h, GPCIC ENVIRONMENTAL SITE ASSESSMENT (PHASE 1) OF OIL FIELD BLOCKS 1,2 4 GREATER UNITY STATES, SOUTH SUDAN Prepared For: Consultant: .9 - 6/ mcnvuroCore GREATER OPERATING COMPANY "You Need It, Environment Needs You, You Need Us" GPOC Tower,Plot No Block 20 VII city centre Iuba,Repuinc of South Sudal Envirocare and waste Management Engineering Gudele road, St Kizito. tha South sudan Tel. +211 911722224, +211 922666899 E-mail: envirocarea@qmail.com Website: 2018 Environmental Site Assessment for oil fields – Block 1,2 & 4 Executive Summary Blocks 1,2 and 4 are located in Greater Unity States about 20 km from Bentiu . The geographic coordinates are 90,28’39.37N, and 29040’28.67E. To ensure sustainable production levels, GPOC intends to review the integrity of Block 1,2 and 4 and carrying out a workover of the oil field. Since Block 1,2 and 4 was operated before south Sudan Petroleum Act 2012, was enacted, and thus no Environmental Impact Assessment (EIA) was conducted, GPOC was directed by the Authority to conduct an Environmental Site Assessment. GPOC commissioned EnviroCare and Waste Management Engineering Ltd of Juba to carry out the Environmental Site Assessment. This Environmental Site Assessment report describes activities undertaken in May-June 2018. To determine how far a project conforms to approved Environmental and Social management Plan (ESMP) and environmental management practices and quality standards; To provide a mechanism to Project Proponent (GPOC) to learn from experience and to refine design and implementation procedure so as to mitigate adverse impacts (now and in the future); To provide regulatory bodies with a framework for checking compliance with and performance of an ESMP. The Environmental Site Assessment was planned and executed in accordance with the requirements of the relevant international standard (Guidelines for Quality and/or Environmental Management Systems Auditing, ISO 19011:2002). 9 days in total were spent at Blocks 1,2 and 4 to complete the following tasks: Site Inspections; community meetings; Meetings with GPOC staff; and Document Review. The principal approach adopted for the ESA was assessment of the project compliance to the requirements by national and international standards and agreements. The exercise followed general EA Protocols, which covered the environmental and occupational health and safety requirements of the assessed facilities; Adherence to company policies and procedures on environmental matters; applicable legislation and regulations; environmental and social impact management plans; environmental and social monitoring plans; and Application of best environmental practices. The tasks that were carried out can be summarized as follows: Development of stakeholder engagement plan, preparation of audit tools to guide onsite assessment; Onsite assessment which looked at Project’s current status information; Implementation of mitigation measures and controls; Conditions / status of relevant environmental and social receptors at the project site (as measure of mitigation effectiveness); and Evidence to verify the self-assessment responses. Different stakeholders were consulted to give their general views on the environmental and social performance and any grievances in general and Block 1, 2 and 4 in particular. Page ii Environmental Site Assessment for oil fields – Block 1,2 & 4 Findings i. Blocks 1,2 and 4 was operated before Environment regulations Bill,2012 and Petroleum Act 2012 were enacted, and the consultant assumed that EIA was not done as no EIA report could be located at GPOC, Ministry of Petroleum or Ministry of Environment and Forestry. ii. Although there was no EIA, consultations with stakeholders revealed that there were negligible environmental and social incidences. iii. Due to the insecurity in December 2013 the oil fields were shut down and there has not been production since this assessment iv. GPOC has in place necessary policies, plans that are necessary to manage potential environmental and social aspects. GPOC complies with legal requirements. This was verified by reviewing annual certificates issued by different authorities at different stages of operation. Key stakeholders were regularly consulted according to their mandates. v. The ESA found out that GPOC has an elaborate organisational structure to manage environmental and social issues. vi. GPOC has a system of inducting all workers and visitors, and it has a system of informing communities on planned activities. vii. Since the EIA was not done the consultant could not establish the extent of funding that was committed to implement environmental management activities. Nevertheless, the assessment could not verify whether there was funding of third party to implement some aspects of ESMP. This was attributed to lack of information on what activities can be funded by the money allocated in the ESMP. This conclusion is based on the fact that the responsible officers did not visit Block 1, 2 and 4 because of lack of funds, while there was no request of fund sent to GPOC for the purpose. viii. Based on the current practices, the Consultant assumed that there was mitigation measure that enabled oil operations without having a major accident. It is therefore assumed that there was regular maintenance was done during shutdown ix. The ESA established that there was lack of proper storage of hazmats. x. Scrap metals were identified at base camp and not transported to Juba for recycling. xi. At the time of the assessment the drill rig was no longer in place, as such the Consultant assumed that there were mitigation measures to control occurrence of fire and explosion. This is based on the fact that no fire or explosion incident was reported. xii. GPOC has a system of protecting workers against occupational and health hazards. xiii. The assessment established that regular information to other resource users was regularly offered. xiv. Furthermore GPOC has a policy of giving employment priority to residents; however, there are no people with requisite skills. xv. Workover environmental impacts are similar to those encountered during drilling operation and hence similar mitigation measures can be used to mitigate the potential impacts. xvi. There were hydrocarbon release in the FPFs, wells, pipes caused by unknown people who disconnected valves and gunshots observed at pipe and tank installations hence oil spillages. xvii. There was corrosion of pipe facilities which led to wear and tear due to lack of maintenance Page iii Environmental Site Assessment for oil fields – Block 1,2 & 4 xviii. xix. Due to insecurity military camp moved closer to oilfields with their families No environmental audits carried out on facilities in the oil field The environmental site assessment has identified following strengths i. GPOC has an elaborate institutional set up to manage environmental and social impacts ii. Health, Safety Environment and (HSE) Manager is responsible for implementation of Environmental and Social management issues iii. Where there were hydrocarbon release some mitigation measures were applied iv. GPOC has Community Development manager who is stationed in Juba v. GPOC sets aside adequate resources to manage environment and social aspects vi. Fireline construction of GPOC fields vii. Security assurance and assessment by GPOC viii. Preparations for second production resumption ix. Hydrocarbon release cleaning at GPOC fields x. GPOC has requisite experience to manage drilling and workover operations xi. An oil spill contingency plan is place xii. GPOC Mitigation team was formed to respond to any emergency spills at any time. The study also identified following recommendations for past and on-going concerns of project stakeholders; i) ii) iii) iv) v) vi) vii) viii) ix) x) xi) xii) Thorough cleanup campaign in their entire oil facilities compound and conduct second phase of ESA and EIAs GPOC,MOE,MOP should collaborate and provide safe drinking water to populations around the oil fields Provision of medical facilities, health centers and train the population importance of first Aid Govt together with others should join hands and construct better roads to facilitate the movement of the people as well as their staff Search for new locations and relocate military camp and communities residing around the oil field facilities GPOC to conduct environmental awareness to the communities around oil field to enable them keep environment clean and safe. Provision of basic needs to oil-production communities to improve their livelihoods Conduct trainings in solid waste management and risk management to the population around oil fields. Recycling of waste materials eg scrap materials Feasibility study on types of legacy wastes, chemicals at the yard for proper storage and deposition. Carrying out EIAs/Environmental Audits for new oil wells and existing wells Perceived threat of oil operations on water sources Page iv Environmental Site Assessment for oil ?elds - Block 1,2 4 Perceived threat on wellbeing of residents from oil operations by carrying out scientific research to correlate illnesses xiv) Lack of clear grievance handling mechanisms xv) Awareness raising of Villagers on xvi) Awareness raising of Villagers on emergency preparedness and response xvii) Carrying out a decommissioning plan Recommended actions Based on the above weaknesses remedial measures were recommended. Idiom Inadequate documentation on implementation of ESMP Weekly reports on the implementation of ESMP should be instituted Inadequate disclosure of ESMP stakeholders to key All key stakeholder shodd be given at least an Executive Summary and ESMP Lack of docunentation at the site to ascertain that monitoring of environmental aspects (air emission, vibration, noise etc.) by the Drilling Contractor was done during this environmental assessment. New contracts should require contractors to keep monitoring records of environmental parameters as contained in ESMP and submit reports to GPOC on weekly basis Inadequate knowledge on roles and responsibilities of different stakeholders Training and awareness raising should be mounted to ensure all key stakeholders are aware of their roles and responsibilities Lack of grievance mechanism Grievance mechanism should be developed and disseminated for use Weak coordination at national and lower levels A coordination mechanism at national and local level should be developed Lack of skills of some national/state of?cers needed to provide the needed oversight to implement ESMP Provide requisite training to different target groups Air pollution water pollution at waste treatment facility New contracts should require contractors to keep monitoring records of environmental parameters as contained in ESMP and submit reports to GPOC on weekly basis Inadequate guidance of project proponent on the implementation of ESMP Modify new ESMP Lack of capacity of local people to meaningfully engage in oil and gas business Develop and implement plan to build local capacity to enable them engage in oil and gas sector meaningfully Military camp established near oil?elds with their families due to insecu'ity Relocation of military camp including families near the oil ?elds The impacts and mitigation measure associated with workover operation for oil resumption are as shown in the table below: inmost ?who Pig-awn Degadation of soil and 0 surface waters; disruption Implement the Waste Management Plans to minimise the chance of accidentally losing items on the surface GPOC Page Environmentd Site Assessment for oil ?elds - Block 1,2 4 Inlet ?ee-n of terrestrial ?ora and fauna due to operational discharges 0 Compliance with International prohibitions on dumping trash and debris on the land. Deg'adation of soil and surface waters; disruption of terrestrial ?ora and fauna due to operational discharges Black Water and Food Waste 0 Black Water: Use of septic tanks and soak away pits 0 Use hired services to handle all organic waste Degadation of soil and surface waters; disruption of terrestrial ?ora and fauna due to operational discharges Drainage Water 0 The workover rig will treat wastewater in accordance with international requirements (15 oil and grease as a maximum limit) Degadation of soil and Produced Water surface waters; disruption 0 Follow IFC Guidelines (29 mg/l maximum 30 day average and 42 mg/l maximum oil of terrestrial ?ora and content fauna due to operational discharges Degadation of soil and Workover Fluids surface waters; disruption of terrestrial ?ora and fauna due to operational discharges 0 Where possible collect used ?uids into a closed system and inject ?uids the formation, or transport used ?uids to the original vendors for recycling or treatment and disposal. 0 Follow IFC Guidelines. Maximum one day oil and grease content of 42 mg/l. and average less than 29 mg/ I. 0 Any acidic workover ?uids used that require discharge will be neutralised by mixing in soda ash, or similar, to attain a pH of 5 to 7 before disposal. The project will only use low toxicity, readily biodegradable and non- bioaccumulative chemical systems, where commercially available, according to the international standards. Chemical selection will bejusti?ed against auditable criteria. Degadation of soil and surface waters; disruption of terrestrial ?ora and fauna due to operational discharges Pro-commissiorl'ng Pressure Testing Fluids 0 Minimise volume by testing equipment prior to importing Preferential use of low toxicity and readily biodegradable chemicals. 0 Ensure correct chemical dilution in the testing ?uids. 0 Pre-comm issioning ?uid dsposal procedures will be developed to control the rate of discharge, chemical use and dispersions. Dispersion will be improved by optimising discharge rate and pressure at the release point. Degadation of soil and surface waters; disruption of terrestrial ?ora and fauna due to operational Chemicd and Fuels Storage 0 Chemicals and Fuels will be stored as explained in text A'r Quality Mitigation for Combution Sources discharges Mitigation measures listed will be used It Elicia- Deg'adation of air quality In addition to the mitigation measure in Table following mitigation measures will be due to atmospheric pollutant emissions and greenhouse gasses. implemented: 0 Compliance with international limits on and N0x, no deliberate emissions of ozone- depleting substances and no incineration of certain products (eg. plastics). - Follow IFC Guidelines for management of small combustion sources, including exhaust emissions using liquid fuels and gas-?red tu'bines. - Use of low-sulphur diesel fuel if it is available locally. 0 Programme of leak detection and repairs to reduce fugitive emissions. 0 Reduce VOC emissions from hydrocarbon and chemical storage and transfer activities through equipment selection and fuelling activities. Waste Management Storage, Segregation and Transport of Waste Use Waste Management Plan (WMP) and manage through project .9 Page vi Environmentd Site Assessment for oil ?elds - Block 1,2 4 Inlet ?who 0 Reduce waste generation and maximise reuse and recycling. Waste identification and classification. Waste collection, storage and segregation 0 Use of speci?ed waste transport containers only All wastes to be transported in a safe manner, in accordance with Material Safety Data Sheet information and via well maintained, legally compliant and suitable vehicles or with appropriate documentation and d'iven by fully trained operators. Waste to be transported by relevant Authority approved waste contractors only. Impacts from oil spills on 01 Sp'll Prevention Measures vulnerable components of To minimise the risk of potential spills following mitigation measures will be implemented: the ecosystem onshore Blow-Out Preventers (BOPs) permanently installed on the oil wells during well environments crops completions and the use of a double mechanical barrier system during production and animals, birds and other injection operations using the Christmas trees and other barriers. livelihoods dependent on A system of wells, flowlines designed to international process codes and with alarm and ecosystem. shutdown systems to maintain the system within its design criteria at all times. The system will be tested, inspected and maintained to ensure performance standards are met. 0 The drainage system will be designed to contain spills (as well as leaks and contaminated wash-down water) Impacts from oil spills on Spill Response Measu'es vulnerable components of ?An Oil Spill Contingency Plan (OSCP) will be used. the ecosystem environments crops animals, birds and other livelihoods dependent on ecosystem. As covered in Table 10 I Conclusion The Environment Site Assessment report has outlined the environmental management structure at Block 1,2 and 4, its operations, its mitigation measures and has assessed the status of compliance with environmental regulations. Review was based on documentary evidence and physical verifications. Furthermore, the impacts of workover of the oil fields facilities for resumtion have been identified and the mitigation measures have been proposed. It is the opinion of Envirocare waste management and engineering that the operations of Block 1,2 and 4 are guided by the ESPM as recommended in the report. El '0 0 Page vii Environmental Site Assessment for oil ?elds - Block 1,2 4 Names Of Consultants SN "Imam Position/Madman Sm 1. Anthony Oryada Lead Consultant and Environmental Assessor 2. Richard Okello Taban Environmental Management and Planning 3. John Waran Geologist 4 Duku Michael Wani Chemical Engineer 5 Akena David Clement Socio -Economist Page Environmental Site Assessment for oil fields – Block 1,2 & 4 Table of Contents Page Executive Summary .......................................................................................................................................... ii Table of Contents List of Tables .. ............................................................................................................................. ix ..................................................................................................................................... xii List of Figures ................................................................................................................................................. xii Abbreviations and Acronyms ......................................................................................................................... xiii Acknowledgement ......................................................................................................................................... xv 1.0BACKGROUND OF THE STUDY ...................................................................................................................... 1 1.1. INTRODUCTION ............................................................................................................................... 1 1.2. RATIONALE FOR CARRYING OUT AN OIL FIELD WORKOVER .............................................................. 2 1.3. REPORT STRUCTURE ........................................................................................................................ 3 2.0 PROJECT’S CURRENT STATUS INFORMATION............................................................................................... 4 2.1. SCOPE OF THE DRILLING AND OPERATION OF BLOCK 1, 2 AND 4............................................................ 4 2.2. PROJECT CURRENT STATUS ................................................................................................................... 9 2.3. PROJECT BOUNDARIES ........................................................................................................................ 19 2.3.1. Core Area .............................................................................................................................. 20 2.3.2. Area of Influence ................................................................................................................... 20 2.3.3. Area in Vicinity of Project Site................................................................................................ 20 2.3. TYPE OF ACTIVITIES ASSESSED ............................................................................................................. 28 3.0 ENVIRONMENTAL ASSESSMENT OBJECTIVES AND SCOPE .......................................................................... 30 3.1. ASSESSMENT OBJECTIVES .................................................................................................................... 30 3.2. SCOPE OF THE ESA .............................................................................................................................. 30 4.0 ESA APPROACH, PROTOCOL, CRITERIA AND METHODOLOGY..................................................................... 32 4.1. APPROACH .......................................................................................................................................... 32 4.2. ESA PROTOCOL ................................................................................................................................... 32 4.3. ESA CRITERIA ................................................................................................................................. 33 4.4. ESA METHODOLOGY ...................................................................................................................... 33 4.4.1. 4.3. OIL WELL WORK OVER IMPACT ASSESSMENT METHODOLOGY ....................................................... 37 4.3.1. General ................................................................................................................................. 37 4.3.2. Impact Identification and Evaluation...................................................................................... 37 4.3.3. Mitigation measures and management controls .................................................................... 39 4.4. 5. Tasks for Carrying Out The ESA .............................................................................................. 33 POST OIL WELL WORKOVER ACTIVITIES .......................................................................................... 39 FINDINGS AND OBSERVATIONS ............................................................................................................. 40 Page ix Environmental Site Assessment for oil fields – Block 1,2 & 4 GENERAL ................................................................................................................................................... 40 Conformity of Components and Contents of the ESMP to Standards ...................................................... 40 HISTORICAL RESEARCH............................................................................................................................... 40 5.1 COMPLIANCE TO LAWS AND REGULATORY FRAMEWORK ..................................................................... 40 Relevant Policies ................................................................................................................................... 40 5.1.2. Relevant Acts ........................................................................................................................ 41 5.1.3. Relevant National Strategies .................................................................................................. 44 5.1.4. Compliance to Policies and Legal Regime ............................................................................... 46 5.2. EFFICACY AND ADEQUACY OF MITIGATION CONTROLS, MEASURES AND PROCEDURES .................. 50 5.2.1. 5.3. 6. 7. PAST AND ONGOING CONCERNS OF PROJECT STAKEHOLDERS ....................................................... 55 5.3.1. Support to Community Development Projects during shutdown ........................................... 55 5.3.2. Support to improvement of community livelihoods ............................................................... 56 5.3.3. Environmental Conservation ................................................................................................. 56 5.3.4. Employment Opportunities ................................................................................................... 57 5.3.5. Workers’ Health .................................................................................................................... 57 5.3.6. Local Governance Structure ................................................................................................... 58 5.3.7. Disruption of community livelihood concerned ...................................................................... 58 5.3.8. Emergence Response mechanism .......................................................................................... 58 WORKOVER FOR OIL RESUMPTION ........................................................................................................ 59 6.1. Introduction .................................................................................................................................. 59 6.2. Major Environmental Impacts ........................................................................................................ 59 EMERGING KEY ISSUES – STRENGTHS AND WEAKNESSES (ESMP) ........................................................... 61 7.1. ESMP EFFECTIVENESS .................................................................................................................... 61 7.1.1. Compliance to Policies, Laws and Regulatory Requirements ................................................... 61 7.1.2. Past and On-Going Concerns of Project Stakeholders ............................................................. 61 7.1.3. Mitigation Measures and Management Practices................................................................... 61 7.1.4. Monitoring and Reporting Programme .................................................................................. 62 7.2. 8. Introduction .......................................................................................................................... 50 INSTITUTIONAL CAPACITY .............................................................................................................. 62 7.2.1. Company ............................................................................................................................... 62 7.2.2. Enablers ................................................................................................................................ 62 RECOMMENDED ACTIONS ..................................................................................................................... 64 8.1. INSITUTIONAL CAPACITY AND NEEDS TO IMPLEMENT ESMP .......................................................... 64 8.1.1. Institutional Development Plan ............................................................................................. 67 8.1.2. Training ................................................................................................................................. 69 8.1.3. Retooling and Technical Assistance ........................................................................................ 70 Page x Environmental Site Assessment for oil fields – Block 1,2 & 4 8.1.4. Budgets and Expenditures ..................................................................................................... 71 8.2. UPDATED ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN ..................................................... 71 8.3. UPDATED ENVIRONMENTAL AND SOCIAL MONITORING PLAN ....................................................... 93 9. COST AND BENEFIT ANALYSIS ................................................................................................................... 103 9.1. COSTS .......................................................................................................................................... 103 9.2. BENEFITS ..................................................................................................................................... 103 9.3 QUANTIFIABLE AND NON-QUANTIFIABLE BENEFITS TO COMMUNITIES ....................................... 103 9.4. POSSIBLE COSTS TO COMMUNITIES ............................................................................................. 103 9.5. POSSIBLE COSTS TO GOVERNMENT .............................................................................................. 103 9.6. ENVIRONMENTAL COSTS AND BENEFITS ANALYSIS ....................................................................... 104 9.7. SOCIO-ECONOMIC COSTS AND BENEFITS ANALYSIS ...................................................................... 104 10. 9. DECOMMISSIONING PLAN ............................................................................................................... 106 SUMMARY AND CONCLUSION ............................................................................................................. 109 9.1. HISTORICAL RESEARCH ................................................................................................................................ 109 9.2. COMPLIANCE TO LAWS AND REGULATORY FRAMEWORK ............................................................................. 109 9.3. EFFICACY AND ADEQUACY OF MITIGATION MEASURE CONTROLS AND PROCEDURES.................................... 109 9.4. RECOMMENDATIONS FOR PAST AND ON-GOING CONCERNS OF PROJECT STAKEHOLDERS ............................ 109 REFERENCES ................................................................................................................................................. 111 10. APPENDICES .................................................................................................................................... 112 Page xi Environmental Site Assessment for oil fields – Block 1,2 & 4 List of Tables Pages Table1: Kill Fluid Table 2: Audit protocol Table 3: Matrix of impact identification Table 4: Compliance matrix Table 5: Potential environment and social impacts Table 6: Potential hazards Table 7: Roles and responsibilities of institution capacity Table 8: SWOT Analysis as related to institutional capacity Table 9: Overall action plan Table 10: Environmental and social management plan Table 11: Mitigation of workover impacts Table 12: Updated environmental and social monitoring plan Table 13: Risk Control plan 8 32 37 47 51 59 64 67 68 72 90 93 105 List of Figures Figure 1: Block 1,2 and 4 Figure 2: Showing oil fields in south Sudan Figure 3: Standard onshore drilling rig Figure 4: GPOC Field layout Figure 5: Typical workover rig Figure 6: Showing road network of oil field Figure 7: Detailed description of well head Figure 8: Combination of significance grades 4 5 5 6 8 9 31 38 List of Plates Plate 1: Power plant facilities destroyed Plate 2: Base camp facilities destroyed Plate 3: Pump station facilities Plate 4: Evaporation ponds status Plate 5: Bioremediation ponds have dried up Plate 6: Corroded and rusty pipelines Plate 7: Chemical storage area with scattered chemical/wastes Plate 8: Mud pit areas have dried up Plate 9: The Airstrip in the oil field Plate 10: Vegetation within project area Plate 11: Black cotton soils and cracks formed Plate 12: Biodiversity including Birds in the area Plate 13: Damaged security light in the area Plate 14: Water sources in the project area Plate 15: Oil spills from pipelines and facilities Plate 16: Christmas tree on Block 1 wellhead Plate 17: Community stakeholders meeting in Pariang 11 12 12 14 15 15 16 17 17 21 22 23 26 27 28 31 55 Page xii Environmental Site Assessment for oil fields – Block 1,2 & 4 Abbreviations and Acronyms AIDS ASL BOD BOP BoQ CBO CDCA CH4 CITES CO2 CPA CSR dB Deg C (or °C) EIA EIS ESIA ESMP GHG GPOC HIV hp HSE HSEMS IMS IUCN KCl kg km LAOs LPs Ltd m 2 m 3 m mm mmscfd MOEF MOP NaCl NGO NOx NPS OBM OGP OH&S OSCP OSHA Acquired Immunodeficiency Syndrome Above Sea Level Biochemical Oxygen Demand Blow-out preventer Bill of Quantity Community-Based Organization Community Development Corporate Affairs Methane Convention on International Trade in Endangered Species Carbon Dioxide Comprehensive Peace Agreement Corporate Social Responsibility Decibel Degrees Celsius Environmental Impact Assessment Environmental Impact Statement Environmental and Social Impacts Assessment Environmental and Social Management Plan Greenhouse Gases Greater Pioneer Operating Company Human Immunodeficiency Virus Horse power Health, Safety and Environment Health, Safety and Environment Management Systems Integrated Management System International Union for Conservation of Nature Potassium Chloride Kilogramme Kilometre Linear alpha Olefins Linear Paraffin Limited Meter Square meters Meter Cubic millimetre Million standard cubic feet per day Ministry of Environment and Forestry Ministry of Petroleum Sodium Chloride Non-Governmental Organisation Nitrogen Oxides Nominal Pipe Size Oil Based Mud The International Association of Oil & Gas producers Occupational Health and safety Oil Spill Contingency Plan Occupational Health and Safety Authority Page xiii Environmental Site Assessment for oil fields – Block 1,2 & 4 PAOs PAPs PEA PLONOR PM PPEs PSA RAMSAR RO ROSS RoW SBF SO2 SPLA SPLM STIs SSBS SSDP ToR TSS WBM WWF Poly alpha olefins Project Affected People Preliminary Environmental Assessment Pose Little or No Risk Particulate matters Personal Protective Equipment Production Sharing Agreement Wetland of International Importance (from Ramsar Convention, Iran, 1971) Reverse Osmosis Republic of south Sudan Right of Way Synthetic based (drilling) fluids Sulphur Dioxide South Sudan Peoples Liberation Army Sudan Peoples Liberation Movement Sexually Transmitted Infections South Sudan Bureau of Standards South Sudan Development Plan Terms of Reference Total Suspended Solids Water-based drilling mud World Wide Fund for Nature Page xiv Environmental Site Assessment for oil fields – Block 1,2 & 4 Acknowledgement The successful preparation of this Environmental Site Assessment(phase 1) of blocks 1 ,2 and 4 would not have been possible without full participation, commitment and hard work of various stakeholders. At the outset, I am grateful to the ,deputy Governor and Executive Directors and state Officers of greater Unity states for sharing their technical inputs, views, providing data on biophysical and socioeconomic of the state and for their availability in all public meetings. I wish to thank Ministries and Government Departments which were involved during this study for sharing their views especially with regard to key environmental issues associated with the block 1 2 and 4 operation. These include NilePet, Ministry of Petroleum and Ministry of Environment and Forestry, south Sudan I wish to thank all state Authorities particularly the community leadership of Budang Rubkona Bentiu ,Parieng for availing themselves for consultations and for organising stakeholders meetings. I am particularly indebted to the team of consultants from EnviroCare and waste management engineering Ltd of Juba for guiding and facilitating the exercise of carrying out this study. Lastly, but not least, I would like to express my sincere gratitude to the Ministry of Petroleum for their technical inputs, cooperation and guidance during the whole period of undertaking this ESA. Mr Guo Xinwen President GPOC Page xv Environmental Site Assessment for oil fields – Block 1,2 & 4 1.0BACKGROUND OF THE STUDY 1.1. INTRODUCTION Resumption of oil production at South Sudan's Unity oilfield moved a step closer in May 2018. The Minister of Petroleum of South Sudan met with Petronas representatives in Kuala Lumpur and secured a commitment from the Malaysian national oil company to invest in resuming operations in the area. Resumption of oil activities in Blocks 1,2 and 4 is legally based on addendum to original EPSA and Transitional Agreement ie related to additional time period for 7 years following the expiration of EPSA. Bringing back production at Unity and other fields, and increasing production overall, are the priorities of the ministry of Petroleum and the Transitional Government of National Unity. GPOC was established on 12th April 2012. It used to produce 65,000 barrels per a day at that time when it was in full capacity .The Unity field, among other fields in South Sudan, has been shut down due to conflict since December 2013. It is situated in Block 1A and operated by the Greater Pioneer Operating Company (GPOC), a consortium of CNPC (40 %), Petronas (30 %), ONGC (25 %) and national oil company Nilepet (5 %). GPOC contracted a third party security assessment contractor as per partners request with final recommendations on stability of Oil fields. In February, the government declared that the areas are now safe for the operators to re-enter. It was requirement to carry out an ESA for resumption of oil production. Block 1 ,2 and 4 are located in greater unity states approximately 1029.8 km north of Juba by road, GPOC intends to review the integrity of blocks 1,2 and 4 by carrying out a workover for resumption of oil production. The south Sudan Environmental Regulation Bill (2012), Part II Section (18), states that “The Authority shall require the proponent or a developer to undertake in the case of an on-going project - (a) an initial environmental audit followed by subsequent environmental control audit studies as may be necessary at such times as shall be agreed upon by the authority and the proponent; and (b) an initial environmental audit to provide baseline information upon which subsequent environmental control audit studies shall be based”. Since blocks 1 ,2 and 4 was operated before the Petroleum Act, 2012 and environmental regulations bill were passed, no EIA was conducted as such GPOC was directed by relevant Authority to conduct an environmental site assessment. GPOC commissioned EnviroCare and waste management Engineering Ltd of Juba to carry out the assessment.This ESA report described activities undertaken between May 2018 and June 2018 The ESA was planned and executed in accordance with the requirements of the relevant international standard (Guidelines for Quality and/or Environmental Management Systems Auditing, ISO 19011:2002). 9 days in total were spent at oil fields to complete the following tasks: Page 1 Environmental Site Assessment for oil fields – Block 1,2 & 4                Provide assessment on the current status of environment at the oilfields. Detailed review of existing environment protection measures at the oilfields. Identify current and historical sources of damage or contamination (actual and potential). Risk assessment on the potential environmental risk of main facilities in the oilfields. Provision of information on Socio-Economic Environment including Population, Land Use (Nomadic Pastoralism, Crop Cultivation), the Social Organization of Production, Industry and Sources of Energy, Transportation in the Block 1, 2 and 4. Program for consultation with leaders of local communities which will be accompanied by GPOC, MOP representatives and other stakeholders. Site Inspection: A brief orientation tour of the facility, followed by detailed inspections of areas of interest including: Power Plant, Pump Station (PS), FSP/FPF Base Camp, Pipelines, Bulk storage, Evaporation Ponds, Bio-remediation Pond, Drilling mud pits, Hazardous Wastes/Chemical Storage Area, Well Pads area and airstrip • Interviews: Meetings with GPOC senior management, HSE Department personnel and selected other staff and contractors). • Document Review: Many documents were reviewed on-site and others were scrutinized after the site audit. These included HSE plans and procedures, monitoring data and various environmental records. Since there was no EIA conducted prior to production of oil fields in Block 1 2 and 4, this assessment is structured to provide guidance on policies and laws governing the operation, baseline information which may be used in future to gauge the environmental performance of the operation of the oil field as well as work over activities. 1.2. RATIONALE FOR CARRYING OUT AN OIL FIELD WORKOVER Given the fact that some of the oil field operations have been suspended because of serious insecurity issues in greater Unity state since December 2013 and the corrosion of some pipes it is necessary that an oil field workover is carried out to ensure integrity of the oil fields by routine maintenance such as replacing worn or malfunctioning equipment,instead of waiting for the moment when the activities will be inevitably suspended. Furthermore, the urgent national energy needs in south Sudan and the current prevailing peace, means that stalling, from production line will be a significant setback in the capacity of energy production, which is not very good for the national economy. Page 2 Environmental Site Assessment for oil fields – Block 1,2 & 4 1.3. REPORT STRUCTURE This report comprises of Chapter 1 presents an introduction to the environmental site assessment exercise. Chapter 2 discussses project’s current status and information. Chapter 3 provides objectives and scope of the environment site assessment . Chapter 4 provides the details of the protocol, criteria and methodology used to undertake the environmental site assessment . Chapter 5 deals with findings and observations while Chapter 6 provides details on Oil field workover. Chapter 7 presents emerging issues which include strengths and weaknesses, while Chapter 8 provides a list of recommended actions on how to improve environmnetal and social management. Chapter 9 discusses cost benefit and Chapter 10 presents a preliminary decomissioning plan while Chapter 11 provides a conclusion of the study. Page 3 Envionmental Site Assessment for oil ?elds - Block 1,2 4 2.0 CURRENT STATUS INFORMATION 2.1. SCOPE OF THE DRILLING AND OPERATION OF BLOCK 1, 2 AND 4 Figure 1 shows the location of the Block 1 ,2 and 4 oil ?eld, whose geographic coordinates are Unity oil field and It is situated in greater unity states, it is bounded by drylands,bushes and scanty vegetation. The area is also accessible by air with light aircraft, for which there is a landing airstrip. Block 1A and 18 0 Exploration, Development, Production 0 5 clusters in Block 1A namely Toma South, El Mar, El Toor, KHNE and Greater Munga. 1 cluster in Block 18 namely Greater Unity. Greater Unity and Talih consists of 21 fault blocks. - Block 4 (South) Exploration Phase 0 2 discovery: Kaikang-l and Lol-l Lowak-l Figure 1: Block 1, 2and4 Page 4 Envionmental Site Assessment for oil fields - Block 1,2 4 I Refineries I Oil producing areas 0 Oil fields Pipelines Proposed pipelines . :1 ?i V1319. Block 1 &2 ETHIOPIA CENTRAL AFRICAN neposuc John . on couoo To Lama, Kenya; Fiwre 2: Showing oil ?elds in south Sudan Production process Drilling phase The oil production involved drilling a 8 to 20 inch diameter oil well bore to a vertical depth of about 1099m, using a standard land drilling rig (see Figure 3), which had the following systems and services to support the drilling operations: Figrre 3: Standard onshore drilling rig BPDC Page 5 Environmental Site Assessment for oil fields – Block 1,2 & 4 a) Bulk Storage facilities: provided for cement (typically 200 tons), bentonite and barite (typically 200 tons combined), fuel (diesel in this case) (typically 500 m3), liquid drilling fluid (typically 300 m3), drill water (typically 2,000 m3) and potable water (typically 200 m3). b) Pipe and Materials Storage: covered storage is provided for sacked material, drilling equipment and spare parts, and deck storage for drill pipe, casing and other wellbore tubulars. c) Power Generation: diesel generators for running the drilling plant and equipment, in the order of 6,500 horsepower. d) Emergency Systems: This includes life-saving appliances and fire detection and protection equipment, and detection systems for combustible gas and hydrogen sulphide. e) Environmental Protection: blow-out prevention equipment, sewage treatment unit, hazardous waste containment and collection pans around diesel and chemical tanks. Block 1,2 and 4 is currently suspended due to insecurity in the state there was destruction of facilities and damage and corrosion problems of some facilities . In order to bring it back online an oil field workover is planned to take place sometime in the 3rd Quarter of 2019. Production phase The primary activity conducted during the production phase is pumping oil to the processing plant. Other activities during production phase include production enhancement, oil well servicing (routine maintenance such as replacing worn or malfunctioning equipment), and oil well workover (a more extensive equipment repair), which is being planned. Figure 4:Gpoc field layout Page 6 Environmental Site Assessment for oil fields – Block 1,2 & 4 Oil well workover The oil well workover is an extensive service on an existing operating or suspended oil and gas well, requiring interventions in the wellbore itself to correct a problem with the well or to maintain it e.g. by replacing corroded pipes and valves with new ones, pipelines, storage tanks, ensure pipes are tested to avoid any rupture or environmental damage. The length of time required for oil well workover can vary depending on the extent of maintenance and or servicing needed. The first step in the workover process is a oil well kill, where heavy material (workover fluid) will be pumped into the well to stop oil from seeping up into the wellbore to maintain oil well control. This will be followed by removing materials inside the wellbore (the completion) so that it can be replaced. The third step will be to check on the integrity of the production casing to determine if issues like leaks or collapses could develop. During the program if the integrity of the production casing warrants, an attempt to repair any casing problems will be made. Well Kill: is a strategy that is used to gain well control of an active well, making it safe to remove the wellhead and perform wellbore operations on the well. While there are several strategies used to accomplish this goal, many will involve the use of what is known as kill mud or fluid to maintain a static head (mud or fluid weight) to block the surge of oil from the well. Finally the wellbore will be recompleted with a packer, completion and wellhead. Since workovers are a very invasive form of oil well maintenance, a predetermined protocol will be developed and followed carefully when bringing the oil well back up to production. This will include developng a checklist for environmental, health and occupational safety, to make sure the oil well will be safely brought back to operation. In case the oil well bore or condition of the oil well will be found in the state where it can be brought back online it will be abandoned. The abandonment will be a permanent plugging of the oil well and the surface returned to existing surroundings. Page 7 Environmental Site Assessment for oil ?elds - Block 1,2 4 Workover Rig During the resumption of oil production testing of the wells that were flowing will be done using a service rig to ensure submersible pumps, well head valves are ok at the GPOC Oil fields.A typical workover rig is as shown on Figure 5 chem '.?8lPiO IOMO mum .m gnu DIESEL MC FCOK Figire 5: Typical workover rig Table 1 shows the type and amount of materials that will be used for workover activities. Table 1: Kill ?uid Mata'ial Type Muslin Type Approximate an?ty er?ty oil well workover treatment See below Methanol (line freezing 200 litres chemicals prevention, oil wells) Emulsion breakers (oil wells) None Water treatment chemicals Salt-7 tons Corrosion inhibitors 50 litres (oil processing None sulper recovery) Biocides 50 litres Paint and thinners None Diesel 5 m3/ day Lead-acid batteries 4 each Gasoline 300 litres/day Herbicides None - 4/ GPOC PageB Environmental Site Assessment for oil fields – Block 1,2 & 4 Fuel Diesel will be used by the workover rig, and supply vehicles. Approximately 5 m3/day of diesel will be used, during the workover campaigns. Water Workover operations will require use of water. There are two possible sources of water (i) from underground using a Reverse Osmosis (ii). Drinking water (approximately 16 tonnes) will be used for the workforce of 150 people for the one month for oil well workover programme. About 45 tonnes of water will be used to prepare oil well control and kill fluids. Water will also be needed for washing and cooking (about 250 tonnes) during the workover operation. After the workover, the domestic water requirement will be similar to what is current. Personel About 150 people will be employed during workover operations. These workers will not be employed by GPOC, but rather are part of the rig owner who move from one site to another paforming similar activities. 2.2. PROJECT CURRENT STATUS Blocks 1, 2, and 4 are located in the Muglad basin, covering an area of 48,388 sqkm .Unity oil field is the largest oil field in unity state .The Road network in the oil fields comprises of the following Ring roads 150Km; Unity FPF-Panakuach 36km, Panakuach-El-Nar 12km, El Nar-Toma south 5km, Toma south-El Toor 23km, Munga FPF-Unity FPF 32Km,El Toor-Munga FPF 38Km, Panakuach-Heglig-35km External roads -Rubkona 24km, El Toor-Alel Gravel pit-78kmUnity-Juba 700-1000km. Figure6: Google map showing road network of GPOC oil fields Page 9 Environmental Site Assessment for oil fields – Block 1,2 & 4 EnviroCare and waste Management engineering ltd was contracted by Greater Pioneering Petroleum Company (GPOC) to carry out an Environmental Site Assessment in the oil fields of Block 1, 2 and 4 in Greater Unity states. The assessment was conducted in the oil facility located in Munga, Kaikang, El Nar, El Toor, Toma south and Unity. The EnviroCare team conducted consultative meetings with the authorities, the communities around the oil field and the military personnel. The team was able to cover all the facilities which include FSP/FPF, Power plant, Pump Station, base camp, pipe line, bulk storage, evaporation ponds, retention ponds, Bioremediation ponds, drilling mud pits, hazardous waste, chemical storage and the air strip in the mentioned areas above. Soil and water samples were also carried out. Block 1,2 and 4 oil production is currently suspended due to the insecurity in the area and is now under protection of the Military. In order to gauge the status of existing infrastructure in the oil fields of Block 1,2 and 4 ,site visits,observations,topographic mapping were used to highlight the facilities.They include the following; a. Field Production Facility (FPF) The Field Production Facility (FPF) was visited on 12 May 2018 at 11:00 AM and the following observations made;        The FPF in Unity /Munga & Northfield (pipelines) were damaged although some of the facilities are not affected. Accommodation for security guards& workshop were dilapidated, the chemical yard has been cleaned up by HSE Mitigation team. Since shutdown 2013 there were several oil spillages at the FPFs and well sites though there was no active presence of GPOC in the fields. It was reported and observed that; GPOC had cleaned oil spill using soil cover techniques The bulky storage tank in Unity field was shot by unknown gunmen which led to high hydrocarbon release almost half of the oil spilled out. The El Naar wells were shot at by unknown gun men and oil spills flowed to retention ponds and some exposed to the environment. Some local communities around oil fields are using empty chemical containers for storage of potable water b. Power Plant Facility The power plant Facility in unity oil field was visited on 12 May 2018 the observations are;   The warehouse is completely destroyed and filled up with solid waste mostly electrical materials like wires, batteries etc. The entrance to the power plant is also littered with these same solid wastes as a result of destroyed materials because of the insurgency. Page 10 Environmental Site Assessment for oil fields – Block 1,2 & 4    There is leakage from the fuel storage tanks in the power plant which has contaminated the soils around the area. The insulations on the tanks are destroyed and this makes the tanks vulnerable to temperature deviations and conditions like rusting. A lot of waste material found in the control rooms mostly of destroyed electrical appliances, computers and other gadgets. Plate 1: power plant facilities that were destroyed c. Base Camp, The base camp needs an overhaul and was severely damaged.The basecamp has not been in operation since December 2013. The facilities have been tampered with and there is need for proper house cleaning .scraps are seen scattered allover,the fence is in bad shape,there has been total abandonement of existing facilities which can be seen below; Page 11 Environmental Site Assessment for oil fields – Block 1,2 & 4 Plate 2;Base camp facilities destroyed ,notice the scrap accumulated d. Pump station,  Generally the pump stations are in good condition except the corrosion on the pipes due to extended periods of time taken without maintenance.  The areas are bushy (short grass and shrubs) which is dangerous in case of fire outbreaks.  The water in the holes at the pump stations have become breeding places for fish and other aquatic living things. Page 12 Environmental Site Assessment for oil fields – Block 1,2 & 4 Plate 3:Pump station facilities e. Evaporation Ponds, The status of the evaporation ponds can be summarized as follows;     From the site observation, the edges of the ponds look to be having traces of crude oil which could be due to leakages or overflow of the ponds. There is vegetation cover on the surrounding areas. Most of the evaporation ponds are either not fenced or the fences destroyed making it risky for animals and even human beings that go around doing their daily activities near the facility. Most of these ponds also do not have linings to prevent leakage of the chemicals and crude down to the water table. Page 13 Environmental Site Assessment for oil fields – Block 1,2 & 4 Plate 4: Evaporation pond status at oil field f. Bio-remediation Pond,  The bioremediation ponds are generally dry due to the long time taken without operations.  There is several plant species present in these ponds which is a sign that breaking of the hydrocarbon chain is progressing well.  The bioremediation ponds are not fenced or the ones which were previously fenced have been destroyed.  Some of the pipes are corroded and others already out of position in that they have been removed from the sites where they were first installed. Page 14 Environmental Site Assessment for oil fields – Block 1,2 & 4 Plate 5:Bioremediation ponds have dried up due to no oil production activities g. Pipelines  Most of the pipe lines in the facilities have their insulation destroyed.  As a result of limited maintenance during the shutdown period, there is corrosion on the pipes.  Some of the pipes have points that leak and this is causing contamination of the soils. Plate 6: Corroded and rusty pipelines in oil field h. Chemical Storage Area, The chemical storage area is completely burnt due to the insurgency in the area at the time and because of this;   The plastic chemical storage containers were completely wiped out. The metallic stands were burnt but remains are still present at the chemical yard. Page 15 Environmental Site Assessment for oil fields – Block 1,2 & 4      The surrounding area is bushy (dry grass due to dry season) which presents a potential fire threat in future. The chemicals previously present in the chemical yard could not be ascertained because of the damage. The store in which other chemicals were locked in is damaged and everything therein destroyed to the level that they cannot be identified. As per the site observation, there should have been a spillage of the chemicals prior to the suspected raiding and burning of the yard. This spillage has not been thoroughly cleaned much as there were efforts made towards containing it.  Plate 7:chemical storage area with scattered chemicals/wastes i. Mud Pits area  Mud pits are dried up, this is attributed to the fact that they have not been in use since the shutdown of operations.  The soils have been washed away to the surrounding areas and potential contamination is suspected. Page 16 Environmental Site Assessment for oil fields – Block 1,2 & 4   No proper containment practices were observed during the site visit and this is deduced from the fact that the mud pits are not protected from potential invasion by animals. Few of the mud pits were accessible since some parts were impassable. Plate 8: Mud pit areas have dried up j. Airstrip. The Airstrip was visited on 12th May 2018 at 2:00pm and the following were the observations ; Plate 9: The airstrip at the oilfield Page 17 Environmental Site Assessment for oil fields – Block 1,2 & 4     The unity airstrip needs renovation although small flight aircrafts like a helicopter can easily land on it. The control room is dilapidated and needs an overhaul for easy communication Since 2013, there is no any single flight that landed in the airspace. The Military men near the airspace are trying their best to maintain the GPOC airspace. General recommendations and suggestions on status of facilities in oil field: 1. Evaporation ponds:  Expansion of the ponds both by depth and length should be considered to prevent unnecessary over flow.  Proper lining should be considered using standard and internationally acceptable lining polymers to prevent leakage of the chemicals to the water table.  Extensive bush clearance around these facilities is advised to minimize damage in case of fire outbreaks from the neighbouring areas.  Proper fencing of these ponds should be adapted to prevent incidences of animals drowning in them and by extension compensation burdens. 2. Bioremediation ponds.  Much as the bioremediation ponds are dry at the moment, proper fencing should be considered as a matter of urgency before resumption for the same reasons as stated earlier.  Replacement and fresh installation of pipes should be considered for effective functioning of the bioremediation ponds.  More efforts should be directed on research more especially on petroleum microbiology to come up with effective microbiological (bacteria) means of degrading the waste to a level that is environmentally friendly. 3. Power plant.  The compound and warehouse should be cleared of all the solid wastes that were observed.  The wastes should be consolidated in one area where sorting and segregation by size, material and ease of safe disposal can be done.  Repair or more realistically replacement of the tanks and pipes should be considered urgently to prevent further pollution of soils and air.  Installation of new insulation for effective temperature regulation of the pipes and storage tanks should also be considered sooner than later.  Thorough cleanup of the soils by removing the contaminated ones and taking them to the treatment sites and replacing them with fresh soils should be done. Page 18 Environmental Site Assessment for oil fields – Block 1,2 & 4 4. Pipe lines.  Testing of pipes for corrosion should be carried out before pumping oil  New insulation for pipes in the FPF/well sites for proper temperature regulation and protection from weather conditions should also be considered.  Fresh painting that is resistant to weather changes and possibly fire proof should be done.  Pipes that leak should be replaced to prevent further pollution of the environment. 5. Mud pits.  Laboratory Soil testing on the mudpits to ascertain level of contamination and for compliance  Proper containment practices should be adapted to prevent incidences of rain water erosion.  Maintaining and opening of new access roads should be done to aid proper supervision. 6. Pump stations.  Bush clearance in and around the pump stations should be looked into.  General renovation of all components of the pump stations should be considered prior to oil production resumption.  The water in the holes needs to be pumped out so as to proceed with thorough cleaning. 7. Base camp  The scrap metals at the base camp should be properly disposed or recycled  Proper house cleaning should be done prior to resumption of oil activities  Emphasis on drainage ie Proper soak away pits  Replace damaged fence of the base camp 2.3. PROJECT BOUNDARIES Greater unity states is one of the 32 states of the new African nation of South Sudan. Prior to an administrative reorganization in 1994, Unity was part of a much larger province of Upper Nile. Unity state is in the Greater Upper Nile region and is located to the north and borders by Upper Nile and Jonglei to the East, Lakes state to the South, and Warrap to the West. It borders and shares a long border to the North Sudan. The total area of the state is 37, 837 sq km which covers more than 25% of the country. The state is further structured into 10 counties, 54 Payams, and 227 Bomas.Greater Unity is inhabited predominately by two ethnic groups, the Nuer (majority) and the Dinka (minority). Page 19 Environmental Site Assessment for oil fields – Block 1,2 & 4 2.3.1. Core Area The core areas, i.e. the areas that may be directly impacted by the project activities e.g. noise emission, air pollution, discharges etc., include the block 1 ,2 and 4, the pipeline to the oil processing plant, the chemicals storage area, waste disposal sites and area in general. 2.3.2. Area of Influence The first oil reserves were discovered here in the 1978 by an American oil company called Shevron.The international oil companies which engaged in oil exploration contributed to the massive displacement of the indigenous population. The environmental and socio-economic influence of oil field extends beyond the Block 1,2 and 4 area . Area of influence includes the sourcing of raw materials from greater Unity states, Juba City etc. and the entire nation considering that the oil fields are yet to function for the development of the nation. 2.3.3. Area in Vicinity of Project Site Physical characteristics Climate Generally, the climatic conditions of Greater Unity state suggest that it is semi arid which is a unimodal climate with 900–1,000 mm of rainfall. It also lies between 9˚ 0’N and 29˚ 42’ Rainfall The rains are received between May and November and this is followed with a long dry season between December and April. Temperature Maximum temperatures range between 29-340C while minimum temperatures range between 25.929.10C. Humidity The humidity rises to 96% in mornings and later in the afternoons it drops to 67% during the most humid months from December to March. Geomorphology (geology and soils) The soils vary from sandy to black cotton and there is a good drainage at higher ground and water is logged at flat plains especially along the eastern lowlands with Bahr el Ghazel river. Unconsolidated sand interceded with clay gravel and shale overlaid with recent alluviation and swamp sediments.The terrain is flat plain with alluvial deposits of main geomophologic feauture.The rocks are water laid ,non marine massively bedded highly weathered medium to coarse –grained sandstones Page 20 Environmental Site Assessment for oil fields – Block 1,2 & 4 Topography It is evident that due to its size and location, the state has a diverse topography with different geographic and climatic zones, and resources. Hydrology The state is crossed by the Bahr el Ghazel river .Along these low lying swamps can be found isolated fish camps surrounded by substantial aquatic life and migratory birds. The Sudd swamp of Unity, Jonglei and Lakes States are perhaps the largest aqua system for fish life in the world. Air Quality The air has not been polluted apart from trading winds that raise dust .The current air quality is normal since there has not been any production of oil in the state since December 2013 Winds During the dry season in November/April the prevailing winds are from the northeast 8mph while during the wet season the winds are predominantly from south/south east of 6-8mph.These wind patterns reflect the shift in the surface air circulation as the ITCZ passes over the area. Fauna: The storage area is a zone with few natural features. There are a few large or small fauna reported or observed. The only wild animals seen were village weaver birds, pied crows, reptiles (lizards), arthropods (insects commonly in grassed areas including Spiders, beetles, mantis, various ants species, etc). There are also quite a number of domesticated animals (e.g. cattle sheep and goats) found grazing around the area. There are no species considered rare, endangered, vulnerable as per Convention on International Trade in Endangered Species of Wild Flora and Fauna (CITES) and International Union for Conservation of Nature (IUCN) lists. Flora: The natural vegetation around includes low shrubs and few trees, It has predominantly deciduous vegetation interspaced with economically valuable timber forests, bamboo, and gum Arabic, neem and mango trees .Theres open tall grass followed by Acacia Seyal and Balanites community.Grasses include;Hyparehenia spp,Brachiana Obsusflora,Cymbopogon nervalus and Echinochlora pyramidilis Plate 10: Vegetation within the project area Page 21 Environmental Site Assessment for oil fields – Block 1,2 & 4 Topography: The terrain is generally flat plain with aluvial deposits of main geomophologic feautures.rocks are water laid,non marine massively bedded highly weathered medium to coarse –grained sandstones. Soils:The soils sandy to black cotton and there is a good drainage at higher ground and water is logged at flat plains especially along the eastern lowlands with Bahr el Gazel river, with very little lose soil.soil in Blocks 1,2 and 4 are predominantly black cotton clay and its chemical composition included calcium bicarbonate,hence requires improvement with nitrification and adition of acid balancing organic matter.The dark cracking clay that contains clay exceeds 60% with carbonate crystals and concretions in the lower horizons.the clay soil on drying out shrinks considerably and a network of wide deep cracks result. During rainy season water percolates through the cracks and when they close up the soil becomes moist ,it becomes impermeable under high rainfall and sheet flow from other areas the clay soil can not absorb all the water and consequently flooding occurs. Inspite of the impeded drainage ,growth of dense annual and perennial grasses is permitted. Plate 11: Black cotton soils with cracks formed Hydrology: The area lies along the Bahr el Ghazel river and Cholpie corridor with high reliance on cattle and fish, although its proixmity towards the nile is near ,the area is generally dry. Much of the ground water in the sedimentary formation is in unconfirmed water bearing zones varying in depth,depending on the strata,enclosing impervious beds,recharge areas and source of replenishment.the depth of water may be up to 6m or more below surface Terrestrial Environment: Along the west bank of the Bahr el Ghazel river is a large expanse of the swampy vegetation that is covered by tall grass and associated vegetation. It is often difficult to puck out the main River Nile boundary that demarcates Unity state and Jonglei state due to the large marshland . It is often difficult to puck out the Bahr el Ghazel river boundary that demarcates bentiu and bentiu town and Rubkona due to the large marshland. Along these low lying swamps can be found isolated fish camps surrounded by substantial aquatic life and migratory birds. The Sudd swamp of greater Page 22 Environmental Site Assessment for oil fields – Block 1,2 & 4 Unity, is perhaps the largest aqua system for fish life in the world and are designated ramasar sites of national and international importance. Birds: Birds are quite common and include some charismatic species such as the Crowned Crane, Spurwing Goose, Open Bill Stork and others. It is very probable that high numbers of migratory birds are present during the period November – March. There are however no data that enable an assessment of the current status of birds.Unfortunately, the global diversity of birds is decreasing incessantly primarily due to anthropogenic disturbances and climate change, habitat alteration and human disturbance Plate 12: Biodiversity including mihgratory Birds in the area Socio economic characteristics Demographic Profile Population According to the estimates of 2008 population census by National Bureau of Statistics (NBS), the total population is estimated at 580,600. This translates into 6.8% of the total population of South Sudan and places the state in the ninth position followed by Western Bahr El Ghazal which has only 333,431(4%). The male population accounts for about 300,247 while the female population is estimated to be 285,554 or 48.7% of the total. About 55% of unity state population is under the age of 18, 79% resides in rural area, and 26% of the adult population is estimated to be literate. Sixty eight percent of the total households (HH) depend on animal husbandry or crop production as their primary source of livelihood. Displacement trends, population needs and humanitarian access have all been negatively affected by the insecurity resulting from the ongoing conflict in greater Unity State, which began in December 2013. Page 23 Environmental Site Assessment for oil fields – Block 1,2 & 4 Wages and employment Specifically,sixty eight percent of population depend on or are engaged in agriculture and grazing activities, and oil and the public sector dominate the formal economy. Unemployment and underemployment are very high with little formal sector employment. In greater Unity State the revenue collected by the state was registered as 10.8% and 5.7% in 2010 and 2011 respectively, indicating much to be done to improve non oil revenue collection. Economic Mainstay It is evident from SSDP that ‘Oil provides 98% of public sector revenue and almost all foreign exchange earnings of the country. Furthermore, oil production has peaked and is projected to decline sharply over the next ten years. While this oil production provides much-needed revenue, the extreme dependence on oil creates a major challenge for macroeconomic and fiscal management and the pending sharp decline in oil income exacerbates this situation. Fiscal sustainability and stable public expenditures are the cornerstones of macroeconomic stability. SSDP promotes efforts to diversify the economy, develop other sources of public revenue and expand employment and livelihood opportunities. A core component of this growth will be building the Government’s non-oil revenues in the coming period (SSDP, 2011) Natural resources The greater Unity state has been blessed with important natural resources in the form of oil deposits. This provides a huge amount of revenue for the country as well as to the state and has the potential to deliver development to the people of South Sudan. Many countries in our position would be very envious of our natural resources. However, it is the responsibility of all of us to ensure that this blessing does not become a curse. Managing our finances in a prudent and organized way, across all levels of the Government system, is crucial. It is important that plans must be formulated, budgets must be prepared and it is imperative that these budgets are adhered to. Farming Farming is done by pastoral nomads and other minority groups on a smaller scale.The type of farming is subsistance oriented.Crops grown are mainly sorghum and maize .Farming by pastoral nomads is often abandoned when it interfears with the demands of nomadic pastrolism or when it generates sufficient surpluses for investment in livestock. Livestock herding Livestock keeping is common, but practiced with free-range grazing by cattle. The most common animals kept in the state include cattle goats sheep, chicken and ducks. Nomadic pastrolists traverse the area from November to the beginning of the rainy season,they do this to satisfy needsof their cattle in respect to water supplies grazing presence of insects and avoidance of muddy grounds. Fishing Fisheries are an important source of food and income with the most productive fishing grounds to the north of the area. Generally, fishing is done on a small scale. The fishery zone is faced with blockage by water weeds and other water related emerging challenges. Page 24 Environmental Site Assessment for oil fields – Block 1,2 & 4 Trading and commerce Among 7,333 formal businesses in the ten states of South Sudan, 305 businesses were registered in capital of unity state-Bentiu which translates into 4.84%. Seventy four percent of these businesses are shops while ten percents represent restaurants and hotels. As the country emerged from the devastating civil war in 2005, and following the signing of the CPA, it was clear that much of its infrastructure had been destroyed and many of its local government institutions had been decimated. Since that time the Local Government Board has been organized and led a programme of significant restoration to local government institutions, which had tremendous improvements in different aspects. Economic Infrastructure Poor transport infrastructure in greater Unity is affecting all facets of the economy. In the State, commendable efforts were made to connect all Counties with a road network, although there is still need to rehabilitate some of the roads if they are to be used throughout the year. However, road connectivity between Counties and lower administrative centres remains low or non-existent. It is evident that poor road/air/water infrastructure isolates some communities from the main stream of socio-economic development; hampers investment, production and shipment of both perishable and non perishable goods to either internal or external markets. All the roads in the area are murram, also with smaller tracks used by the residents and developers and traders for local travel. Air transport There is an airstrip which is largely used by GPOC but has overgrown grass and abandoned. The airstrip is mostly used by UN and NGOs to transport personnel to Juba.However,the airstrip and control room needs an overhaul. Communication networks Telecommunication networks available are zain network, However, the coverage for other cellular networks is poor. Energy Previously the village electricity power supply was provided by the Unity Power Plant located at the oil field to more than 400 households ‘formally’ connected to this electricity supplies power to Bentiu. However at the time of the assessment there was no power supply as the powerplant was not running due to the insecurity. Firewood is still the main source of energy used by majority in the area for cooking, smoke fishing, etc. Social infrastructure and Services Water supply Water supply to the area has been affected by the insecurity and therefore difficult to find adequate sources of water for consumption .some of the already installed boreholes have broken down and ojthers need rehabilitation. Page 25 Environmental Site Assessment for oil fields – Block 1,2 & 4 Health services The area had one dispensary at the base camp. The medical facilities have been shutdown due to the insurgency that occured in december 2013. This health facility facilitated the base camp and nearby communities Security There is a public security service stationed at site (SPLA military ).Due to the last war that broke out in December 2013, SPLA has been stationed at the oil fields to boost security from the disturbing rebels.By the time of this assignment there was heavy deployment of military personel at the GPOC oil fields. Security installations such ssecurity lights have also been broken down Plate 13: Damaged security light in the oil fields that needs a workover Education There were no primary school or secondary schools found near the site.However, independence the republic of South Sudan inherited a fragile economy that is currently posing immense developmental challenges at State and lower levels of the government. Nevertheless, the State is doing its best to deliver services to a highly expectant population at the backdrop of limited resources. HIV and AIDS The level of awareness among the community with respect to HIV/AIDS is on the high side, and the infection rates are equally lower than the national average.GPOC should ensure education and awareness programmes is in place. Cultural Characteristics Cultural sites Places of worship for cultural activities were identified eg Pariang in Gokuo,theres a protected shrine.Its a place of worship during harvest period such places should be protected for national heritage. Page 26 Environmental Site Assessment for oil fields – Block 1,2 & 4 Gender equality and women empowerment Like most states, the greater unity state is not quite gender balanced. Women, who constitute the majority, are weakly organized and exercise a limited amount of freedom in comparison with their male counterparts. Planned Future Developments On the other hand GPOC is expected to conduct workovers and revamp for a number of existing oil wells .a anumber of community based iniatives ie building more schools,acess to feeder roads for communities,construction of health centers etc Existing environmental threats and challenges Within the general area of the oil fields there are no industrial activities (other than the power Plant processing). The probable threats may be ; Water pollution This may originate from oil Plant operations (produced water discharges) and contaminated rainwater runoff. These are not regulated and theres need to mitigate against any form of pollution.This was evident during the site assesment in the oil fields.However these water sources were located far from oil field operations Plate 14: Water sources within the project influence area. Air pollution Again, the main source is power plant that supplies energy up to Bentiu.Previously the release of sulphur dioxides and nitroxides to the atmosphere caused pollution during oil production.Theres also need to use scrubbers and filters on heavy machinery to reduce on air emmisions although at the time of assessment there was no threat of air pollution. Page 27 Environmental Site Assessment for oil fields – Block 1,2 & 4 oil spill pollution/hydrocarbon release Waste disposal from the oil fields is not managed and frequently results in pollution, hydrocarbon release have been evident from the FPFs/oil wells. Wastes are mainly in the form of scrap, and chemicals. The oil spills/hydrocarbon release are a result of unknown people opening valves thinking its diesel they can sell,some of the tanks and pipes where shot at consequently causing spills and lack of mantenance of the Facilities since shutdown in december 2013 led to tear and wear . Plate 15: Oil spills from pipes and facilities Over carrying capacity utilisation With a new overhaul of the oil fields and a new residential area inevitably pressure will be exerted to resources and carrying capacity of the oil field. Already there has been significant clearance of vegetation, there will be new road to supply to the GPOC staff. It is recommneded that a Strategic Environmnetal Assessment is carrried out by relevant authority to estabalish the extent of cumulative impacts that may result from this concentration of oil and gas activities. 2.3. TYPE OF ACTIVITIES ASSESSED Following activities were subject of this ESA: 1. Oil production activities likely to have caused pollution of soils/ land, waters including incidental discharges of oily materials in drainage, drilling chemicals, drilling cuttings and domestic wastes. 2. Oil production activities likely to have caused damages and disturbances to terrestrial life e.g. noise, vibration and light emmisions; well as by materials dicharged on land 3. Oil production activities likely to have caused degradation of natural habitats and biodiversity from accidental events including; fuel spillages, , drilling chemicals as well as spillage of hazardous materials and wastes. 4. Oil production activities likely to have caused workers health, safety and security (HSS) Risks including: Inadequacies in water and sanitation provisions, transmission of communicable diseases, infection / exposure to disease vectors, inadequacies in the use of personal protective equipment (PPE), working conditions and facilities and absence of code of practices at the work place. Page 28 Environmental Site Assessment for oil fields – Block 1,2 & 4 5. Oil production activities likely to have caused improvement of community livelihoods including: Market / income generation to local suppliers and businesses and employment opportunities and income to locals. 6. Oil production activities likely to have caused disruption of community livelihoods and blocked /restricted access. 7. Oil production activities likely to have caused public health, safety and security hazards and disturbances including: Injuries and fatalities from accidental events, contaminations by wastes of land and water resources depended on by local communities and Local community cultural / behavioural changes due to interactions . Page 29 Environmental Site Assessment for oil fields – Block 1,2 & 4 3.0 ENVIRONMENTAL ASSESSMENT OBJECTIVES AND SCOPE 3.1. ASSESSMENT OBJECTIVES The main objectives of environmental and social audit are were adopted from those stipulated under south Sudan national environmnetal policy 2012: the policy guidance on oil exploration activities atributes to the following; i. Conduct petroleum operations in a manner that shall not pollute or degrade the environment and shall be in accordance with best national and international environmental practices ; ii. Develop legal frameworks (policy, legislation, regulations and guidelines etc) for management and regulation of the oil sector; iii. Ensure full compliance of oil companies in the implementation of Environmental Management Systems (EMS) and adherence to the relevant ISO; iv. Ensure that oil companies contract authorized and accredited individuals or companies, in conducting environmental audit annually and to be reviewed by the relevant ministry; v. Ensure that oil companies undertake restitution, rehabilitation and recovery programs for the affected local communities as well as of the degraded environment attributable to their negligent operations; 3.2. SCOPE OF THE ESA To meet the above objectives, the ESA covered the following scope: a) b) c) d) e) Provide assessment on the current status of environment at the oilfields. Detailed review of existing environment protection measures at the oilfields. Identify current and historical sources of damage or contamination (actual and potential). Risk assessment on the potential environmental risk of main facilities in the oilfields. Provision of information on Socio-Economic Environment including Population, Land Use (Nomadic Pastoralism, Crop Cultivation), the Social Organization of Production, Industry and Sources of Energy, Transportation in the Block 1, 2 and 4. f) Program for consultation with leaders of local communities which will be accompanied by GPOC, MOP representatives and other stakeholders. g) Site Inspection: A brief orientation tour of the facility, followed by detailed inspections of areas of interest including:Power Plant, Pump Station (PS), FSP/FPF,Base Camp, Pipelines, Bulk storage, Evaporation Ponds, ,Pond, Drilling mud pits,, Hazardous Wastes/Chemical Storage Area, Well Pads area and airstrip h) Document Review: Many documents were reviewed on-site and others were scrutinized after the site audit. These included HSE plans and procedures, monitoring data and various environmental records Page 30 Environmental Site Assessment for oil fields – Block 1,2 & 4 well head A well head is the component at the surface of an oil or gas well that provides the structural and pressure containing interface for the drilling and production equipment. The Oil well head is composed of casing heads, casing spools, tubing head spools, tees, and crosses. The casing head is part of the connection between the casing and the wellhead itself. Typically, multiple pieces of wellhead equipment are integrated into a wellhead assembly called a "Christmas tree". The servicing (routine maintenance such as replacing worn or malfunctioning equipment), and oil well workover (a more extensive equipment repair), is being planned for resumption of oil production Plate 16: Christmas tree on block 1,2 and 4 wellhead This wellhead assembly allows tubes to be placed into the well while valves and chokes are used to control the flow of oil and/or gas at the surface. Figure 7 shows typical detailed schemiatic diagram of the wellhead. Figure 7: Detailed description of wellhead Page 31 Environmental Site Assessment for oil ?elds - Block 1,2 4 4.0 ESA APPROACH, PROTOCOL, CRITERIA AND METHODOLOGY 4.1. APPROACH The principal approach adopted for the ESA was assessment of the project compliance to the requirements by national and international standards and agreements, particularly the south sudan requirements EIA and EA Regulations Bill of 2012. The ESA was guided by the Terms of Reference (T oR)of the client (Appendix 3) through a phased approach:, onsite audit, and post-audit. 4.2. ESA PROTOCOL The assessment followed general Protocols, which cover the environmental and occupational health and safety requirements of the assesed facilities. These can be separated in the subjects shown in Table 2. Table 2: Assessment protocol Aspen loans to [in General Environmental Implementation of recommended best pratices (since this activity was Requ'rements done without an EIA) Air Enission Mitigation measures that were implemented to add'ess known potential Management impact of oil and gas drilling and operation activities; Effectiveness of the Mitigation measures (as per national international Air Emission standards, etc.) Chemicals and Mitigation measures that were put place to manage hazardous chemicals Hazardous Materials (types of chemicals and hazardous materials, storage, handling, transport, Maiagement I Transport risk assessment) Effectiveness of the mitigation measures (as compared with national standards and international agreements) Effectiveness of chemicals handling and transportation (as per Material Safety data Sheets Waste and hazardous Mitigation measures that were put in place to deal with hazradous waste Waste Management (types of wastes [general and hazardous], quantity, storage, handling, transport, disposal methods) Effectiveness of the mitigation measures (pollution to land and water bodies, national/international standards) Facility/Technical Sdety Mitigation measures that were put in place to manage facility and technical Mmagement aspects (management of fire hazards, explosive hazards, machinery and equipment safety [con?ned space, pressure vessel, electrical etc.], accidental events, gas blow out etc.) Effectiveness of the mitigation measures (ocurance of hazardous events, accidental events etc.) Noise, Vibration And Mitigation measures that were put in place to manage noise, vibration and :2 GPDC Page 32 Environmentd Site Assessment for oil ?elds - Block 1,2 4 Aspect ijn Emission Mmagement light Effectiveness of the mitigation measures (as per national international noise, vibration and light levels and standards etc.) Emergency Preparedness Response Mitigation measures that were put in place to manage emergencies (accidents and incidents prevention measures, ?re ?ghting procedures, evacuation procedures, communty awareness, drills etc.) Effectiveness of the Mitigation measures (occurance of emergency, affectiveness of the emergency response) Occupational Health and Safety Management Mitigation measures that were put in place to manage occupation health and safety (working environment, PPE, Ocupation Health and Safety (OHS) training, ?rst aid, medical su'veillance, ergonomics, exposure to disease vectors etc., Effectiveness of the mitigation measures (Ocupation Health and Safety Agency (OSHA) guidelines and standards) Public Health and Safety Mmagement Mitigation measures that were put in place to manage public health and safety hazards (mitigation of transmission of communicable diseases, community security, rowdiness /disorder iness etc.) Effectiveness of the Mitigation measures (OSHA guidelines and standards) Community Well Being Mitigation measures that were put in place to deal with community well being employment, procurement of local supplies, local expectation, stakeholder engagement, support to community development projects etc.) Effectiveness of the mitigation measures (number of employed locals, local procured materials) 4.3. ESA CRITERIA The criteria against which the initial audit and environ mental site assessment was conducted are: 0 Adherence to company policies and procedures on environmental matters; Adherence to applicable legislation and regulations; Adherence to environ mental and social impact management plans; Adherence to environ mental and social monitoring plans; Application of best environmental practices; 4.4. ESA METHODOLOGY 4.4.1. Tasks for Carrying Out The ESA The following tasks were carried out to cover the above scope of work through a phased approachz, onsite assessment, and post-assessment. Task 1:Preparation of site assessment tools to guide further docunentary review aid on-site assessments Activities under this task included preparation of three categories of assessment tools: .9 Page 33 Environmental Site Assessment for oil fields – Block 1,2 & 4 1. Stakeholders Engagement Plan (SEP) including determining community stakeholders and engagement protocol, procedures and messages. 2. Questionnaires for audit participants: i. Questionnaire for GPOC key staff for self audit. ii. Questionnaire for implementers of oil operations iii. Questionnaire for entities resposible for monitoring and reporting implementation of the environmnetal perforamance. iv. Questionnaire for environmental and social management authorities at national, regional, Local Government Authorities (LGA), and community levels. 3. Field investigation guides: i. Description of the current project status and status at source of impacts (past and current if any). ii. Description of the current status of the key environmental and social receptors at the project site and area of influence. On- Site Assessment Task 2: On-site Assessments The ESA activities were conducted as per developed tools and guides focusing on the environmnetal performance of the project activities. Focus of the assessment was to find out the following:  Complete shutdown current status information;  Implementation of mitigation mesures and controls;  Conditions / status of relevant environmental and social receptors at the project site (as measure of mitigation effectiveness); and  Evidence to verify the self assessment responses. Task 3: Stakeholders consultations The assessment involved consultation in accordance to the SEP to verify findings and emerging issues. Conduct on-site assessments based on a combination of methods. 1. Conduct of meetings and site inspection with project management and personnel  Opening meeting with manager and site personnel to:  Introduce audit and site assessment team members  Present ESA scope and objectives  Outline the audit approach and methodology  Address questions or concerns of site personnel  Rally staff support and assistance  Staff Interview The purpose of the interview was to obtain information on:  Actual practices (current and past) Page 34 Environmental Site Assessment for oil fields – Block 1,2 & 4  Compliance with/or deviation from statutory and departmental requirements Awareness of requirements and expectations  Ideas to do it better  Comments and suggestions  Undertake historical research involving review of relevant documents to assess implementation status of the following (but not limited) documents:  Management policy  Management system documentation  Operational procedures  Records (utility, inventory, accidental events, monitoring, calibration, training etc.)  Detailed site inspections conducted with the aid of on-site audit protocols to look for evidence on: o Compliance with legislative and regulatory requirements o Conformance with internal policies, procedures and guidelines o Status of operational practice o Staff participation in management system implementation  Closing meeting provided an opportunity at the conclusion of on-site assessment to:  Debrief the senior site management  Summarize the audit activities and findings  Highlight system strengths and weaknesses  Discuss preliminary findings and recommended corrective actions  Bring up findings requiring immediate attention  Clarify any outstanding issues  Address staff questions or concerns  Agree on reporting schedule and chain of communication 2. Conduct of stakeholders engagemet / meetings Meetings with third parties responsible for monitoring and reporting implementation of the environmnetal management; environmental management authorities; and Interested and Project Affected Persons.  Prior information (introduction letters, notification),  Questionare administration (as relevant.)  One on one meetings and discussions  Focus group meetings The list of satkeholders met is attached (appendix 4 ) and their summarised concerns are presented in Appendix 5. Page 35 Environmental Site Assessment for oil fields – Block 1,2 & 4 Post – Assessment Task 4: Determination of the efficacy of mitigation controls, measures and procedures Under this task the focus was to determine:  How far production oil activities and complete shut down conform with environmental management practices and (iii) quality standards in terms of: o having in place the requisite infrastructure, technology, techniques for avoiding, minimizing or eliminate the negative impacts; o having in place management procedures to implement prosed mitigation measures that are compliant to regulation / standards;  Effectiveness of mitigation measures – whether the receptor was maintained as originally found (baseline), made better or worse.  Arising issues (weaknesses and / or strengths). Each of the above aspect was supported by sources of verification including documentation, Auditor’s own observations and feedback from authorities and stakeholders. Task 5: Determination of the insitutional capacity and needs to supervise environmnet and sacial management Under this task the focus was to determine how far oil production activities and complete shut down conform with acceptable environmental management practices in terms of having in place institutional and individual management capacity and resources to implement proposed mitigation measures that are compliant to regulation / standards. Task 6: Development of the ESMP from lessons learnt (- & + ) Develop a ESMP Matrix with recommendations for improvements on the key aspects:  Complete shutdown activites causing impacts  Emerging impacts  Proposed mitigation measures  Standard / criteria, and comformity to approval conditions  Parameters for monitoring mitigation effectiveness  Responsibilities for mitigation measures implementation  Time frame / schedules  Cost Recommendations on institutional stucture and capacity building measures Task 7: Preparation of environmental site assessment Report. The ESA report was prepared as per draft environmental Audit Regulations ,2012 Page 36 Environmentd Site Assessment for oil ?elds - Block 1,2 4 4.3. OIL WELL WORK OVER IMPACT ASSESSMENT METHODOLOGY In general, workover refers to any kind of well intervention or remedial treatment on oil or gas well involving different methods and techniques common in oil industry and completion as such the methodology used to conduct impact assessment is similar to that of oil and gas well drilling. 4.3.1. General Guidelines provided in the south sudan draft Environment Audit Regulations Bill of 2012 were followed to analyse the impacts associated with oil well workover. The study adopted the following approach, identifying, collecting and analysing information that included: Baseline data and stakeholders involvement The base line data is similar to what is presented in Chapter 2. The stakeholder involvement was done simultaneously with the assessment execrcise. lnpact Assessment Impact assessments were determined by superimposing workover activities onto the existing environmental conditions of the project site(s). This involved analysis of data for identification, prediction and evaluation of foreseeable impacts, both beneficial and adverse, of the proposed workover programme using checklists, simple matrices and expert judgement; and reference to standards and guidelines. 4.3.2. Impact Identification and Evaluation The methodology used considered all the potential impacts using a standard matrix approach which takes into account impacts on the physical environment air quality, soil and ground water quality), impacts on the ecology flora and fauna) and, impacts on human socio-economic setting, as shown inTable 3. Table 3:Matrix of impact identi?cation Project Physical awlronmert Ecolodcalenvirormit Sodo-eoonomicsetting e.g. Air land Flora Fauner Other Social Economic CLItu'al Activityl Activity II etc. .9 GPDC Page 37 Environmental Site Assessment for oil fields – Block 1,2 & 4 Environmental, health, safety risk (and other risks) is a measure of the potential threats taking into account the likelihood that events will cause or lead to damage or degradation and the potential severity of that damage or degradation. The Consultant used the general criteria, listed below, to evaluate significance of the identified impacts. i. ii. iii. iv. v. vi. vii. Magnitude and likelihood of impact to occur Spatial and temporal extent Potential to implement mitigation measures and controls Likelihood and degree/timescale of environmental recovery Value of the affected environment/social component Level of public concerns Political repercussions of the ESA The scale of negative and positive impacts that are likely to occur were determined using a range of low, medium and high, as follows: L+ M+ H+ LMH0 = Low positive = Medium/moderate positive = High positive = Low negative = Medium/moderate negative = High negative = No apparent impact Significance The grades for compliance and ecosystem have also been combined, as shown in Figure to arrive at an overall grade for the aspect’s environmental significance, which favours the medium of the two grades. H H H H M M M M L Compliance L Ecosystem L Socio-Economic L Figure 8: The combination of significance grades. The resulting terms for the overall assessment for each environmental aspect were defined thus:   High – Risk / impact not acceptable (if any criteria is awarded a (H) high grade); Medium – Risk / impact acceptable if managed (if the criteria have grades combining (M&L) medium and low); and Page 38 Environmental Site Assessment for oil fields – Block 1,2 & 4  Low - Risk / impact acceptable (if all criteria are (L) low and there will be no further comment). The assessment also considers the contribution to local and national environmental and socioeconomic issues as well as global environmental issues of air quality. 4.3.3. Mitigation measures and management controls Identifying and proposing mitigation measures that aim at eliminating or minimising the potential negative impacts and promote positive ones using expert judgement. 4.4. POST OIL WELL WORKOVER ACTIVITIES After the oil well workover activities the well will either be connected to the oil processing plant for production in which case the monitoring plan provided will apply. Post oil well workover activities involves testing the wells that were flowing involving use of the service rig to ensure submersible pumps, well head valves are ok After the oil well workover activities are completed done the well will either be connected to the FPF for processing. Page 39 Environmental Site Assessment for oil fields – Block 1,2 & 4 5. FINDINGS AND OBSERVATIONS GENERAL Conformity of Components and Contents of the ESMP to Standards The oil production activities was done without Environmnetal Impact assessment as such there was no ESMP that was developed. Alignment of ESMP with Approval Conditions from MOEF Since the oil production activities was done without Environmnetal Impact Assessment no EIA Certificate was issued by the relevant Authority(Ministry of Environment and Forestry) HISTORICAL RESEARCH The historical or current environmental and social management were assessed by administering a questionnaire and interview shedules with stakeholders. 5.1 COMPLIANCE TO LAWS AND REGULATORY FRAMEWORK 5.1.1 Interim National Constitution of South Sudan& Transitional National Constitution of South Sudan,2011 Following the CPA and the regaining of autonomous status,south sudan adopted an interim constitution that became the supreme law of the newnation. The constitution emphasises on environment issues as key milestone to protecing the environment. Every person shall have right to have environment protected for present and future generations through appropriate legislative action and other measures that ; prevent pollution, prevent ecological degradation, promote conservation, secure ecological sustainable development and use natural resources while promoting rational economic and social development so as to protect genetic stability and biological diversity Concerning Lands; States shall manage issues related to land leases, utilization of land in towns and rural planning, agricultural lands within the state boundaries and land tenure. Relevant Policies 5.1.1.1. Environment South sudan National Environmental Policy (2012) It is apparent that, the absence of a national Environmental Policy for the Republic of South Sudan has been a setback with respect to efforts exerted in the recent past to protect the environment, arrest its gradual degradation and to integrate environmental concerns into development policies. Page 40 Environmental Site Assessment for oil fields – Block 1,2 & 4 At the same time, the current trends of natural resource utilization have neither been sustainable nor environmentally friendly. Other equally important causes of environmental degradation are the lack of legal framework and institutional capacities. Improper oil exploration, production, and transportation activities have the potential to cause severe impacts on the environment. Relevant sections of the policy to block 1 ,2 and 4 are: Chapter 2 paragraph 2.1 (3) which calls for full compliance of oil companies in the implementation of Environmental Management Systems (EMS) and adherence to the relevant ISO; Ensure that oil companies contract authorized and accredited individuals or companies, in conducting environmental audit annually and to be reviewed by the relevant ministry. 5.1.2. Relevant Acts 5.1.2.1. Environment Investment Promotion Act, 2009 The Investment Promotion Act henceforth gives directives to investors who wish to invest in south Sudan. Section 42 emphasizes protection of indigenous communities in whose areas investments take place and ensure indigenous enterprises and investments are promoted, encouraged and protected. The First schedule paragraph C on environment friendly investment, notwithstanding any provision or rule and subject to provisions of this directive, states that any company investing in south Sudan shall observe and implement environment friendly corporate rules and regulations for the following purposes; i. ii. iii. iv. Preservation of the top soil, subsurface and subterranean water and river bank flora and fauna ecosystem biodiversity; Redemption or preparing the land to the natural position after use or expiry of mining activities; Responsible solid waste management and disposal of trash,waste,toxic substances in landfills or recycling facilities, composing/decomposing sites; Responsible management of noise, clean air, clean water(ponds, rivers, streams and swamps/ wetlands Liability, any investor who fails to design and implement environmentally friendly rules and regulations shall be guilty of an offence and liable of fines, payment of damages or remove or clean waste where applicable in accordance with the law Page 41 Environmental Site Assessment for oil fields – Block 1,2 & 4 Southern Sudan Land Act 2009 The Act stipulates the rights of the citizens on land, compensation modalities if people are relocated from the land they had been using. According to Sections 74, 75 and 77 of the Land Act, “expropriation of land for public interests (including oil production among others) should be based on the consultation process with the communities, negotiation and agreements endorsed by the impacted community and individuals evidenced by a written protocol between the individual or traditional authorities and their communities and signed by the local government and traditional authority” The Land Act classifies land as (a) communal, (b) public, or (c) private land. Only South Sudanese citizens can own land, but foreigners can lease land. The document defines rights and restrictions of land users and owners. The Land Commission supervises the application of the Land Act and its institutional set-up at the different administrative levels is elaborated in the Act. The Act prescribes EIA for investment projects, but there are no elaborate provisions for land use planning such as land use categories or planning and allocation procedures. A Land Policy is still under development and it will include some amendments to the Land Act. Wild Life Conservation and National Parks Act, 2003 The Act stipulates that “No persons, without authorization, other than wildlife officials on duty shall enter a national park unless in possession of a valid permit” and no person shall within any national park cut, clear or remove any tree, bush or other vegetation, mine quarry and gravel and use the park as a disposition ground for any kind of waste”. Environment and Protection Management Bill,2012 Environment and Protection Management Bill, 2012 that has not yet been passed into law by parliament states that ‘The goal of the environment bill is to ensure the protection, conservation and sustainable use of the natural resources of South Sudan, without compromising future generations. ‘The Ministry of Environment through an environmental protection agency will require a systematic environmental impact assessment, audits, monitoring and evaluation of all development projects to mitigate adverse impacts and enhance environmental benefits. The south Sudan Environment Regulations Bill, (2012) The regulations provide guidance on the procedure to be followed to conduct environmental audit. Part 20 is dedicated to audit procedure including the structure and content of environmental audit report. Part II section 17(2) gives an overview on how audits Improve a project´s activity with regards to compliance with environmental legislation, regulations and standards such as on air emission, effluent and waste management .Also it highlights a list of offences one can commit and hence liable to fines which include among others breach of conditions stipulated in the certificate, giving false statement in EA report and failure to implement audit report recommendations for improvement. Page 42 Environmental Site Assessment for oil fields – Block 1,2 & 4 South Sudan Petroleum Act,2012 Section 50,(1) states that Petroleum activities shall be conducted in such manner as to ensure that a high level of health and safety is achieved, maintained and further developed in accordance with technological developments, best international practice and applicable law on health, safety and labour. Any person conducting petroleum activities shall ensure active compliance with legislation and best international practices on health and safety in the working environment. Section 59,(3) states that the licensee or contractor shall, concurrently with the environmental and social impact assessment, conduct a comprehensive environmental baseline study that provides for an understanding of the existing environment in the contract area in which the activities referred to in subsection (2) of this Section are intended to take place. The assessments referred to in subsections (1) and (2) of this Section shall      be appropriate to the scale and possible effects of the petroleum activities subject to the assessments; include consultation with the public, including local communities; evaluate, after consideration of the consultations conducted under subsection (b) of this Section, the preliminary geological, geophysical and geochemical data and the actual and potential impact of petroleum activities on various interests in the relevant area, including local communities, the environment, sites of historical importance, trade, agriculture and other industries and past, present or potential conflict; and be in the form and containing the information prescribed in the regulations. Be consistent with international practice as reflected in the Social and Environmental Performance Standards of the International Finance Corporation. Be made publicly available, including in the area where petroleum activities are planned, as soon as notice is published in the Gazette. South Sudan Mining Act , 2012 Section 121,(1 and 2)of the Mining Act states that, the title holder of a mineral title shall, in accordance with the current Act and in accordance with good mining industry practice, conduct his or her operations in such a manner as to preserve in as far as possible the natural environment, minimize and control waste or undue loss of or damage to natural and biological resources, to prevent and where unavoidable, promptly treat pollution and contamination of the environment and shall take no steps which may unnecessarily or unreasonably restrict or limit further development of the natural resources of the license area or adjacent areas. Further clause (2,) states that ,In accordance with good international mining industry standards, the applicant for a mining Licence or Retention licence or any renewal of either shall prepare and submit a comprehensive environmental and social impact assessment as part of the business plan as required or for an exploration and mining as per mining agreement as per section 102. Page 43 Environmental Site Assessment for oil fields – Block 1,2 & 4 5.1.3. Relevant National Strategies 5.1.3.1. Environment South Sudan Development Plan The main guiding document for the developmentof the country is the South Sudan Development Plan (SSDP) which addresses conflict management,poverty reduction and economic development.One of the goals of the document is to strive for less dependence on oil. The Government’s role is not toundertake economic activities itself, but to create an enabling environment for economic development by assuring peace, security, rule of law, macroeconomic stability, basic infrastructure and effective tax administration. The SSDP is structured through four Pillars, namely: Governance, economic development, social and human development, and conflict prevention and security. Within these pillars, cross cutting issues are defined as (1) anti-corruption, (2) capacity development, (3) environment, (4) gender, (5) HIV and AIDS, (6) youth, and (7) human rights. Under the Governance Pillar, the Government’s role is to:    ensure that development is sustainable through enforcing environmental and social Impact assessments for all development programmes and projects accede to and ratify applicable and beneficial multilateral environmental treaties, conventions and agreements promote inclusive participation, access to information and good governance in Sustainable natural resources management and environmental protection. The Economic Development Pillar covers the following priority programme areas: agriculture and forestry, roads and road transport development, development of energy, mineral and mining sectors (including oil), animal resources and fisheries, and Water resources management, development, utilisation and provision of sanitation services. Environmental sustainability of economic development and related activities including oil extraction, logging and charcoal production is to be ensured. The use of environmental impact assessments (EIAs) is required for infrastructure and power supply development. 5.1.3.2. International Conventions and standards International Finance Corporation ,2012 (IFC)-Performance Standards on Environmental and Social Sustainability) IFC’s Sustainability Framework articulates the Corporation’s strategic commitment to sustainable development, and is an integral part of IFC’s approach to risk management. The Sustainability Framework comprises IFC’s Policy and Performance Standards on Environmental and Social Sustainability, and IFC’s Access to Information Policy. The Policy on Environmental and Social Sustainability describes IFC’s commitments, roles, and responsibilities related to environmental and social sustainability. IFC’s Access to Information Policy reflects IFC’s commitment to transparency and good governance on its operations, and outlines the Corporation’s institutional disclosure obligations regarding its investment and advisory services. Page 44 Environmental Site Assessment for oil fields – Block 1,2 & 4 The objective of performance 3 is to;  To avoid or minimize adverse impacts on human health and the environment by avoiding or minimizing pollution from project activities.  To promote more sustainable use of resources, including energy and water.  To reduce project-related GHG emissions. Performance Standard 3 (Resource Efficiency and Pollution Prevention) recognizes that increased economic activity and urbanization often generate increased levels of pollution to air, water, and land, and consume finite resources in a manner that may threaten people and the environment at the local, regional, and global levels. There is also a growing global consensus that the current and projected atmospheric concentration of greenhouse gases (GHG) threatens the public health and welfare of current and future generations Performance 3 section 10, on pollution prevention states that the client (GPOC)will avoid the release of pollutants or, when avoidance is not feasible, minimize and/or control the intensity and mass flow of their release. This applies to the release of pollutants to air, water, and land due to routine, non-routine, and accidental circumstances with the potential for local, regional, and transboundary impacts. Where historical pollution such as land or ground water contamination exists, the client will seek to determine whether it is responsible for mitigation measures. If it is determined that the client is legally responsible, then these liabilities will be resolved in accordance with national law, or where this is silent, with EHS guidelines. United Nations Framework Convention on Climate Change ,1992 (UNFCCC) The objective of UNFCCC is to stabilize the concentration of greenhouse gas (GHG) in the atmosphere, at a level that allows ecosystems to adapt naturally and protects food production and economic development. Article 4 commits parties to develop, periodically update, publish and make available national inventories of anthropogenic emissions of all greenhouse gases not controlled by the Montreal Protocol (by source) and inventories of their removal by sinks, using agreed methodologies. It commits parties to mitigate GHG as far as practicable. Since Oil and gas exploration is recognised as a key sector that emits GHG, south sudan is obliged to include such activities in its published national statistics. Since south sudan is a Party to the Convention will have to account for all sources of GHG in her first communication. Ramsar Convention,1971 The Convention on Wetlands, called the Ramsar Convention, is the intergovernmental treaty that provides the framework for the conservation and wise use of wetlands and their resources. The Convention was adopted in the Iranian city of Ramsar in 1971 and came into force in 1975. Since then, almost 90% of UN member states, from all the world’s geographic regions, have acceded to become “Contracting Parties”. Page 45 Environmental Site Assessment for oil fields – Block 1,2 & 4 The convention entered into force in South Sudan on 10 October 2013. South Sudan currently has 1 site designated as Wetlands of International Importance (Ramsar Sites) 1, with a surface area of 5,700,000 hectares. The sudd includes National Park and game reserves. One of the largest tropical wetlands in the world, located in South Sudan in the lower reaches of Bahr el Jebel, a section of the White Nile. The site is composed of various ecosystems, from open water and submerged vegetation to floating fringe vegetation, seasonally inundated woodland, rain-fed and river-fed grasslands, and floodplain scrubland. Montreal protocal and vienna convention The Republic of South Sudan has acceded to the Vienna Convention for the Protection of the Ozone Layer (1985) and the Montreal Protocol on Substances that Deplete the Ozone Layer (1987); 5.1.4. Compliance to Policies and Legal Regime Table 4 provides an analysis of policy and legal regime compliance of GPOC. 1 A Ramsar site is a wetland site designated of international importance under the Ramsar Convention. The Sudd is a Ramsar site in south Sudan. Page 46 Environmental Site Assessment for oil ?elds Block 1,2 4 Table 4: Compliance matrix SN Reqiement Con-pianos Measues Dd?kiency Corrective Mean tlon POUCES 1 National Environmental Environmental Impacts Assessment shall be ESIA was not done Lack of Environmental and This is an ESA Policy (2012) carried out prior implementation of the prq'ect Social management and . Environmental Audit will be monitoring plans done according to the EIA and EA Regulations Bill (2012) Industries should be planned in a manner that minimises adverse effects on the environment at all stages location, ef?uent discharge, waste disposal, use and disposal of products) Area is located in designated area for oil developrn ent The method of disposal of wastewater is not known The method of disposal of drilling waste is not known but there is no recollection of impact from disposal of the same EIA was not done No documentation of the activities that took place then This ESA provides updated ESMP Documentation will be ensured in current in future activities Workers health shall be adequately protected from environmental health hazards There is no documentation on the type of protection that was put in place (it may however be assuned since oil and gas is a standard operation procedure, proper protection of workers were instituted No documentation of the workers protection Documentation will be ensured in current in future activities To ensure compliance with Health, Environment GPOC has HSE Policy that is attached as None None Safety and standards in the oil value chain appendix Appendix 7 To support activities in the oil industry based on GPOC has no Policy None None Page 47 Environmental Site Assessment for oil ?elds Block 1,2 4 SN Poicy/Gddelnes/Legsla Reqi'ement CormImoe Measues Deficiency Corrective Meme tion gender issues and addressing and other infectious diseases To ensure maximization of bene?ts from the oil I GPOC has Prodiction Sharing Agreement None None industry through projects with MOP ACTS Environmental Impact is mandatory for oil and I EIA was not done - EMA Bill was not in Lack of Environmental An ESA has been carried out Environmental gas exploration and development place at the time of exploration and Social Management 2 protection Management Plan Pi"! 2012) Annual audits should be done I Annual audit were not done No audt has been done Annual audits should be done as per gudelines Environmental Impact is mandatory for oil and I EIA was not done EMA Bill was not in Lack of Environmental Environmental Site gas exploration and development place at the time of exploration and Social Management Assessment has been carried The Envirorm ent Im pact Plan 0Ut 3 Assessment and Audit Annual audits should be done I EIA was not done Bill was not in place at No aucit has been done Annual audits should be done Regulations Bill, (2012) the time of exploration as per guidelines Provide procedure and guidelines to carry audit I This ESA has followed the procedure and None None guideline provided in the regulations 4 South sudan Land Act, Governs procedures to obtain right of The site needed consent from communities None None 2009) occupancy The Petroleum Act Provides for sharing of oil and gas proceeds I This is being implemented None None 5 (Exploration and Advocate for environmental protection I This ESA is implementing the requirement Production) 2012 Provides for environment friendly investment I . This is not yet implemented Lack of proper indegenous None and Emphasizes protection of indigenous I indigenous enterprises and investments community protection 6 Investment Promotion communities in whose areas investments take have not been promoted since shutde involvement Act, 2009 place and ensure indigenous enterprises and investments are promoted, encouraged and protected NATIMAL STRATEUES All) 7 South Sudan Protection of environment I Although there is no written document on None None Development plan how the drilling was done, based on the :3 Page 48 Environmental Site Assessment for oil ?elds Block 1,2 4 SN Reqi?anent Carpimce Measu'es Ddidency Corrective Waste tion historical research there is no incidence that is being recalled To involve communities in decision making I The audit found out that there were Communities involvement Documentation of community minimal consultations throughout the is not documented involvement will be enhanced project cycle but the level of involvement in decision making is not clear MNVENIIONS AND 8 (Ref. UN, 1992) To mitigate GHG emission GPOC machines uses electricity instead of None Usage of scrubbers or ?lters heavy fuel oil I industrial fuel oil hence from heavy mad'iines to produces less GHG reduce on GHG 9 RAMSAR Convention of Protects wetlands GPOC follows international best practices None None Wetlands of International importance 1971, (Ref. Ramsar Convention Secretariat, 1971) 10 IFC Performance 0 To avoid or minimize adverse impacts GPOC follows international best practices Communities involvement None standards on environment and social sustainability, 2012 on human health and the environment by avoiding or minimizing pollution from project activities. 0 To promote more sustainable use of resources, including energy and water. 0 To reduce project-related GHG emissions is not documented Conclusion Based of historical research and stakeolders consutations it can be concluded that to a less extent the laws, policies were complied with, even though Block 1,2 and 4 was drilled before the EMA Bi (2012) and Petroleum Act (2012)was put in place. The compliance of laws and regulations is therefore ranked average. Page 49 Environmental Site Assessment for oil fields – Block 1,2 & 4 5.2. EFFICACY AND ADEQUACY OF MITIGATION CONTROLS, MEASURES AND PROCEDURES 5.2.1. Introduction Although the oil exploration and production was done without EIA, it is assumed that there were some mitigation measures that were implemented to ensure that the environment and human health were protected. Since these were not documented, this ESA has adopted best practices and used generic environmental and social impacts that are common to any drilling activity to assess the environmental and social performance of the activities. The assessment was done in stages (i) review of documents for future oil production (ii) self-audit, where GPOC was requested to provide information on how they operated the Oil facilities in the Blocks 1,2 and 4 while ensuring that the human health and the environment were protected (iii) field or site visit which involved stakeholder consultations. Since GPOC was not responsible for oil production at the time and that the oil exploration took place before the south Sudan became independent, the response from GPOC are taken to be the same that they have put in place while operating the oil field facilities. Table 5 provides a summary of generic impacts and possible mitigation measures. Similar impacts may occur during work over execution. Page 50 Environmental Site Assessment for oil ?elds Block 1,2 4 Table 5: Potential environmental and social impacts for workover resumption WWI/said Input/Risk BA Filth, STE PHASE Landtake Terrestrial habitats, plants, Change of land uses The impacted land was limited they needed land fauna, avifauna, and livestock activities Loss of land/property/ or land rights I The land belonged to people I No land owners were compensated according to the Land Act provision during time of assessment Effects of natu'al factors and neighbouring anthropogenic activities Blocked access/resources use Project structures and facilities (bioremediation ponds,mud pits, oil pipeline, base camp etc.), people (project personnel, community). Damage to project structures or disruption of schedules I Block 1,2 and 4 has been in operation until it was shutdown and there was destruction of facilities. Security has now been beefed up at oil sites Disturbance con?icts with local community I The initial conflicts that were experienced were resolved I Currently there is no con?ict mm midi-o) Atmospheric emissions generating equipment and processes Air quality and climate change Reduction of air quality effect on climate change It is not known of the implementation measures that were put in place Handling and disposal of wastes Soils quality, anlity, fauna and avifauna, visual quality, agriculture livestock activities, population (community public). Soils were affaected by hydocarbon release,electrical appliances,chemicals were all littered at facilities especially power plant It is not known of the implementation measures that were put in place Noise-emitting equipment, and oil production activities Resident fauna and People (local labour force and personnel, general Nu'sance disturbance to fauna people It is not known of the implementation measures that were put in place Page 51 Environmental Site Assessment for oil ?elds - Block 1,2 4 Projectenv'mnnentdasput VI: Input/Risk ESA Filip population). Staf?ng People's welfare Employment and income I Some people were employed and laid off but the ESA could not establish actual numbers of people that were employed during oil production phase I Currently there are no permanent employees and casual labourers only security personnel Utilization of Local Resources Freshwater quantity and project operations Resources depletion at extraction point and operational downtime I built a water tank to supply water to the village but this could not be sustained as pumps were being stolen I Currently the villagers are getting water from nearby unsafe water Occupational Health and safety People (personnel of the various project entities crews of vessels) and project equipment and properties Disturbances and/or health and safety risks to workers Damage and/or loss of equipment; and operational downtime I It is not known of the implementation measures that were put in place I Currently GPOC has elaborate system of managing occupation health and safety hazards Public Health and safety People (personnel and community members living in or on the land), equipment and property Disturbances and/or health safety risks to the people I It is not known of the implementation measures that were put in place I However, since the chilling was done by international company it may be assuned that standards were used I Currently GPOC has elaborate system of managing public health and safety hazards Sight preparation Vegetation around the oil ?eld sites Disturbance/ loss of vegetation and biodiversity I It is not known of the implementation measures that were put in place Page 52 Environmental Site Assessment for oil ?elds Block 1,2 4 Projectenviuunantdasput Input/Risk Drilling materials Soils quality, terrestrial fauna and avifauna Decreased land water quality increase in turbidity It is not known of the implementation measures that were put in place. However no major event is being recalled by Villagers Disposal of cuttings Fauna and avifauna, visual quality, agiculture livestock activities, population (community public). Restricted land use It is not known of the implementation measures that were put in place. However, discussion with Villagers it seems that the handing of solid waste did not resdt in negative events Communication with reservoir section fresh water/ hydrocarbon reservoirs and other forms of sub-su'face aquifers Decreased quality of subsurface aquifers It is not known of the implementation measures that were put in place oil production People, Project Proponent, Increased supply of oil to the Block 1,2 and 4 was in operation until it was shutdown in Government market december 2013 and had capacity to produce 66,000 barrels per day I I Disposal of demolition waste hydrocarbon reservoirs and other forms of SLb-surface aquifers Contamination impaired quality of receiving bodies The dilling rig was hired and thus was disassembled The staff camp was dismantled but there is no record on how this was done Loss of employment Workers Loss of income It is not known of the implementation measures that were put in place AWMEVEHB Major leaks and spills of chemicals, materials and wastes land/, vegetation Decreased land quality It is not known of the implementation measures that were put in place, major oil leaks and waste disposal was seen in the facilities,FPFs/oil wells Major oil spill at re-fuelling points Land/, vegetation Decreased land quality It is not known of the implementation measures that were put in place, however major leaks has been reported by the Villagers Vehicle collision :d People (personnel and Inju'ies and possible loss of life No vehicle collision has ever been experienced Page 53 Environmental Site Assessment for oil ?elds Block 1,2 4 ?Md/mid Input/Risk community members living in or transient on the land), vehicles oil well blowout People (personnel and community members living in or transient on the land), equipment and property Inju'ies and possible loss of life; loss of equipment and property It is not known of the implementation measures that were put in place, but no blowout occured Pipeline leakage explosion People (personnel and community members living in or transient on the land), equipment and property, Inju'ies and possible loss of life; loss of equipment and property It is not known of the implementation measures that were put in place, there was leakage of storage tanks in Unity ?eld that were shot by errant soldiers manning the pipelines Fuel tank explosion People (personnel and community members living in or transient on the land), equipment and property, lneries and possible loss of life; loss of equipment and property However, no major explosion has been reported by Villagers Page 54 Environmental Site Assessment for oil fields – Block 1,2 & 4 5.3. PAST AND ONGOING CONCERNS OF PROJECT STAKEHOLDERS Stakeholder consultations were carried out during the auditing exercise to identify and respond to project issues of concern to stakeholders. Consultations were carried out in Budang/Rubkona and Mayom under Northern Liech State ,Aliny and Touch county under Ruweng state. Plate17: community stakeholders meeting at Pariang The Following is a summary of stakeholders concerns that were identified during site meetings with the community and community leaders. 5.3.1. Support to Community Development Projects during shutdown GPOC as part of its Corporate Social Responsibility (CSR) through CDCA has financed a number of State and community projects in sectors such as education and health. Before the shutdown of oil activities in December 2013 plans were underway to support community initiatives. However the following activities have been taking place during shutdown; Education sector  Distribution of textbooks to various schools within the state  Program to enhance English program in secondary schools  Programme for Construction of classrooms Health Sector  Distribution of drugs to various health centres  Support has involved construction of dispensary including staff quarters for medical staffs.  Capacity enhancement through medical personnel at health centres through part time.  General support through i.e. finances paid to state council for general development projects. Page 55 Environmental Site Assessment for oil fields – Block 1,2 & 4 Lack of involvement of local residents in implementation of the projects. The Villagers are concerned that the disclosure of actual financing of the above project is lacking, i.e. the Village Leadership at times fail to reconcile the quality of the project against the money claimed to have been invested. Lack of sustainability of the projects Some of the financed projects lack management such as building of a health Centre at village but there is no support in term of hiring regular doctors, no support for procurement of drugs and maintenance of the building infrastructures. This concern is raised because there is an understanding at State level that the dispensary is getting support from GPOC, and there seem to be nothing in writing on which components are supported by GPOC. 5.3.2. Support to improvement of community livelihoods Health GPOC is planning to construct health centres in designated areas for residents when they assume operations. However the distribution of drugs to health centres to the communities has impacted on the populations. Education Plans are underway to construct primary schools and secondary schools this will increase knowledge transfer and add skills to the youth who eventually will be employed in the near future Water supply GPOC is providing Boreholes to villagers. Two issues were raised (i) there is no system of knowing how the boreholes are distributed. This observation is based on the fact the distribution of water is not uniform (ii) the boreholes are not enough. This is due to the fact that the population of the area is increasing compared to when operations were asumed to be adequate. Some of the water points may have been polluted since the insecurity and may be a major cause of waterborne diseases 5.3.3. Environmental Conservation Environmental degradation GPOC and other stakeholder fetch sand from near communities for building/construction purposes, by doing so they cause environmental degradation to the Land. The company is advised to fetch the soil from nearby sand dunes to protect the land. In the response GPOC responded that they rarely collect sand from villages but if it happens it has to be approved by the authorities Environmental Committee. Pollution on human and Terrestrial Environment The community at block 4 suspect that the oil leaks may be responsible for the degradation of soils/crops - however, they are not sure if this has anything to do with exploration drilling and oil Page 56 Environmental Site Assessment for oil fields – Block 1,2 & 4 processing activities. They also reported that there were increase in diseases as a result of oil activities such as skin diseases, miscarriages in older women affecting reproduction.They requested that a research should be done to establish why the diseases are coming from to know this problem. 5.3.4. Employment Opportunities Increase of per capital income to residents The company has increased per capital income to villagers by employing a number of the community residents. Many of the employed people are from the Bentiu exception of skilled man power. locals are employed in semi skilled jobs as laboures e.g. securities it has employed .But the Villagers are worried that this number is about to decrease as there seem to be undisclosed plan of sending these people to other Supply Base Solution (SBS) projects under the contract terms of not being redeployed when the outside job expires. However GPOC responded that this is a normal work rotation. Envirocare & Waste Mgt Engineering Ltd is reccomending that GPOC should monitor this concern. Employment procedures are not transparent Contractors employ its workers without consulting the village government according to what the EIS recommends, this might result into some problem. e.g incase a worker is involved in any activity that is unethical like theft; the company will not get support/assist from village authority. Also there is suspicion of nepotism. However GPOC responded that they normally consult villagers and attribute this concern to presence of other companies that may not be consulting villagers and that employmet is based on qualificatins and skills . EnviroCare Is reccomending that GPOC should monitor this concern. Permanent employment to labourers There are casual workers who have been working for Contractors without being employed permanently. Although GPOC does not breach the Employment and Labour Relations this does not guaratee these young men/women any social security when they will be retired permanently. The Village is arguing that if these people have aquired some skills (considering the fact that the same people are being used again and again) they should be employed on suitable terms. However GPOC responded that they don’t have calsual labourers. Envirocare Is reccomending that GPOC should monitor this concern and try to clarify it with the Villagers. 5.3.5. Workers’ Health GPOC is providing health care services to its workers. Apart from having a first aid facility it has a system of evacuation of people falling sick to well equiped health facilities in Bentiu, Juba or overseas. Furthermore GPOC conducts annual health monitoring to its workers. Page 57 Environmental Site Assessment for oil fields – Block 1,2 & 4 5.3.6. Local Governance Structure Lack of clear grievance redress mechanisms The existing grievance handling /redress mechanisms follow the existing grievance redress mechanisms which follow local government structure from village-Payam -state offices and the system is acceptable. It involves logging complaints through local government to chiefs, administration and vice versa. Both parties should obey the grievance mechanism in place. It seems that the grievance mechanism agreed is not effective in solving the existing conflicts. The experience shows that some of the conflicts occurred were solved against the mechanism, which means that there is no gurantee that the conflicts will not occur again. 5.3.7. Disruption of community livelihood concerned Increase in the spreading of communicable diseases On arrival of GPOC at Block 1,2 and 4; there was an increase in the number of people from diverse cultural backgrounds hence cultural interaction. This could pose a risk of increase in communicable diseases such as HIV/AIDS. In the past GPOC used to support HIV/AIDS awareness campaigns to Villagers. But this has stopped for reason not known to the community. GPOC should participate in HIV and AIDs sensitization campaign by continuously educating people on HIV and AIDs. They can also participate by sponsoring the volunteer group existing in the communities However, in its response GPOC Management is committed to continue participating in HIV/AIDS campaigns. 5.3.8. Emergence Response mechanism Lack of an Active/ sustainable induction programmes GPOC have offered training to the community on emergences ( e.g fire/explosion of the oil wells) only during the initiation phases of the project but these have stopped. They advised awareness on emergence and preparedness should be intergated with other campaigns to keep the commuity informed. Emerging issues  Capacity enhancement for better quality desired quantity which have been lacking.  Contribution to improvement of local livelihood is not tangible.  Influx of workers in the area constantly changing in terms of numbers background while the local (in habitats) remain constant in many respect hence the nature positive of the impacts due to interactions this aggravates the positive impact from social interaction between local and outsider hence increased of HIV/Sexually Transmitted Diseases (STDs) transmission  Is the grievance the system acceptable, does it work for all cases and is there any alternative options?  Boundaries of jurisdiction between local,state, and ministry are not clear on land. Page 58 Environmental Site Assessment for oil ?elds - Block 1,2 8: 4 6. WORKOVER FOR OIL RESUMPTION 6.1. Introduction In general, workover refers to any kind of oil well intervention or remedial treatment on oil or natural gas well involving different methods and techniques common in drilling and completion operations. In most cases it implies the wireline or slickline operations, tubing replacement, coiled tubing services, snubbing unit services etc. Reasons for such treatments or interventions are mainly mechanical damage of downhole equipment (corroded or damaged tubing string, stuck wellbore tools), reservoir productivity impairment, flow restriction due to sand production or scale deposition, cross flow in the wellbore or behind casing, downhole control system failures, wellhead completion parts failures and testing the wells that were flowing involving use of the service rig to ensure submersible pumps, well head valves are ok other. Usually, if a workover operation is needed, a workover rig is used. After the oil well workover activities are completed done the well will either be connected to the FPF for processing. 6.2. Major Environmental Impacts The potential environmental impacts associated with workover activities are similar to those encountered in the oil and gas drilling operations. The following is a summary of potential hazards associated with workover for Block 1,2 and 4. Table 6: Potential hazards WW Blowout or kick Uncontrolled release of hydrocarbon to surface resulting in an oil spill Contamination of land, surface waters Danger to health and safety of employees and contractors Iry'ury to terrestrial ?ora and fauna Loss of reserves and reservoir pressure Cement failure Uncontrolled release of hydrocarbon to surface resulting in an oil spill Contamination of land, surface waters Danger to health and safety of employees and contractors Injury to terrestrial ?ora and fauna Loss of reserves and reservoir pressure Casing failu'e Uncontrolled release of hydrocarbon to surface resulting in an oil spill ,Contamination of land, surface waters Loss of reserves and reservoir pressure Lubricator failure Release of atmospheric pollutants and greenhouse gas, Uncontrolled release of hydrocarbon to surface resulting in an oil spill Injury to terrestrial ?ora and fauna Loss of reserves and reservoir pressure Danger to health and safety of employees and contractors Packer failu'e Formation cross flow Loss of reserves and reservoir pressure Page 59 Environmental Site Assessment for oil ?elds - Block 1,2 4 Hui! WW Tubing failure Formation cross?ow Loss of reserves and reservoir pressure Loss of containment of gas or oil while production testing. Danger to health and safety of employees, contractors. Contamination of land, surface waters (oil) Injury to terrestrial ?ora and fauna Explosion or ?re at the oil wellsite Contamination of la nd, surface waters Danger to health and safety of employees and contractors Injury to terrestrial ?ora and fauna Spill or leak associated with service rig ?uids and chemicals (via truck and storage and handling at lease) Contamination of soil, groundwater and /or watercourses, Danger to health and safety of employees and contractors Spill associated with on service rig equipment (diesel fuel, oils) Contamination of soil, groundwater and /or watercouses Injury to terrestrial flora and fauna Danger to health and safety of employees and contractors Spills or leaks associated with storage and disposal of oil and gas liquids or other produced ?uids. Contamination of soil, groundwater and /or watercourses ,lnjury to terrestrial flora and fauna Danger to health and safety of employees and contractors Flaring of oil during production testing Release of atmospheric pollutants and greenhouse gas Disposal of hydocarbon and formation waters Localised contamination of receiving environment body Page 60 Environmental Site Assessment for oil fields – Block 1,2 & 4 7. EMERGING KEY ISSUES – STRENGTHS AND WEAKNESSES (ESMP) This chapter assesses comprehensiveness of the existing environmental management system(EMS). The assessment focuses on the Project Proponent commitment to environmental management through its environmental policy, health and safety management plan, having in place a system to deal with environmental issues and dedicating funds to the management of environment. 7.1. ESMP EFFECTIVENESS 7.1.1. Compliance to Policies, Laws and Regulatory Requirements Strengths 1. The oil production operations were done with fairly applicable national policies, laws regulations and international agreements. 2. Non-conformance report was filled daily and this was used to partially monitor the conformance to laws and standard at the time of production. Weaknesses 1. There was no written plan on how to monitor conformance to the national laws, policies 2. The auditing has not been done according the environmental law provisions that have not been passed 3. No decommissioning plan for facilities 7.1.2. Past and On-Going Concerns of Project Stakeholders Strengths 1. GPOC has maintained communication with state / Village Administration 2. Local government system may be used to handle grievances and complaints, however this is not specific to the oil activities Weaknesses 1. state officers feel that they are not fully involved because of lack of funds 2. state officers were not involved in the monitoring of oil production operations, and if they were they do not have requisite knowledge to do that 3. The EIS is not sent to the state as such the officers do not know their responsibility as far as ESMP implementation is concerned 4. Not clear who was supposed to give mandates to monitor environmental compliance 5. There is no grievance handling mechanism 7.1.3. Mitigation Measures and Management Practices Strengths 1. GPOC is committed to protect the environment through implementation of ESMP Page 61 Environmental Site Assessment for oil fields – Block 1,2 & 4 2. GPOC provides adequate funds to implement ESMP Weaknesses 1. Awareness on HIV/AIDS campaign for the community is not done despite interaction between workers and villagers 2. Awareness of emergency preparedness and response to the communities is not done 3. Insecurity in the area is key problem to stall of oil production 7.1.4. Monitoring and Reporting Programme Weakness 1. less monitoring mechanism in place since shut down of oil activities since December 2013, this has not been effective enough Strengths 1. Hydrocarbon release hence Oil spills is now being monitored according to GPOC to avoid any consequence damage on the environment 7.2. INSTITUTIONAL CAPACITY 7.2.1. Company Strengths 1. GPOC has an elaborate institutional set up to manage environmental and social impacts 2. HSE Manager is responsible for implementation of ESMP 3. GPOC sets aside adequate resources to manage environment and social aspects Weaknesses 1. GPOC does not have an elaborate Stakeholder Engagement Plan 7.2.2. Enablers Strengths  The Petroleum Act 2012, and the south sudan EA Regulations Bill (2012) provides clear guidance on roles and responsibilities of managing environmental issues Weaknesses  EIA results are not disseminated to Regional, state and Local Authorities for monitoring purposes  Roles and responsibilities of national and Local Authorities are not communicated  National and Local Authorities lack capacity to undertake the monitoring of oil and gas activities  Relevant Authority did not provide necessary supervision on the implementation of the ESMP Page 62 Environmental Site Assessment for oil fields – Block 1,2 & 4    Coordination of different national and local actors is lacking A system of managing local expectations is not in place There is no system of empowering local communities to meet requirements needed by GPOC and Contractor Page 63 Environmental Site Assessment for oil ?elds - Block 1,2 4 8. RECOMMENDED ACTIONS The Environmental Site Assessment has established that GPOC has frivolously operated the drilling operations in accordance to the national policies and laws, international agreements, Environmental and Social Management Plan and conditions prescribed by relevant authorities. However, there is scope for further improvement, as shown in section 8.3. The updated ESMP is intended to guide future operations of the oil Facilities including the workover. 8.1. INSITUTIONAL CAPACITY AND NEEDS TO IMPLEMENT ESMP Table 7: Roles and responsibilities of institution capacity IRoles-IdRosponsiliiu President Ensure sustainability (environmental and social issues) is integrated into GPOC's management and decision-making processes such as management meetings and reporting, and risk management Ensure sustainability is integrated into numerous operational functions such as main of?ce operation, Base operation, human resou'ces, supply chain (including secu'ity), sustainable development, ?nance and legal. Allocate adequate hu?nan and ?nancial resources to enable effective functioning and continual improvement of the Sustainability Management System Establish and maintain a governance system to monitor performance of the Sustainable Development team Field environment Implement the sustainability management system at Base, which will include the of?cer environmental and social management plan and action plan, and other components. Hold the contractors and their teams responsible for sustainability performance. Ensure sustainability is integrated into base management and decision-making processes such as management meetings and reporting, and risk management Attend stakeholder forms such as community meetings, as appropriate, to demonstrate senior management support HSE Manager Develop and implement an Environmental and Social Management System that adheres to national and international standards. Manage the support team of environmental, health and safety, and liaison/ community development of?cer to implement the ESMS. Prepare monitoring reports for submission to the Managing Director and to stakeholders. Ensuring integration of environmental and social functions throughout the operation. Report to the Management Meeting and its committees on sustainability issues Environmental Implement environmental policies, procedures, and management plans. my Of?cer Review and analysis of monitoring results and preparation of reports to In management and stakeholders. GPOC Page 64 Environmentd Site Assessment for oil ?elds - Block 1,2 4 ides and Collaboration with Planning of and carrying out environmental training programs and awareness for CDCA Manager employees and contractors. Obtaining and maintaining all necessary environmental permits in liaison with the Legal service. Management of the environmental related components of the grievance mechanism. Inspections/audits of environmental protection requirements by employees and sub-contractors. Sampling and data capture in accordance with the environmental monitoring program and analysis of results. Assistance with the preparation of environmental monitoring reporting and permit applications. Compile environmental data for inclusion in the annual report. Conduct environment risk assessment for the operation. legal advice Ensure that assessment of compliance with National Law and International standards, frameworks and codes of practice takes place regularly CDCA Field Of?ce? Implementation of social policies, procedures, and management plans, notably the Stakeholder Engagement Plan, the social components of the ESMP and the Social Development Plan (SDP). Planning of and carrying out social and stakeholder engagement training programs for employees and contractors. Developing and maintaining relationships with local community stakeholders and in particular coordinate the Stakeholder and Community Form in collaboration with stakeholders. Establishment and overall management of the grievance mechanism in conjunction with the environmental, and health and safety coordinators, and in liaison with the Human Resources Manager. Assistance with stakeholder engagement and building relationships with local community stakeholders. Act as the primary points of contact between communities and GPOC. Implementation of the social management system including social management plans. Health and Safety Implementation of health and safety policies, procedures, and management plans, Officers notably the workplace health and safety plan. Review and analysis of monitoring results and preparation of reports to management and stakeholders. Planning of and carrying out safety training programs for employees and contractors. Obtaining and maintaining all necessary safety permits. Management of the safety related components of the grievance mechanism. Inspections/audits of safety requirements by employees and sub-contractors. Sampling and data capture in accordance with Safety monitoring program and .9 GPDC Page 65 Environmental Site Assessment for oil ?elds - Block 1,2 4 ides-dim analysis of results. Assistance with the preparation of reporting and permit applications. Finaneid Manager Incorporate financial resources related to the implementation of the sustainability management system salaries, skills development and training, equipment, liabilities including rehabilitation and closure, social development initiatives, independent audit/assurance etc.) into company ?nancial systems Follow uni/monitoring of Contractors Drill Rig Implement the ESMP and ensure adherence to the national legal requirements, and international standards (International Finance Corporation (IFC) Performance Standards, EHS Guidelines, ILO) Ensure staff members are regularly trained and awareness is built relating to environmental and social management Waste Handing Implement waste, and hazardous waste management plan Companies Ensure that all handlers are registered by responsible authorities to offer such services Ensure that staff are regularly trained and awareness is built relating to environmental and social management or its performance Ensure that guidelines for bulk material transfer is followed and monitored Monitor air emissions from incinerator (particularly criteria pollutants including dioxins and furans) Ensure GPOC receives regular reports on waste management practices Suppliers Ensure they abide to the provision of ESMP Otbr Endllers Ministry of Enforce the implementation of EMA bill/Act Environment am! Conduct review performance audits Forestry . Disseminate the ESMP to relevant bodies that oversee implementation of the bill/ Act Inform national and local Authority on their role Empower the Regional Secretariat and state Authority to ensure they are able to monitor the implementation of the bill/Act Develop communication line with all responsible agencies Review environmental regLIations to make it more effective and reduce paper work and time needed to get a permit Ministry of Regulate the operation and licence of oil companies Petroleum Facilitate coordination of environmental management systems issues within the Enforce the petroleum act on the operator Monitor adherence to environmental safeguards. local Facilitate coordination of environmental management issues within the state. Emnronmental Oversee implementation of the Act in the state Town. Committee Village Monitor implementation of the Act at village level Environmental Coordinates all environmental management functions within the community Committee 9 GPOC Page 66 Environmentd Site Assessment for oil ?elds - Block 1,2 4 8.1.1. Institutional Development Plan The institution development plan is based on the and weaknesses that have been identified in Chapter 7. Table teases out those threats and weaknesses that are relevant to institutional capacity. Table 8: SWOT analysis as related to institutional capacity I Availability of knowledgeable staff in GPOC to manage environmental matters I Availability of other resou'oes technical) to implement ESMP I Existence of long term experience in dealing with (?nancial, environmental and social issues as related to oil and gas industry ?use I GPOC's commitment to environmental I Inadequate documentation on implementation of stewardship ESMP I Inadequate disclosure of ESMP to stakeholders I Inadequate monitoring of environmental aspects key (air emission, vibration, noise etc.) by the Contractor I Inadequate knowledge on roles and responsibilities of different stakeholders I Lack of grievance mechanism I Unclear communication channel between state village on issues related to environmental management I Weak coordination at state village levels I Lack of skills of some state village needed to provide the needed oversight to implement ESMP I Inadequate air pollution water pollution at waste treatment facility I Inadequate guidance of project proponent on the implementation of ESMP 0 .. I Dynamic environmental and social challenges in area I Increased evacuation of oil through construction a new pipeline I Poor perception of local residence on the bene?ts of oil industry to their wellbeing I Lack of capacity of local people to meaningfully engage in oil business Page 67 Environmentd Site Assessment for oil ?elds - Block 1,2 4 To solve or reduce the institutional weaknesses and threats that can disrupt the implementation of ESMP the following plan of action is proposed. Table 9: Overall action plan SN Action We ?main 2. Inadequate docunentation on Weekly reports on HSE Manager Immediately implementation of ESMP the implementation of ESMP should be instituted 3. Inadequate dsclosure of ESMP to All key stakeholder should be Ministry of 1 Week after key stakeholders given at least an Executive environment approval of Summary and ESMP Forestry. EIS 4. Inadequate monitoring of New contracts should require GPOC Immediately environmental aspects (air contractors to keep monitoring Management emission, vibration, noise etc.) by records of environmental the Drilling Contractor during this parameters as contained in assessment ESMP and submit reports to GPOC on weekly basis 5. Inadequate knowledge on roles Training and awareness raising HSE Manager Within six and responsibilities of different should be mounted to ensue Liaison Officer months stakeholders all key stakeholders are aware of their roles and responsibilities 6. Lack of grievance mechanism Grievance mechanism should GPOC Immediately be developed and disseminated Management for use 7. Unclear communication channel A communication strategy HSE Within six between state and village on issues should be developed months related to environmental management 8. Weak coordination at National and A coordination mechanism at State Within six lower levels national state level should be secretariat months developed 9. Lack of skills of some Regional Provide requisite training to GPOC Immediately state needed to provide the needed different target groups Management oversight to implement ESMP State authorities 10. air pollution water pollution at New contracts should require GPOC Immediately waste treatment facilities contractors to keep monitoring Management records of environmental parameters as contained in ESMP and submit reports to GPOC on weekly basis 12. Inadequate guidance of project Modify new ESMP Consultant Done proponent on the implementation of ESMP 13. Lack of capacity of local people to develop and implement plan to State within the meaningfully engage in oil business build local capacity to enable GPOC next 1 year them engage in oil sector Management meaningfully a PDC Page 68 Environmental Site Assessment for oil fields – Block 1,2 & 4 8.1.2. Training The main objective of this component is to empower different actors in the environmental management hierarchy to fulfil their mandates as provided in the Environmental laws. These may include awareness raising, environmental education, environmental reporting and opportunities for participation in environmental decision making. a. Training Objectives The objective of training of different groups is to enhance their understanding of the importance of good environmental stewardship. Specific objectives of the training are to make the target trainees to care for issues like resource depletion, environmental pollution, land degradation, accelerating species extinctions and sustainable extraction of resources and sustainability; make them aware of the impacts the projects to the resources, environment and social wellbeing; make them understand their roles in the overall management and human health protection. Therefore the ESMP forms the basis for the trainings as it will focus on:  Awareness and sensitivity about the environment and environmental challenges in relation to the project activities;  Knowledge and understanding about the environment and environmental challenges in relation to the business activities;  Attitude concern for the environment and help to maintain environmental quality;  Skills to mitigate the environmental problems; and  Participation for exercising existing knowledge and environmental related programs. b. Training Needs Assessment (TNA) For effective training, it is essential that environmental training needs assessment is done. Training needs assessment is a systematic inquiry of training needs of target audience for the purposes of identifying priorities for each group and making decisions on the type of training, and allocating resources in a manner consistent with identified program goals and objectives. There will be four levels training needs assessment:  Organizational assessment: This will evaluate the level of organizational performance. It will determine the skills, knowledge, and ability needs of GPOC organisational structure to implement ESMP. This will also identify what is required to alleviate the problems and weaknesses of GPOC as well as to enhance strengths and competencies. Organizational assessment will also take into consideration factors such as changing demographics, political trends/environment, technology, and the economy. Page 69 Environmental Site Assessment for oil fields – Block 1,2 & 4  Occupational assessment: This will examine the skills, knowledge, and abilities required for affected occupational groups such as those working on the drilling rig, supply vehicles, base, and waste handling facility. While the main focus of the assessment will be on the implementation of ESMP and roles of individuals, the occupational assessment will identify how and which occupational discrepancies or gaps exist, as well as examining new ways to do work that could fix those discrepancies or gaps.  Individual assessment: This will analyse how well an individual employee is doing a job and determines the individual's capacity to do new or different work in relation to ESMP. Individual assessment will provide information on which employees need training and of what kind.  Community needs assessment: This will be a combination of information gathering, community engagement and focused action with the goal of environmental management. It will identify the strengths and weaknesses (needs) within a community as far as ESMP is concerned. Community leaders, local government, advocacy groups or a combination will be trained to address these identified needs. In all cases the focus will be the ESMP, particularly roles and responsibilities. 8.1.3. Retooling and Technical Assistance Technical retooling is a term used to describe activities targeted at enhancing capacity of different stakeholder to implement ESMP. The retooling programme may include: Provision of information, technical assistance, and financial incentives to individuals, groups, communities, and units of government to implement specific activities within ESMP. Following list of activities is based on the findings of the ESA: a. Public awareness There is low awareness on the part of community on emergence preparedness and response, HIV/AIDS. GPOC should identify the necessary awareness requirement and develop a comprehensive awareness campaign. b. Low community participation It is acknowledged that participation of local communities is limited due to low education levels, lack of requisite trades, lack of capacity to supply quality goods and services needed by oil and gas companies. These facts will remain true unless concerted efforts are made to assist the local communities to meet the required competencies. GPOC in collaboration with other oil and gas companies, the central, regional and local governments should develop a programme to capacitate the local communities to acquire required skills, capacities and competences to supply good quality goods and services. Page 70 Environmental Site Assessment for oil fields – Block 1,2 & 4 c. Low community capacity to exploit Water resources Community livelihood in affected areas is linked with water resources as such any disruption whether intentional, accidental is taken negatively by the communities (eg fishing though on small scale) considering the limited ability to take their fishing activities far away from the site. GPOC in collaboration with contractors may provide planning and technical assistance to this group to enhance their livelihoods i.e develop aquaculture etc. d. Lack of capacity to monitor oil and gas activities The environmental policy provides mandate to different stakeholder to enforce the implementation of the policy. Unfortunately these are, state and community and do not know their roles they do not have requisite knowledge of the industry and monitoring aspects. GPOC should work with other oil companies and Ministry of Environment and Forestry to develop a programme to capacitate these actors to be able to meet their obligation under the environmental laws 8.1.4. Budgets and Expenditures The costs estimates provided under ESMP are meant for initial and recurring expenses for implementation of the ESMP, including provision for: mitigation and enhancement actions; training and environmental awareness requirements; monitoring; auditing; and corrective actions. It should be noted the budget provided is required to meet not only activities undertaken by GPOC, but also other activities implemented by other agencies provided they are associated with ESMP. Therefore the budget for initial and recurring expenses for implementing an ESMP should be included in the overall project budget. Recurring expenses include all costs (administrative, design and consultancy, operational and maintenance, monitoring and auditing costs) associated with meeting specific project criteria. However, it should be noted that the provided costs are only estimates. It is expected that GPOC will maintain sufficient flexibility to meet unforeseen, but reasonable, costs, after actual costs have been established. 8.2. UPDATED ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Table 10 provides an updates ESMP for the Block 1, 2 and 4. Page 71 Environmental Site Assessment for oil ?elds - Block 1,2 4 Table 10: Updated Environmental and social management plan Orgarisationd GPOC keep Lp to the following policies and plans: To protect both human Plans, Policies md Reg'ster of Pat of Comnl'tmont health and the project cycle Procedures plans. policies costs I Environmental Policy (Corporate, env'tonment and procedures Company, Prq'ect) (EP) and their I Health and Safety (HS) Policy implementation I Oil Spill Contingency Plan (OSCP) plan I Emergency Response Plan (ERP) I Waste Management Plan I Health and Safety Plan Stakeholders Management Plan GPOC shodd maintain a suitably quali?ed Objectively verify Operation Defne scope of Manager Weekly audit 0 persomel to verify compliance of ESMP compliance with phase work and report to be implementation on a weekly basis for the duration the ESMP mandate submitted of the project and follow lp activities to senior executives of GPOC GPOC to ensure that all Contractor(s) will adhere to To ensure the plans Operation Implementation GPOC ESMP 0 the above policies/ plans/ procedures and provide procedures me 'n Phase report Management compliance progess on their 'lnplemertation place Trailing GPOC /Contractors will continuously provide Ensu'e that all relevant Project life Induction course HSE Manager As part of the per (Inducing trairing to relevant personnel within the company personnel always have materials EHS year Induction on and possibly other SLpport organisations suf?ciert knowledge management particularly service providers and skills necessary for system implementation of the As part of the c? Page 72 Environmental Site Assessment for oil ?elds Block 1,2 4 Issue Action Objective Projed: PHI. police, her-Ho Rm Cost Pl'nse proud-Is I perm I USD or 0th. mm Tap! denunciation [shill-1h management systems Corporate and programmes Social Responsibility GPOC Contractors will continuously conduct Ensure all stakeholders Project life Training Materials HES Manager As part of ES ln-house induction training according to the needs of each are always aware of Site Manager auditing staff group including visitors HES issue Contractor Envirorl'nental GPOC Contractors will continuously provide Effective Project life Training schedule Contractor As part of the per Education and training to all site personnel to have basic implementation of and attendance HSE Environment year General Trailing understanding of environmental principles (value of mitigation and register Health, Safety ecosystem services protection and conservation) management Management measures System (EHSMS) Contractual GPOC will include ESMP requirements in the tender Allocate suf?cient Operation Contractual CDCA 0 documents to ensure that contractors are aware of resource to the documentation As part of the their responsibilities implementation of the EHSMS ESMP GPOC will continuously induct all contractors on the Effective Operation Training sd1edule CDCA Periodic audit In-house contents of the ESMP and penalties arising from implementation and and attendance report to be staff noncompliance ?nancial provisions for register submitted to remedial action in the Penalties senior event for contractor executives at non-conformance GPOC As part of the HSEMS legal GPOC will develop an EHS legal register and Ensure compliance to Project life EHS legal register HSE audit In-house Compliance audit compliance therewith as part of the EHS all laws and report to be staff management system international Audit reports at submitted of agreements by GPOC the appropriate GPOC Page 73 Environmental Site Assessment for oil ?elds - Block 1,2 4 GPOC will continuously comply with all and other Contractor relevant national policies, laws, regulations, As part of the international ageements EH5 - GPOC will continuously inform stakeholders of ?We? . . . . . system their roles and under ESMP hplomontation I GPOC will maintain a designated To make sure the Project life Monitoring President As part of MP Part of folow ups Envirormental Control Of?cer (ECO) to Stakeholders are reports HSE Manager Implementation salaries continuously follow up ESMP implementation informed 0f on site implementation of . ESMP GPOC continuously conduct regular monitoring of the ESMP implementation Stakeholders I GPOC will continuously provide community To ensu'e all Project life Awareness CDCA Manager part of MP 5,000 per engagement awareness-raising (Information and stdreholders are aware materials Implementation year Communication) prog'amme with respect to of the prq'ect . . . . implication orl well operatlon Includlng emergency preparemess Finanrial GPOC will continuously ensu'e finds to To ensue that ESM-P is Project life Budgets Financial Mmager As part of ESM-P 0 com-?tment implement the ESMP (including third pa'ty implemented Implementation Implementers) are available on request Emission from GPOC will continuously undertake maintenance of Ensu'e that vehicle Project life Equipment As part of the of mad'lines and all vehicles and machinery (vehicles, energy units at emissions service HSEMS Operation equipment accommodation quarters generators) being created are not records and in excess of Maintenance the manu?acturer's Emission records costs GPOC Page 74 Environmental Site Assessment for oil ?elds - Block 1,2 4 speci?cations (COXZ). Nox, VOC, of exhaust C02 output GPOC will mainta'n energy conservation measures Minimise GHG and Prq'ect life Emission records Contractor As part of the 0 to reduce fossil fuel combustion other pollutants (NOX, (002, Nox, VOC, HSEMS VOC, 50X, PM) SOX) emissions Atmospheric GPOC will continuously 00an regular To ensue oil is not Continuously Monitoring report Production As part of per emissions of GHG monitoring of suspended oil wells for Ieddng after oil well Manager HSEMS year and other air integity and prepare their status reports plugging N0 leakage pollutants Risk and impacts GPOC will continuously carry out risk assessment Risks are identi?ed and Production Risk assessment As minimum 10;, 000 per and risk management for the facilities managed phase and risk risk as possible management plan and implementation reports The Contractor GPOC will continuously monitor Con?rm the Prq'ect life Env'ronmental HSE the effectiveness of the mitigation of impacts effectiveness of the and social monitoring year mitigation measues performance report to be assessment submitted to senior executives at GPOC As part of the c? [3 Page 75 Environmental Site Assessment for oil ?elds - Block 1,2 8: 4 HSEMS If requied, GPOC will identify and implement the Enhance Project life Amended 5, (D0 per necessary additional corrective and preventive envirmmental and env'ronmental environmental year actions social performance and social action and social plan action plan to relevant Authority as required As part of the EHSMS GPOC will establish a procedues for the Identify and mitigate Project life Envi'onmental HSE As part of the 10,000 identi?cation and mitigation of unforeseen risks and unforeseen risks and social risk and EHSMS impacts as put of the HSEMS mitigation identi?cation procedure GPOC will continue with its efforts to min'mise Reduce amomt of Project life Water usage Field base Periodic audit water usage water used monitoring results Manager report to be submitted to senior executives at GPOC As part of the HSEMS Hazardous GPOC will continuously monitor spill of hazardous Mitigate and manage Prq'ect life Spills CDCA part of the per GPOC Page 76 Environmental Site Assessment for oil ?elds Block 1,2 4 Issue Action Objective Puget: panes, her-lilo Rm Cost Phase M. I person I USD or all. lulu-I Tug-t denunciation [shill-1h Materials?'lazmats) materials and manage them environmental, health management plan HSEM-S year and safety risks associated with the uncontrolled release of hazardous materials. Waste chenicals 0 Dagmar-I lirqn'nnont dictation of ?80? am we: the nab mampmont GPOC will continuously update and implement the Prevent the release of Project life Waste HSE As part of the Developed as hazardous waste (chemicals) transfer protocol hazardous waste to the management plan Field base HSEMS part of environment manager hazardous waste management plan GPOC will dispose of chemical waste, according to Control and manage Project life Project layout HSE Developed as MOEF-approved disposal method access to general waste plan illustrating Field base of?oer part of storage areas to ensure areas for storage hazardous health and safety of of waste workers and other hazardous management persons materials plan GPOC will continuously Lpdate md implement a Establish management Hazardous Field se off oer As part of the Developed as hazardous materials management plan priorities and the materials HSEMS part of correct allocation of hazardous resources based on the waste risk posed by materials management plan Page 77 Environmental Site Assessment for oil ?elds - Block 1,2 4 GPOC will continuously procedu'e for preventing Avoid envirormental, Project life Operational policy Periodic audit Developed as the uncontrolled releases of hazardous materials health and Manager report to be part of safety impacts submitted to hazardous senior waste executives at management GPOC plan As part of the HSEMS GPOC will continue to incinerate waste oil and Limit the emission of Project life Emission records HSE As part of the Part contract lubricants and general waste (mix waste, which is air pollutants to the (002, Nox VOC, Contractor HSEMS with waste not possible to sort and recycle) including atmosphere e.g. SOX) Site Manager handler maintenance and packag'ng wastes and other hazardous chemical and smstances from (killing worls. Domestic waste I GPOC will continue to implement sound waste To protect ecosystem Project life Waste generation Site Manager, As part of the per management management system existing which is based on component cycle register HSE Manager HSEMS year principles of segegation into recyclable waste, Contractor hazardous wmte, oil and other non-combustible and combustible general waste: Wastes will be collected and segegated into recyclables and non-haza'dous combustible using dearly Imelled bins. Incineration will be done for those waste that can safely be burned Develop instructions to buy the organic wastes that can easily decompose and places c? Page 78 Environmental Site Assessment for oil ?elds - Block 1,2 8: 4 dispose the waste this way will be speci?ed Other categories of waste, e.g. d'y cells, car batteries. plastic, cans and glass bottles etc. to approved recycling or disposal facility (in Juba) using the existing system I Waste oil from the Drilling rig will be transported tojiba where it will be disposed of in boilers or fu'naces Scrap metal I GPOC continue to inplement the following To protect Project life Scrap metal HSE part of ESMP per management my?; environment aesthetics transfer register Environment Implementation year I Segegate scra metal, tran art the Of?cer sp Contractor scrap metal tojlba for recycling Druns and will be thoroughly cleaned before they are sent for recycling. Fire hand The GPOC will continue to implemert the following To protect machinery Prq'ect life Risk assessment HSE Manager ESMP per measures to protect hunm health and the safety of 8? equipment from and implementation year the facilities: potential ?re hazard management I Ma'nta'n passive ?re protection system. I I Ensure no igiition sauces Fire dill reports I Ma'nta'n ?re alarm system. I Ma'nta'n active f're protection systems. I Ensu'e all fre systems are located in a safe a'ea Fire equ'pment GPDC Page 79 Environmental Site Assessment for oil ?elds - Block 1,2 8: 4 of the facility, protected from the fre by service certi?cate distance. Ensure explosive atmospheres in confined spaces Incident reports is avoided Maintain ?re ?gIting equipment and procedures. Ensure personnel are continuously trained on ?re safety and drills. Vehicles colision I GPOC will contimously ensue that the supply To protect vessels Prq'ect life Incident reports HSE Manager Pet of ESMP Pat of 300 vehicles are running at speci?ed safe distances ECO implementation and at recommended speed limits The Contractors S3Gtm/ hr ?l-M Emergency GPOC will continuously monitor possible risks to Ensu'e community Project life Risk reg'ster Periodic audit Incidents the as it relates to emergency health and safety In the Confraaor report to be incidents event of an CDCA submitted to emergency senIor executives at GPOC As part of the HSEMS [3 I: Page 80 Environmental Site Assessment for oil ?elds - Block 1,2 4 GPOC will continuously implement emergency Appropriately manage Project life Emergency Periodic audit Developed as response and preparemess plan community health and response and Contractor report to be part of safety in the event of prepa'emess CDCA submitted to emergency an emergency plan senior plan executives at GPOC Emergency response plan to be submitted to directly affected communities (where applicable) As part of the HSEMS Accidental oil GPOC maintain the following mitigation measures To protect sensitive Project life Risk assessment HSE Manager The bind wall Pat of 300 spillage Oil Storage ecological components and risk Field base should have - Diesel oil tanks shall be those designed ?Wm manager capacity 0? according to acceptable stmdards i.e. those Pawiat: with protection features for explosion and ?re I Shall be ?tted with pressu'e relief and explosion protection Install ?re suppression gadgets All diesel storage tanls will be bundled Oil Transportation :9 '3 Page 81 Environmental Site Assessment for oil ?elds - Block 1,2 4 Objective Project: poi-in, nape-m inputting Coot Phase prosodic. I'll I perm I USD or at]. "Inuit Tm amen Ima- I The oil transport will always have empty containers around the main storage tanks so as to tap the spilling oil. I Use spills benns to contain the spill I Clean-up the area as soon as possible I Have in place an Oil Spill Contingency Plan I All diesel storage tanks will be bundled. Fire explosion Covered under machinery and equipment Con-nullity valuing Eruption on Employmontma?on I Elli-need u-rbt {a Iced panda. Disruption of I The GPOC - ECO are required to clearly To avoid interference Project life Incident report CDCA As part of ESMP 5,000 anthropogeric indicate/ point out to the Drilling Contractor With activities Implementation activities and Support Vehicle Owner(s) the areas that they will have in their possession for the duration of the contract Employment I GPOC and the Contractor were required to: To enhance local Mobilisation, GPOC Human Resource As many as In phases I Enhance local employment opportunities benefits and drilling employment Manager possible by offering skills and literacy training to phases policy locals particularly youth. 8? Ensue that where no specialised skill is Employment records needed, employ people from the village. Allocatejob fairly among villagers. Establish a system to manage local expectations Page 82 Environmental Site Assessment for oil ?elds - Block 1,2 4 Issue Action Objective Project: Plan. prides, hon-u. hon-m Coot ?use We. I'll I perm I USD or at]. about Tm douunonul?ul liuululdb . Train locals for specialized activity as appropriate local incomes GPOC will identify items that can be procured Increase commodities Project life List of items CDCA As part of the In-house locally that can be procured CSR staff locally GPOC will continue funding capacity building Increase pull of people Project life Training schedule CDCA As part of the 20,000 prog'ammes that may empower local communities with certain trades Attendance CSR to be employed in oertainjobs register GPOC will continue funding capacity building Increase pool of local Project life Training schedule CDCA As part of the prog'ammes that may empower local communities suppliers Attendance CSR to supply some consumable items to the company register local Expectations GPOC in collaboration with other oil companies will To minimise con?icts Project life Operational policy CDCA As part of the 10,000 develop a programme to manage local expectation with local communities CSR as a way of mitigating tension between communities and the companies Occupational health, safety and ?50mm! Expoun 0!an to maptionhodth and lnadupau'uh diam olPorsonalProtctin Warm wa?rgoorlio'omandhdi?u; [adoloodo ofpracticuattho Imdorpuiuinwatorandunitation proving Tran-minim! ofnrmun?cdlo Juana; Mution/ am a: in.? Mort; Randi-l or Jamar-nu; Fio ham-do Occupational Health and Safety GPOC will continuously communicate project progess, material changes to the prq'ect, grievances received and corrective action taken Protect workers' health Project life Minutes of meetings and record of grievances received and response and action taken CDCA HSM Periodic audit report to be submitted to senior executives at GPOC 5,000 Page 83 Environmental Site Assessment for oil ?elds - Block 1,2 4 As part of the HSEMS GPOC will continuously monitor potential hazards Ensu'e safe waking Project life Hazard risk report HSE Manager Periodic risk Developed and develop responses to eliminate sou'ces of risk conditions report to be under risk or minimize workers' exposure to hazards submitted to management senior plan executives at GPOC As part of the HSEMS GPOC will continue to control the residual risls Ensu'e safe wa'king Project life Personal HSE Manager Periodic audit Pat of hazard at source through the use of protective conditions protective report to be solutions and provide adequate personal protective equipment issue submitted emipmert (distribution) to senior register executives at GPOC As part of the EHSMS GPOC will continue providng mining to all workers Ensue safe working Project life Training sd'iedule HSE Manager As part of the on relevant aspects of occupational health and conditions and attendance HSEMS safety msociated with their dain work register GPOC will continuously docunert and report Ensue safe working Project life Accidents and HSE Manager review 0 occupational injuries, illnesses and fatalities conditions inciderts register to be submitted (including near misses) (inducing near to misses) senior executives at GPOC Page 84 Environmental Site Assessment for oil ?elds - Block 1,2 4 As part of the HSEMS I'hlnan hedth and Incl-being GPOC will continuously implement code of practice To mininise accidents Project life Code of practice I-EE Manager Contractor ECO Periodic audit report to be submitted to senior executives at GPOC As part of the HSEMS 5000 GPOC will continuously update measures to avoid/minimise hazardous conditions (high noise levels, chemical exposue) To protect workers' health Project life Envi'onmental quality report HSE Manager Contractor Periodic audit report to be submitted to senior executives at GPOC I-hlnan hodth and Incl-being GPOC will continue providing and enforcing use of Personal Protective Equipment (PE) To protect workers' health Project life PPE procurement and list of trained people HSE Manager Contractor ECO As part of the Periodic audit report to be submitted to senior executives at GPOC Aspartofthe 10,000 per year Page 85 Environmental Site Assessment for oil ?elds - Block 1,2 4 HSEMS GPOC will continuously employ trained Iquali?ed To minimise accidents Project life I-RM Manager Periodic audit 0 and competent personnel and mechanics for the Contractor report to be specializedjobs with the intention of mitigating ECO submitted to avoidable accidents senior executives at GPOC GPOC will continue to use competent supervisors To protect workers' Project life MSDS at all HSE Manager As part of the 0 (specialists, MSDS's) on site at all times during health releva'lt sites Contractor HSEMS Periodic specific operations; ECO audit report to be submitted to senior executives at GPOC As part of the HSEMS GPOC will mainta'n appropriate signage to guide To protect workers' Project life Signage on the HSE Manager Periodic audit people on appropriate PPE to use in different places health facility Contractor report to be of the plant ECO submitted to senior executives at GPOC I'hlnan hodth and GPOC continue to provide adequate access to ?rst Ensu'e safe waking Project life First aid kit HSE Manager Pat of 300 on-boing aid and medical assistance in cases of work related conditions availability md As part of the accidents or iry'u'ies adequacy audt HSEMS report c? Page 86 Environmental Site Assessment for oil ?elds Block 1,2 4 Objective Puget: Phase ?police, oral-walnut denunciation Inga-Ila perm hm ml T's-t [m GPOC will maintain site management system with adequate capacity for oversight of occupational health and safety matters Ensure safe working conditions Project life Systems audit report Health and Safety Manager audit report to be submitted to senior executives at GPOC As part of the HSEMS 10,000 Physical Hazards to Workers GPOC will continuously monitor all physical risks to workers and develop/ update and implement the appropriate mitigation measures Eliminae physical hazards to workers and effective mitigate any residual risks Project life Hazard risk report HSE Manager ECO Periodic audit report to be submitted to senior executives at GPOC As part of the HSEMS Developed under risk management plan Protection of safety of workers aga'nst faling oly'ects Whenever needed GPOC will secure equipment and demarcate any hazardous areas To protect workers' wellbeing Project life Incident report HSE Manager ECO Periodic audit report to be submitted to senior executives at GPOC As part of the HSEMS Part of costs Protection of hedth of workers GPOC will continuously maintain good sanitary environment through provision of suf?cient water, To protect workers' Project life Environmental quality report HSE Manager ECO Periodic audit report to be Part of Page 87 Environmental Site Assessment for oil ?elds - Block 1,2 8: 4 Vilago tranquility I Provide medcal personnel to test workers for potential infections and provide treatment to those infected. I Monitor and maintain records of infections - GPOC and the Contractor will maintain the following measues: I Ensu'e project personnel a'e accommodated at a dedicated camp To avoid con?icts with communities Prq'ect life Incident reports Contractor Periodic monitoring report to be submitted to against working adequate nunber of anenities, regqu cleaning wellbeing submitted to under marital] senior ?for? executives at GPOC As part of the HSEMS hotoction of safety GPOC and the Contractor continue to implement To ensure workers a'e Prq'ect life Health status I-RM Manager Periodic audit 10,000 of workers the following wastes to mitigate spread of protected from reports report to be r'nk submitted to own. to I Undertake awareness education senior disease Indus programmes to workers. executives at I Establish worker's health protection procedues GPOC I Provide vector protection to workers. As part of the I Institute a mala'Ia protection prog'anme HSEMS a, :1 GI 11 CI 0 Page 88 Environmental Site Assessment for oil ?elds - Block 1,2 8: 4 Discouage use of alcohol within the (kill- senior platform. executives at I Conduct proper screening of security personnel. GPOC GPOC will continue providing awareness To mitigate spread of Project life Health records HSE rt of the 51110 per Transnission education prog'ammes to Communities Contractor was year a Page 89 Environmental Site Assessment for oil ?elds - Block 1,2 4 Table 11: Mitigation of workover impacts Page 90 Degadation of soil and surface waters; 0 Implement the existing Waste Management Plans to minimise the chance of accidentally Installation Contractor Part of 300 disription of terrestrial ?ora and fauna losing items Commissioning HSE due to operational discharges 0 Operation Field base Decommissioning Manager (Warmer) Degadation of soil and surface waters; Black Wamr aid Food Waste Installation Contractor Part of 300 of terrestrial ?ora and fauna 0 Black Water: Use of septic tanks and soak away pits Commissioning HSE due to operational discharges 0 Use 833 services to handle all organic waste Operation Field base Decommissioning Manager Degadation of soil and surface waters; Prodiced Water Operation Contractor Part of 300 disruption of terrestrial ?ora and fauna 0 Continuous monitoring of oil-in-water levels and alarm/re-routing system to an off-spec tank Testing HSE due to operational discharges with 24 hour storage capacity for re-treatment if required. Field base 0 Follow IFC Guidelines (29 mg/ I maximum 30 day average and 42 mg/l maximum oil content Manager and no visible sheen). Degadation of soil and surface waters; Workovor ?uids Operation during Contractor Part of BOO of terrestrial ?ora and fauna 0 Where possible collect used ?uids into a closed system and inject ?uids the formation, or workover HSE due to operational discharges used ?uids to the original vendors for recycling or treatment and disposal. Field base 0 Only discharge used wellbore cleanup ?uids. Manager 0 Follow IFC Guidelines. Maximum one day oil and grease content of 42 mg/l. and average less than 29 mg/l. 0 Any acidic workover ?uids used that require discharge will be neutralised by mixing in soda ash, or similar, to attain a pH of 5 to 7 before disposal. The project will only use low toxicity, readily biodegadable and non- bioaccumulative chemical systems, where commercially available. Chemical selection will be usti?ed against auditable criteria. Degadation of soil and surface waters; Pro-mnv'su'oning Pressure Testing Fluids Commissioning Contractor Part of 300 disription of terrestrial ?ora and fauna Minimise volune by testing equipment prior to importing HSE due to operational discharges - The volune of pre-commissioning water required will be reduced by testing equipment Field base onshore where possible. Manager Environmental Site Assessment for oil ?elds Block 1,2 4 Preferential use of low toxicity and readily biodegradable chemicals. Pre-commissioning fluid dsposal procedures will be developed to control the rate of discharge, chemical use and dispersions. Dispersion will be improved by optimising discharge rate and pressure at the release point. Degadation of soil and surface waters; Chenicd and Fuels Storage Installation Contractor Part of 300 of terrestrial ?ora and fauna 0 Chemicals and Fuels will be stored as explained in Table 9. Commissioning HSE due to operational discharges Operation Field base Decommissioning Manager Air Quality Mitigation for Canbusu'on Socrws 0 Mitigation measures in Table 9 will be used Degadation of soil and surface waters; Produced Sand Installation Contractor Part of 300 disruption of terrestrial ?ora and fauna 0 Install sand control in all wells during oil well workover to prevent produced sand. Commissioning HSE due to operational discharges 0 Sand monitoring installed for each oil well. Operation Field base Decommissioning Manager initials Deg'adation of air quality due to In addition to the mitigation measure in Table 9 following mitigation measures will be Installation Contractor Part of 300 atmospheric pollutant emissions and implemented: Commissioning HSE greenhouse gasses. - Compliance with international limits on and no deliberate emissions of ozone- Operation Field base depleting substances and no incineration of certain products plastics). Decommissioning Manager 0 Follow IFC Guidelines for management of small combustion sources. Use of low-sulphur diesel fuel if it is available locally. - Prog'amme of leak detection and repairs to reduce fugitive emissions. - Reduce VOC emissions from hydrocarbon and chemical storage and transfer activities through equipment selection and fuelling activities. Waste Management Storage, Seg'egation and Transport of Waste Installation Contractor Part of 300 - Use Waste Management Plan (WMP) and manage throug1 project Commissioning HSE 0 Reduce waste generation and maximise reuse and recycling. Operation Field base 0 Waste identi?cation and classification. Decommissioning Manager Waste collection, storage and segregation in base camps Use of speci?ed waste transport containers only All wastes to be transported in a safe manner, in accordance with Material Safety Data Sheet information and via well maintained, legally compliant and suitable vehicles or vessels, with 3 Page 91 Environmental Site Assessment for oil ?elds - Block 1,2 4 appropriate docunentation and d'iven/crewed by fully trained operators. 0 Waste to be transported by ministry of environment and Forestry approved waste contractors only. Impacts from oil spills on vulnerable Oil Spill Mention Mom Installation Contractor Part of 300 components of the ecosystem in onshore To minimise the risk of potential spills following mitigation measues will be implemented: Commissioning HSE environments 0 Blow?Out Preventers (BOPs) permanently installed on the oil well completions and the use of Operation Field base a double mechanical barrier system during production and irjection operations using the Decommissioning Manager christmas trees and other barriers. A system of oil wells, ?owlines desig'ied to international process codes and with alarm and shutdown systems to maintain the system within its design criteria at all times. The system will be tested, inspected and maintained to ensure performance standards are met. The drill deck and damage system will be desigied to contain spills (as well as leaks and contaminated wash-down water) to minimise the potential for release. Impacts from oil spills on vulnerable Spill Response Measures Installation Contractor Part of 300 components of the ecosystem in onshore An Oil Spill Contingency Plan (OSCP) will be used. Commissioning HSE environments Operation Field base . Decommissioning Manager As covered in Table 10 Installation Contractor Part of 300 Commissioning HSE Operation Field base Decommissioning Manager (i El 1] El Page 92 8.3. The Monitoring and Social Monitoring Plan has been modified to bring it in line with the updated environmental and social management plan Environmental Site Assessment for oil ?elds - Block 1,2 4 Table 12: Updated environmental and social monitoring plan UPDATED ENVIRONMENTAL AND SOCIAL MONITORING PLAN Tim] Mil-"toil. Morin Plunder! Fm of I Tm Rospomihiity [sf-lined Pm To be locatim Mel-"toting W3 mill-?Ii ?0?01 STAGE: uncommon MAM ASPECTS Top soil All chemical and Visual inspection of areas for At start-up and To avoid Soil 8588 Environmental 1,000 waste storage chemicals spills and leaks then (and Of?cer areas which might impact top soil ultimately quality (and ultimately surface water potentially groundwater) and groundwater contamination). At the oil well Visual checking of: At start - up and To minimize the No hahazard Environmental Part of waste disposal 0 Project sites for scrap then of risk of aethetic disposal of scrap Of?cer site metals and drilling bits pollution metal during drilling phase Surface and At drilling site in Visual checking of: Start - up of To minimize the 3583 Environmental 1,000 waters quality Block 1,2,4 0 Project sites for drainage activities risk of pollution Of?cer pipes involving of At disposal site 0 Chemical analysis of outfalls works near and at surface water from wastewater water bodys. body Page 93 Environmental Site Assessment for oil ?elds Block 1,2 4 Meritor'm' Mel-"tail. Pnneters Freq?Icy of I Tl'et Reeponiliity Eetin?ed Pnneter To be "criteria W3 morita'erl hydrocarbons) treatment To avoid Health systems which discharge to during risks to a water body (Biological drilling phase residents. Oxygen Demand (BOD), To minimize Total Suspended Solids damages to (T33), and Pathogens) aquatic 0 Sediments at drilling site vegetation. To minimize damage to riparian and aquatic fauna. All chemical and Visual inspection of areas for At start-up and To avoid surface SSBS Environmental 1,000 waste storage chemicals spills and leaks then water Of?cer areas which might impact surface contamination water quality Air Quality On site C02, At the start Meeting 8588 HES Manager 5,000 Combustion Air monitoring procedures then Air quality Gases will be during standards implemented mobilisation, and minimizing at sensitive drilling impacts to receptors and ?aring workers and neighbouring sensitive receptors Noise Drilling site Measurement of noise level at At the start and To minimize SSBS HSE Manager 1,000 sensitive receptor then and noise pollution during flaring from (filling Page 94 Environmental Site Assessment for oil ?elds - Block 1,2 4 Rm] Moritolilg Mal-"unit. Pm Fm of Stand-d Tm Responiliity [sf-noted Pm To be loutim Mar-"tori. W3 morita'ed activities Landscape and Entire project site Visual checking of landscape, At start - up and To assure that None HSE Manager 0 visual amenity disturbance of the project area then of landscape is ECO and waste accumulation during drilling maintained in phase good order At the waste Visual checking of: At start - up and To minimize the No hahazard Environmental Part of disposal site 0 Project site for scrap metals then of risk of aesthetic disposal of scrap Of?cer and drilling bits during drilling pollution metal ECO phase Flora Entire project site Monitor type of Before the start To assure that None HSE Manager 1,000 vegetation/trees that have of the the indigenous ECO been cleared to give way to mobilisation vegetation/ the project. The listing should trees are indicate whether the species protected are in IUCN list SOCIAL mm Land use change Village Of?ces Disrupted activities related to Once before the To assure that All affected Environmental 500 land use changes should be start of the affected families families Of?cer recorded in an appropriate project have alternative manner to allow for data land for their ECO processing, monitoring and economic reporting, for example: type of activities land use eg. animal grazing, ?rewood collection etc. Influx of people Village Of?ces Monitor type and number of Once before the To assure that As minimum as Community Part of people moving into area start of the social amenities possible Development dLring d'illing campaign. The project and then and not Of?cer Page 95 Environmental Site Assessment for oil ?elds Block 1,2 4 Meritor'm' Mel-"tail. Pnneters Freq?Icy of Stand-d I Tl'et Reeponiliity Eetin?ed Pnneter To be leeatim "criteria W3 morita'ed information should also stretched include the type of activities To assure that they are doing is not promoted through in?ux of sex workers Occupational GPOC Offices Monitoring compliance with Before the start To avoid Contractor Part of Health and safety Health Centre applicable standards and of the Project occupational HSE ECO measures national activities Injuries and or standards for workers Legislation and use of PPE Every working day Professional illnesses GPOC Offices Monitor and document types At the beginning To avoid No occupational Contractor 5.000 Health Centre of health impacts with of the project and occupational related illnesses HSE Of?cer intention of establishing their once every month ineries and or relation to the occupational Professional health hazards illnesses Public Health and Communities 0 Safety barriers and Prior to the start Mitigating health As minimum as Contractor 5,000 Safety signage. of the project And safety possible ECO 0 Monitoring of Community Daily checking Risks to health of construction residents and safety educational program to ensure that it is effective 0 Monitoring accidents incidences and near misses. 0 Monitor complaints from sites boundaries. Annual health records Page 96 Environmental Site Assessment for oil ?elds - Block 1,2 4 Rm] Mal-"tom. Mal-"tum. Pm Fm of Stand-d Tm Responsiliity [sf-noted Pm To be loutim Mal-"toting W3 Incl-"tired residents through the grievance mechanism 0 Monitoring of Community status awareness campaigns to ensure they are effective Village Of?ce Monitor handling and disposal Daily checking To ensue no No chemicals ECO Part of of empty chemicals containers of construction chemicals poisoning CDCA and other unused materials sites Boundaries poisoning Local At the Monitoring of number of Before the Ensuring local As many as CDCA 0 employment Project sites locals commencement communities possible Employed on the project. The of construction bene?t from records should contain such works. employment information of names, sex, during opportunities age, local South sudanese the foreign Implementation Ensure no Period discrimination STAGE: common Soil All chemical and Visual inspection of areas for At start-up and To avoid Soil 8588 Environmental 1,000 waste storage chemicals spills and leaks then (and Of?cer areas which might impact top soil ultimately quality (and ultimately surface water ECO potentially groundwater) and groundwater contamination). At the waste Visual checking of: At start - up and To minimize the No hahazard Environmental Part of disposal site 0 Project sites for scrap then risk of aethetic disposal of scrap of?cer Page 97 Environmental Site Assessment for oil ?elds Block 1,2 4 Meritor'm' Mel-"tail. Pnneters Freq?Icy of I Tl'et Reeponiliity Eetin?ed Pnneter To be Meritorilg W3 morita'erl metals and drilling bits during pollution metal and waste operation phase ECO Surface and water At all project sites Visual checking of: Start - up of To minimize the 5585 Environmental quality in vicinity of 0 Project sites for damage activities risk of pollution of?cer surface pipes and bridges. involving of ECO watercourses Retention basins or works near surface water grassed ?lter zones. and at To avoid . Chemical analysis of watercourses. affections outfalls from wastewater to ?ow and treatment systems which during sedimentation discharge to surface construction patterns. water. To avoid health 300 and pathogens to residents. To minimize damages to aquatic vegetation. To minimize damage to riparian and aquatic fauna. Air Quality On site C02, Meeting 3388 HSE Manager 5.000 Combustion during Air quality ECO Gases Air monitoring construction standards procedu'es will be works and minimizing implemented impacts to Page 98 Environmental Site Assessment for oil ?elds - Block 1,2 4 Rm] Mar-"tori. Mal-"tail. Pm Fm of Stand-d Tm Respon?iity [sf-noted Pm To be loutim Mar-"loin. W3 moritwed at sensitive receptors workers and neighbouring sensitive receptors Landscape and Entire project Visual checking of landscape, Once - one year To assure that None HSE Manager 0 visual amenity land disturbance of the project area after drilling landscape is ECO and waste accumulation campain maintained in (including scrap metals) Flora Entire project site Growth rate of trees should be Once evely year To assure that None HSE Manager Part of monitored and recorded in there is ECO appropriate manner to allow vegetation assessment of performance of recovery the forest project. The data to be recorded should include for example, number of failed trees, growth rate of sampled trees, SOCIAL ASPECTS Stakeholder Villages The number and types of Regular To allow and No gievance CDCA 5,000 per year Engagement stakeholder engagement monitoring on provide full goes unresolved activities should be monitored bases engagement of and reported on - activities stakeholders need to be processed and during operation analyzed monitoring to be phase done through following activities: how many public meetings were held, how Page 99 Environmental Site Assessment for oil ?elds Block 1,2 4 Pnneter To be militia-ed Maia-in. mm mil/rm Reeponiliity Eetin?ed many people attended, what issues were discussed, what were the comments/ grievances about, how will they be addressed, etc . The number and types of grievances received should also be monitored and reported on. This should also Involve processing and analysis, for example: categorization of grievances (those related To land acquisition, Economic displacement, Health and safety, construction nuisances, community impacts, etc.), average time to respond, outstandng grievances, Social Monitoring GPOC Office and Village Of?ces Record the number of job vacancies resulting from the project and the number of vacancies taken up by Every three months To assure proper management of Local As many as practicable CDCA Part of Page 100 Environmental Site Assessment for oil ?elds Block 1,2 4 Mel-"twin Mel-"tail. Pnneters Freq?Icy of Stand-d I Tl'et Reeponiliity Estin?ed Pnneter To be "criteria W3 militia-ed residents of affected local recruitment communities plan Monitoring effects on Every three To assure that Positive CDCA Part of population by reporting on a months theproject improvement number of question for the realization impairments and will improve life improvements of the life from ofthe residents project realization and speci?c problem identi?ed by local residents Labour Workforce GPOC Office and Monitoring of protection Regularly on To assure that all No major HSE Of?cer Part of Monitoring Village Of?ces measures for preventing daily basis required disputes workers accidents during standards No injuries operational phase, worker are ful?lled and labour inspections and disputes Monitoring the safety of Regularly on To prevent No major HSE Of?cer Part of workers daily basis workers accident alcohol testing for drunk accidents drivers) Community GPOC Office and Checking that the progam is Regular To avoid No major CDCA 5,000 per year Health and Safety Village Of?ces prepared and implemented. monitoring accidents accident educational Visual monitoring of the on that may occur program implementation through basis during developed for the media and other education the operation Project operation forms. .9, I: I: Page 101 Environmental Site Assessment for oil ?elds - Block 1,2 8: 4 Loss of At Block 1,2 and 4 Monitoring of number of Six montls after To avoid creating All redundunt 0 employment locals decomissioning an army of employees CDCA that have lost employment disilusined should be and their occupation individuals who monitored /Iivelihood may be a nuisance in the community .9 Page 102 Environmental Site Assessment for oil fields – Block 1,2 & 4 9. COST AND BENEFIT ANALYSIS 9.1. COSTS The financial analysis of the workover of oil facilities and activities has been carried out to justify the investment. It is estimated that the workover will cost about USD 14-40 Million to implement. The workover activity is a technically feasible exercise. 9.2. BENEFITS Given the urgent national energy needs in south sudan, it is essential that Block 1,2 and 4 are kept online. The daily 66,000 barrels oil rate which was being produced prior to the conflict in December 2013 now is very important to maintain the power production and sale of oil to industries. 9.3 . QUANTIFIABLE AND NON-QUANTIFIABLE BENEFITS TO COMMUNITIES Other benefits include  Continue to meet the growing demand for energy needs in south sudan using a domestic natural resources  To maintain reduced levels of the country's dependence on imported oil for electric power generation using for example emergence IPPs  Continue to provide an alternate, lower-cost and more reliable power source.  Ensure continued availability of oil for industry use  Continue providing power, and associated economic benefits to greater unity states and communities along the pipeline route  Continue promoting private investment in the energy sector and contribute to government revenue through fees, taxes and royalties 9.4. POSSIBLE COSTS TO COMMUNITIES The workover will be done on existing site there will be no family that will be displaced and most likely it will not disrupt any socioeconomic activity of greater Unity states residents. 9.5. POSSIBLE COSTS TO GOVERNMENT The workover of oil production facilities in Blocks 1,2 and 4 for resumption of oil exploration and production is inevitable. However,the Government will incur no cost. Page 103 Environmental Site Assessment for oil fields – Block 1,2 & 4 9.6.ENVIRONMENTAL COSTS AND BENEFITS ANALYSIS Environmental cost benefit analysis is assessed in terms of the negative and positive impacts. Furthermore, the analysis is considering whether the impacts can be mitigated and the costs of mitigating the impacts are reasonable. It should be noted that the cost benefit are discussed based on the commitment of GPOC that all mitigation measures will be implemented. As presented in the above chapters and the identified impacts can be mitigated. 9.7. SOCIO-ECONOMIC COSTS AND BENEFITS ANALYSIS Although there are some negative environmental and social impacts as shown in previous chapters, the continued availability of oil production means continuous availability of power which is needed for a multitude socioe conomic activities. 9.8 RISK ASSESSMENT Oil pollution is a very serious risk, particularly in wetlands. From various persons who managed to visit the oil exploration sites in, greater Unity States, it was understood that oil pollution around these sites is visible . However, these sites were then under the control of the Khartoum Government and the Government of Southern Sudan generally had no access and no control. It was therefore impossible to monitor the level of respect paid to the environment by the oil companies. Cooper and Catterson (2007) stated that : “The areas in greater Unity state currently yielding petroleum are dotted with small ponds created near the well heads to hold the “produced water” that typically comes out of the ground from the oil wells. Produced water is produced with the oil, often with high concentrations of chemicals, minerals or mixed with oil, and frequently at high temperatures. The high amounts of the contaminants (salts or chlorides, hydrocarbons, well treatment chemicals, oil separation and water treatment chemicals) can reach toxic concentrations that will pollute the surrounding areas or waters if dispersed directly into them . They are currently being stockpiled in man-made ponds adjacent to the drilling sites where the expectation is that they will be disposed of by evaporation over time.” Some other risks of oil exploitation are:       Oil spills causing contamination at exploration/production facilities and around pipelines; Disruptions to the local hydrology (of various types and magnitudes and with varying collateral adverse socio environmental impacts); Contamination as a result of disposal and release of produced water; Disposal and release of hazardous materials used in drilling; Pollution from human waste, solid waste from oil camps and/or fuel and lubricants associated with mechanized equipment; Species and habitat loss from increased accessibility to otherwise remote areas Page 104 Environmental Site Assessment for oil ?elds - Block 1,2 8. 4 GPOC is committed to protecting the health and safety of its employees and those of its contractors, to ensuring that all activities are conducted in accordance with current industry norms and applicable local legislation. a manner that protects the environment and people's health. The plan is as shown under the Table 13 Table 13 Risk control plan Use of faulty equipment, tools and risk practices Standards and operations procedures diving, hazardous substances etc; trained /qualified and competent personnel (Operators and Mechanics, Supervisors (specialists, MSDS's) on site at all times during specific operations; Working conditions and facilities Provision of appropriate equipments, enforcement of use of Personal Protective Equipment secure working areas and demarcated hazardous areas, signage and graphics. Code of practices at the work place Comply with International Performance Standards; Procedures and guidelines for speci?c operations, certi?ed operation equipment, inspections and maintenance system, traf?c management; ln-house health and safety manual /guidelines; and Emergency Response Equipment and Procedures. Water and sanitation Proper assessment of water needs; increase existing water extraction and provisions storage capacity; establish water saving measures (Education, Information, and Communication (EIC) package with and Fire risk Fire fighting equipments and procedures and training to personnel and ?re drills; First Aid and ER facility at the drill location; Risk Assessment and Emergency Response Plan (ERP) taking into considerations treatment and ER capabilities of local medical services providers and hospitals. Rowdiness disorderliness Project personnel accommodated at the dilling unit; Vehicles alcohol-free use within drilling unit discouraged; proper screening of security personnel. Risk of infection exposure to (isease vectors Provide vector protection to workers i.e. malaria protection programme: '0 Page 105 Environmental Site Assessment for oil fields – Block 1,2 & 4 10. DECOMMISSIONING PLAN Background Since this is an Environmental Site Assessment(Phase 1) for Block 1,2 and 4 for oil production resumption,However theres no decomissioning plan.A decomissioning plan is highlighted in the Petroleum Act,2012,Cessation of petroleum activities chapter XII,section 39. This chapter therefore provides an initial decomissioning plan of the oil Field site. Once drilling is completed and irrespective of whether any hydrocarbons have been discovered in the reservoir sections, the well will be plugged and permanently abandoned. This will involve leaving the well in a condition so that water, gas or oil cannot leak out at the surface. Abandonment of the well requires the insertion of cement plugs across the reservoir section that was identified and an abandonment cap on top of the well (following standard procedures). GPOC will set cement plugs in the reservoir section when wells are abandoned. Cement plugs will also be set at various points in the well, including across the stump of the conductor pipe just below the surface. The drilling rig and camp will be dismantled and towed to another site. Re-Instatement On abandonment, all synthetic or man-made material will be removed. Water in the waste pit to which cuttings and mud have been discharged will be discharged to a designated area. Monitoring Following Well Abandonment and Decommissioning In order to monitor habitat recovery after the rig sites, site monitoring will be done continuously for six months to make sure that there is no leaking well. Target In Block 1,2 and 4, the Wellheads shall be decommissioned appropriately in accordance with good engineering practices in consideration of the environment. As a minimum, the following must be achieved:       Compliance with all regulatory requirements. Isolation of groundwater aquifers within the well from each other and hydrocarbon zones. Isolation of hydrocarbon zones within the well from each other, from groundwater aquifers or from zones of different pressure. Isolation of the surface casing and production casing from open hole. Placement of a surface cement plug in the top of the casing. Recovery or removal of the wellhead. Page 106 Environmental Site Assessment for oil fields – Block 1,2 & 4 Details of well decommissioning must be provided to Ministry of Environment & Forestry for approval Six months prior decommissioning    These details must give sufficient information to demonstrate that the well will be decommissioned successfully and all regulatory requirements will be met. After decommissioning a report shall be submitted to relevant Ministry/Authority providing sufficient information to demonstrate that the well has been decommissioned successfully and all regulatory requirements have been met. Records of procedures conducted will be kept by the reevant ministry/Authority. Rehabilitation of surface disturbance must be undertaken to a high standard a) Rehabilitation planning must be undertaken prior to the disturbance occurring and included in environment plans b) Rehabilitation standards must be developed in consultation with ministry of Petroleum. c) Rehabilitation must commence as soon as practical (about six months) after the area is no longer required for ongoing operations. d) Rehabilitation must strive to return areas to their pre-disturbance condition. e) Native and endemic species must be used wherever possible. f) Weeds and pests must be managed in rehabilitated areas. g) Erosion must be minimised in rehabilitated areas. h) Where areas disturbed are environmentally sensitive, higher standards of rehabilitation will be imposed. Any contamination must be remediated Contaminated land surveys of high risk areas (e.g. waste transfer facilities, flowback storage areas etc.) must be undertaken prior to relinquishment in accordance standards set by the relevant Authority. If wastes have been disposed of on-site, future monitoring and management requirements must be agreed with the Ministry of Environment and Forestry.(MOEF)   Plans for leak detection and monitoring must be comprehensive and endorsed by the relevant regulators. Where a residual risk may be inherited by the GOSS Government, operators are required to provide sufficient security in relation to the risk. If scrap metals, and hazardous wastes have been disposed of off-site  Transportation plans must be developed,   Consent from receiving entity should be sought, Permits for transporting the wastes should be obtained from relevant authorities before transportion is made from Ministry of Environment and Forestry Page 107 Environmental Site Assessment for oil fields – Block 1,2 & 4 Success of rehabilitation must be demonstrated   Success of rehabilitation must be verified by a suitably qualified person. Success of rehabilitation of vegetation must have been monitored for sufficient time to demonstrate it will continue to be successful (e.g. taking into account annual and seasonal variation, ground cover establishment and natural variability). Decomissioning costs Cost of decomissioning a well head is estimated to cost 200,000 USD annualy in 10 years Page 108 Environmental Site Assessment for oil fields – Block 1,2 & 4 9. SUMMARY AND CONCLUSION Environmental site Assessment of the Block 1, 2 and 4 was conducted pursuant to international law and the south Sudan draft Environmental Regulations (2012), an initial environmental audit to provide base in information upon which subsequent environmental control audit studies shall be based. The objectives of the environmental site assessment were to assess the environmental and social performance of the GPOC Oil facilities and operations and current status to provide a mechanism to learn from experience, and to propose an ESMP, and to provide regulatory bodies with a framework for checking compliance with, and the performance of proposed ESMP. As such the environment site assessment focussed mainly on five aspects, historical research, compliance to legal requirements, effectiveness of mitigation control measures and procedures and past and on-going concerns of project stakeholders. 9.1. HISTORICAL RESEARCH Block 1,2 and 4 were drilled without an EIA as such mitigation measures that were put in place then were not documented. However, its operation has spanned the period of EIA regime. Since the Block was taken over in 2012 by GPOC it is safe to assume that the mitigation measures and procedures applied to GPOC to other oil wells also apply to this Block 1,2,and 4 well. Based on the fact that minimal adverse environmnetal and social impacts have resulted tolerable mitigation controls have worked. 9.2. COMPLIANCE TO LAWS AND REGULATORY FRAMEWORK Analysis of laws and policies that apply to the GPOC oil facilities have shown that a limited amount of laws and policies have been complied with. This has been conformed both from the historical research and consultations to key stakeholders. 9.3. EFFICACY AND ADEQUACY OF MITIGATION MEASURE CONTROLS AND PROCEDURES The environmental site assessment has established that the current GPOC oil field implemented limited mitigation measures and procedures though no significant adverse environmental and social impacts have been experienced. 9.4. RECOMMENDATIONS FOR PAST AND ON-GOING CONCERNS OF PROJECT STAKEHOLDERS The environmental site assessment has established that there are a number of concerns exist and these need urgent attention. These include the following: i. Thorough cleanup campaign in their entire oil facilities compound and conduct second phase of ESA and EIAs Page 109 Environmental Site Assessment for oil fields – Block 1,2 & 4 ii. iii. iv. v. vi. vii. viii. ix. x. xi. xii. xiii. xiv. xv. xvi. xvii. GPOC,MOE,MOP should collaborate and provide safe drinking water to populations around the oil fields Provision of medical facilities, health centers and train the population importance of first Aid Govt together with others should join hands and construct better roads to facilitate the mov’t of the people as well as their staff Search for new locations and relocate military camp and communities residing around the oil field facilities GPOC to conduct environmental awareness to the communities around oil field to enable them keep environment clean and safe. Provision of basic needs to oil-production communities to improve their livelihoods Conduct trainings in solid waste management and risk management to the population around oil fields. Recycling of waste materials eg scrap materials Feasibility study on types of legacy wastes, chemicals at the yard for proper storage and deposition. Carrying out EIAs/Environmental Audits for new oil wells and existing wells Perceived threat of oil operations on water sources Perceived threat on wellbeing of residents from oil operations by carrying out scientific research to correlate illnesses Lack of clear grievance handling mechanisms Awareness raising of Villagers on HIV/AIDS Awareness raising of Villagers on emergency preparedness and response Carrying out a decommissioning plan Page 110 Environmental Site Assessment for oil fields – Block 1,2 & 4 REFERENCES 1. Ali Elredaisy SM Ecological benefits of bioremediation of oil contaminated water in Rich savannah of Palogue, Upper Nile area –south Sudan. University of Khartoum. Journal of Bioremed Bodegrad 2. Cooper, J.C., & Catterson, T. (2007). Scoping statement for the programmatic environmental assessment of the oil exploration and production activities in Southern Sudan. Washington, DC: STEP/IRG. 3. Community consultation report unity state south Sudan(2012) UNDP south Sudan Published by South Sudan Bureau for Community Security and Small Arms Control South Sudan Peace and Reconciliation Commission United Nations Development Programme may 2012 4. EIA –(1998) Muglad basin oil production project field production facilities prepared by Institute of environmental studies, University of Khartoum for China Petroleum Engineering Corporation(CPEC) 5. Government of Southern Sudan (2011). Southern Sudan Development Plan (draft). Juba, South Sudan: Government of South Sudan 6. Interim National Constitution of South Sudan& Transitional National Constitution of South Sudan 7. Laws of south Sudan, The Land Act 2012 8. Laws of south Sudan, The Mining Act,2012 9. Laws of south Sudan environment and protection management Bill,2012 10. Laws of south sudan,environment policy,2012 11. Laws of south Sudan, Investment Promotion Act,2009 12. Laws of south Sudan The Petroleum Act,2012 13. Species Richness and Abundance of Birds in and Around Nimule National Park, South Sudan (2016)Department of Wildlife, University of Juba, Juba, South Sudan 14. Environmental impacts and risk and opportunities assessment, natural resource management and climate change in south sudan,GOSS,UNDP Published by the Government of the Republic of South Sudan Ministry of Environment With support from the United Nations Development Programme, South Sudan office 15. International Finance Corporation (IFC) Performance Standards on Environmental and Social Sustainability 2012 16. Wildlife Conservation and National Parks Act,2003 Ministry of Wildlife and Tourism WEB REFERENCES 17. Situation Overview: Unity State, South Sudan (October 2017) - South ... https://reliefweb.int/report/south-sudan/situation-overview-unity-state-south- Acessed on 29/5/2018 18. Accession by South Sudan to the Convention on Wetlands of ... - Unesco portal.unesco.org/.../ accesed on 7/6/2018 Page 111 Environmental Site Assessment for oil fields – Block 1,2 & 4 19. APPENDICES Appendix 1: Certificate of Registration Page 112 Environmental Site Assessment for oil fields – Block 1,2 & 4 Appendix 2: Memorandum and Articles of Association Page 113 Environmental Site Assessment for oil fields – Block 1,2 & 4 Appendix 3: GPOC Terms of Reference (ToR) EXHIBIT – B SCOPE OF WORK GREATER PIONEER OPERATING COMPANY LIMITED referred to in this section hereinafter as (GPOC) is desirous to contract ______________________ , hereby referred to in this section as Service Provider/Contractor who accepted the terms and conditions as mentioned in Exhibit-A. ____________________ and GPOC are hereby referred to as parties. 1 Scope of Service The Contractor has agreed to carry out the works and shall be responsible for providing GPOC all services as listed as per the following Scope of Work. Phase I Environmental Site Assessment for Health, Safety & Environment A Conduct Phase I ESA on Block 1, 2 and 4 in South Sudan particularly facilities including FSP/FPF, Power Plant, Pump Station (PS), Base Camp, Pipelines, Bulk storage, Evaporation Ponds, Bioremediation Pond, Drilling mud pits, Hazardous Wastes/Chemical Storage Area, Well Pads area and airstrip. i. Provide assessment on the current status of environment at the oilfields. ii. Detailed review of existing environment protection measures at the oilfields. iii. Identify current and historical sources of damage or contamination (actual and potential). iv. Risk assessment on the potential environmental risk of main facilities in the oilfields. v. Provision of information on Socio-Economic Environment including Population, Land Use (Nomadic Pastoralism, Crop Cultivation), the Social Organization of Production, Industry and Sources of Energy, Transportation in the Block 1, 2 and 4. vi. Program for consultation with leaders of local communities which will be accompanied by GPOC, MOP representatives and other stakeholders. Requirement on risk mitigation measures at Block 1, 2 and 4 The bidder will split his team into to two groups for below area a) Group A - Unity field and Kai Kang Group B - Northfields ( Elnar, Toma South and Eltoor ) and Munga Page 114 Environmental Site Assessment for oil fields – Block 1,2 & 4 b) Each team shall include representative from MoP and GPOC HSE, Production, Facility, Security and CD/CA totalling to six personnel for each location. Bidders shall include all cost of the mentioned accompany team in their proposal (Food and Accommodation, Basic First Aid Medicine and Transportation within the field and others related) Bidder is responsible to arrange own communication, local liaison and any other requirement at site to support delivery of the Statement of Work. The qualification of Bidder shall be based on GPOC requirement as per Attachment A B. Deliverables Successful Bidder shall produce a comprehensive Phase I ESA report detailing all findings and recommendations, within 4 week of issuance of award letter The report shall cover the followings and but not limited to: i. Background information of the existing environment in Block1, 2 and 4 ii. Identify significant environment risks in the resumption of production. iii. List the existing damage or contamination and analyze the critical factors of any damage or contamination caused in the oilfields. iv. Recommendation on additional risk mitigation measures by government authorities. v. The reports shall also include a fully record on the current status of GPOC Oil Field by pictures and video GPOC Obligation:   GPOC to provide the accompany team as mentioned above All Flight from Juba to site location, i.e Unity and Yida, are limited to a maximum of 12 personnel which shall include the accompany team (6 personnel) for 2 return flight per location shall be arrange by GPOC. 2. Services - Should GPOC requires additional services, GPOC shall inform the Contractor of such, and the Contractor shall arrange to provide the required services within Three (5) working days after notice of such from GPOC. - Providing GPOC with the "as per the prices" mentioned in Exhibit C will be the basis for the additional payment. Page 115 Environmental Site Assessment for oil fields – Block 1,2 & 4 3. Service Agreement Duration Subject to the termination provision provided herein, this CONTRACT shall commence on the Effective Date stipulated in the preamble and shall be valid for a period of Thirty (30) days with the inclusion of Deliverables as described in Section 1 B above. GPOC shall have the right to extend the duration of this CONTRACT under the same terms and conditions. End of Exhibit B Page 116 Environmental Site Assessment for oil fields – Block 1,2 & 4 Appendix 4: List of People Consulted Names Designation Zaraka Machar Deputy Governor North Liech State Malong Reng Security officer Refinery Camp Mr william Dak Kot Commisioner Bul East county Hon Deng Deng Ngok Commisioner Ruweng state Hon Achail Awat Commisioner Ruweng state Commander Commander Tharwany Yele Military Barracks Commisioner Commissioner Budang county Community households Community Budang county Hon Them Machar Kuol Governor Ruweng state Community Aling and Tuoch community Michael Odwa Marian - Community Development officer(CDO)-GPOC William Majak Makuach CDCA Manager -GPOC Chabany Maker HSE section deputy Head-GPOC Dr Bill Gueth Charhow HSE Manager-GPOC Gatchang Madit Giel HSE personnel-GPOC Humoon Chol Deng Director HSE-Ministry of Peteroleum Dhan Keach Puk Director CDO-Ministry of Peteroleum Angok Daniel Chol Head Legal Administration-Ministry of Petroleum David Batali DG-Planning & Envt Mgt- Ministry of Environment,Juba Page 117 Environmental Site Assessment for oil ?elds - Block 1,2 4 Appencix 5: Issues raised by stakeholders Hon. Zaraka Machar/ Deputy Governor of Northern Liech State( Former Unity State) There is a need of clean drinking water Oil ?elds in Unity are polluted There is a need of transportation and medical facilities GPOC should provide the basic services to the surrounding communities and clean up the oil spill at the oil ?elds. Hon. William Dak Kot/ Commissioner of Bul East County More than one hundred cattle's died due to the contaminated water Cases to do with deformation where some children were born with missing body parts There is a need of referral hospital and clinic to provide health services Construction of roads, hospitals, building more schools including primary and secondary and conducting an environmental awareness to the community The Security forces in Unity Serious leakage around the oil ?elds which need some attention There is a need of clean drinking water and inadequate boreholes. Due to the high contamination there are issues to do with skin diseases, swelling of human bodies and deformation. Deployment of soldiers to the four reconnaissances and provision of clean d'inking water. Military Commanders/ ThanNany yele Military Barracks There is a need of hand pump, clean drir?king water and ?ltered water Construction of boreholes and health PUB Page 118 Environmental Site Assessment for oil fields – Block 1,2 & 4  5 Commissioner of Budang county     6 Community of Budang County       7 Michael Odwa Marian- (CDO)-GPOC  There is a need for hospital, clinics and other health facilities Availability of unknown chemicals in the area There is water scarcity There is need for the relocation of the community around the oil fields to another area. Spreading of diseases such as Hepatitis B, deformation and skin diseases. Diseases such as Malaria, typhoid, blood diahrrea, skin diseases and paralysis is very common. There is need for hospital, clinics and medical facilities There is need for clean drinking water. There is a need for mosquito nets, bed sheets, torch, blanket sheets, plastic containers. There is need for provision of transportation means. Accumulation of waste deposition in the ponds during the rainy season. Mandate is to provide services for communities ie safe drinking water,health facilities however in 2011 operations were shutdown Page 119 facility. Relocation of the community around and construction of water facilities as well as health facilities. Construction of hospitals, schools, water facilities, relocation of the community and conduction an environmental awareness to the community.  Provide awareness communities on their rights to Environmental Site Assessment for oil fields – Block 1,2 & 4   8 William Majak Makuach –CDCA GPOC   9 Humoon chol Deng-Head Health Safety Environment(HSE) Ministry of Petroleum   and crisis came in. Currently supplying medicines, textbooks to schools Budgets were small to provide all the needed services Integrate HIV/AIDS Awareness Supervise and monitor activities Shutdown had influence on community activities Reduced activities was also constrained by budget  Prices of oil, the security crisis led to shutdown of activities. Role of ministry is to regulate and supervise the oil companies      Page 120 CSR plan to make community roads, building schools, health centres etc Distribution of IEC materials for awareness on various issues on health, education etc Need for EIAs to be done on new wells and after resumption. Plan management of wastes ie landfills ,there no gates ,watchmen etc.No where to dispose off leachates No CSR in communities and yet an obligation to train and equip residents Relocation of communities must be done to complete model settlments to international Environmental Site Assessment for oil fields – Block 1,2 & 4 standards 10 Angok Daniel Chol- Head of Legal Administration -Ministry of Petroleum   11 Dhan Keach Puk- Director CDO-Ministry of Petroleum    Resumption of oil activities in Blocks 1,2 and 4 is legally based on addendum to original EPSA and Transitional Agreement ie related to additional time period for 7 years following the expiration of EPSA. Main principles of environment are enshrined in the constitution and enacted Acts and Regulations in particularPetroleumAct,2012,Health safety and Environment mgt Plan regulations,2014,Occupational Health and safety regulations,2014 The department deals with negative issues affecting communities Support to communities in terms of their rights i.e. clean water,education,agriculture,vaccina tions to livestock’s Activities have slowed down because of the shut down Page 121  GPOC should give compliance with environmental regulations in place a priority while carrying on its activities  After resumption of oil activities clean water provision, drugs should be distributed to communities Construction of buildings/facilities for communities, health centers, water points etc must be emphasised by GPOC  Environmental Site Assessment for oil fields – Block 1,2 & 4 12 David Batali-Director General for planing Mgat,Ministry of Environment and Forestry & Envt   The oil companies must identify the environmental problems caused at the oil fields The Ministry has been pushing oil companies to carry out Environmental Audits (EA) Page 122    GPOC to do environmental Audits before oil resumption Environmental problems must be addressed and oil companies must show concern. Liaise with Ministry of Environment and Forestry for further guidance Environmental Site Assessment for oil fields – Block 1,2 & 4 Appendix 6: Charter for overseas medical treatment. GREATER PIONEER OPERATING COMPANY LIMITED CHARTER FOR OVERSEAS MEDICAL TREATMENT CONTENTS 1. 2. 3. 4. 5. 6. PURPOSE OF THE CHARTER WHY IS IMPORTANT TO ENGAGE AN OVERSEAS HOSPITAL MEDICAL CRITERIA FOR TREATMENT ABROAD WHAT WE EXPECT FROM THE HOSPITAL AND TREATING DOCTOR WHAT THE HOSPITAL EXPECT FROM GPOC COMPLAINTS AND DISSATISFACTION MANAGEMENT PURPOSE OF THE CHARTER The GPOC treatment charter is a guide to what it means to be treated in overseas hospital at this current shutdown mood followed insecurity within South Sudan since outbreak of violence 2013. It also sets out what GPOC expect from: I. II. The treating doctor at the overseas hospital The hosting hospital overseas in term of accommodation, nursing, clinical management and transportation services. This charter provides payment mechanism for staff medical costs and others services in line with HR policy adapted 2013 UHRPM {UNITED HUMAN RESOURCE POLICY MANUAL}. WHY IT IS IMPORTANT TO CONTRACT AN OVERSEAS HOSPITAL GPOC management committee has observed uncontrolled medical referrals by South Sudan medical commission for the first 6 months of 2014; therefore HSE has adapted approved this overseas treatment guide:    To minimize rapid demand for medical tourism and medical referrals to abroad hospitals To reduce medical overstay in other far countries To introduce medical cost transfer techniques for the first 2 months before full medical insurance coverage.  To provide best efficient medical treatment in a single hospital for all staff and their dependants at this current financial instability for the first 2 months. MEDICAL CRITERIA FOR TREATMENT ABROAD Eligible individuals for overseas treatment: 1. National staff and their dependants Page 123 Environmental Site Assessment for oil fields – Block 1,2 & 4 2. Secondees from partners in case of emergency 3. Direct hire in case of emergency Medical conditions to be covered at the moment: A. Life-threatening injuries/diseases B. Dysfunctional medical conditions C. Treatable masses D. Critical illness requires tertiary medical care not for transplant surgery. Requirements for abroad medical referrals: A. Previous hospitalization reports and records B. Referral letter from recognized medical institution C. Letter from medical commission D. Endorsed referral documents by ministry of foreign affairs. E. HSE-Medical form to be signed by referral hospital F. Second Medical opinion from independent Medical Specialist attached. G. Attached recent Medical laboratory tests, Interventional or Invasive radiology films H. HR sick report form I. HRC - Recommendation letter approved by the President Excluded medical and laboratory procedures:  Molecular biology investigations such as PCR, FISH etc.  Seminal analysis and ICSI  IVF and egg donation  Fluoroscopy for optical reason. Reasons for rejecting Medical referral application:     Self-Referral Medical cases Failure to fulfil referral requirements Routine Medical check up All listed conditions in Chapter 13: Section 1.2.2 in UNIFIED HR POLICY 2013 WHAT WE EXPECT FROM THE HOSPITAL AND TREATING DOCTOR    The choice of staying at the hospital or hiring a hotel: A referred staff will be asked before or on admission to Nairobi hospital whether he/she wishes to stay in the wards or outside. A consent medical form which provides clear explanation of any medical or surgical intervention during your treatment period. An explanation of any treatments associated with risk before receiving any treatment: The treating Doctor must give clear explanation of medical diagnosis and treatment options available. A right to withdraw from treatment at any stage without penalties is preserved. In case of emergency medical condition where it is not possible to obtain consent, an immediate treatment must be given to save life Advice about seeking other medical opinions within Nairobi town: It may cost double pay for GPOC, therefore a recommendation letter or email to HSE by treating hospital explaining the medical procedures or third consultation opinion; shall be forwarded to the President final approval. GPOC has right to reject unnecessary or non-convincing request of changing treatment options. Page 124 Environmental Site Assessment for oil fields – Block 1,2 & 4   Visiting rights while staying in the hospital: A family member has right to visit a love one In case of death GPOC staff; the president could approve one family member to accompany the deceased person from foreign Country to Juba. The choice of selecting a Doctor and access to medical treatment within Nairobi: A staff has right to choose a Doctor who can treats his medical condition All GPOC staff will stay in normal rooms within the hospital except GM, VP and President.  Ambulatory and taxi transportation services: An ambulance will be provided by the hospital in case of life-threatening condition. A taxi could be provided by the hospital in case of dysfunctional medical condition where no threat to life.  Confidentiality and access to staff medical records: GPOC management committee reserve right to enquire medical data of each staff for future medical treatment plan or on job transfer. Medical costs could be reduced if the medical records reveal low life quality as result of long stay medical treatment after approval from South Sudan medical commission.  Treatment with respect and dignity: Our staff must be treated with courtesy or with polite behaviour. Our staff with diverse cultural, religious and ethnic practices must be respected while staying in the hospital GPOC ID card must be seen together with referral letter.  Advice about care after discharge: A staff must be consulted before leaving the hospital as a part of planning for continuing health care. Transportation services to airport and home medicines instructions. WHAT THE HOSPITAL EXPECT FROM GPOC  Regular, timely and accurate payment transfer: GPOC financial department will receive undisputable medical invoices after verification by HSE & HR departments. Bank money transfer on case treatment-based Ambulatory, taxi, accommodation and treatment invoices are required in a seal envelop written to HSE and HR departments.  Termination letter at the end: GPOC management committee shall notify in written form termination of the services 15 days in advance. A certificate of good job could be issued by a the President if needed COMPLAINTS AND DISSATISFACTION MANAGEMENT  Treatment dissatisfaction arguments: A staff has right to explain his/her treatment dissatisfaction to the hospital managerial system If not satisfy with the hospital response, then HR and HSE could approach politely the hospital to resolve it Page 125 Environmental Site Assessment for oil fields – Block 1,2 & 4 HSE Department HSE Medical Referral Evaluation Form Medical Referral No: _____ Priority Urgent Routine Follow up         Meeting No: _____ Name Patient: _________________________GPOC ID: ______ AGE: ____________ GPOC Insurance Company: ______________________ Membership ID: ___________ Referral Physician: ___________________________ Hospital: __________________ Referral Country: ___________________________GPOC Medical Policy: Yes No Medical service requested: Consultation Tests or Procedures Follow up Proposed date of Medical service: ________________________________ Type of Stay: Outpatient Inpatient Provisional Diagnosis: _____________________________________________ S/N Criteria must be met before medical authorization 1. Medical necessity 2. Covered medical condition 3. Medical service is not available in South Sudan 4. Referral parameters ( Frequency/ Duration/ Intensity 5. Clear medical provider abroad is defined 6. Attachment document from previous medical provider YES NO Score Remarks Page 126 Environmental Site Assessment for oil fields – Block 1,2 & 4 7. Final scoring rate Panel members: 1. 2. HSE Manager ____________________________________ Team Leader Signature: _______________________________________ Health Section Head: _______________________________ Member Signature: ______________________________________ 3. Company Medical Officer: ___________________________ Member Signature: _______________________________________ HSE Department Health Section Referring provider information: Referring MD:----------------------------- Medical Institution: ------------------------------- Mobile phone: ----------------------------------- Address: --------------------------------------This form completed By: -------------------------------------- Signature: --------------------Date: ------------------------Patient information: Name: ---------------------------------------------- sex: -------------------- Age: ------------------Staff GPOC ID: --------------------- Dependent: Yes / No Relationship: -------------------Resident: -----------------------------------------------Duration of Illness: -------------D /M /Y Patient physical status: Urgent Yes/No Non-urgent Yes /No Page 127 Environmental Site Assessment for oil fields – Block 1,2 & 4 Reason for Referral: Suspected Diagnosis: -------------------------------------------------------------------------------Service/ specialty requested: ----------------------------------------------------------------------Physician Requested: -------------------------------------------------------------------------------Type of medical services requested: Consultation Yes/No 2nd opinion Yes/ No Radiology services Yes/No Lab services Yes/ No Follow up Yes/No Surgery Yes/No Others Please specify: -----------------------------------------------------------------------Reason for Referral: ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- on required/ attached with this form: 1. 2. Recent /relevant typed clinical notes/tests results .i.e. History& physical , MRI/CT/X-rays results Valid stamp from referring medical institution: -------------------------------------------- Page 128 Environmental Site Assessment for oil fields – Block 1,2 & 4 GREATER PIONEER OPERATING COMPANY LIMITED Plot No 2, Block 2C VII City Centre - Juba Republic Of South Sudan _____________________________________________________ CONFIRMATION MEDICAL REFERRAL LETTER Date: ---------------------------------------------SUBJECT: -------------------------------------------------------------------------------------------    With NAME: ---------------------------------------------------------------------------------------------------ID: ------------------------------------------------------------------------------------------------------AGE: ----------------------------------------------------------------------------------------------------DEPENDANT: YES ------------- NO: -------------------reference to the UNIFIED HUMAN RESOURCE MANUAL chapter 13 section 2 which indicates oversea treatment for GPOC staff that was blessed by MPMI in 2013. He/She was diagnosed as----------------------------------------------------- and has taken several medications and investigations in Juba and was asked for ---------------------------------------------------------------------------------------. Due to his inability to work effectively and poor health facilities in the country, he is therefore, referred to -------------------------------------------------- management. I kindly refer his case to your esteem offices for approval in accordance with GPOC policies for abroad Medical referral. Best regards. Desmond kabuya Ring Majok Dut Chen Yong Dr. wu Ruikun Manager, HR GM, C & S President Co. Medical officer Page 129 Environmental Site Assessment for oil fields – Block 1,2 & 4 Appendix 7:Health and Safety Policy Page 130 Environmental Site Assessment for oil fields – Block 1,2 & 4 Appendix 8: GPOC Integrated Emergency Response Management policy 1.0 INTRODUCTION This ERM is developed with a view to formalize effective procedures to response to any emergencies affecting all worksites and/or installations. The objective is to ensure that appropriate resources are made available, and a coordinated response is made between all parties involved in order to comply with GPOC requirements, Republic South Sudan legislation and satisfying all moral obligations of the Company in the event of any emergency throughout the daily operations. Besides, this document is intended to complement Intra Oilfields Emergency Response Plan (ERP) i.e. GPOC L2 S008 2015); the worksite-specific procedure which is required for all worksites and/installation owned and/or operated on behalf of GPOC Operations. 1.1 Purpose The purpose of this plan is to provide a framework of effectively managing emergency response efforts, from the worksite to headquarter. It is a single point guide for organizing and directing the emergency response effort, as well as a ready reference to information needed during the emergency. The following objectives have been established for this manual:  Sets forth fundamental policies, planning assumptions, a concept of operations, the emergency management team responsibilities, and response and mitigation actions.  Addresses linkages to other existing emergency coordination manual developed for specific incidents. Maximize the effectiveness of counter-measures through an established manual that consists of the following: - Notification and mobilization to activate the manual - Mitigate to minimize impact and damages - Protect employees, contractors, and the public from injury - Minimize damage or injury to people, property, and the environment - Mitigate the effect of an incident on the commercial and business life of GPOC.  Assign responsibilities to designated EMT members and for emergency support groups during periods of mitigation.  Serves as the foundation for the development of detailed supplemental procedures to complement this manual for response activities, rapidly and efficiently.  Ensure compliance with applicable regulatory requirements and industry standards for emergency management. 1.2 Scope These main objectives of this ERM are as follow: (a) Provides planning guidance, and outlines the operational concepts for response to an incident or emergency within GPOC; (b) Serves as a reference for further development of detailed GPOC and Contractors’ Incident Action Plans and Contingency Plans; (c) Includes guidelines for notification and coordination of response activities, supporting operations, and coordination of emergency information across all levels; and (d) Illustrates ways in which the Company, Contractors and Authorities can most effectively unify and synchronize their response actions. Page 131 Environmental Site Assessment for oil fields – Block 1,2 & 4 This ERM is an emergency management action that needs to be implemented to complement with the other related documents, including amongst others, Contractors’ Specific ERP and Installation specific ERP that will be referred separately. 1.3 GPOC Operations The Greater Pioneer Operating Company (GPOC) is the appointed Operator for Blocks 1A & 1B exploration, development and production activities. GPOC has been producing crude oil from Block 1A & 1B in South Sudan. Block 1A & 1B are located onshore within the Muglad Basin which is approximately 950 km north-west of the capital Juba. The blocks cover an area of approximately 4,610 sq. km. The oil from the field is pumped through a 20” pipeline to Heglig where it will be injected into the current crude pipeline that transports crude from GNPOC blocks 2 & 4 concession areas to Port Sudan, 750 km North of Khartoum. Block 1A & 1B areas that are classified as Savannah Grassland and are under developed with little or no local infrastructure other than that supporting the operations in the Unity and Northfield. There are currently 5 fields that are producing crude oil namely Unity, Munga, Toma South, El Nar and El Toor. The crude oil is collected at the Oil & Gas Manifolds (OGMs) and piped to the Field Processing Facilities (FPF). The separated crude is then stored in crude storage tanks before it is exported through the 20” pipeline to Heiglig where the crude will be injected into the main pipeline from Heglig to Port Sudan. The Processing Facilities and the Control Centre are powered by a heavy fuel power generation system. The power system also provides the required power for the accommodation facilities that houses the crew operating the fields and processing facilities. During exploration, drilling and production activities, GPOC staff and contractors are located at Wizeen Camp and Unity Base Camp that are set up to provide the resources, both hardware and manpower that necessary to carry out the work. 2.0 GOVERNING POLICIES 2.1 General a) All worksites, installation or facilities are require to have a comprehensive emergency management system to ensure that:  The emergency management teams can respond effectively to emergencies or crisis and can provide emergency assistance so that appropriate response measures are taken to protect personnel, the public, the environment, the property and the company reputation;  Emergencies are promptly recognized and classified, and parameters associated with the emergency are monitored to detect changed or degraded conditions;  Emergencies are reported and notifications are made; and  Re-entry activities are properly and safely accomplished, and post-emergency activities commence properly. (b) Each worksite shall declare an emergency when events or conditions require time-urgent response. The On-Scene Commander and Incident Commander have the authority to direct and coordinate emergency management operations and may delegate this authority to a government On-Scene Commander, when necessary. Page 132 Environmental Site Assessment for oil fields – Block 1,2 & 4 (c) On-duty GPOC EMT members shall serve as the point of contact for receipt of all emergency notifications and reports. Accordingly, GPOC EMT receives, coordinates, and disseminates emergency information to JubaEMT management and other parties. (d) All responding ERT and EMT members have authorities over all response efforts. (e) Where outside country assistance is required (e.g. for the use of equipment, transports, etc), all requests will be channeled through Juba-EMT. The requirements should subsequently be confirmed in writing, wherever possible. (f) The GPOC President shall be informed of any emergency by Incident Commander / Duty Manager. He shall consider strategic issues, such as the impact as a whole in terms of operability and continuity of operations, public relations, high level liaison with government authorities, other organizations and representation when dealing with the media. (g) Regular training of all personnel shall be conducted to ensure effective emergency response preparedness exists throughout the business operations. Page 133 Environmental Site Assessment for oil fields – Block 1,2 & 4 Appendix 9: GPOC Oil Spill Contingency Plan(OSCP)) GREATER PIONEER OPERATING COMPANY LTD OIL SPILL CONTIGENCY PLAN HSEMS 1.0 Rev 0: May, 012 Page 134 Environmental Site Assessment for oil fields – Block 1,2 & 4 OIL SPILL CONTINGENCY PLAN INTRODUCTION 1.1 Overview The response to any work site emergencies, including the accidental release of oil or oil-based products to the environment, shall be managed by the Person-in-Charge of the work locations, in accordance with the respective Work Site’s Emergency Response Plan. Further, the overall management of such emergencies for Greater Pioneer Operating Company (GPOC) shall be managed by the Duty Emergency Response Manager based in Juba, South Sudan; in accordance with GPOC Emergency Response Plan. This requirement is applicable for all for all worksites and facilities owned by and/or operated for and on behalf of GPOC, including activities being carried out by Contractors. 1.2 Purpose The purpose of this Oil Spill Contingency Plan (OSCP) is to provide clear and concise guidelines for use by management and operations personnel in the implementation of response and recovery actions following an accidental release of oil or oil-based products to the environment. This OSCP is to be used in conjunction with GPOC’s Emergency Response Plan and the respective Work Site’s Emergency Response Plan. 1.3 Scope In developing this Oil Spill Contingency Plan (OSCP), the risk of accidental release of hydrocarbons, oil base mud or fuels to the environment are identified. Thereafter, the strategies and responses to be implemented in the event of a spill are considered, with a view to ensuring that the spill is managed effectively and efficiently and in a manner that is environmentally responsible.The scope of this document covers the whole operations of GPOC Concession Blocks respectively it includes the management of any oil spills that can possibly occur during:      Production Drilling Development of facilities Production operations Transportation of crude oil product by pipeline.  The procedures contained in this Plan are provided as a guideline for assessing the response operations; however, variations based on sound management, engineering, or environmental judgment and operational experience are anticipated and may be authorized by the appropriate Incident Commander(s). This plan also covers the notification to and interfacing with appropriate agencies, governmental authorities, and community representatives, as required. Page 135 Environmental Site Assessment for oil fields – Block 1,2 & 4 2.0 OIL SPILL PREVENTION PROGRAMS The prevention techniques for oil spill include:        2.1 Corrosion control program Inspection and records Preventive maintenance Active Security Tank leak protection Training programs Transfer procedures Potential Spill If an oil spill or release occurs at the site, product may reach the surrounding environment through the following:      direct release to surface water; flow over land; migration in groundwater; through the unsaturated subsurface soil or bedrock; or, through storm water transport. 2.2 Oil spills or leaks at the site would most likely occur as a result of the following possible events:  Overfill/Overflow spills Oil may be spilled due to accidents involving containers or fuel tanks (i.e., vehicles, generator etc.). These accidents typically include overfilling or spills such as punctures, leaks, corrosion, improper storage, etc. Every effort will be taken during truck unloading activities to prevent damage to petroleum containers, etc. and thus the creation of spills.Temporary or permanent containment structures will be provided, as required. These types of spills are often due to operator error, but sometimes can be the result of defective equipment. These spills are the most common types of spills, and spill prevention should be emphasized during employee training. Pipe rupture A break in piping or will cause the contents to be pumped or drainedonto the ground. This failure can occur as a result of damage tothe pipe, defective connections, or errors by facility personnel. Oil drum/container rupture or puncture A rupture caused by equipment puncture or Corrosion could release oil to the ground. Leakage due to corrosion or loose fittings may also occur. Page 136 Environmental Site Assessment for oil fields – Block 1,2 & 4 2.3 Event Criteria The following chart outlines factors requiring evaluation to determine whether an oil spill is an event the requires to invoke an entire OSCP and an Incident Management Team. An oil spill becomes an Incident that warrants consideration of an emergency declaration or initiation of OSCP when the following conditions are evident or liable to occur Incident Human Safety and Welfare      Poisoning of water or food sources and supply Presence of toxic fumes or explosive condition. Damage to personal property Need for evacuation of people Interference with public or commercial transport Environment  Injury or loss of animal or plant species, or their habitat, that are of economic or ecological importance such as: Commercial or subsistence fisheries(plants, fish, aquaculture facilities) - wetlands - endangered species populations/habitats   impact to recreational areas Impact to ecological reserves, parks and cultural sites  Land contamination Page 137 Environmental Site Assessment for oil fields – Block 1,2 & 4 Appendix 10: Material safety data Sheets for different chemicals KS-60-22 REVERSE DEMULSIFER MATERIAL SAFETY DATA SHEET 1. IDENTIFICATION OF THE SUBSTANCE/PREPARATION AND THE COMPANY Product trade name: KS-60-22 REVERSE DEMULSIFER SINO OIL KING SHINE CHEMICAL CO., LTD. NO. 10 JIN YUAN EAST RD. DEVELOPMENT ZONE, LANGFANG, HEBEI, P.R.C. TELEPHONE: (86)316-5919778 FAX: (86)316-5919779 Company: CAS number Unknown Synonyms Coagulant for water treatment Preparation / Revision 21,May 2012 Generic chemical name Polyaluminum Chloride Solution Product Type Unknown Emergency tel and fax number: (86)316-5919778; (86)316-5919779 MSDS No 60-22 2. COMPOSITION/INFORMATION ON INGREDIENTS Identification of the preparation: Formulated product, Aromatic Hydrocarbons Hazardous Ingredients Component Polyaluminum chloride Formula Al2(OH)xCl6-x O