APPENDIX 2 ACG PHASE III Proposed HSE Design Standards 31648-046 ACG Phase 3 ESIA A2/1
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HEALTH Descriptions Medicals All project personnel will be medically screened prior to starting work, with particular consideration to hearing and dermatitis checks. Specific surveillance programs will be instituted for personnel potentially exposed to toxic or radioactive substances. Medical support will be provided to all project construction work sites. Hygiene Routine assessment of water quality and catering facilities will be conducted at project construction work sites in Azerbaijan. Changing, toilet and washing facilities will be provided at project construction work sites in Azerbaijan. Lunch will be provided at project construction work sites in Azerbaijan. Noise During project execution, tasks and working environments will be assessed for noise and measures put in place to ensure that levels will be kept as low as possible. The codes used are Noise & Statutory Nuisance EPA 1990 / 1995 and UK HSE Control of Noise (COP for Construction and Open Sites Orders 1984 / 1987) and Noise at Work Regulations 1989. The design will be assessed for noise and the following measures used: 85 dba (average level) exposure for a maximum of 12 hours. 45 to 60 dba inside the accommodation (depending upon location such as office or sleeping areas). Health Risk Management Workplace, environmental, and travel health hazards will be identified and risks assessed and managed. 31648-046 ACG Phase 3 ESIA A2/3
SAFETY Descriptions Training All project personnel will receive an appropriate level of safety and environmental training. A training matrix will be developed for each site and will include training to cover operation of equipment, emergency survival and fire fighting, safe chemical handling and use of MSDSs, emergency response procedures, PPE, evacuation, and applicable regulatory requirements. Project leadership will be trained in Advanced Safety Auditing and Accident and Incident investigation. Design Safety Reviews Hazard Management Plan A risk-based design approach will be adopted, supported by blast calculations, escape and evacuation assessments, fire and explosion risk analysis, HAZOPs, HAZIDs (including supplier packages), formal project safety reviews, and Temporary Refuge impairment analysis. A QRA will be carried out to confirm the Individual Risk and Temporary Refuge Impairment values achieved and to assist in demonstrating that risk has been reduced to ALARP. An overall Hazard Management Register to explain the hazards and the measures included to manage them will be prepared by the design team and approved by the Business Unit Leader. SIMOPS Simultaneous Operations (eg drilling and HUC, drilling and production, installation and production) will be assessed and procedures will be prepared to control the identified risks to an acceptable level. Manual Handling A lifting and access assessment of the design will be completed to eliminate the need for manual handling > 50 kg between two men in the operating phase. During project execution, tasks will be assessed and the need for manual handling > 50 kg between two men will be eliminated. Hazardous Substances The design will be based on eliminating the exposure of individuals to hazardous substances in the operating phase, including well work. Particular emphasis will be placed, in the design phase, on assessing and eliminating the gaseous emission of the carcinogens benzene, toluene, and xylene (BTX) in the operating phase. During project execution tasks will be assessed to ensure adequate controls are in place to minimise the impact of hazardous substances on individuals. Seismic Event The platform will be designed to withstand the 50-year return period seismic event where no loss of life, no loss of containment and little or no damage to the platform is expected. Design will be checked against the 3,000-year return period, where the platform can sustain damage but should not collapse and there should not be major health or safety consequences. Storm The off-shore design will be such that personnel can survive a 100-year storm without leaving the platform. Road Safety A Road Safety Strategy will be developed and implemented for the Project in line with the Business Unit s Road Safety Management, with the aim of eliminating or minimising transportation risks. The strategy will focus on the areas of: Safe driving procedures transportation logistics and journey planning vehicle standards and maintenance training, competence and behaviour of drivers, passengers and others road and access planning safe driving performance measures and assessment assurance that management of Road Safety is implemented and functioning as intended. 31648-046 ACG Phase 3 ESIA A2/4
ENVIRONMENT Description Applicable Guidelines Monitoring and Measurement Ozone Depleting Substances (ODS) Other Halocarbons with Potential for Global Warming Water Based Drill Fluids and Cuttings The project will be designed to comply with the relevant health, safety and environmental guidelines, standards and practices of International Finance Institutions (IFIs) and Export Credit Agencies (ECAs). The design will provide sufficient sample and measurement points to enable adequate monitoring of emissions and discharges during the operating phase. These substances will not be used. ODS are defined as those substances which are controlled by the Montreal Protocol on Substances that Deplete the Ozone Layer. Other halocarbons that do not deplete the ozone layer, but which have other environmental concerns such as a high global warming potential (GWP) will not be used unless suitable alternatives are not available. These include hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulphur hexafluoride (SF 6 ). Water based cuttings and fluids from the Top Hole (i.e. the conductor hole, nominally 36 ) will be discharged to sea in accordance with the Standards below. Note that it is not technically feasible or safe to return the fluid and cuttings from this section to the rig, and therefore in accordance with normal safe drilling practice they will continue to be discharged directly to the seabed in accordance with the PSA. Options for the management and disposal of all other water based fluid and cuttings has been subject to a Best Practicable Environmental Option (BPEO) Assessment which has concluded that discharge to sea is the BPEO. This study will not be reassessed unless there is a significant change in the assumptions made with respect to the Phase 3 project. Water-based drill cuttings and fluids shall be discharged to sea providing the following conditions are met: 1. The mud systems used are tested and meet US EPA 96 Hour LC 50 toxicity tests (i.e., > 30,000 ppm) or Caspian Specific Ecotoxicity Tests, should these be agreed; 2. Platform discharge is via a caisson that will be at a depth of at least 15m to 20m below the sea surface in all instances except where returns are directly to seabed. 3. All barite used will meet the following heavy metal criteria: Hg < 1 mg/kg and Cd < 3 mg/kg dry weight (Total). 4. Products known or suspected to cause taint, endocrine disruption or contain heavy metals as defined by UK Off-shore Chemical Notification Scheme (OCNS) will be avoided. In the event that suitable alternatives are not available, the impact of the chemical will be risk assessed and mitigation measures agreed as part of the EIA process. Land-take at Sangachal Nuisance at Sangachal Open Drains Offshore There will be no discharge of drill cuttings or fluids unless the maximum chloride concentration is less than four times the ambient concentration in the receiving water. The design of Sangachal will minimise the foot-print without compromising safety. During project execution the impact on the community of dust, noise, light, odours and general disruption will be minimised. There will be no visible sheen on the surface of the sea from deck and open drain discharges. 31648-046 ACG Phase 3 ESIA A2/5
Description Open Drains Onshore Venting Unburned Gas Clean drains will discharge to the Caspian at less than 10 mg/l monthly average and 19 mg/l on a daily basis. Any fluids discharged will be treated to ensure there is no significant or long-lasting impact on the environment. Sample points will be provided to enable verification of the above standard (ie measurement of water quality and quantity). Oily water from the contaminated open drains will be routed to the produced water disposal facility. During project execution unignited emergency venting will not take place unless it is required for safety reasons. The design will ensure that during normal operation there will be no disposal of gas by continuous venting. Chemicals The design will challenge the need for all chemical use. A management strategy will be put in place to minimise the environmental impact of chemicals through correct selection, transportation, storage, deployment and disposal. Chemicals known or suspected to cause taint, endocrine disruption or contain heavy metals as defined by UK OCNS will be avoided. In the event that suitable alternatives are not available, the impact of the chemical will be risk assessed and mitigation measures agreed as part of the EIA process. Only heavy metal-free pipe dope will be used. Chemicals will be evaluated and tested, based on the European Harmonised Off-shore Chemical Notification Format (HOCNF) and UK OCNS classification, until such time as Caspian-specific standards are agreed. No chemicals will be discharged to land or sea in the project execution phase (eg chemically treated hydrotest fluids) without complete identification and a thorough assessment of their impact. The facility design will prevent, so far as reasonably practical, the need to discharge production and utility chemicals to land or sea. Sewage Sewage from offshore will be discharge to sea following treatment using US Coastguard approved Marine Sanitation Device with an effluent of average residual chlorine concentration of 1 mg/l. Preference will be given to systems that avoid the use of chemicals. The design will ensure that there are no floating solids. Discharge will be via a caisson that is permanently submerged and at least 15 m below the surface. Desalination Waste Desalination unit waste shall be discharged via a caisson that is permanently submerged and at least 60 cm below the surface. Pipeline Construction Activities will be timed to ensure impact on the fish population and other marine life is minimised. Sand The design will enable sand and any associated liquid to be re-injected offshore. In the event that re-injection is not possible sand will be transported to shore, treated and recycled or disposed of on-shore at a location approved by the regulator. Liquid and Solid Waste There will be no discharge of solid and liquid waste to sea during project execution or operations except as provided for elsewhere in these standards. During project execution waste will be managed according to the following hierarchy: reduction at source, re-use, recovery, re-cycle and render harmless through treatment. The design will ensure waste production in the operating phase is minimised and waste can be handled safely. Wax disposal and handling Alternative methods of wax treatment and disposal will be reviewed using the BPEO process and taking into consideration BACT. An effective option will be selected so that the impact of wax waste on the environment is minimised. In the event that sulphur is recovered as a by-product in the onshore sweetening process, appropriate means of sulphur handling and disposal will be reviewed using the BPEO process and taking into consideration BACT. 31648-046 ACG Phase 3 ESIA A2/6
Description Cooling Water The effluent should result in a temperature increase of no more than 3 C at the edge of the zone where initial mixing and dilution takes place. The boundary of the zone will be defined on a case by case basis taking into account factors such as the existing ecology. Seawater Abstraction for Operations Produced Water Offshore The design will allow seawater to be abstracted during operations at depths > or = 50m. A BPEO will be conducted to determine minimization of chemicals in seawater discharged back to sea. In FFD the design will permit produced water to be re-injected. In the event of the plant being unavailable, produced water discharged to the Caspian must not exceed oil and grease concentration > 42 mg/l on a daily basis or > 29 mg/l monthly average. The design will incorporate treatment facilities to meet these discharge standards. Discharge will be via a caisson to below the productive zone (-40m Lowest Astronomical Tide). Operational procedures will be developed when the produced water facilities are installed to control the time allowed for overboard discharge. Decommissioning Design will ensure that the facilities can be safely decommissioned in compliance with OSPAR and IMO regulations, without long-term impact on the environment. Fugitive Emissions Storage Tanks Fugitive Emissions Compressors, Valves, Seals, Flanges Combustion Emissions Produced Water Onshore Routine Flaring Onshore Fugitive emissions from the Sangachal oil storage tanks will be controlled using external floating roof technology with primary, secondary rim seals and low-loss fittings. The aim will be to minimise fugitive emissions throughout the design process by measures including: Component evaluation and selection. Material evaluation and selection. Best Available Control Technology (BACT) PSA. The design will be based on minimising combustion emissions (eg SOx, NOx, CO 2, CO and particulates). Options for minimizing combustion emissions will be assessed to determine Best Available Control Technology as required by the PSA. Dry low emission technology will be adopted onshore. Re-injection of on-shore produced water from Sangachal Terminal is the Base Case but final disposal route will be subject to BPEO and BACT assessment. The design implications and options for the disposal of onshore produced water during non-availability of the PW re-injection system will be reviewed using the BPEO process and taking into consideration BACT consistent with the PSA. The flare will be designed to allow for continuous flaring and emergency relief. Any flaring will be smokeless under normal operations. Flare gas metering will be installed. The design will minimise flaring from pilots without compromising safety. This will include installation of inert gas purge and conservation pilots. Flare gas recovery will be installed. Operational flare policy for Phase III will be developed in conjunction with Phase I and II. The policy will address the potential need to flare sour gas. The design eliminates all routine non-emergency flaring, with the exception of pilots, without compromising safety. 31648-046 ACG Phase 3 ESIA A2/7
Description Routine Flaring Offshore The flare will be designed to allow for continuous flaring and emergency relief. Any flaring will be smokeless under normal operations. Flare gas metering will be installed. Flare will be designed for >98% combustion efficiency. The design will minimise flaring from purges and pilots without compromising safety. This will include installation of purge gas reduction devices and conservation pilots, or alternative if BACT and BPEO. Source gas reduction measures will be implemented. Options to address reduction in offshore flaring and combustion emissions will be evaluated. Operational flare policy for Phase III will be developed in conjunction with Phase I and II. Well Testing Well testing, resulting in emissions, will be by exception and strongly challenged. If testing is justified, then all best available techniques will be utilised to minimise emissions to air, land and sea. Energy Efficiency The Phase III design will be based on maximising energy efficiency in line with BPEO. Non-water-based Drill Fluids and Cuttings For platform drilling the base case is cuttings re-injection with a contingency option of shipment to shore and treatment or disposal on-shore at an approved location. For drilling from a mobile offshore drilling unit the base case is shipment to shore and treatment or disposal on-shore at an approved location. There will be no discharge of oil-based or synthetic-based drilling fluids or cuttings from the Phase 3 drilling programme. Should drilling fluids be developed that meet international and Caspian acceptability criteria for discharge then they will be evaluated and the option to use and discharge considered. An operating policy will be developed to address the actions to be taken in the event of down-time of cuttings re-injection equipment. All barite used will meet the following heavy metal criteria: Hg < 1 mg/kg and Cd < 3 mg/kg dry weight (total). Products known or suspected to cause taint, endocrine disruption or contain heavy metals as defined by UK OCNS will be avoided. In the event that suitable alternatives are not available, the impact of the chemical will be risk assessed and mitigation measures agreed prior to use. The system will be designed to prevent mud loss on cuttings so far as technologically practical and economically justifiable. 31648-046 ACG Phase 3 ESIA A2/8