
All Drilling subof impact on Sasol and all contractors shall comply with this.
contractors
environment.
Effluent
4.8.2. management
domestic waste
water
Prevention
The Contractor shall prepare a method statement describing effluent Drilling
ground and
management at the well sites that shall include, but not be limited to: Contractor
surface water •
Expected effluent to be produced during the drilling phase of the
pollution.
project;
•
How effluent will be stored prior to treatment;
•
How the effluent will be treated to meet the standards required
under Mozambican legislation: Decree no 18/2004 “Regulation
on Environmental Quality and Effluents Emission Standards”
•
Measures to ensure that there will be no release of polluted
runoff from the site.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Performance
indicator(s)
Prior to drilling.
Submission,
approval and
implementation of
drilling
management plan.
Prior to initiation of Submitted,
activities on site. approved and
implemented
effluent
management plan.
Audit findings.
Scheduling
Training
Requirements
Contractor
training on
relevant
requirements.
None.
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Objective
Domestic
Prevention
4.8.3. wastewater at the ground and
well sites
surface water
pollution.
Non potable
4.8.4. Water Supply
Requirements/ specifications
Responsibility
•
Measures to prevent erosion at any discharge point.
•
The duration of the use of the site
Sasol shall approve the Method Statement.
In the event that the Contractor proposes a septic tank and
soakaway system, it shall be designed in accordance with a
recognised standard, such as that of the City of Cape Town ***.
It shall accommodate at least three times the expected daily flow
rate (approximately 90 litres per day worker) and the soakaway shall
meet the requirements of the standard or other recognised standard.
No septic tank and soakaway system shall be situated closer than
150 m from a community borehole.
Water abstraction for the project shall be from groundwater wells.
The project shall have no detrimental impact on groundwater
volumes available to existing users in the area.
Should the use of surface water be considered, this shall be taken
from the Govuro River only and shall be subject to the approval of
the Environmental Co-ordinator/ ESO’s and the necessary permits
must be obtained from Ara Sul and the Administrator, prior to the
start of abstraction.
All water abstracted for drinking purposes from ground or surface
water sources shall be tested for suitability and treated if required.
Drilling
Contractor
Sasol
Drilling
Contractor
Potable Water
Avoidance of
health issues.
Mosquito control
Minimisation All contractors shall align their Malaria control strategy with the
Sasol
of contraction CPF’s Malaria strategy, which includes pre-secondment and postAll Drilling subof malaria.
secondment procedures. The Contractors shall undertake a risk
contractors
management inspection and design a programme to control vectors
of the disease, in conjunction with and with the approval of Sasol.
The relevant training of employees by Contractors with regards the
risk and avoidance measures of malaria shall be undertaken.
Should pesticides be used for vector control, they shall be selected
so as to avoid any negative effects on non-target species. The
spraying programme shall be approved by the EC and shall provide
the following information:
•
chemicals used with MSDS’s,
•
schedule of spraying,
•
training of personnel spraying, and
•
disposal of containers
The disposal of the waste pesticide and pesticide containers shall be
as per requirements of Section 4.7 and 8.
4.8.5.
4.8.6.
Avoidance of
impact on
water
sources.
Page 35
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Sasol
Drilling
Contractor
August 2014
Scheduling
Performance
indicator(s)
Training
Requirements
Prior to initiation of Design submitted None
activities on site. as part of method
statement and
waste
management plan.
Design
implemented as
per specifications
At all times.
Volume of ground None.
and surface water
used (records).
At all times
Records of water
quality testing.
None
Prior to and
throughout the
commencement of
construction
activity.
Number of malaria
cases.
Documentation on
spraying
programme.
Written approval
from EC
Training of
employees re:
malaria risk and
preventative
measures and
early reporting of
symptoms.
Sasol Petroleum Temane Lda (SPT)
4.9.
Ref.
Page 36
SITE WATER MANAGEMENT
Activity
Objective
Requirements/ specifications
Responsibility
4.9.1.
Obstruction of Prevention of
water flow
impact.
Impediments to natural water flow shall be avoided, or, if
unavoidable, be allowed for in the design by means of
appropriately sized and positioned drains, culverts etc.
4.9.2.
Stormwater
management
Prevention of Potentially contaminated stormwater shall be kept separate from
contamination other drainage at the drilling sites. Potentially contaminated
of stormwater. stormwater shall, if necessary, be tested and treated to remove
contaminants before being released into the environment.
4.9.3.
Flood
management
Prevention and
Minimisation of
impacts on
water flow and
drainage.
Scheduling
Sasol
Drilling subcontractor
At all times.
Sasol
Base camp
management
contractor
At all times.
The location of areas prone to flooding relative to the well sites,
Sasol
and access roads shall be confirmed and any consequences of
Drilling subthis for drilling programme shall be determined and minimised as contractors
soon as possible.
Every effort shall be made to ensure the maintenance of the
natural flow of water following storm events.
No works shall increase the risk of erosion during storm events.
Should this be unavoidable specific erosion control measures shall
be implemented for the duration that the risk exists.
At all times.
Performance
indicator(s)
No damming of
water or
obstructions to
water flow.
Water quality
monitoring records.
Identification of
areas where
activities could
cause
contamination and
evidence of
measures taken to
avoid these.
No alterations to
natural flows.
Details of measures
implemented to
prevent erosion.
Training
Requirements
Contractor
training on
relevant
requirements.
None.
Performance
indicator(s)
Training
Requirements
None.
4.10. SOLID WASTE MANAGEMENT: GENERAL ISSUES AND NON-HAZARDOUS WASTE
Ref.
Activity
General
4.10.1.
Objective
Prevention
and
Minimisation
of impact of
waste
generation
and disposal.
Final - English version Revision 12
Requirements/ specifications
Responsibility
Sasol shall develop an overall waste management strategy that
defines, but shall not be restricted to, the following:
•
Waste minimisation;
•
Waste collection;
•
Waste transport; and
•
Waste disposal methodology.
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Sasol
All Drilling subcontractors
August 2014
Scheduling
Prior to the
initiation of
construction
activities
Submitted,
approved and
implemented waste
management
strategy.
Contractor
training on
relevant
requirements.
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Objective
Page 37
Requirements/ specifications
Responsibility
All drilling sub-contractors shall comply with the waste management
strategy.
All contractors shall be responsible for ensuring waste minimisation,
with specific emphasis on reducing the quantities of hazardous
waste.
In general, littering, or discarding of any materials shall not be
allowed on or off site.
Burying of non-hazardous materials shall be allowed with permission
of Sasol. The ESO or EC shall verify the type, location and manner
of burial.
Waste storage Avoidance of A clear distinction shall be made between the hazardous and nonimpact.
hazardous components of the waste stream, with separation
4.10.2. and transport
occurring at source.
Storage of hazardous and non-hazardous waste shall occur
separately until disposal.
Hazardous and non- hazardous wastes shall be transported to their
disposal facilities separately.
Domestic waste must be contained and stored in a manner to
prevent scavenging by persons or animals.
Lids shall be kept on waste drums at all times.
Waste containers shall bear labels that identify the contents.
Containers shall be lined or constructed of materials that are
compatible with the wastes to be stored. Containers shall be in good
condition, free from corrosion, leaks or ruptures.
Waste disposal Avoidance of Waste must be disposed in a safe, proper and responsible manner
pollution.
as per international best practice, Mozambican law (as per Appendix
4.10.3.
1) and Sasol’s requirements.
Recycling of
4.10.4. waste
Incineration of
4.10.5. waste
Minimisation
of waste.
Where markets exist for the re-use or recycling of waste materials,
these materials shall be separated from the waste stream at their
point of generation and stored separately for collection by the
recycling agent.
Prevention of Waste disposed at the well sites via incineration shall comply with
air pollution
internationally accepted emission guidelines, including the World
Bank Guidelines. All necessary approvals for the operation of an
incinerator shall be obtained by the contractor. All necessary
monitoring as pre-determined by Sasol, with verification by an
independent consultant, shall be undertaken to meet international
standards.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Scheduling
Performance
indicator(s)
Training
Requirements
Sasol
All Drilling subcontractors
At all times.
Separate containers None.
for hazardous and
non-hazardous
waste.
Evidence of
appropriate
locations and
containers for waste
storage.
Signage on waste
storage containers
Sasol
All Drilling subcontractor
NA
As per requirement. None.
Audit findings.
Sasol
All Drilling subcontractors
At all times.
Records of re-use,
recycling.
None.
Sasol
Contractor
managing
incinerators
All time
Air quality
monitoring results
Permits from GOM
None
August 2014
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Objective
Page 38
Requirements/ specifications
Responsibility
The ash from the incinerator shall be tested and disposed of
according to its categorisation.
Transportation Prevention of The following requirements shall apply to the off-site disposal of
ground and
waste 2:
4.10.6. of waste and
off-site disposal water
•
The transportation shall be undertaken by a recognized
contamination
contractor familiar with the health, safety and environmental
requirements regarding the type of waste to be transported
(including hazardous);
•
The frequency of waste collection by the transportation
contractor shall be specified. The interim measures for the
storage of waste on site shall be appropriate and shall be such
that it does not pose an unacceptable risk to either the
environment or human health and safety;
•
The transportation contractor shall have in place the means to
respond appropriately to spillages of waste anywhere along the
route within a time limit acceptable to Sasol;
•
Certificates of safe disposal shall have to be provided to Sasol
for all wastes removed from site. Such certificates shall be
issued by a recognized waste disposal operation; and
The site at which such waste is disposed of shall be approved by the
GOM for the specific waste being disposed and shall comply with
the international standards of operation. As such it shall have to be
audited at intervals appropriate to the risk associated with the
disposal operation.
Borrow pit
Avoidance of No borrow pit, unless approved by EC, shall be used as a waste
disposal site, either temporary or permanent, with the exception of
4.10.7. management impact.
use for concrete and building rubble.
Scheduling
Performance
indicator(s)
Training
Requirements
Sasol
At all times
Waste
Transporting
Contractor
Waste Disposal
Facility
Management
Drilling subcontractors
Certificates of
disposal
Permits from the
disposal facility to
(a) operate and (b)
records of the
specific type of
waste being
disposed of
Independent audit
reports on the
disposal facility
Sasol
All
Construction
contractors
As per requirement. None.
2
At all times.
None
While in some circumstances it shall be preferable to remove waste material from site for disposal, this must be done in such a manner so as not to create risks of non-compliance with legislation or company
policy for the Natural Gas Project. This is particularly important in the context of the institutional environment within which the project will be operating which is characterised by a lack of both waste disposal
facilities and the capacity for transportation of waste.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Sasol Petroleum Temane Lda (SPT)
Page 39
4.11. HAZARDOUS MATERIALS MANAGEMENT AND DISPOSAL
Ref.
Activity
General
4.11.1.
Objective
Legal
Compliance.
Management
4.11.2. of hazardous
materials
Prevention of
soil and water
contamination.
Minimisation of
risk of incident.
Storage and
4.11.3. handling of
hazardous
materials
Prevention of
contamination.
Minimisation of
risk of incident.
Final - English version Revision 12
Requirements/ specifications
Responsibility
The drilling sub-contractors shall at all times comply with all
applicable laws, regulations, permit and approval conditions and
requirements relevant to the storage, use and proper disposal of
hazardous materials.
All hazardous materials and wastes shall be managed in a safe and
responsible manner so as to prevent contamination of soils, pollution
of water and/or harm to people or animals as a result of the use of
these materials.
A hazardous materials management plan shall be prepared as a
method statement to be submitted to Sasol prior to establishment on
site. The plan shall include, but shall not be limited to, measures to
prevent:
•
Soil contamination;
•
Pollution of water;
•
Accidental fires; and
•
Risk/ injury to people or animals.
Contractors shall at all times be aware of the health risks associated
with any hazardous substances used (e.g. smoking near refuelling
depots), and shall provide staff with appropriate protective clothing/
equipment in case of spillages or accidents.
“No Smoking” signs shall be posted in fuel storage areas and areas
where potentially flammable chemicals are stored.
A hazardous materials inventory, with the associated Material Safety
Data Sheets (MSDS)’s must be kept and be readily available at the
CPF contractor’s yard, at the Temane 3 logistics and service
camp, at theSHEQ Office and Contractors’ offices, at the
designated clinic, and at paramedics offices at well sites.
A comprehensive list of all potential hazardous wastes and
estimated volumes must be compiled for all activities, Specifications
for storing and handling of all hazardous substances (e.g. fuel and
chemicals) and waste according to recognised international codes of
practice shall be adhered to. Material Safety Data Sheets (MSDS)
shall be used in assessment of possible risk and best approach to
handling and disposal methods.
Hazardous chemicals in the Base Camp shall be stored on an
impermeable, concreted floor and surrounded by a bund wall with
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Scheduling
Performance
indicator(s)
Audit findings.
Sasol
All Drilling subcontractors
At all times.
Sasol
All Drilling subcontractors Base
camp
management
contractor
At all times.
Prior to the
initiation of
construction &
drilling activities.
Sasol
All Drilling subcontractors
From project
Hazardous
initiation and at all materials inventory.
times.
Availability of
MSDSs for all
hazardous
materials.
Certificates of
disposal.
August 2014
Submitted,
approved and
implemented plan.
Records of training
conducted.
Provision of PPE.
Audit findings.
Training
Requirements
Contractor
training on
relevant
requirements.
None.
Training on
use, handling
etc. of
hazardous
materials.
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Disposal of
4.11.4. Hazardous
Waste
Objective
Page 40
Requirements/ specifications
Responsibility
sufficient capacity to contain 110% of the largest waste drum stored
inside the bund.
At well sites, hazardous materials and waste shall be stored
temporarily (less than 1 week) on a plastic lined area on pallets, with
a tarpaulin over the material awaiting use or transport back to the
CPF contractor’s yard or the Temane 3 logistics and service
camp .
No fuel or any other chemical storage shall be below ground (either
partially or completely). Any fuel storage facilities with a capacity
greater than 1000L shall be located only on flat or gently sloping
ground. An impermeable berm/bund shall be constructed around the
facility to contain at least 110% of the total capacity of the largest
storage containers.
Chemicals, fuels (and refuelling facilities), lubricating oils and any
other hazardous materials shall not be stored within 100m of a
surface water body or within the floodplain of rivers or any area of
temporary inundation.
No fuel storage tanks shall be located in any location other than at
approved plant yards of well sites
Cement shall be stored and mixed: on compacted ground in
designated areas. This ground shall be lifted and disposed of as
cover fill in a designated waste site. Solid waste concrete may be
disposed of in a borrow pit or existing quarries with the permission of
the Sasol ESO / EC.
Fire extinguishers shall be stored in close proximity to flammable /
combustible liquid waste and materials.
Avoidance of Hazardous waste (excluding oil or condensate) shall be collected at
impact due to various points of generation and transported to the CPF contractor’s
contamination. yard or to the Temane 3 logistics and service camp for further
Avoidance of handling and characterisation. All hazardous waste shall be stored
incidents.
in the hazardous waste and materials facility at the CPF contractor’s
yard or the Temane 3 logistics and service camp.
Prior to demobilisation of the rig, all hazardous waste shall be
transported to the CPF contractor’s yard or Temane 3 logistics and
service camp for temporary storage in the hazardous waste facility
(a concrete lined area). All hazardous waste stored at the well sites
shall be appropriately placed on a plastic lined area on pallets
awaiting transport to the CPF contractor’s yard or Temane 3
logistics and service camp If the hazardous waste storage facility is
not yet operational at the CPF contractor’s yard or Temane 3
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Scheduling
All Drilling sub- At all times.
contractors
Immediately after
CPF Base camp any Spill.
management
contractor
August 2014
Performance
indicator(s)
Records of waste
disposal.
Incident and
corrective action
records.
Training
Requirements
Training in
hazardous
material
handling.
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Objective
Page 41
Requirements/ specifications
Responsibility
logistics and service camp, hazardous waste shall be stored on
plastic lining on pallets for no longer than 1 month, during which time
a hazardous waste facility shall be built. This facility shall be a
concrete bunded facility.
Sasol and/or its contractors shall store these wastes and make
arrangements for their disposal. All waste oils, greases, fuels etc.
shall be collected and disposed of in an appropriate manner, with
the approval of the Environmental Co-ordinator / ESO. The contents
of grease traps or other waste oil, grease and/or fuel disposal/
storage containers shall under no circumstances be voided to the
surrounding area.
Chemicals that are no longer used, necessary, or past their shelf life
date shall be stored at the CPF contractor’s yard or Temane 3
logistics and service campfor appropriate disposal.
Pesticides used for control of mosquitoes shall be selected so as to
avoid any negative effects on non-target organisms and humans.
However, waste pesticide and pesticide containers used in the
control of mosquitoes will be disposed of as hazardous waste.
Waste containers shall bear labels that identify the contents.
Containers shall be lined or constructed of materials that are
compatible with the wastes to be stored. Containers shall be in good
condition, free from corrosion, leaks or ruptures.
Records of hazardous waste shall be kept by the Contractors and
shall be submitted to the Sasol EC. It shall include quantities
generated, location stored at and disposal. If disposal occurs away
from the Sasol operations, it shall be undertaken according to
section 4.10.7.
Hazardous
Prevention of A hazardous waste storage area shall be provided at CPF
4.11.5. waste storage soil and water contractor’s yard or Temane 3 logistics and service camp p and as a
areas
contamination minimum should entail an impermeable, bunded area, with sufficient
capacity to contain 200% of the largest waste drum stored inside the
bund (refer to the c-EMP for the CPF.
Scheduling
Sasol
At all times
All Drilling subcontractors
CPF Base camp
management
contractor
Contaminated Soil and water Small quantities of soils contaminated by hydrocarbons (less than
Sasol
Immediately after
soils
pollution.
20kg)
shall
be
treated
in-situ
using
bioremediation.
Large
quantities
All
contractors
any spill
4.11.6.
of contaminated soils (greater than 20kg) or if there is the potential
to cause pollution to groundwater, surface water or community water
facilities shall be removed to the area allocated by the EC at the
CPF contractor’s yard or Temane 3 logistics and service camp for
longer-term bioremediation. Contractors shall be responsible for the
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Performance
indicator(s)
Training
Requirements
Evidence of
None
appropriate storage
areas
Record of incident
and remedial action
taken / disposal
method
Training of
employees in
bioremediation
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Objective
Page 42
Requirements/ specifications
Responsibility
bioremediation of their own contaminated soil until the following
standards are met:
•
There is no hydrocarbon odour
•
The soil particles do not coagulate as a result of hydrocarbon
contamination
•
There is no visual evidence of hydrocarbons in the soil.
•
Where there is uncertainty the soil shall be sent for analysis.
•
Where soils are contaminated by other hazardous chemicals
they shall be removed and disposed of as per hazardous waste
disposal requirements, indicated in the MSDS’s
Disposal of
Prevention of The CPF Clinic shall define a procedure for the management of
4.11.7. medical waste contamination. medical waste that is consistent with the operating procedures at the
CPF.
All medical waste shall be stored centrally at the CPF contractor’s
yard or Temane 3 logistics and service camp after which it will be
incinerated at the CPF as per the Operations EMP (o-EMP).
Records of disposal for all medical waste shall be kept and
submitted to the EC.
Medical waste will be kept separate from all other waste at the Base
camp. It shall be clearly labelled as medical waste.
No medical waste may be disposed with non-hazardous waste or
any other hazardous waste.
Medical waste shall be stored in a manner, which does not
compromise the health or safety of personnel. It shall be disposed of
at the CPF at a minimum of a weekly basis.
Used oil and
Recycling
Used oils and greases shall be separated and recycled wherever
possible, or disposed appropriately, in accordance with an approved
4.11.8. fuel
method statement.
Scheduling
Performance
indicator(s)
Training
Requirements
Sasol
All
At all times.
Records of disposal. None.
Medical waste
containers
Sasol
All drilling subcontractors
All time
Records of recycling None
or disposal
Method statement
for disposal
4.12. VEHICLE AND MACHINERY USE & MAINTENANCE
Ref.
Activity
Vehicle
4.12.1. maintenance
Objective
Requirements/ specifications
Responsibility
Prevention of All equipment and machinery shall be maintained in good working Sasol
water and
order so as to prevent oil, fuel or other such leaks.
All Drilling subsoil pollution.
contractors Base
Camp
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Scheduling
At all times.
Performance
indicator(s)
Records of
maintenance and
inspections.
As per requirement.
Training
Requirements
None.
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Page 43
Objective
Rig washing
Prevention of
water and
soil pollution.
Refuelling
Prevention of
water and
soil pollution.
4.12.2.
4.12.3.
Requirements/ specifications
Responsibility
Vehicle maintenance shall only be performed within designated
areas at the CPF contractor’s yard or Temane 3 logistics and
service camp.
These areas shall be underlain by drip trays. Oil shall be collected
and stored for appropriate disposal. No hydrocarbon-contaminated
water may be voided to the environment.
Vehicle maintenance and equipment maintenance may be
performed on the well pad in an area overlain by a disposable
absorbent pad.
Rig washing shall be reduced by the use high pressure, low
volume hoses. The frequency of rig washing shall be reduced
through measures such as drip pans, drilling saver valves, drilling
fluid buckets and drill string floats.
All reasonable precautions shall be taken to prevent fuel and
lubricant spills on the well pad, including:
•
No overfilling of diesel bowsers, generators and equipment
tanks.
•
Regular inspections to verify that no leaking or defective
equipment is brought onto site.
•
Capture of any oils or lubricants discharged during routine
vehicle servicing on site using drip trays, containers or other
appropriate containment measures.
•
No refuelling of vehicles en route to the well pads, outside of
the CPF contractor’s yard or Temane 3 logistics and service
camp or well sites, unless in an emergency situation, in which
case due care should be taken to prevent spillage.
Performance
indicator(s)
Scheduling
Training
Requirements
Management
contractor
Sasol
All Drilling subcontractors
At all times.
Quality of effluent
water.
None.
Sasol
All Drilling subcontractors
Base Camp
Management
contractor
At all times.
As per requirement.
None.
4.13. DRILLING OPERATION
Ref.
Activity
General
Objective
Requirements/ specifications
Responsibility
Scheduling
Legal
compliance
All drilling activities shall adhere to international best practices
Sasol
and the Guidelines for the Regulation for Petroleum Operations. Drilling subcontractors
At all times
4.13.1.
Community
4.13.2. consultation
Avoidance of
conflict.
Communities within a 5km radius of the well sites shall be
consulted, via the CLO, regarding the drilling process and
emergency procedures.
Sasol
Drilling subcontractors
At all times.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Performance
indicator(s)
Audit results.
Training
Requirements
Contractor
training on
relevant
requirements.
Complaints register. None
Record of
community
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Casing of wells
4.13.3.
Drilling Muds
4.13.4.
Page 44
Objective
Requirements/ specifications
Responsibility
Prevention of
incidents.
Prevention of Surface casing of all wells shall be installed below the surface at Sasol
groundwater
the appropriate levels as determined by the groundwater levels All Drilling subcontamination. to prevent groundwater contamination by hydrocarbons.
contractors
Prevention of
soil and water
pollution.
Rehabilitation
of site.
Sasol
A method statement shall be prepared either by Sasol or an
All Drilling subindependent environmental specialist outlining the disposal of
contractors
the drill cuttings / muds, including water, for each drilling
campaign based on the following:
•
the types of muds to be used and their chemical and
physical composition,
•
the volumes to be generated,
•
the specifics of the environments in which the wells are
located.
•
The specifics of the environments in which the muds will be
disposed if it is not at the well site.
The objective of the disposal technique used shall be to minimise
environmental risk and long term environmental liability.
If the method statement is prepared by Sasol, it shall be
reviewed by an independent environmental consultant with
drilling experience. It shall then be submitted to MICOA for
approval.
In the event that land spreading is considered as a means of
mud disposal, a review of the 2008 land spreading at f the Pande
well sites (excluding P-4) shall be used as a basis for evaluating
the suitability of the method, and taking lessons forward for any
proposed application of the method for the current project.
Use of oil based Prevention of In the event that a decision is taken to use oil based muds, the
soil and water method statement described above shall include specific and
4.13.5. drilling muds
pollution.
detailed reference to proven disposal techniques elsewhere,
Rehabilitation since Sasol has no experience of the disposal of these muds on
of site.
the natural gas project. The method statement shall include
evaluation of alternative methods of mud disposal, in addition to
land spreading, such as incineration and thermal desorption.
Disposal of
Prevention of Completion fluids shall be temporarily stored on the well pad in a
4.13.6. completion fluids soil and water manner which minimises the risk of pollution. A method
pollution.
statement shall be prepared indicating disposal methods, which
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Scheduling
At all times.
Performance
indicator(s)
consultation
meetings.
Casing integrity
tests
Training
Requirements
None
At all times.
Method Statement None
either developed by
independent expert
or reviewed by
independent expert
Sasol
All Drilling subcontractors
At all times
Method Statement None.
to be developed by
independent expert
Sasol
All Drilling subcontractors
During
completion
Method statement None
for the disposal of
completion fluids
Approval by the EC.
August 2014
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Page 45
Objective
Requirements/ specifications
Responsibility
must be approved by the Environmental Co-ordinator. It shall
then be submitted to MICOA for approval.
The method statement shall include the following information:
•
the types of fluids to be used and their potential
environmental impact,
•
the volumes to be generated,
•
the specifics of the environments in which the wells are
located.
•
The specifics of the environments in which the fluids will be
disposed if it is not at the well site.
•
The methodology of disposal and any appropriate mitigation
measures to avoid the environmental impacts
•
Identification of appropriate monitoring indicators and a
monitoring schedule, if relevant.
Disposal of
Prevention of Waste condensate /oil from well test operations shall preferably
be flared on site in burn pits as per design specifications
4.13.7. condensate / oil accidents.
according to international standards (see 4.17.8 below).
If the condensate /oil can be stabilised, then it can be:
(a) Transported to the CPF for disposal;
(b) Transported to where it could be used on site or disposed of
in a safe manner that will not cause environmental pollution
e.g. re-injection into the wells;
c) Given or sold to a third party to transport it from site, subject to
proof of compliance with Sasol’s requirements for responsible
transport, disposal or use of the material.
If the condensate /oil is transported off the well sites, the
appropriate procedures shall be put in place to ensure its safe
transport and disposal. A method statement shall be prepared
detailing what these procedures shall be.
Flaring of
Minimisation of Horizontal and vertical flares shall be used for the flaring of the
condensate /oil, depending on the quantities produced. The
4.13.8. Condensate /oil air pollution
and the health height of the vertical flare shall be determined by the subeffects on
contractor undertaking the flaring, the Field Superintendent and
surrounding
Environmental Co-ordinator, depending on the surrounding
communities. biophysical and social environment.
Prevention of Design of the flare pit shall be as per Appendix 2, with specific
fire.
concern for fire hazard. Any deviation from these set up
distances requires permission from the Senior Completions
Engineer and Sasol Drilling Manager.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Scheduling
Performance
Training
indicator(s)
Requirements
Submission letter to
MICOA.
Monitoring of
indicators relevant
to disposal
methodology
chosen
Sasol
All Drilling subcontractors
At all times.
Audit results.
None
Sasol
All Drilling subcontractors
During well test
operations.
Number of fires.
Response to
incidents.
Audits of set up
distances.
None
August 2014
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Spill
4.13.9. management
Page 46
Objective
Requirements/ specifications
Responsibility
All equipment on location shall be electrically grounded,
including condensate/oil transport.
Procedures shall be put in place, where necessary, to minimise
liquid carry over to the flare and to capture and liquid rain out for
later disposal.
Smoking areas may only be situated off the well pad a minimum
of 50m from condensate/oil storage areas or any fuel storage
area.
Firefighting equipment shall be positioned around the well pad.
Wind direction must be observed when flaring gas during well
tests.
Produced gas shall be flared on site in burn pits as per design
specifications in Appendix 2.
Minimisation of All spills of fuels, oils or other hazardous substances must be
Sasol
impact/
immediately cleaned up and measures taken to remediate the
All Drilling subpollution.
spill as per Section 4.9 & 10.
contractors
Vegetation
4.13.10. behind burn pit
Minimisation of An area of approximately 100m x 100m may be cleared behind
risk of fire
each burn-pit outside of the fenced area. Vegetation in these
areas should be stripped to ground level, but not uprooted, and
this shall only be undertaken with the permission of the
Environmental Co-ordinator.
All dry and dead vegetation from site clearance in the area
behind the burn pit shall be removed to prevent spontaneous
combustion.
Formation
Prevention of Drilling operations at the well sites shall be done in accordance
with recognized best international standards for the management
4.13.11. Pressure Control blow-out.
of formation pressure.
Scheduling
Immediately
following any
spill.
Performance
indicator(s)
Sasol
Before flaring
Incident and
corrective action
records.
Availability of tools
and materials.
Number of fires
Sasol
Drilling subcontractors
During drilling.
Audit results.
Training
Requirements
Training in spill
handling and
clean up.
None
None
Waste
4.13.12. management
Prevention of Specifications of Sections 4.9 and 4.10 shall apply. Waste
Sasol
soil and water lubricants, solvents, used oil filters, rig refuse, batteries, drilling All Drilling subpollution.
fluid additives and other wastes from drilling are considered to be contractors
hazardous and require disposal as per Section 4.10.
At all times.
Monitoring of
None
groundwater quality.
Re-instatement
4.13.13. of well site at
demobilisation
ReAfter drilling, all pits on-site shall be re-instated to the surface
Sasol
instatement of level with the material originally from the pit. No material shall be All Drilling subthe site
buried in the pit (such as in M-B-C for mud/cuttings disposal)
contractors
unless a method statement has been approved by the Sasol
Environmental Co-ordinator. The method statement shall explain
the material to be buried, reasons for burial, and potential
At all times.
Record of closure.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
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August 2014
None
Sasol Petroleum Temane Lda (SPT)
Ref.
Activity
Page 47
Objective
Requirements/ specifications
Responsibility
impacts on the environment and mitigation measures to reduce
any adverse impacts.
The area shall also be compacted wherever possible.
Securing of the Rehabilitation If a well is a dry hole or is not sufficiently productive, it shall be
of site.
plugged and abandoned or suspended in accordance with best
4.13.14. well sites
international practice (The NORSAC D10 Abandonment and
Suspension Procedures shall be applied).
Rehabilitation of Rehabilitation At the end of the drilling campaign the EC, Drilling Manager and
of site.
Field Superintendent shall determine which wells require re4.13.15. well site
instatement based on whether, a well is a dry hole or is not
sufficiently productive. They shall also determine which access
routes shall be re-instated. These works shall be undertaken in
accordance with the requirements for re-instatement and
rehabilitation in the c-EMP (Infrastructure).
Demobilisation / Minimisation of The EC / ESO shall sign off on each site once the site has been
impacts
adequately cleaned up. A demobilisation and close-out plan shall
4.13.16. Clean up
be written which sets out the sign off of each site, any
outstanding environmental issues / liability and how they shall be
managed. Lessons learnt shall also be recorded in this
document
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
Scheduling
Performance
indicator(s)
Training
Requirements
Sasol
Drilling subcontractors ESO
After drilling.
Record of closure
procedure.
None
Sasol
Drilling subcontractors
ESO
After drilling.
Record of closure
procedure.
None
Sasol
Drilling subcontractors
ESO
After Drilling
Record of sign off
None
August 2014
Sasol Petroleum Temane Lda (SPT)
5.
Page 48
PERFORMANCE ASSESSMENT, REVIEW & CORRECTIVE ACTION
The assessment of environmental performance has three key aims:
1. Confirmation of compliance with the EMP requirements, i.e. Sasol / drilling sub-contractors
performance;
2. Measurement of environmental performance (degree of success of the EMP and its
specifications); and
3. Identification and remediation of any deficiencies in the EMP.
This shall be achieved using three important tools: monitoring, auditing / inspections and management
review. Corrective action will be critical in ensuring that any identified problem areas are effectively
addressed. Specifications for monitoring, auditing and review are provided in the sections that follow.
Inspections and audits shall be conducted to evaluate compliance with the requirements of the EMP.
Section 5.1 defines the site inspection requirements and associated responsibilities for the drilling /
completions phase of the project. Section 5.2 defines the auditing requirements for the drilling /
completions phase of the project.
5.1.
ENVIRONMENTAL MONITORING STRATEGY
A monitoring3 strategy must be defined to ensure that the effectiveness of mitigation measures can be
tracked and corrective action identified as necessary. Note that monitoring shall be intended to evaluate
the effectiveness of environmental management, independently of whether the specifications in the EMP
have been complied with. Proper monitoring shall enable any impacts of the project on the environment
to be detected as early as possible and corrective action implemented as required.
Table 5-1 defines, in broad terms, the monitoring requirements necessary during the drilling project.
Where monitoring is specified as a requirement, the responsible party shall develop a monitoring,
measurement and reporting procedure that shall outline:
•
The monitoring objectives;
•
A detailed description of the required monitoring measures, including responsibilities,
parameters to be measured, methods to be used, sampling locations, frequency of
measurement, detection limits and the definition of thresholds that shall signal the need for
3
Monitoring is a process of surveillance, based on specified approaches and schedules, used to detect whether any changes
have occurred in the predefined, quantifiable properties of the particular environment under consideration.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Sasol Petroleum Temane Lda (SPT)
Page 49
corrective actions (see 5.4); The approach to the analysis of results and the identification of
activities and impacts requiring corrective action; and
Reporting requirements, with defined responsibilities, to ensure early detection of conditions that require
corrective action and approach to initiating corrective action.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Sasol Petroleum Temane Lda (SPT)
Page 50
TABLE 5-1.MONITORING REQUIREMENTS.
Note: it is the responsibility of the Contractor if they are having the environmental impact as determined by the Sasol Environmental co-ordinator and the Sasol Field Superintendent to ensure that adequate
monitoring is undertaken to demonstrate compliance to the requirements of the EMP. In some cases performance indicators have been indicated in the EMP standard and thus additional monitoring may be
required in addition to that presented in the table.
Parameters to be monitored
Monitoring location
Frequency of monitoring
Performance indicator /
threshold limit
Visual observation. Design
as per appropriate standard
such as City of Cape Town
Guidelines and
Specifications for Septic
Tanks*** or other
recognised standard.
Visual observation
.
Sewage effluent quality
Septic tank and
soakaway
Fortnightly or as
recommended by the ESO /
EC
Site runoff water quality
Potentially contaminated
site runoff from well pad
During and after storms
Groundwater quality
(parameters to include Monitor for
Boreholes at well pad (2)
Baseline to be obtained as
early as possible (predrilling).
Monthly sampling during
drilling, taken over after
drilling contract close out by
the monitoring requirements
of the o-EMP
Change in water quality
from monitored baseline.
At location of community
complaint or if the EC /
ESO deems it necessary
at a specific well pad
Dust monitoring shall occur
based on the following:
(a) based on complaints if
the dust suppression actions
do not resolve the
complaint.
(b) if the EC or ESO deems
it necessary based on
excessive dust.
Mozambique Decree
18/2004 Air Quality
Standards Total Suspended
Particulates:
Max. 24-hour average – 70
μg/m3
IFC, 2007, Interim Target 3
PM10 (24-hr): 75 μg/m3
South African National
Ambient Air Quality
Standard for fall out dust
physical (pH, TDS, EC, T.Alk,
Salinity)Total and Dissolved Metals
(Al, As, B, Be, Cd, Cr, Cu, Fe, Pb,
Mn, Hg, Ni, K, Se, V, Zn), Nutrients
(PO4, NO3-N, NH3-N), Major Ions
(Ca, Mg, Na, F, SO4, Cl) and
Organics (PAH including
Naphthalene, Oil and Grease,
BTEX)
Environmental dust
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Reporting
Responsibility
Report to Sasol
Environmental Coordinator
Drilling sub-contractor
Sasol
Report to Sasol
Environmental Coordinator
Report to Sasol
Environmental Coordinator
Drilling sub-contractor
Sasol
Report to Sasol
Environmental Coordinator
Drilling sub-contractor
Sasol
Camp Contractor
Drilling sub-contractor
Sasol Petroleum Temane Lda (SPT)
Page 51
Performance indicator /
Reporting
Responsibility
threshold limit
(residential areas) 600
mg/m2/day, averaged over a
measuring period of 1
month.
Noise levels**
At nearest household to Monitoring at start of drilling
The World Health
Weekly report to Sasol
Drilling sub-contractor
drilling site
to establish compliance at
Organization guidelines,
Environmental Conearest household.
adopted by the IFC/World
ordinator
Thereafter monitoring once
Bank (2007), for daytime
per week for the period of
and night-time noise levels
drilling (daytime and nightin residential areas, which
time reference periods).
are:
•
55 dBA (07:00 to 22:00)
•
45 dBA (22:00 to 07:00
** Note: Noise levels to be monitored using a calibrated integrating sound level meter in accordance with the methods specified in SANS 10103: 2008. Measurement period shall be of
sufficient length for the readings on the equivalent A-weighted setting (LAeq) to stabilize (typically 10 - 15 minutes). Readings shall be taken when the drilling rig Is fully operational. Notes
shall be taken as to the characteristics of the sound.
***Note:https://www.capetown.gov.za/en/CityHealth/Documents/Guidelines,%20Specifications/Specifications%20%20Septic%20Tanks,%20Soakaways%20and%20Conservancy%20Tanks_new.pdf
Parameters to be monitored
Final - English version Revision 12
Monitoring location
Frequency of monitoring
ONSHORE DRILLING ENVIRONMENTAL
MANAGEMENT PLAN (d-EMP)
August 2014
Sasol Petroleum Temane Lda (SPT)
5.2.
Page 52
SITE INSPECTIONS
The SHE Officer, in conjunction with the Environmental Co-ordinator / ESO where necessary, will
undertake regular inspections of all works (including Drilling sub-contractors sites and storage facilities)
and campsites so as to identify any project activities or components that are causing, or may cause, a
potential environmental impact (as per Table 5-2). The Owner’s Representative (Field Superintendent)
will also undertake regular inspections for the same purpose. Inspections will be ongoing and will form
part of the day-to-day function of the ESO or EC and Owner’s Representative (Field Superintendent).
The ESO or EC will immediately notify the Owner’s Representative (Field Superintendent) and the
SHEQ Manager of any non-conformances who will then immediately bring any identified nonconformances to the attention of the responsible party for rectification. Any problem areas will be logged
and managed as per the requirements of Section 5.3 (Corrective and Preventive Action).
5.3.
AUDITS
The main goals of an EMP audit are to evaluate compliance with stipulated EMP requirements, to identify
any non-conformance and to assess whether objectives and performance standards have been
achieved. Audits may be conducted internally or by an external auditors. An audit programme and
procedure shall be developed by Sasol to ensure that these audits are sufficiently comprehensive and
scheduled. Audits, and specifically external ones, shall be done in accordance with the Mozambican
Decree 25/2011, Regulation on the Environmental Audit Process.
Auditing must consider the results obtained from monitoring to assess whether objectives and targets
have been met, and whether there is any non-conformance with stipulated EMP and associated legal
requirements. The audit shall confirm that the EMP is effective in controlling environmental impacts. The
audit shall verify that any identified corrective action has been undertaken and assess the effectiveness
of that action.
Sasol shall develop a procedure for conducting EMP audits that shall incorporate details of:
•
The approach to the audits;
•
Scheduling of audits;
•
Reporting of results; and
Responsibilities for auditing and corrective measures.
Table 5-2 defines the minimum requirements in terms of audit types and frequency that will be
conducted during the construction phase of the project.
TABLE 5-2. MINIMUM AUDITING REQUIREMENTS FOR DRILLING PROJECT.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
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Page 53
Nature and scope of audit
Conducted by
Reported to
1. Internal EMP compliance inspection.
HS Representative
Visual Inspection of all works including drilling Sasol Environmental
sub-contractors yards, campsites, equipment Co-ordinator or ESO
etc.
•
2. Internal EMP compliance audit
An EMP compliance audit of all activities
•
HS Representative
Sasol Environmental
Co-ordinator or ESO
•
•
2. External EMP compliance audit.
Audit of all works including drilling subcontractors yards, equipment etc.
Independent consultant •
– appointed by Sasol.
•
Frequency of
audit
At each site visit.
Sasol
Environmental Coordinator.
Drilling subcontractors
Quarterly
Sasol
Environmental Coordinator.
Drilling subcontractors
Annually
Sasol
Environmental Coordinator.
MICOA.
3. Demobilisation audit.
Audit of all works, requirements, storage areas
etc. related to demobilisation by any drilling
sub-contractor.
The Sasol Environmental Co-ordinator (EC)
shall verify that the requirements of the EMP
have been met. Where not, the drilling subcontractors shall rectify the defects prior to
project completion. The Sasol Environmental
Co-ordinator (EC) shall produce a final audit
report. The report shall include:
• A defects list for rectification by the drilling
sub-contractors.
• Certification that, subject to the rectification
of the identified defects, the environmental
requirements of the EMP have been met.
• Recommendations for further auditing
following rectification of defects by the
drilling sub-contractors.
• An assessment of the effectiveness of the
EMP in managing the project impacts.
• Recommendations for any necessary postcontract maintenance and monitoring.
Sasol Environmental
Co-ordinator with the
assistance of the ESO
an environmental
consultant where
required
Sasol
Once, prior to
demobilisation by
any drilling subcontractor.
4. Government audit.
As per the requirements of Government.
MICOA.
Sasol Environmental
Co-ordinator.
Annually or as
requested by
Government.
Note: Auditing of drilling sub-contractors’ performance against the EMP will be based on the concept of ‘deemed to satisfy’. If the
drilling sub-contractor complies with the project specification then his/her/its contractual obligations will have been met. It is in the
nature of environmental auditing to be conservative. Wherever latitude exists in interpretation, the auditor will take the most
conservative (worse case) stance. Credit will only be given to the drilling sub-contractors for management actions that
demonstrably comply with the project standard.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
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Sasol Petroleum Temane Lda (SPT)
5.4.
Page 54
CORRECTIVE AND PREVENTIVE ACTION
The need for corrective action will arise from deviations from EMP requirements. In this regard, Sasol
and the drilling sub-contractors(s) shall report corrective and preventive action according to the
procedure established for the drilling campaign. The procedure includes details for:
•
Ensuring the recording of incidents/non-conformances;
•
Reporting channels for incidents/non-conformances; and
•
The identification of corrective and preventative action measures.
Corrective actions will be identified based on incidents/non-conformances reported and on the results
of EMP monitoring, EMP audits and/or management review. Corrective action should result in:
•
The implementation of a specific action to remedy the identified deficiency(ies); or
•
A change to the performance standards or objectives set in the EMP4; and
•
A documented paper trail capable of audit.
In a situation where corrective action needs to be taken for which provision is not made in the EMP, the
Environmental Co-ordinator shall recommend the necessary action to minimise the environmental
impact and shall motivate this by preparing a written report for approval by the Field Superintendent and
if necessary, the SHE Manager (depending on the scale of the non-compliance). The report shall be
filed and if necessary used as a basis for changes to the EMP.
If Government authorities consider it that drilling / completions activities are causing unacceptable
environmental damage, Sasol will immediately be consulted and shall evaluate the concerns and will
propose reasonable measures to rectify the situation, in consultation with the authorities. Such agreed
measures will be undertaken immediately to prevent further damage and to repair any damage that may
have occurred.
5.5.
REVIEWS
A detailed complaints and compliments register will be kept and regularly updated. All sources are
important and should be treated as such (formal or informal). This register will be issued by the CLO to
4
Modification to the EMP may only be made by the Sasol Environmental Co-ordinator. If the changes are major or are material
changes as defined in SPT’s agreement with the World Bank, an independent environmental specialist shall verify their
applicability. Any changes will be handled as per Section 3.2.
Final - English version Revision 12
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Sasol Petroleum Temane Lda (SPT)
Page 55
the Environmental Co-ordinator on a monthly basis and will be discussed on the Sasol Community
Liaison Meetings.
A management review meeting shall be held, as required, to review the status of EMP implementation
and to ensure the continued appropriateness and effectiveness of the EMP. The review meeting will be
attended by the SHE Officer, a member of the CLT, the Sasol Environmental Co-ordinator, the Owner’s
Representative (Field Superintendent) and Sasol Drilling Manager. The meeting shall be documented.
The management review shall:
•
Review EMP objectives and evaluate the need for new or revised objectives;
•
Set new objectives as appropriate;
•
Evaluate environmental performance and the effectiveness of the EMP by reviewing monitoring
and audit results;
•
Evaluate changing circumstances and how these may influence and be reflected in the EMP.
This could include changes to permits, contracts, loan agreements etc; and
•
Examine the results of any action items from the previous management review meeting.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
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6.
Page 56
COMPETENCY, TRAINING AND AWARENESS CREATION
Those persons who are involved in activities that could result in an environmental impact(s) must receive
appropriate awareness training. Sasol employees and drilling sub-contractors shall ensure that training
is provided such that all persons are made aware of Sasol‘s undertaking to conduct the proposed
activities in a manner that is respectful to local people, and which prevents unnecessary damage to their
land and resources and to sensitive biophysical habitats. Training will take the form of, but not be limited
to induction training, use of educational posters and daily environmental discussion topics prior to the
start of each shift.
During these training sessions, the following principles should be presented / discussed:
•
Sasol corporate environmental, health and safety policies and applicable Mozambican
environmental regulations;
•
Statement and clarification of Sasol communications policies;
•
EMP commitments;
•
Restrictions and procedures for operations, including the need to refrain from destruction of
animals and plants, indiscriminate defecation, pollution of local soil and water resources;
•
Restrictions and procedures for collection, treatment and disposal of waste and hazardous
substances;
•
Fire fighting and emergency response procedures; and
•
Procedures for incident reporting and handling.
Final - English version Revision 12
ONSHORE DRILLING ENVIRONMENTAL
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EMERGENCY PREPAREDNESS AND RESPONSE
Sasol shall establish and maintain an Emergency Response Plan (ERP) to identify the potential for, and
to respond to accidents and emergency situations, in accordance with recognised international
standards. As specified in Section 4.1.1, Sasol shall update its ERP to cover the potential risks
associated with a major oil spill. The requirements for the present project include:
•
Updating the Risk Assessment undertaken for the EIA to include detailed and well-specific
information once this becomes available during the Front End Engineering and Design;
•
Preparation of an Immediate Response Plan which includes the actions that must be taken in
the first few hours after a spill;
•
Preparation of a Well Control Contingency Plan (generic for most wells but site specific for wells IG6-PX-1 and I-G6PX-6 where a spill could impact on coastal streams, mangroves and coastal resources
in Bazaruto Archipelago National Park, an area with international conservation and tourism significance),
Provision shall be made for Tier 1 to Tier 3 response capability, which means the following:
Tier 1: response is that which is immediately available on site, geared for the most
frequently anticipated spill
Tier 2: Response is for less frequently anticipated oil spills of larger size and for which
external resources will be required to assist in monitoring and clean-up
Tier 3: response is for very rarely anticipated oil spill of major proportions and which
will possibly require national and international resources to assist in control clean up
and protection of vulnerable areas.
Actions taken after initial classification and spill response shall be in accordance with the measures set
out for the relevant tier in the Well Control Contingency Plan (WCCP).
Table 7-1 provides a breakdown of the typical content of a WCCP.
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TABLE 7-1: TYPICAL CONTENT OF A WELL CONTROL CONTINGENCY PLAN (WCCP)
Scenario
identification
Operational and
environmental
information
The plan should identify potential well control failure scenarios (e.g. Blow-out-prevention (BOP)
failure, rig fire, loss of well bore integrity) and the associated probabilities of these occurring. The
plan should also outline the implications of each scenario on the potential response options.
Operators should not eliminate loss of well control scenarios from further consideration simply
because they consider there is a very low likelihood of them occurring. For example, when
identifying blowout scenarios, the fact that a range of control measures may be put in place to
minimise the risk of a blowout does not mean that this scenario no longer requires further
preparedness and response controls that may contribute to minimising the consequence of the
event.
The purpose of this information is to inform well control options and oil spill response. This
information should include, but is not restricted to the following:
Likely reservoir characteristics: The operator should identify well and reservoir information
including information outlining a prediction of the nature of the potential hydrocarbons (gas/oil and
contaminants including maximum expected concentrations); the well flow characteristics; and the
maximum expected shut-in wellhead pressure. If there are reservoir characteristics relevant to this
information, such as High Pressure and High Temperature (HP/HT) conditions, this information
should also be included.
Analogues could be used to demonstrate an understanding of potential reservoir content. Where
there is uncertainty surrounding reservoir characteristics, operators should describe the possible
range anticipated for each characteristic, and confirm these details where relevant as they
become available after commencing drilling.
Maximum anticipated discharge flow potential: The plan shall include information on the
realistic worst-case scenario in relation to the potential release of reservoir hydrocarbons including
the potential daily release rate and the total quantity of hydrocarbons that could be released during
the maximum time that it could take to stop the release. The scenario should be directly related to
the particular circumstances of the installation, the proposed activities, and the reservoir
characteristics, and should be consistent with the information used by other operational
departments, e.g. well engineering.
For example, if the operation involves the drilling of a dry gas well, and no oil or condensate is
expected, or there is insufficient reservoir pressure for a well to flow naturally, or if the flow rate is
likely to reduce significantly during the period of any release, or if there is the likelihood that the
well will “bridge over” (i.e. seal itself with rock fragments from collapsing formations), this should
be reflected in the WCCP as it is likely this will affect the pollution response strategy and the
assessment of any potential environmental impact.
If the WCCP covers more than one well, details of each well’s flow rates should be included to
allow the plan user to gain an understanding of potential release rates in the event of a well
incident. The well with the greatest discharge flow potential should be used for modelling purposes
and to determine adequate response recourses.
The selected flow rate should be used to calculate the predicted total loss of hydrocarbons during
the period covered by the modelling, and during the estimated time taken to stop the release, and
the calculated volumes should be clearly stated.
Oil and Trajectory
modelling
Intervention
options for loss
of well control
scenarios
Environmental factors affecting the dispersion of a spill: The plan should include terrain, soil
and geohydrological conditions that will impact on well control and oil spill response operations.
Oil spill trajectory modelling must be provided to determine the impact of potential oil spills with
results giving an indication as to the likely fate (weathering and transport) of the oil. This may
include surface and subsurface plume dispersion modelling (update of the work done for the EIA)
Source control: Regardless of the spill source, the plan should consider the options available to
minimise, control or stop the continual flow of oil / gas into the environment. In the context of loss
of well control this may involve an evaluation of the relative merits of intervention such as source
capping, relief wells or any other suitable technologies as they are developed. All the available
options for reducing or containing the volume of spilt oil should be considered so as to identify
options that will reduce the consequence of the spill to the maximum extent practicable.
Description of intervention options: The WCCP shall include potential source control measures
that could be taken to prevent further release or escalation of release of hydrocarbons. This may
include measures that would be taken to stop the maximum anticipated discharge of liquid
hydrocarbons from the reservoir, and an estimate of the maximum duration of the release. This
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will normally be the time taken to implement appropriate measures to stop or control the release
(e.g. use of a capping or containment device), and the time taken to drill a relief well).
Where appropriate, details of plans to implement the capping of a well, and the drilling of a relief
well to re-establish primary well control of the original well, should be included to demonstrate that
there is adequate planning or provision in place for these eventualities.
The plan should also provide a description of how the response activities will be coordinated
between operator and well control specialists.
Relief Wells: Where drilling one or more relief wells is identified as a potential control option,
operators must provide details of their plans to initiate the management of such an operation,
including details of the operator contacts responsible for initiating the relief well plan, and contact
details of any contractor potentially involved in the operation should the need arise. Where
relevant, confirmation should be provided of any communication or contracts with third party
providers and how to proceed to access those resources. It will also be necessary to confirm that
consideration has been given to relief well design and location.
There should be a plan in place to source a drilling rig if one is required. The WCCP should
therefore include details of any drilling rig or potential sources that have been identified in the
event that the installation drilling the primary well is not available, and confirm whether a specific
type of drilling rig that would be required to drill the relief well. Again, where relevant, confirmation
should be provided of any communication or contacts with third-party providers, so that the
response personnel know how to proceed to access an appropriate drilling rig.
Responsibilities
of Parties during
a Response
Response
Equipment and
Services
Mobilization
Plans
The WCCP should also provide a clear breakdown of the indicative timetable to source a drilling
rig (including provision for suspension of any current operations), to relocate the drilling rig to the
relief well site, and to drill the relief well and kill the original well. A brief explanation outlining the
complexities and uncertainties associated with diverting a drilling rig, and the potential effects this
could have on the timetable, should also be included.
The WCCP should provide instruction on when and how the operator will seek assistance from
other stakeholders and external responders, including any dependence on the availability of
contractors and suppliers. The plan must outline the roles and responsibilities of these parties and
where they fit in the emergency response structure.
The plan should identify critical equipment and services necessary to implement any identified
intervention option. This may include, but is not limited to:
•
relief well drilling rigs
•
intervention equipment
•
survey equipment,
•
contractors and suppliers (including call out contracts)
•
transport facilities
•
multipurpose service vehicles
•
other specially equipped emergency response vehicles (eg: aircraft).
The WCCP shall include mobilisation plans for personnel, equipment, material and services
identified as required for implementation of well control procedures. Operators should consider
how they will mobilise equipment and personnel and the routes these resources will take to arrive
on site.
Mobilization timing: The WCCP shall include mobilisation plans for personnel, equipment,
material and services identified as required for implementation of well control procedures.
Operators should consider how they will mobilise equipment and personnel and the routes these
resources will take to arrive on site.
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IMPLEMENTATION SCHEDULE AND COST PROVISIONS
The requirements of this EMP shall be implemented as per the implementation schedule in section 4.
Costs associated with the implementation of the EMP will form part of the total drilling project costs as
applicable.
Drilling sub-contractors and Sasol shall make financial provision for unforeseen potential impacts that
may require specific mitigation / management measures.
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APPENDIX 1:
LIST OF RELEVANT ENVIRONMENTAL LEGISLATION
This list has been determined based on Sasol’s legal register as completed in 2005. As Regulations are
subject to revocation, change and updates, Contractors should verify this list.
Environmental
Environment Law no.20/97, BR no.40, I Serie, 3º Supplement, 07/10/97
Decree nº 18/2004, Regulation on the Environmental Quality and Effluents Release Standards, BR no.
22, I Serie, Supplement, 02/06/04
Water Law no. 16/91, BR no. 31, I Serie, 2º Supplement, 03/08/91
Legislative Diploma, 2091, General Regulation on the Supply of Water, B.O. No. 19, I Serie, 13/05/61
Law no. 10/99, Protection of Flora and Fauna Resources, BR no. 27, I Serie, 4 Supplement, 12/07/99
Resolution no. 8/93, Ratifies The Vienna Convention for the Protection of the Ozone Layer, BR no. 49,
I Serie, 2nd Supplement, 08/12/93
Convention on Biological Diversity, Rio de Janeiro, Ratified by the Government of Mozambique on
25/08/1995
Waste and Hazardous Waste
Decree-Law 48 871, Regulation for Public Civil Construction Works, BO no.12, 1972
Decree 36 270, Safety Rules for Warehousing and Industrial Treatment of Crude Oils By-products and
Residues, BO no. 8, I Serie, 09/05/47
Resolution 14/98, Bilateral Agreement on Carriage of Goods by Road Between Republic of Mozambique
and Republic of South Africa, BR no 17, I Serie, 8 Supplement, 06/05/98
Resolution no. 18/96, Ratifies the Basel Convention on the Control of Transboundary Movements of
Hazardous Wastes and Their Disposal, BR no. 47, I Serie, 28/11/96
Resolution no. 19/96, Ratifies the Convention on the Ban of the Import into Africa and the Control of
Transboundary Movements of Hazardous Wastes with Africa, (Bamako, January 1991), BR no. 47, I
Serie 5th Supplement, 28/11/96
Decree nº 13/2006: Regulations on the Management of Solid Waste
Decree nº 8/2003: Regulations on the Management of Bio-medical Waste
Ministerial Diploma nº153/2002 de 11 Setembro: Regulatins on Pesticides
Manual on the Integrated Management of Urban Solid Waste in Mozambique (Nov 2006)
Technical Directive for the Implementation and Operation of Waste Management Areas Directiva (not
approved)
Cultural and Archaeological
Law no.10/88, Legal Protection of the Cultural and Natural Heritage of Mozambique, BR no. 51, I Serie,
3rd Supplement, 22/12/88
Decree no. 27/94, Regulation of the Protection of Archaeological Heritage Property, BR no. 29, I Serie,
Supplement, 20/07/94
Resolution no. 17/82, Approves the Convention Concerning the Protection of the World Cultural and
Natural Heritage, BR no. 44, I Serie, 13/11/82
Audits
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Decree 32/2003, Regulation on the Environmental Audit Process, BR no. 34, I Serie, Supplement,
12/08/2003
Land Rights
Land Law no. 19/97, BR no. 40, I Serie, 3rd Supplement, 07/10/97
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APPENDIX 2:
SCHEMATIC DESIGN FOR FLARING IN BURN PITS AND SET-UP
DISTANCES FOR FLARING GAS AND CONDENSATE
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Condensate Burn Pit – Well sites
Pit Width: 5
m
Burner
tip
Flame
air (from
compressor)
50 m
condensate
2.7 m
1.6m
5.7
m
5.7 m
3.6 m
15 m
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